SUPPORTING STATEMENT FOR

EPA INFORMATION COLLECTION REQUEST NUMBER 2002.05

“CROSS-MEDIA ELECTRONIC REPORTING RULE” 

June 22, 2011

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 ..............................................................................6

2(a) NEED AND AUTHORITY FOR THE COLLECTION...........................................................6

2(b) PRACTICAL UTILITY AND USERS OF THE DATA..........................................................7

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA................9

3(a) NONDUPLICATION ...............................................................................................................9

3(b) PUBLIC NOTICE.....................................................................................................................9

3(c) CONSULTATIONS..................................................................................................................9

3(d) EFFECTS OF LESS FREQUENT COLLECTION..................................................................9

3(e) GENERAL GUIDELINES......................................................................................................10

3(f) CONFIDENTIALITY.............................................................................................................10

3(g) SENSITIVE QUESTIONS......................................................................................................11

4. THE RESPONDENTS AND THE INFORMATION REQUESTED ..............................................12

4(a) RESPONDENTS AND NAICS CODES ................................................................................12

4(b) INFORMATION REQUESTED.............................................................................................12

5. THE INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT ......................................................19

5(a) AGENCY ACTIVITIES .........................................................................................................19

5(b) COLLECTION METHODOLOGY AND MANAGEMENT ................................................20

5(c) SMALL ENTITY FLEXIBILITY...........................................................................................20

5(d) COLLECTION SCHEDULE..................................................................................................20

6. ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION ..............................22

6(a) ESTIMATING RESPONDENT BURDEN HOURS..............................................................22

6(c) ESTIMATING AGENCY HOUR AND COST BURDEN ....................................................25

6(d) ESTIMATING RESPONDENT UNIVERSE AND TOTAL HOUR AND

COST BURDEN .....................................................................................................................26

6(e) BOTTOM LINE HOUR AND COST BURDEN ...................................................................35

6(f) REASONS FOR CHANGE IN BURDEN..............................................................................35

6(g) PUBLIC BURDEN STATEMENT.........................................................................................39
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 2002.05, 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.

The following paragraphs describe the respondent activities examined in this ICR. 

NOTE: 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:

 Private sector entities; and

 State/Local agencies that are regulated entities2.

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

CROMERR3. In this document, we refer to these respondents as “State/Local

agencies acting as regulators.”

 

2

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

definition of respondent in the Paperwork Reduction Act (PRA).

3

 Ibid.
3

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

CROMERR4. In this document, we refer to these respondents as “State/Local 

agencies that are regulated entities.” 

(1) Registering with EPA Electronic Document Receiving System

40 CFR 3.10(a) and (b) establish Federal environmental reporting requirements that 

facilities must satisfy to submit electronic documents to EPA. Among other things, 

Section 3.10(a) provides that a person may use an electronic document to satisfy a Federal 

reporting requirement, or otherwise substitute for a paper document or submission permitted or 

required under other provisions of 40 CFR only if the person submits the electronic document to 

EPA’s CDX, or to another EPA electronic document receiving system that the Administrator 

may designate for the receipt of specified submissions, complying with the system’s 

requirements for submission. The electronic document must bear all valid electronic signatures 

as required under 40 CFR to sign the paper document for which the electronic document 

substitutes, unless EPA announces special provisions to accept the signature on separate paper 

submission. 

In accordance with the above requirements, as well as the requirements of CDX, direct 

reporters must register initially with CDX. They also must update their registration information 

as needed.

(2) Compliance with Identity Proofing Requirements

Direct and indirect reporters must comply with the identity proofing provisions of CDX 

and CROMERR, as applicable. As provided by CDX and 40 CFR 3.2000(a)(2), any electronic 

document must bear the valid electronic signature of a signatory if that signatory would be 

required under the EPA or State/Local environmental program to sign the paper document for 

which the electronic document substitutes, unless the program makes special provisions to accept 

a handwritten signature on a separate paper submission, as specified. 

In the case of an electronic document that must bear electronic signatures of individuals, 

as provided by CDX or 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, for each electronic signature device used 

to create an electronic signature on the document, the identity of the individual uniquely entitled 

to use the device and their relation to any entity for which they will sign electronic documents 

must be determined with legal certainty by EPA or States/Locals, as applicable. In the case of 

priority reports, this determination must be made before the electronic document is received, by 

means of:

 

4

 Ibid.
4

 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.

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

States/Locals that receive, or wish to begin receiving, electronic documents in lieu of 

paper documents to satisfy requirements under authorized programs must revise or modify the 

EPA-approved State/Local environmental program to ensure that it meets the requirements of 

40 CFR Part 3. In making these program revisions or modifications, States/Locals must submit 

an application that complies with 40 CFR 3.1000(b)(1), and use either the applicable procedures 

for revision or modification of such programs in other parts of 40 CFR; or, at their option, the 

procedures provided in 40 CFR 3.1000(b) through (e). The procedures provided in 

Sections 3.1000(b) through (e) may only be used for revising or modifying an authorized 

program to provide for electronic reporting and for subsequent revisions or modifications to the 

electronic reporting elements of the authorized program as provided under 40 CFR 3.1000(a)(4). 

(40 CFR 3.1000(a)(1))

States/Locals that accept 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 3.1000(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 40 CFR 3.2000. Where the Administrator determines that such changes 

require EPA review and approval, EPA may request that States/Locals submit an application for 

program revision or modification. Additionally, States/Locals may submit applications on their 

own initiative for program revision or modification respecting their receipt of electronic 

documents. (40 CFR 3.1000(a)(4))

To obtain EPA approval of program revisions or modifications using procedures 

provided under 40 CFR 3.1000, States/Locals must submit an application to the Administrator 

that includes the elements in Section 3.1000(b)(1)(i)-(iv). (40 CFR 3.1000(b)(1))

States/Locals that revise or modify 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 (1) authorized program, provided the consolidated application complies 

with Section 3.1000(b)(1) for each authorized program. (40 CFR 3.1000(b)(2))

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

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

documents, to satisfy requirements under such programs must use an acceptable electronic 
5

document receiving system as specified and 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 unless the 

program makes special provisions to accept a handwritten signature on a separate paper 

submission, where such provisions are addressed in the application submitted under 

Section 3.1000(b)(1) and ensure that the paper submission contains references to the electronic 

document sufficient for legal certainty that the signature was executed with the intention to 

certify to, attest to, or agree to the content of that electronic document.

As provided at 40 CFR 3.2000(b), 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 in Sections 3.2000(b)(1) through (5).
6

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).5 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 

 

5

 Title XVII of Pub. L. 105 277.
7

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.

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 
8

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).
9

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, EPA issued a public notice in 

the Federal Register on February 2, 2011 (76 FR 5802). The public comment period extended 

through April 4, 2011. EPA did not receive any written comments on the ICR in response to the 

Federal Register notice.

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. For example, EPA analyzed State 

feedback on the number of electronic document receiving systems and reporting facilities, and 

reflected updated input in the supporting statement. No additional consultations were conducted 

in the development of this ICR. 

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 
10

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. 

3(e) GENERAL GUIDELINES

This ICR adheres to the guidelines stated in the Paperwork Reduction Act (PRA), Office 

of Management and Budget’s (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.
11

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.
12

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.

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 
13

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.
14

(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.

 Contact the Help Desk for technical support.
15

 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.

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.
16

 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.

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, 
17

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.

 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.
18

(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.
19

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.
20

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.
21

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.
22

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.

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 $57.87 for legal staff, $37.09 for managerial staff, $36.78 for technical staff, and $16.18 for 

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

CROMERR ICR (i.e., EPA ICR Number 2002.04, dated February 15, 2008), and updated to 

2011 levels using Employment Cost Indexes developed by the Bureau of Labor Statistics.6

 

6

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

workers, by occupational and industry;” Employment Cost Index, Historical Listing, Continuous Occupational and 

Industry Series, September 1975 – March 2011; April 29, 2011. Available online at: 

http://www.bls.gov/web/eci/ecicois.pdf, last accessed on June 8, 2011. Civilian Workers, All Workers, March 

2008=107.6 and March 2011=114.0.
23

(b) State/Local Agencies

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

of $38.95 for legal staff, $38.95 for managerial staff, $29.50 for technical staff, and $14.00 for 

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

CROMERR ICR (i.e., EPA ICR Number 2002.04, dated February 15, 2008), and updated to 

2011 levels using Employment Cost Indexes developed by the Bureau of Labor Statistics.7

(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 $144,330 and that each 

Local agency will incur a cost of $54,817. These capital costs were obtained from the previously

approved CROMERR ICR (i.e., EPA ICR Number 2002.04, dated February 15, 2008), and 

updated to 2011 levels using Consumer Price Indexes developed by the Bureau of Labor 

Statistics.8 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 

 

7

 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, Continuous 

Occupational and Industry Series, September 1975 – March 2011; April 29, 2011. Available online at: 

http://www.bls.gov/web/eci/ecicois.pdf, last accessed on June 8, 2011. State and Local Government Workers, All 

Workers, March 2008=108.9 and March 2011=116.6.

