# Economic Analysis for the Lead

- B ased Paint Program

Minor Amendments Final Rule

February 2016

Economic and Policy Analysis Branch

Chemistry, Economics, and Sustainable Strategies Division

Office of Pollution Prevention, and Toxics

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue

Washington, DC 20460

## Acknowledgement

Analytical and draft preparation support was provided by Abt Associates Inc. under EPA Contract No.

EP

- W

- 08

- 0100 and EP

- W

- 12

- 001

.

### i 

## Table of Contents

Executive Summary

................................ ................................ ................................ ................................ . ES

- 1

1. Introduction

................................ ................................ ................................ ................................ ...... 1

- 1

1.1 Regulatory and Programmatic Background

................................ ................................ ............. 1

- 1

1.2 Summary of Analytic Approach

................................ ................................ .............................. 1

- 2

1.3 Organization of This Report

................................ ................................ ................................ ..... 1

- 3

2. Affected Entities

................................ ................................ ................................ ................................ 2

- 1

3. Industry Cost Savings

................................ ................................ ................................ ...................... 3

- 1

3.1 Abatement Multi

- jurisdiction Registration Fee Amendment

................................ ................... 3

- 1

3.2 Renovator Refresher Training Course Amendment

................................ ................................ . 3

- 2

3.3 RRP Training Provider Notification Amendment

................................ ................................ .. 3

- 16

3.4 Total Industry Cost Savings

................................ ................................ ................................ ... 3

- 29

3.5 Other Industry Costs

................................ ................................ ................................ .............. 3

- 30

4. Agency Costs

................................ ................................ ................................ ................................ ..... 4

- 1

5. Social Cost Savings

................................ ................................ ................................ ........................... 5

- 1

6. S mall Entity Impact Analysis

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

- 1

7. Other Impact Analyses

................................ ................................ ................................ ..................... 7

- 1

7.1 Paperwork Reduction Act

................................ ................................ ................................ ........ 7

- 1

7.2 Unfunded Mandates Reform Act

................................ ................................ ........................... 7

- 10

7.3 Executive Order 13132

– Federalism

................................ ................................ ..................... 7

- 10

7.4 Executive Order 13175

– Consultation and Coordination with Indian Tribal Gov ernments

. 7

- 10

7.5 Executive Order 13045

- Children’s Health

................................ ................................ ........... 7

- 11

7.6 Executive Order 13211

– Energy Supply, Distribution, or Use

................................ ............. 7

- 11

7.7 National Technology Transfer and Advancement Act

................................ ........................... 7

- 11

7.8 Executive Order 12898

– Environmenta l Justice

................................ ................................ ... 7

- 11

8. References

................................ ................................ ................................ ................................ ......... 8

- 1

Training Courses Tuition Data

................................ ................................ .......................... A

- 1

Rule Amendment Options

- Derivation of Estimates for the Number of Individuals

Seeking Recertification

................................ ................................ ................................ .............................. B

- 1

Detailed E xhibits of Total Renovator Training Costs

................................ ...................... C

- 1

### ii 

## List of Exhibits

Exhibit ES

- 1 : Regulatory Options

................................ ................................ ................................ ......... ES

- 2

Exhibit ES

- 2: Expected Number of Renovators Seeking Training Each Year (rounded to the nearest

thousand)

................................ ................................ ................................ .......................... ES

- 3

Refresher Training under Existing Rule and Amended Final Rule

– Option 4(c)

................................ ES

- 5

Exhibit ES

- 3: Summary of Total Costs and Cost Savings for Refresher Training Regulatory Options

Over a Ten Year Period, 2016 thr ough 2025 (millions of 2014$)

................................ ... ES

- 6

Exhibit ES

- 4: Pre

- and Post

- training Notification Cost Savings for Regulatory Options Over a T en Year Period, 2016 through 2025 (2014$)

................................ ................................ .................. ES

- 8

Exhibit ES

- 5: Total and Annualized Social Cost Savings of Minor Amendments Rule Over 10 Years

(millions of 2014$) 1



### ................................ ................................ ................................ ........ ES

- 10

Exhibit ES

- 6: Itemized Total and Annualized Cost Savings of the Final Rule Over 10 Years (thousands

of 2014$)

................................ ................................ ................................ ........................ ES

- 11

Exhibit 1

- 1: Assumed Duration of Existing RRP Training Courses

................................ ........................ 1

- 2

Exhibit 2

- 1: Lead

- based Paint Activities Individuals and Firms Applying for (Re)certification and

Training Providers Applying for (Re)accreditation from 2011

- 2013

................................ .. 2

- 1

Exhibit 2

- 2: Renovator Initial Certifications under the RRP Program Rule from 2009

- 10 through 2014

and Expiring Certifications Under the Extension Rule

................................ ....................... 2

- 2

Exhibit 2

- 3: Steady State Average Number of Renovator Certifications from 2016 through 2025

......... 2

- 2

Exhibit 3

- 1: Annual Multi

- jurisdiction Registration Fees for Individuals and Firms Applying for

(Re)certification, and Training Providers Applying for (Re)acc reditation

......................... 3

- 1

Exhibit 3

- 2: Ten Year Net Present Value and Annualized Cost Savings for Individuals and Firms