8

 Bureau of Labor Statistics, Table Containing History of CPI-U U.S. All Items Indexes and Annual 

Percent Changes From 1913 to Present, May 13, 2011. Available online at: 

ftp://ftp.bls.gov/pub/special.requests/cpi/cpiai.txt, last accessed on June 8, 2011. All items, March 2008=213.528 

and April 2011=224.906.
24

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. 

(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 $3.31 to mail a one-ounce letter by certified mail 

(i.e., $0.44 for first-class letter postage, $2.85 for the certified-mail fee, and $0.02 for 

standard business envelope).

9, 10, 11

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

LRA will incur a cost of $0.46 to mail a one-ounce letter using first-class mail 

(i.e., $0.44 for first-class letter postage and $0.02 for standard business 

envelope).

12, 13

 EPA estimates that indirect reporting firms will incur a cost of $2.63 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 2002.04, 

dated February 15, 2008), and updated to 2011 levels using Consumer Price Indexes 

developed by the Bureau of Labor Statistics.14

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

 

9

 U.S. Postal Service; “First-Class Mail Prices.” Available online at: http://www.usps.com/prices/firstclass-mail-prices.htm, last accessed on June 8, 2011.

10

 U.S. Postal Service; “Extra Services Prices.” Available online at: http://www.usps.com/prices/extraservices-prices.htm, last accessed on June 8, 2011.

11

 Standard business envelope cost based on current market price, as of March 7, 2011 (i.e., box of 500 

standard business envelopes with gummed closure at $8.99). 

12

 U.S. Postal Service; “First-Class Mail Prices.” Available online at: http://www.usps.com/prices/firstclass-mail-prices.htm, last accessed on June 8, 2011.

13

 Standard business envelope cost based on current market price, as of March 7, 2011 (i.e., box of 500 

standard business envelopes with gummed closure at $8.99). 

14

 Bureau of Labor Statistics, Table Containing History of CPI-U U.S. All Items Indexes and Annual 

Percent Changes From 1913 to Present, May 13, 2011. Available online at: 

ftp://ftp.bls.gov/pub/special.requests/cpi/cpiai.txt, last accessed on June 8, 2011. All items, March 2008=213.528 

and April 2011=224.906.
25

(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 $5.42 to mail a nine-ounce 

large envelope by certified mail ($2.48 for first-class large envelope postage, $2.85 for the 

certified-mail fee, and $0.09 for catalog envelope).15, 16, 17 These O&M costs are shown in 

Exhibit 1 for all applicable respondent activities.

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 $64.93 for legal staff (GS-14, Step 5), $54.94 for 

managerial staff (GS-13, Step 1), $46.21 for technical staff (GS-12, Step 1), and $23.44 for

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

Schedule (GS) Salary Table 2011.

18

 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 $159,360 in CDX 

development, operation, and maintenance activities.

19

 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 $1.20 per subscriber agreement.20 

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

 

15

 U.S. Postal Service; “First-Class Mail Prices.” Available online at: http://www.usps.com/prices/firstclass-mail-prices.htm, last accessed on June 8, 2011.

16

 U.S. Postal Service; “Extra Services Prices.” Available online at: http://www.usps.com/prices/extraservices-prices.htm, last accessed on June 8, 2011.

17

 Catalog envelope cost based on current market price, as of March 7, 2011 (i.e., box of 100 6” x 9” 

brown kraft catalog envelopes with gummed closure at $8.79). 

18

 US Office of Personnel Management, “Base Hourly Rate,” 2011 General Schedule (Base), January 

2011. Available online at: http://opm.gov/oca/11tables/indexgs.asp, last accessed on June 8, 2011.

19

 Based on EPA’s Capital Planning and Investment Control (CPIC) for CDX. Data current as of May 26, 

2011.

20

 Based on data current as of May 26, 2011.
26

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:

 Private sector entities; and

 State/Local agencies that are regulated entities21.

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

CROMERR22. 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 

CROMERR23. In this document, we refer to these respondents as “State/Local 

agencies that are regulated entities.” 

(1) Respondent Universe

(a) Direct Reporters

Table 1 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, 28,084 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.

 

21

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

definition of respondent in the Paperwork Reduction Act (PRA).

22

 Ibid.

23

 Ibid.
27

Table 1

Annual Number of Direct Reporters 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 23,880

State/Local Agencies that are Regulated Entities 4,204

Total 28,084

a

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

requirements.

Table 2 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.
28

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 2

Annual Number of Subscriber Agreements to Be Submitted to EPA

during the Three-Year Period Covered by the ICR

Type of Subscriber Agreement

Annual Number of

Subscriber Agreements a, b

Average

2011 2012 2013

Private Sector Entities

Non-ESA Registrants 7,684 6,690 6,990 7,121

ESA Registrants 17,444 14,232 14,027 15,234

Reuse (Consolidated) ESA Registrants 4,077 5,301 5,317 4,898

Third Party ESA Registrants 496 1,060 1,047 868

Subtotal 29,701 27,283 27,381 28,122

State/Local Agencies that Are Regulated Entities

Non-ESA Registrants 1,353 1,178 1,230 1,254

ESA Registrants 3,071 2,505 2,469 2,682

Reuse (Consolidated) ESA Registrants 718 933 936 862

Third Party ESA Registrants 87 187 184 153

Subtotal 5,229 4,803 4,819 4,950

Total

Non-ESA Registrants 9,037 7,868 8,220 8,375

ESA Registrants 20,515 16,737 16,496 17,916

Reuse (Consolidated) ESA Registrants 4,795 6,234 6,253 5,761

Third Party ESA Registrants 583 1,247 1,231 1,020

Total 34,930 32,086 32,200 33,072

a

 Table contains data provided by EPA’s Office of Information Collection (OIC), and are current as of May 26, 2011.

b

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

(b) Indirect Reporters

Table 3 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, 25,924 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 

medium-size and large firm). Table 3 presents information on the annual number of employee 

registrants by type of firm.
29

As shown in Table 3, EPA estimates that, on average, 13,960 employees from small firms 

and 11,964 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 3

Annual Number of Indirect Reporters 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 11,870

Medium-Size and Large Firms 10,173

Subtotal 22,043

State/Local Agencies that are Regulated Entities

Small Firms 2,090

Medium-Size and Large Firms 1,791

Subtotal 3,881

Total

Small Firms 13,960

Medium-Size and Large Firms 11,964

Total 25,924

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 3, EPA estimates that, on average, 13,960 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 employees24, for a total of 4,654 small firms (i.e., 13,960 employees 

÷ 3 employees/firm).

EPA also estimates that, on average, 11,964 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 employees25, 

for a total of 665 medium-size and large firms (i.e., 11,964 employees ÷ 18 employees/firm).

 

24

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

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

25

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

Cost Benefit Analysis, Final, dated November 17, 2004. 
30

(d) States/Locals Submitting Electronic Document Receiving System 

Applications to EPA

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, five States/Locals (i.e., 4 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. 

(2) Annual Respondent Burden (Exhibit 1)

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

Reporters

EPA estimates that, on average, 28,084 employees of direct reporting facilities will 

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

the 28,084 employee registrants, approximately 10 percent (or 2,808) 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.

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 8,375 paper subscriber agreements

each year. EPA also estimates that, of the 8,375 paper subscriber agreements prepared each 

year, 89 percent (7,454) will be from new and existing employee registrants (e.g., employees 

registering for the first time with a data flow); 10 percent (837) will be associated with employee 
31

turnover, which 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 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 17,916 ESAs each year. EPA also 

estimates that, of the 17,916 ESAs prepared each year, 89 percent (15,945) will be from new and 

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

percent (1,792) will be associated with employee turnover, which requires the submittal of a new 

subscriber agreement by the employee replacement; and one percent (179) 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, 5,761 employee 

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

that, of the 5,761 reuse (consolidated) ESAs, 89 percent (5,127) will be from existing employee 

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

percent (576) will be associated with employee turnover, which requires the submittal of a new 

subscriber agreement by the employee replacement; and one percent (58) 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 1,020 third party ESAs each 

year. EPA also estimates that, of the 1,020 third party ESAs prepared each year, 89 percent 

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

first time with a data flow); 10 percent (102) will be associated with employee turnover, which 

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

percent (10) 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 33,072 employee registrants from direct reporting facilities, 

three percent (992) will have to work with EPA to resolve problems involving their agreements 

or certifications each year. 
32

(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 

(13,960) and 98 percent of employee registrants from medium-size and large firms (11,964 x 

0.98 = 11,725) 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.26 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 33,391subscriber 

agreements each year (i.e., [13,960 small firm employees + 11,725 medium-size and large firm 

employees] x 1.3 subscriber agreements/employee).

EPA also estimates that, of the 33,391subscriber agreements prepared each year, 

89 percent (29,718) will be from new and existing employee registrants (e.g., employees 

registering for the first time with a data flow); 10 percent27 (3,339) will be associated with 

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

replacement; and one percent (334) 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 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.28 Based on these assumptions, 

 

26

 Ibid.

27

 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.

28

 Ibid.
33

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

their LRA a total of 239 subscriber agreements each year (i.e., [11,964 medium-size and large 

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

EPA estimates that, of the 239 subscriber agreements prepared each year, 89 percent 

(213) will be from new employee registrants; 10 percent (24) will be associated with employee 

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

replacement; and one percent (2) 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 25,685 employee registrants from indirect reporting facilities 

(13,960 + 11,725 = 25,685), three percent (771) 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 (665 x 0.02 = 14) 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 14 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. 

Collect Subscriber Agreements from Reporters

EPA estimates that, on average, LRAs will collect a total of 239 subscriber agreements 

each year. Of these 239 subscriber agreements, 213 will be from new employee registrants, 24 

will be associated with employee turnover, and 2 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. 
34

(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 33,391subscriber agreements each year. This includes 

29,718 subscriber agreements from new employee registrants, 3,339 subscriber agreements 

associated with employee turnover, and 334 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 239 subscriber agreements to their LRAs. This includes 213 subscriber agreements from 

new employee registrants, 24 subscriber agreements associated with employee turnover, and 2 

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, 14 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 771 employee 

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

information requests. 

(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, 24 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.
35

Submit Electronic Document Receiving System Application

EPA estimates that, on average, five 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 four States and one 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, four 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

Exhibit 3 summarizes the total annual respondent hour and cost burden associated with 

all the requirements covered in this ICR. As used in this document, the term “respondent” 

includes private sector and State/Local entities.29 As shown in the exhibit, EPA estimates the 

annual respondent burden to be 39,763 hours and $2,167,446. The bottom line burden to 

respondents over three years is estimated to be 119,289 hours and $6,502,338.

(2) Agency Tally

Exhibit 4 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 21,771 hours and $1,169,096. The bottom line burden to the agency over three

years is estimated to be 65,313 hours and $3,507,288.

6(f) REASONS FOR CHANGE IN BURDEN

The annual respondent burden estimate in the previously approved CROMERR ICR 

(EPA ICR Number 2002.04) was 78,035 hours. The annual respondent burden estimate for this 

ICR (EPA ICR Number 2002.05) is 39,763 hours. This represents a decrease of 38,272 hours.

 

29

 Refer to Section 6(d) for additional clarification on the types of respondents examined in this ICR.
36

This decrease occurred for two primary reasons. First, there was a decrease in the 

annualized number of respondents. The total number of employees registering with EPA’s 

electronic document receiving system and/or complying with CROMERR’s identity proofing 

requirements decreased from 93,325 in the previously approved ICR to 87,080 in this ICR. In 

addition, the total number of State/Local authorized programs upgrading their existing electronic 

document receiving systems or developing new electronic document receiving systems, and 

submitting documentation associated with the approval of CROMERR applications decreased 

from 61 in the previously approved ICR to 24 in this ICR. EPA conducted a thorough 

examination of available information (e.g., number of application received over the past three 

years) in estimating the number of respondents subject to the requirements of this ICR. EPA 

thinks that the number of respondents included in this ICR is a reasonable approximation of the 

actual respondent universe. 

Second, in developing this ICR, EPA carefully reviewed the respondent activities 

associated with compliance with identify proofing requirements. EPA made a few changes to 

the assumptions associated with subscriber agreement and LRA alternatives to be consistent with 

actual compliance of respondents with these requirements. For example, EPA reduced the 

proportion of respondents that use the LRA alternative while increasing the proportion of 

respondents that comply with subscriber agreement requirements. This resulted in a burden 

decrease because the burden associated with subscriber agreements is less than the LRA burden. 

EPA notes that few, if any, respondents opted to use the LRA alternative over the past three 

years.

Table 4 provides information on changes in burden. As shown in Table 4, 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.
37

Table 4

Reasons for Change in Respondent Burden Hours from EPA ICR Number 2002.04 to EPA ICR Number 2002.05 a

Changes in EPA ICR Number 2002.05 Type of Change

Burden Hours in 

EPA ICR Number 

2002.04

Burden Hours in 

EPA ICR Number 

2002.05

Change in Total 

Annual Burden 

Hours in EPA ICR 

Number 2002.05

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 1,477 4,269 2,792 

Compliance with Identity Proofing Requirements - Direct and Indirect Reporters

Comply with Subscriber Agreement Provisions

Decrease in the number of first-time subscriber agreements Adjustment 23,583 17,762 (5,821)

Decrease in the number of subscriber agreements, due to employee turnover Adjustment 2,359 1,996 (363)

Decrease in the number of subscriber agreements, due to compromised 

electronic signature Adjustment 76 53 (23)

Decrease in the number of employee registrants that contact the Help Desk 

for technical support Adjustment 7,439 3,988 (3,451)

Submit Subscriber Agreement to Local Registration Authority

Decrease in the number of new employee registrants that prepare subscriber 

agreements Adjustment 5,830 70 (5,760)

Decrease in the number of subscriber agreements, due to employee turnover Adjustment 593 8 (585)

Decrease in the number of subscriber agreements, due to compromised 

electronic signature Adjustment 1,173 1 (1,172)

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 5,770 1,763 (4,007)

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 13,652 184 (13,468)

Decrease in the number of redesignated LRAs, due to turnover Adjustment 157 1 (156)
Table 4 (continued)

Reasons for Change in Respondent Burden Hours from EPA ICR Number 2002.04 to EPA ICR Number 2002.05 a

38

Changes in EPA ICR Number 2002.05 Type of Change

Burden Hours in 

EPA ICR Number 

2002.04

Burden Hours in 

EPA ICR Number 

2002.05

Change in Total 

Annual Burden 

Hours in EPA ICR 

Number 2002.05

Collect Subscriber Agreements from Reporters

Decrease in the number of new employee registrants that prepare subscriber 

agreements Adjustment 1,016 72 (944)

Decrease in the number of subscriber agreements, due to employee turnover Adjustment 190 8 (182)

Decrease in the number of subscriber agreements, due to compromised 

electronic signature Adjustment 2 1 (1)

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

Inclusion of State/Local burden associated with compliance with subscriber 

agreement provisions as "respondent burden" Adjustment 0 5,676 5,676 

Inclusion of State/Local burden associated with the LRA alternative as 

"respondent burden" Adjustment 0 43 43 

Inclusion of State/Local burden associated with designating a LRA as 

"respondent burden" Adjustment 0 8 8 

Inclusion of State/Local burden associated with on-going management as 

"respondent burden" Adjustment 0 1,928 1,928 

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 92 36 (56)

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 14,625 1,534 (13,091)

Addition of new activity under which States/Locals submit amendment to 

original CROMERR application to EPA Adjustment 0 360 360 

Increase in number of States/Locals submitting 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

Adjustment 0 3 3 

Total Change in Burden Hours (38,272)

a

 Exhibit includes rounding error.
39

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.
40

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 
41

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.
42

EXHIBIT 1

CROSS-MEDIA ELECTRONIC REPORTING RULE

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

 $57.87/ $37.09/ $36.78/ $16.18/ 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 $5.52 $0.00 $0.00 28,084 4,212.60 $155,023.68

Update the information as needed 0.00 0.00 0.02 0.00 0.02 $0.74 $0.00 $0.00 2,808 56.16 $2,077.92

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies Varies 4,268.76 $157,101.60

Comply with Requirements for Identifier, Attribute, or Alternative Method

Prepare and submit requested information 0.00 0.25 1.00 0.10 1.35 $47.67 $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 $9.20 $0.00 $3.31 7,454 1,863.50 $93,249.54

File subscriber agreement 0.00 0.00 0.08 0.00 0.08 $2.94 $0.00 $0.00 7,454 596.32 $21,914.76

Prepare and submit a new subscriber agreement, for employee turnover 0.00 0.00 0.25 0.00 0.25 $9.20 $0.00 $3.31 837 209.25 $10,470.87

File new subscriber agreement, for employee turnover 0.00 0.00 0.08 0.00 0.08 $2.94 $0.00 $0.00 837 66.96 $2,460.78

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 $2.94 $0.00 $3.31 84 6.72 $525.00

Contact the Help Desk for technical support 0.00 0.00 0.06 0.00 0.06 $2.21 $0.00 $0.00 8,375 502.50 $18,508.75

Comply with Subscriber Agreement Provisions - ESA Registrants

Prepare and submit a subscriber agreement 0.00 0.00 0.17 0.00 0.17 $6.25 $0.00 $0.00 15,945 2,710.65 $99,656.25

File subscriber agreement 0.00 0.00 0.08 0.00 0.08 $2.94 $0.00 $0.00 15,945 1,275.60 $46,878.30

Prepare and submit a new subscriber agreement, for employee turnover 0.00 0.00 0.17 0.00 0.17 $6.25 $0.00 $0.00 1,792 304.64 $11,200.00

File new subscriber agreement, for employee turnover 0.00 0.00 0.08 0.00 0.08 $2.94 $0.00 $0.00 1,792 143.36 $5,268.48

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 $2.94 $0.00 $0.00 179 14.32 $526.26

Contact the Help Desk for technical support 0.00 0.00 0.06 0.00 0.06 $2.21 $0.00 $0.00 17,916 1,074.96 $39,594.36

Prepare and submit a subscriber agreement 0.00 0.00 0.17 0.00 0.17 $6.25 $0.00 $0.00 5,127 871.59 $32,043.75

File subscriber agreement 0.00 0.00 0.08 0.00 0.08 $2.94 $0.00 $0.00 5,127 410.16 $15,073.38

Prepare and submit a new subscriber agreement, for employee turnover 0.00 0.00 0.17 0.00 0.17 $6.25 $0.00 $0.00 576 97.92 $3,600.00

File new subscriber agreement, for employee turnover 0.00 0.00 0.08 0.00 0.08 $2.94 $0.00 $0.00 576 46.08 $1,693.44

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 $2.94 $0.00 $0.00 58 4.64 $170.52

Contact the Help Desk for technical support 0.00 0.00 0.06 0.00 0.06 $2.21 $0.00 $0.00 5,761 345.66 $12,731.81

Prepare and submit a subscriber agreement 0.00 0.00 0.17 0.00 0.17 $6.25 $0.00 $0.00 908 154.36 $5,675.00

File subscriber agreement 0.00 0.00 0.08 0.00 0.08 $2.94 $0.00 $0.00 908 72.64 $2,669.52

Prepare and submit a new subscriber agreement, for employee turnover 0.00 0.00 0.17 0.00 0.17 $6.25 $0.00 $0.00 102 17.34 $637.50

File new subscriber agreement, for employee turnover 0.00 0.00 0.08 0.00 0.08 $2.94 $0.00 $0.00 102 8.16 $299.88

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 $2.94 $0.00 $0.00 10 0.80 $29.40

Contact the Help Desk for technical support 0.00 0.00 0.06 0.00 0.06 $2.21 $0.00 $0.00 1,020 61.20 $2,254.20

Conduct On-Going Management

Identify and resolve problems 0.00 0.00 1.00 0.00 1.00 $36.78 $0.00 $0.00 992 992.00 $36,485.76

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies Varies 11,851.33 $463,617.51

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
43

EXHIBIT 1 (CONTINUED)

CROSS-MEDIA ELECTRONIC REPORTING RULE

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

 $57.87/ $37.09/ $36.78/ $16.18/ 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 $47.67 $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 $9.20 $0.00 $3.31 29,718 7,429.50 $371,772.18

File subscriber agreement 0.00 0.00 0.08 0.00 0.08 $2.94 $0.00 $0.00 29,718 2,377.44 $87,370.92

Prepare and submit a new subscriber agreement, for employee turnover 0.00 0.00 0.25 0.00 0.25 $9.20 $0.00 $3.31 3,339 834.75 $41,770.89

File new subscriber agreement, for employee turnover 0.00 0.00 0.08 0.00 0.08 $2.94 $0.00 $0.00 3,339 267.12 $9,816.66

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 $2.94 $0.00 $3.31 334 26.72 $2,087.50

Contact the Help Desk for technical support 0.00 0.00 0.06 0.00 0.06 $2.21 $0.00 $0.00 33,391 2,003.46 $73,794.11

Prepare subscriber agreement and send to LRA (non-ESA registrant) 0.00 0.00 0.33 0.00 0.33 $12.14 $0.00 $0.46 213 70.29 $2,683.80

Prepare new subscriber agreement and send to LRA, for employee turnover (nonESA registrant)

0.00 0.00 0.33 0.00 0.33 $12.14 $0.00 $0.46 24 7.92 $302.40

Report breach of security or comprimise/surrender of electronic signature device 0.00 0.00 0.08 0.00 0.08 $2.94 $0.00 $0.00 2 0.16 $5.88

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 $12.14 $0.00 $0.46 2 0.66 $25.20

Conduct On-Going Management

Identify and resolve problems 0.00 0.00 1.00 0.00 1.00 $36.78 $0.00 $0.00 771 771.00 $28,357.38

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 $499.23 $0.00 $5.94 14 182.00 $7,072.38

Register LRA with the electronic document receiving system 0.00 0.00 0.17 0.00 0.17 $6.25 $0.00 $0.00 14 2.38 $87.50

Redesignate LRA, due to turnover, and send application materials 0.00 0.00 1.00 0.00 1.00 $36.78 $0.00 $5.94 1 1.00 $42.72

Register new LRA with electronic document receiving system 0.00 0.00 0.17 0.00 0.17 $6.25 $0.00 $0.00 1 0.17 $6.25

Collect and securely store subscriber agreements 0.00 0.00 0.17 0.00 0.17 $6.25 $0.00 $0.00 213 36.21 $1,331.25

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 $6.25 $0.00 $2.57 213 36.21 $1,878.66

Collect and securely store subscriber agreements, for employee turnover 0.00 0.00 0.17 0.00 0.17 $6.25 $0.00 $0.00 24 4.08 $150.00

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 $6.25 $0.00 $2.57 24 4.08 $211.68

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 $6.25 $0.00 $0.00 2 0.34 $12.50

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 $6.25 $0.00 $2.57 2 0.34 $17.64

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies Varies 14,055.83 $628,797.50

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
44

EXHIBIT 1 (CONTINUED)

ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN

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

 $38.95/ $38.95/ $29.50/ $14.00/ 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 $14.75 $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 $5.02 $0.00 $0.00 29,718 5,052.06 $149,184.36

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

employee turnover

0.00 0.00 0.17 0.00 0.17 $5.02 $0.00 $0.00 3,339 567.63 $16,761.78

Receive, process, review, approve report compromise/surrender electronic 

signature device 0.00 0.00 0.17 0.00 0.17 $5.02 $0.00 $0.00 334 56.78 $1,676.68

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

storage

0.00 0.00 0.17 0.00 0.17 $5.02 $0.00 $0.00 213 36.21 $1,069.26

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 $5.02 $0.00 $0.00 24 4.08 $120.48

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 $29.50 $0.00 $0.00 2 2.00 $59.00

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 $5.02 $0.00 $0.00 2 0.34 $10.04

Receive application to designate first-time LRA 0.00 0.00 0.50 0.00 0.50 $14.75 $0.00 $0.00 14 7.00 $206.50

Receive application to designate LRA, for LRA turnover 0.00 0.00 0.50 0.00 0.50 $14.75 $0.00 $0.00 1 0.50 $14.75

Identify and resolve problems 0.00 0.00 1.00 0.00 1.00 $29.50 $0.00 $0.00 771 771.00 $22,744.50

Respond to information requests 0.00 0.00 1.50 0.00 1.50 $44.25 $0.00 $0.00 771 1,156.50 $34,116.75

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies Varies 7,654.10 $225,964.10

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
45

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

 $38.95/ $38.95/ $29.50/ $14.00/ 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 $51.34 $0.00 $0.00 24 36.00 $1,232.16

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 $10,057.45 $144,330.00 $5.42 4 1,324.00 $617,571.48

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 $6,384.00 $54,817.00 $5.42 1 210.00 $61,206.42

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 $783.60 $0.00 $5.42 15 360.00 $11,835.30

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 $24.49 $0.00 $5.42 4 3.00 $119.64

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies Varies 1,933.00 $691,965.00

TOTAL Varies Varies Varies Varies Varies Varies Varies Varies Varies 39,763.02 $2,167,445.71

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
46

EXHIBIT 2

ESTIMATED ANNUAL EPA HOUR AND COST BURDEN a

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

 $64.93/ $54.94/ $46.21/ $23.44/ 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 0.00 285.00 8,598.00 0.00 8,883.00 $412,971.48 $159,360.00 $0.00 1 8,883.00 $572,331.48

Subtotal 0.00 285.00 8,598.00 0.00 8,883.00 $412,971.48 $159,360.00 $0.00 1 8,883.00 $572,331.48

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

information 0.00 0.00 0.50 0.00 0.50 $23.11 $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 7,454 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 $0.00 837 0.00 $0.00

Receive, process, review, approve report compromise/surrender electronic 

signature device 0.00 0.00 0.17 0.00 0.17 $7.86 $0.00 $0.00 84 14.28 $660.24

Receive, process, review, approve and file new subscriber agreements 0.00 0.00 0.52 0.00 0.52 $24.03 $0.00 $0.00 15,945 8,291.40 $383,158.35

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

employee turnover

0.00 0.00 0.52 0.00 0.52 $24.03 $0.00 $0.00 1,792 931.84 $43,061.76

Receive, process, review, approve report compromise/surrender electronic 

signature device 0.00 0.00 0.17 0.00 0.17 $7.86 $0.00 $0.00 179 30.43 $1,406.94

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 5,127 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 $0.00 576 0.00 $0.00

Receive, process, review, approve report compromise/surrender electronic 

signature device 0.00 0.00 0.17 0.00 0.17 $7.86 $0.00 $0.00 58 9.86 $455.88

Receive, process, review, approve and file new subscriber agreements d 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $1.20 908 0.00 $1,089.60

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 $1.20 102 0.00 $122.40

Receive, process, review, approve report compromise/surrender electronic 

signature device 0.00 0.00 0.17 0.00 0.17 $7.86 $0.00 $0.00 10 1.70 $78.60

Identify and resolve problems 0.00 0.00 1.00 0.00 1.00 $46.21 $0.00 $0.00 992 992.00 $45,840.32

Respond to information requests 0.00 0.00 1.50 0.00 1.50 $69.32 $0.00 $0.00 992 1,488.00 $68,765.44

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies Varies 11,759.51 $544,639.53

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 

$1.20 per subscriber agreement.

Collect Subscriber Agreements - Third Party ESA Registrants

Conduct On-Going Management
47

EXHIBIT 2 (CONTINUED)

ESTIMATED ANNUAL EPA HOUR AND COST BURDEN a

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

 $64.93/ $54.94/ $46.21/ $23.44/ Hours/ Cost/ S tartup 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 $7,393.60 $0.00 $0.00 4 640.00 $29,574.40

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 $3,696.80 $0.00 $0.00 1 80.00 $3,696.80

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 $1,109.04 $0.00 $0.00 15 360.00 $16,635.60

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 $554.52 $0.00 $0.00 4 48.00 $2,218.08

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies Varies 1,128.00 $52,124.88

TOTAL 0.00 Varies Varies Varies Varies Varies Varies Varies Varies 21,770.51 $1,169,095.89

a

 Exhibit includes rounding error.

Approval of State/Local Electronic Document Receiving System Applications

CROSS -MEDIA ELECTRONIC REPORTING RULE

Hours and Labor Costs Per Respondent Per Activity Total Hours and Costs
48

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 3,629.76 $133,584.72 $0.00 $0.00 $133,584.72

Compliance with Identity Proofing Requirements - Direct Reporters 10,077.74 $370,662.97 $0.00 $23,570.51 $394,233.48

Compliance with Identity Proofing Requirements - Indirect Reporters 11,952.26 $440,019.89 $0.00 $94,669.83 $534,689.72

Subtotal 25,659.76 $944,267.58 $0.00 $118,240.34 $1,062,507.92

Reporting to EPA Electronic Document Receiving System - Direct Reporters 639.00 $23,516.88 $0.00 $0.00 $23,516.88

Compliance with Identity Proofing Requirements - Direct Reporters 1,773.59 $65,233.29 $0.00 $4,150.74 $69,384.03

Compliance with Identity Proofing Requirements - Indirect Reporters 2,103.57 $77,440.13 $0.00 $16,667.65 $94,107.78

Compliance with Identity Proofing Requirements - State/Local Agencies Acting as Regulators 7,654.10 $225,964.10 $0.00 $0.00 $225,964.10

Approval of State/Local Electronic Document Receiving System Application - State/Local Agencies that Are Regulated Entities 1,933.00 $59,697.92 $632,137.00 $130.08 $691,965.00

Subtotal 14,103.26 $451,852.32 $632,137.00 $20,948.47 $1,104,937.79

Registering with EPA Electronic Document Receiving System - Direct Reporters 4,268.76 $157,101.60 $0.00 $0.00 $157,101.60

Compliance with Identity Proofing Requirements - Direct Reporters 11,851.33 $435,896.26 $0.00 $27,721.25 $463,617.51

Compliance with Identity Proofing Requirements - Indirect Reporters 14,055.83 $517,460.02 $0.00 $111,337.48 $628,797.50

Compliance with Identity Proofing Requirements - State/Local Agencies Acting as Regulators 7,654.10 $225,964.10 $0.00 $0.00 $225,964.10

Approval of State/Local Electronic Document Receiving System Application - State/Local Agencies that Are Regulated Entities 1,933.00 $59,697.92 $632,137.00 $130.08 $691,965.00

Total 39,763.02 $1,396,119.90 $632,137.00 $139,188.81 $2,167,445.71

3-year Total 119,289 $4,188,360 $1,896,411 $417,567 $6,502,338

a

 Exhibit includes rounding error.

All Respondents (i.e., Private Sector and State/Local)

Private Sector Respondents

State/Local Respondents

Note: The exhibit presents hour and cost burden for private sector and State/Local respondents. Information is needed in this format for submission of the ICR into EPA’s 

Information Collection Request, Review, and Approval System (ICRAS), the electronic system that EPA uses to transmit ICRs to OMB for approval. 
49

EXHIBIT 4

CROSS-MEDIA ELECTRONIC REPORTING

TOTAL ESTIMATED EPA HOUR AND COST BURDEN SUMMARYa

Annual Burden 

Hours

Annual Labor

Cost

Annual Capital/ 

Startup Cost

Annual O&M

Cost

Total Annual Cost

Registering with EPA Electronic Document Receiving System 8,883.00 $412,971.48 $159,360.00 $0.00 $572,331.48

Compliance with Identity Proofing Requirements 11,759.51 $543,427.53 $0.00 $1,212.00 $544,639.53

Approval of State/Local Electronic Document Receiving System Applications 1,128.00 $52,124.88 $0.00 $0.00 $52,124.88

Total 21,770.51 $1,008,523.89 $159,360.00 $1,212.00 $1,169,095.89

3-year Total 65,313 $3,025,572 $478,080 $3,636 $3,507,288

a

 Exhibit includes rounding error.
50

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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 cumulative number of employee registrants for 

years 2007 through 2010. We then estimated the annual number of new employee registrants for 

the three-year period covered by the ICR (i.e., years 2011 through 2013) based on analysis of 

new registrant growth rates. 

1.2. Detailed Discussion

EPA took the following steps to carry out the methodology.

A. Compile historical information on cumulative number of employee registrants. EPA 

referred to CDX in order to compile historical information on the cumulative number of 

registrants for years 2007 through 2010.

Year Cumulative Number of

Employee Registrants

2007 70,669

2008 91,761

2009 120,653

2010 150,820
B-2

B. Estimate cumulative number of employee registrants for years 2011 through 2013 

(i.e., the three-year period covered in the ICR). We estimated the cumulative number of 

registrants for years 2011 through 2013 by using the following equation: 

Cumulative 

Number of

Registrants

for Year Y

= RegistrantsY-1 + ([3 x (RegistrantsY-1 – RegistrantsY-2)] + [2 x (RegistrantsY-2 – RegistrantsY-3)] + 

[RegistrantsY-3 - RegistrantsY-4]) / 6

The table below shows the results of using the above equation for years 2011 through 

2013:

Year Calculation

Cumulative 

Number of 

Employee 

Registrants a

2011 150,820 + ([3 x (150,820 - 120,653)] + [2 x (120,653 - 91,761)] + [91,761 - 70,669]) / 6 179,050

2012 179,050 + ([3 x (179,050 - 150,820)] + [2 x (150,820 - 120,653)] + [120,653 - 91,761]) / 6 208,036

2013 208,036 + ([3 x (208,036 - 179,050)] + [2 x (179,050 - 150,820)] + [150,820 - 120,653]) / 6 236,967

a

 Includes rounding error.

C. Estimate total number of new employee registrants for years 2011 through 2013. We 

estimated the total number of new registrants for years 2011 through 2013 by using the 

following equation:

Number

New Registrants

For Year Y

= RegistrantsY – RegistrantsY-1

The table below shows the results of using the above equation for years 2011 through 

2013:

Year Calculation

Number of

New Employee 

Registrants a

2011 179,050 - 150,820 28,230

2012 208,036 - 179,050 28986

2013 236,967 - 208,036 28931

Total for Years 2011 through 2013 86,147

a

 Includes rounding error.

D. Estimate annual number of new employee registrants over the three-year period covered 

in the ICR. We assumed that one third of the total three-year projection will register with 

CDX in each year of the ICR. That is, we assumed that 28,716 new registrants 

(i.e., 86,147 ÷ 3) will register with CDX each year.
B-3

E. 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 83.16 percent of U.S. employees work for 

the private sector, 14.64 percent of employees work for States/Locals, and 2.20 percent of 

employees work for the Federal government. We applied these percentages to the annual 

number of new employee registrants in Step D. 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 23,881

States/Locals 4,205

Total 28,086

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 2007 through 2010. 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 2011 through 2013) based on analysis of growth rates 

and implementation rates.
B-4

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 paper subscriber agreements for years 2011 through 2013, we 

referred to CDX in order to compile historical information on the number of non-ESAs, 

by CROMERR data flow, for years 2007 through 2010. 

CROMERR

Data Flow

Number of Paper Subscriber Agreements

2007 2008 2009 2010

e-GGRT 552 1,072 1,924 4,442

EMTS 157 288 550 1,319

SDWIS 235 225 200 196

UCMR2 3,525 3,276 2,919 1,861

Total 4,469 4,861 5,593 7,818

B. Estimate total number of paper subscriber agreements, by CROMERR data flow, for 

years 2011 through 2013 (i.e., the three-year period covered in the ICR). We estimated 

the total number of paper subscriber agreements, by CROMERR data flow, for years 

2011 through 2013 by using the following equations: 

For year 2011:

Total Number

of Subscriber 

Agreements

for Year Y

= Subscriber AgreementsY-1 + ([3 x (Subscriber AgreementsY-1 - Subscriber AgreementsY-2)] + 

[2 x (Subscriber AgreementsY-2 - Subscriber AgreementsY-3] + 

[Subscriber AgreementsY-4]) / 6

For years 2012 and 2013:

Total Number

of Subscriber 

Agreements

for Year Y

= ([3 x Subscriber AgreementsY-1] + [2 x Subscriber AgreementsY-2] +

[Subscriber AgreementsY-3]) / 6
B-5

The table below shows the estimated number of paper subscriber agreements, by

CROMERR data flow, for years 2011 through 2013. Note that, for certain data flows, we 

revised the estimated number of subscriber agreements based on available program 

information. 

CROMERR

Data Flow

Number of Paper Subscriber Agreements a

2011 2012 2013

e-GGRT 6,072 4,837 5,183

EMTS 1,813 1,319 b

1,484

SDWIS 184 196 b

192

UCMR2 1,172 1,693 1,547

Total 9,240 8,045 8,405

a

 Table includes rounding error.

b

 Estimate is based on available program information, not on use of equation.

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 2008 through 2010. 

CROMERR

Data Flow

Number of ESAs a

2008 2009 2010

OTAQ 387 367 610

ODS-CBI 35 23 13

TRIMEWeb 10,043 11,779 8,994

RMPeSubmit 694 5,483 1,976

eTSCA 19 34 293

eTSCA-PDS b

eIUR 94 145 32

eIUR2 b

Total 11,272 17,831 11,918

a

 Table includes rounding error.

b

 New CROMERR data flow for years 2011 through 2013. Data flow is 

included in this table to facilitate discussion in subsequent steps.

D. Estimate number of ESAs, by CROMERR data flow, for years 2011 through 2013 

(i.e., the three-year period covered in the ICR). We estimated the number of ESAs, by 

CROMERR data flow, for years 2011 through 2013 by using the following equation: 

Number of ESAs

for Year Y

= ([3 x RegistrantsY-1] + [2 x RegistrantsY-2] + [RegistrantsY-3]) / 6
B-6

The table below shows the estimated number of ESAs, by CROMERR data flow, for

years 2011 through 2013. Note that, for certain data flows, we revised the estimated 

number of ESAs based on available program information. 

CROMERR

Data Flow

Number of ESAs a

2011 2012 2013

OTAQ 1,719

c

1,124 1,236

ODS-CBI 20 18 18

TRIMEWeb 10,097 10,010 9,870

RMPeSubmit 2,931 3,038 2,826

eTSCA 161 184 194

eTSCA-PDS 5,000 c

2,500 c2,500 c

eIUR b

80

eIUR2 968 c

240 c225 c

Total 20,976 17,114 16,868

a

 Table includes rounding error.

b

 eIUR was discontinued and replaced by eIUR2.

c

 Estimate is based on available program information, not on use of equation.

E. Estimate number of reuse (consolidated) ESAs, by CROMERR data flow, for years 2011 

through 2013. We estimated the number of reuse (consolidated) ESAs, for participating 

data flows, by applying implementation rates 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

2011 2012 2013

OTAQ 100%

ODS-CBI

TRIMEWeb 50% 50%

RMPeSubmit

eTSCA 50%

eTSCA-PDS 50% 50% 50%

eIUR

eIUR2 70.7% 50% 50%
B-7

The table below shows the estimated number of reuse (consolidated) ESAs, by

CROMERR data flow, for years 2011 through 2013. 

CROMERR

Data Flow

Number of Reuse (Consolidated) ESAs a

2011 2012 2013

OTAQ 1,719

ODS-CBI

TRIMEWeb 5,005 4,935

RMPeSubmit

eTSCA 97

eTSCA-PDS 2,500 1,250 1,250

eIUR

eIUR2 684 120 112

Total 4,903 6,375 6,394

a

 Table includes rounding error.

F. Estimate number of third party ESAs, by CROMERR data flow, for years 2011 through

2013. We estimated the number of third party ESAs for participating data flows by

applying implementation rates provided by CDX to the number of ESAs obtained in

Step D. Specifically, we estimated that third party ESAs are 10 percent of the estimated 

ESAs for the following data flows: 

 For year 2011: eTSCA-PDS and eIUR2.

 For years 2012 and 2013: eTSCA-PDS, eIUR2, and TRIMEWeb.

The table below shows the estimated number of third party ESAs, by CROMERR data 

flow, for years 2011 through 2013. 

CROMERR

Data Flow

Number of Third Party ESAs a

2011 2012 2013

OTAQ

ODS-CBI

TRIMEWeb 1,001 987

RMPeSubmit

eTSCA

eTSCA-PDS 500 250 250

eIUR

eIUR2 97 24 22

Total 597 1,275 1,259

a

 Table includes rounding error.
B-8

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 2011 through 2013. The results are presented in the table below.

Type of Subscriber Agreement

Number of Subscriber Agreements

Year 2011 Year 2012 Year 2013 Average

Non-ESAs (Paper Subscriber Agreements) 9,240 8,045 8,405 8,563

ESAs 20,976 17,114 16,868 18,319

Reuse (Consolidated) ESAs 4,903 6,375 6,394 5,891

Third Party ESAs 597 1,275 1,259 1,044

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 83.16 percent 

of U.S. employees work for the private sector, 14.64 percent of employees work for 

States/Locals, and 2.20 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-9

Exhibit B-2

Annual Number Subscriber Agreements to be Submitted to 

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

Type of Subscriber Agreement Average Annual Number

of Subscriber Agreements a

Private Sector

Non-ESAs (Paper Subscriber Agreements) 7,121

ESAs 15,234

Reuse (Consolidated) ESAs 4,898

Third Party ESAs 868

Subtotal 28,122

States/Locals

Non-ESAs (Paper Subscriber Agreements) 1,254

ESAs 2,682

Reuse (Consolidated) ESAs 862

Third Party ESAs 153

Subtotal 4,950

All (Private Sector and States/Locals)

Non-ESAs (Paper Subscriber Agreements) 8,375

ESAs 17,916

Reuse (Consolidated) ESAs 5,761

Third Party ESAs 1,020

Total 33,072

a

 Federal government employees are exempt from ICR requirements. As a result, their subscriber 

agreements are not included in the exhibit.
B-10

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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 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).30, 31 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 (2011) 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.

 

30

 “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.

31

 “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 electronic document receiving systems, we referred to EPA’s “Status 

of CROMERR Applications from States” Web site

(http://www.epa.gov/cromerr/application_status.html), which contains data current as of 

December 2010. 

To identify States with new electronic document receiving systems, we referred to EPA’s 

CROMERR universe tracking spreadsheet, which contains data current as of 

September 14, 2010. For purposes of this analysis, “new electronic document receiving 

systems” are those that meet the following criteria, as indicated in the spreadsheet:

 Name of the system is available;

 System is subject to CROMERR; and

 System is categorized as “planned.”

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 memorandum.

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.

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 (2011), we took the following 

steps:

 Referred to the Information Collection Request, Review, and Approval System 

(ICRAS) to obtain data on annual number of respondents in the ICRs listed in 

Attachment C-3. For each ICR, we obtained respondent universe estimates for at 
C-3

least two different years (e.g., 2002 and 2008) 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 9 to estimate percent change over the 

2002-2011 period.

 Applied the 2002-2011 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.32 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. 

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 

 

32

 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: 2008,” February 15, 2011. Available 

online at: http://www.census.gov/econ/susb/, last accessed on February 23, 2011. These are the latest Statistics of 

U.S. Businesses (SUSB) annual data.
C-4

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 2011 through 2013 (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.33 These data indicate that 83.16 

percent of U.S. employees work for the private sector, 14.64 percent of employees work 

for States/Locals, and 2.20 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.

Attachments C-6 and C-7 present details on the application of the above methodology to 

existing and new receiving systems, respectively.

 

33

 Bureau of Labor Statistics; Quarterly Census of Employment and Wages; Number of Employees (US 

Total, All Industries, All Establishment Sizes); 2009 (Annual). Available online at: 

http://data.bls.gov/pdq/querytool.jsp?survey=en, last accessed on April 27, 2011. 
C-5

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

Type of Firm

Average Annual Number of Facility Employees

Existing Receiving Systems New Receiving System All Receiving Systems

(i.e., Existing and New)

Private Sector

Small Firms 8,714 3,156 11,870

Medium-Size and Large Firms 7,469 2,704 10,173

Subtotal 16,183 5,860 22,043

States/Locals

Small Firms 1,534 556 2,090

Medium-Size and Large Firms 1,315 476 1,791

Subtotal 2,849 1,032 3,881

All (Private Sector and States/Locals)

Small Firms 10,248 3,712 13,960

Medium-Size and Large Firms 8,784 3,180 11,964

Total 19,032 6,892 25,924

a

 Federal government employees are not reflected in the table because they are exempt from ICR requirements.
C-6

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C-7

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 X

Alaska X X X

American Samoa

Arizona X

Arkansas X X

California X

Colorado X X

Connecticut X

Delaware X X X

District of Columbia

Florida X X X

Georgia X 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 X

Maryland X 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 X X

Nebraska X

Nevada X X

New Hampshire X X

New Jersey X X X
C-8

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

North Dakota X

Northern Mariana Islands

Ohio X X X

Oklahoma X X X

Oregon X X

Pennsylvania X X X

Puerto Rico

Rhode Island X X

South Carolina X X

South Dakota X X X X

Tennessee X X

Texas X X X

U.S. Virgin Islands

Utah X

Vermont X X X

Virginia X

Washington X X X

West Virginia X

Wisconsin X X X

Wyoming X X X

Sources: (1) U.S. Environmental Protection Agency (USEPA), “Status of CROMERR Applications from States” Web site 

(http://www.epa.gov/cromerr/application_status.html), data current as of December 2010.

(3) U.S. Environmental Protection Agency (USEPA), “Master Sprdsht with EPA sprdsht” worksheet of the 

“Summary CROMERR Universe 20100914 Draft V1.xls” Excel file, dated September 14, 2010. 
C-9

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-10

Attachment C-3

List of ICRs Used in Analysis, by Environmental Program

ICR Numbers ICR Name

Air

916.12

916.13 Consolidated Emissions Reporting (NEI)

1587.06

1587.07 State Operating Permit Regulations

111.10

111.12 NESHAP for Asbestos

1088.10

1088.12 NSPS for Industrial-Commercial-Institutional Steam Generating Units

Water

229.15

229.16 NPDES and Sewage Sludge Monitoring Reports (DMR)

1842.04

1842.05

Notice of Intent for Storm Water Discharges Associated with Construction Activity Under 

a NPDES General Permit

2.11

2.14 National Pretreatment Program

270.42

270.43 Public Water System Supervision Program

Waste, USTs, Emergency Planning

261.14 Notification of Regulated Waste Activity

976.11 2007 Hazardous Waste Report

976.14 Notification of Regulated Waste Activity and 2009 Hazardous Waste Report

1380.07

1380.08

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 February 22-28, 2011.
C-11

Attachment C-4a

ICR Data Used to Update Number of Facilities Obtained from CROMERR CBA

Air Programs

Consolidated Emissions Reporting (NEI)

EPA ICR Number 

916.12

EPA ICR Number 

916.13

2006 2009

Industry Respondents and States/Territories/Local Agencies 2,038 1,863 -8.6% 3 -2.9% 0.06 -0.2% -1.1%

State Operating Permit Regulations

EPA ICR Number 

1587.06

EPA ICR Number 

1587.07

2004 2007

Permitting Authorities and Sources Subject to Permitting under 40 CFR Part 70 17,738 16,930 -4.6% 3 -1.5% 0.57 -0.9%

NESHAP for Asbestos

EPA ICR Number 

111.10

EPA ICR Number 

111.12

2003 2009

Respondents 9,848 9,432 -4.2% 6 -0.7% 0.32 -0.2%

NSPS for Industrial-Commercial-Institutional Steam Generating Units

EPA ICR Number 

1088.10

EPA ICR Number 

1088.12

2003 2010

Respondents 1,230 1,500 22.0% 7 3.1% 0.05 0.2%

Total Number Respondents for All ICRs 29,725

Number 

of Years

Weight

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

Weighted Annual 

Percent Change in 

Number of 

Respondents

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

Respondent Universe

Respondent Universe

Respondent Universe

Respondent Universe

Annual Number of Respondents

Annual Number of Respondents

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

Number 

of Years

Number 

of Years

Number 

of Years
C-12

Attachment C-4b

ICR Data Used to Update Number of Facilities Obtained from CROMERR CBA

Water Programs

NPDES and Sewage Sludge Monitoring Reports (DMR)

EPA ICR Number 

229.15

EPA ICR Number 

229.16

2001 2005

Permittees and States/Tribes/Territories 86,135 81,988 -4.8% 4 -1.2% 0.19 -0.2% -3.4%

Notice of Intent for Storm Water Discharges Associated with Construction Activity Under a NPDES General Permit

EPA ICR Number 

1842.04

EPA ICR Number 

1842.05

2003 2006

Permittees and States/Tribes/Territories 201,259 157,546 -21.7% 3 -7.2% 0.37 -2.7%

National Pretreatment Program

EPA ICR Number 

2.11

EPA ICR Number 

2.14

2004 2007

Industrial users (IUs), POTWs, and States 28,285 24,740 -12.5% 3 -4.2% 0.06 -0.3%

Public Water System Supervision Program

EPA ICR Number 

270.42

EPA ICR Number 

270.43

2004 2008

Existing PWSs, Primary Agencies, and Laboratories 161,682 158,113 -2.2% 4 -0.6% 0.37 -0.2%

Total Number Respondents for All ICRs 422,387

Weighted Annual 

Percent Change in 

Number of 

Respondents

Percent Change 

in Number of 

Respondents

Number 

of Years

Number 

of Years

Weight

Weighted Annual 

Percent Change in 

Number of 

Respondents

Number 

of Years

Weight

Weighted Annual 

Percent Change in 

Number of 

Respondents

Number 

of Years

Weight

Respondent Universe

Annual Number of Respondents

Respondent Universe

Annual Number of Respondents

Respondent Universe

Annual Number of Respondents

Respondent Universe

Annual Number of Respondents

Annual Percent 

Change in Number 

of Respondents

Average Annual 

Percent Change for 

Environmental 

Program

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

Percent Change 

in Number of 

Respondents

Annual Percent 

Change in Number 

of Respondents

Weight

Weighted Annual 

Percent Change in 

Number of 

Respondents
C-13

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 

976.14

2003 2009

Initial and Subsequent Notifications under RCRA Section 3010; 40 CFR Part 273, Subpart C; and 40 CFR Part 279 31,125 46,186 48.4% 6 8.1% 0.16 1.3% -0.2%

Hazardous Waste Report

EPA ICR Number 

976.11

EPA ICR Number 

976.14

2003 2009

Respondents to the Hazardous Waste Report 10,178 8,542 -16.1% 6 -2.7% 0.03 -0.1%

Underground Storage Tanks: Technical and Financial Requirements, and State Program Approval Procedures

EPA ICR Number 

1360.07

EPA ICR Number 

1360.08

2004 2008

Private and Governments 254,705 237,578 -6.7% 4 -1.7% 0.81 -1.4%

Total Number Respondents for All ICRs 292,306

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

Number 

of Years

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

Respondent Universe

Annual Number of Respondents

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
C-14

Attachment C-5

Number of Establishments (Facilities) by Employment Size, 2008

STATE Less than 20 Employees 20 or More Employees Total

United States 5,349,024 2,252,145 7,601,169

Alabama 68,196 35,679 103,875

Alaska 14,718 5,216 19,934

Arizona 94,436 45,645 140,081

Arkansas 45,595 21,073 66,668

California 638,535 240,490 879,025

Colorado 115,392 41,292 156,684

Connecticut 65,132 27,465 92,597

Delaware 16,475 8,699 25,174

District of Columbia 12,554 8,527 21,081

Florida 379,105 127,922 507,027

Georgia 156,600 70,993 227,593

Hawaii 22,584 10,320 32,904

Idaho 34,635 11,611 46,246

Illinois 226,845 95,097 321,942

Indiana 98,736 51,365 150,101

Iowa 56,204 26,149 82,353

Kansas 52,079 24,017 76,096

Kentucky 60,675 31,912 92,587

Louisiana 70,230 33,777 104,007

Maine 30,944 10,811 41,755

Maryland 96,416 42,191 138,607

Massachusetts 123,065 51,225 174,290

Michigan 160,153 69,157 229,310

Minnesota 104,812 44,033 148,845

Mississippi 40,811 20,107 60,918

Missouri 103,753 48,687 152,440

Montana 29,247 8,071 37,318

Nebraska 36,457 15,695 52,152

Nevada 41,596 20,230 61,826

New Hampshire 27,520 11,386 38,906

New Jersey 179,269 59,171 238,440

New Mexico 31,797 14,403 46,200

New York 399,765 118,867 518,632

North Carolina 153,708 71,450 225,158

North Dakota 15,221 6,337 21,558

Ohio 171,583 92,178 263,761

Oklahoma 63,606 27,776 91,382
C-15

Attachment C-5 (continued)

Number of Establishments (Facilities) by Employment Size, 2008

STATE Less than 20 Employees 20 or More Employees Total

Oregon 81,131 30,419 111,550

Pennsylvania 205,633 97,482 303,115

Rhode Island 22,096 7,663 29,759

South Carolina 72,043 34,635 106,678

South Dakota 18,839 6,850 25,689

Tennessee 86,991 49,594 136,585

Texas 346,045 176,291 522,336

Utah 52,244 19,189 71,433

Vermont 16,829 5,292 22,121

Virginia 134,612 63,104 197,716

Washington 133,446 48,761 182,207

West Virginia 26,362 13,279 39,641

Wisconsin 98,516 45,565 144,081

Wyoming 15,788 4,997 20,785

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: 2008,” February 15, 

2011. Available online at: http://www.census.gov/econ/susb/, last accessed on February 23, 2011. 

These are the latest Statistics of U.S. Businesses (SUSB) annual data.
C-16

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

2002-2011 Percent 

Change for 

Environmental 

Program

Updated Total

Number of

Facilities in CBA

Air NJ, NM, OH, PA, WI 17,197 -1.1% -9.9% 15,494

Water FL, ND, OH, WI 7,525 -3.4% -30.6% 5,222

Waste, USTs, Emergency Planning NJ, OH, WI 2,580 -0.2% -1.8% 2,534

Environmental Program

Number of

Establishments for 

States with Facility 

Data in CBA

Number of

Establishments for 

States with Existing 

Receiving Systems

Scaling Factor

Air 995,597 5,067,196 5.09

Water 936,427 6,879,540 7.35

Waste, USTs, Emergency Planning 646,282 4,181,706 6.47

Environmental Program

Updated Total Number 

of Facilties in CBA

Scaling Factor

Total Number of 

Facilities for States 

with Existing 

Receiving Systems

Air 15,494 5.09 78,864

Water 5,222 7.35 38,382

Waste, USTs, Emergency Planning 2,534 6.47 16,395

Total Number of Facilities for All Environmental Programs 133,641
C-17

Attachment C-6 (continued)

Application of Methodology to Existing Receiving Systems

Year Number of Facilities

2005 40,092

2006 9,355

2007 8,419

2008 7,578

2009 6,820 Legend:

2010 6,138

2011 5,524

2012 4,972

2013 4,474

2014 4,027

2015 3,624

2016 3,262

2017 2,936

2018 2,642

2019 2,378

2020 2,140

Year 1 Year 2 Year 3

Small Firms 3,867 3,480 3,132 3,493 10,479

Medium-Size and Large Firms 1,657 1,492 1,342 1,497 8,982

Total 5,524 4,972 4,474 4,990 19,461

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-18

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

2002-2011 Percent 

Change for 

Environmental

Program

Updated Total

Number of 

Facilities in CBA

Air NJ, NM, OH, PA, WI 17,197 -1.1% -9.9% 15,494

Water FL, ND, OH, WI 7,525 -3.4% -30.6% 5,222

Waste, USTs, Emergency Planning NJ, OH, WI 2,580 -0.2% -1.8% 2,534

Environmental Program

Number of 

Establishments for 

States with Facility 

Data in CBA

Number of 

Establishments for 

States with New 

Receiving Systems

Scaling Factor

Air 995,597 330,587 0.33

Water 936,427 1,499,092 1.60

Waste, USTs, Emergency Planning 646,282 323,158 0.5

Environmental Program

Updated Total Number 

of Facilties in CBA

Scaling Factor

Total Number of 

Facilities for States 

with New Receiving 

Systems

Air 15,494 0.33 5,113

Water 5,222 1.60 8,355

Waste, USTs, Emergency Planning 2,534 0.50 1,267

14,735

4,912

Year 1 Year 2 Year 3

Year 1 1,474 344 309

Year 2 0 1,474 344

Year 3 0 0 1,474

Total 1,474 1,818 2,127

Year 1 Year 2 Year 3

Small Firms 1,032 1,273 1,489 1,265 3,795

Medium-Size and Large Firms 442 545 638 542 3,252

Total 1,474 1,818 2,127 1,807 7,047

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