Applying for (Re)cer tification, and Training Providers Applying for (Re)accreditation
(2014$)

................................ ................................ ................................ ................................ 3

- 2

Exhibit 3

- 3 : Regulatory Options

................................ ................................ ................................ .............. 3

- 3

Exhibit 3

- 4: Refresher Training Requirements Under Regulatory Options

................................ ............. 3

- 4

Exhibit 3

- 5: Procedure to Estimate In

- person Classroom Refresher Training Course Tuition (2014$)

.. 3

- 6

Exhibit 3

- 6: Summary of Refresher Course Tuitions (2014$)

................................ ................................ . 3

- 7

Exhibit 3

- 7 : Average Renovator Travel Cost (2014$)

................................ ................................ ............. 3

- 8

Exhibit 3

- 8: Summary of Refresher Training Costs (2014$)

................................ ................................ ... 3

- 9

Exhibit 3

- 9 : Expected Number of Renovators S eeking Refresher Training Each Year

........................ 3

- 12

Exhibit 3

- 10: Summary of Total Costs and Cost Savings for Refresher Training Regulatory Options
Over a Ten Year Period, 2016 through 2025 (2014$)

................................ ...................... 3

- 14

Exhibit 3

- 11: Pre

- training Notification Cost Savings for Regulator y Options Over a Ten Year Period,
2016 through 2025 (2014$)

................................ ................................ ............................... 3

- 18

Exhibit 3

- 12: Initial and Recurring Burden Associated with Submitting Notifications via the CDX

... 3

- 20

Exhibit 3

- 13: Net Present Value and Annualized Costs Over a Ten Year Period of Initial a nd Recurring

Notification Submissions via the CDX (2014$)

................................ ................................ 3

- 21

Exhibit 3

- 14: Post

- training Notification Cost Savings for Regulato ry Options Over a Ten Year Period,
2016 through 2025 (2014$)

................................ ................................ ............................... 3

- 24

### iii Exhibit 3

- 15: Pre

- and Post

- training Notification Cost Savings f or Regulatory Options Over a Ten Year Period, 2016 through 2025 (2014$)

................................ ................................ ................... 3

- 27

Exhibit 3

- 16: Total and Annualized Industry Cost Sav ings Over 10 Years (2014$)

............................. 3

- 29

Exhibit 4

- 1 : EPA Wage Rate

................................ ................................ ................................ ................... 4

- 1

Exhibit 4

- 2: Ten Year Net Present Value and Annualized Cost to EPA Under the Final Rule (2014$)

. 4

- 2

Exhibit 5

- 1: Total and Annualized Social Cost Savings Over 10 Years (2014$)

................................ .... 5

- 1

Exhibit 7

- 1: Incremental RRP Training Provider Burden Hours per Activity for th e Final Rule

........... 7

- 3

Exhibit 7

- 2: Incremental RRP Training Provider Total Burden Hours for the Final Rule, Scenario I

.... 7

- 4

Ex hibit 7

- 3: Loaded RRP Training Provider Wage Rates

................................ ................................ ........ 7

- 5

Exhibit 7

- 4: RPP Incremental Training Provider Cost for the Final Rule, Sc enario I (2014$)

................ 7

- 6

Exhibit 7

- 5: Renovator Recertification Burden per Activity

................................ ................................ ... 7

- 7

Exhibit 7

- 6: Change in Total Renovator Recertification Burden

................................ ............................. 7

- 7

Exhibit 7

- 7: Loaded Renovator Wage Rates

................................ ................................ ............................ 7

- 8

Exhibit 7

- 8: Incremental Renovator Cost for the Fi nal Rule, Scenario I, (2014$)

................................ ... 7

- 8

Exhibit 7

- 9: Annual Incremental Respondent Burden and Cost Summary

................................ .............. 7

- 9

Exhibit A

- 1: Sample of Renovation (Re)certification Training Courses

................................ ................ A

- 1

Exhibit B

- 1: Option 2, Scenario I

- 50% of Active Stock Chooses Online Refresher Training

.............. B

- 3

Exhibit B

- 2: Option 2, Scenario

- 50% of Active Stock Chooses Online Refresher Training

................ B

- 6

Exhibit C

- 1 : Baseline

- Ten Year Net Present Value and Annualized

Costs for Renovators Seeking Recertification (2014$)

................................ ...................... C

- 1

Exhibit C

- 2: Option 1

- Ten Year Net Present Value and Annualized Costs for Renovators Seeking

Recertification (2014$)

................................ ................................ ................................ ....... C

- 2

Exhibit C

- 3: Option 2

- Ten Year Net Present Value and Annualized Costs for Renovators Seeking

Recertification (2014$)

................................ ................................ ................................ ....... C

- 3

Exhibit C

- 4: Option 3(a)

- Ten Year Net Present Value and Annualized Costs for Renovators Seeking

Recertification (2014$)

................................ ................................ ................................ ....... C

- 4

Exhibit C

- 5: Option 3(b)

- Ten Year Net Present Value and Annualized Costs for Renovators Seeking
Recertification (2014$)

................................ ................................ ................................ ....... C

- 5

Exhibit C

- 6: Option 4(a)

- Ten Year Net Present Value and Annualized Costs for Renovators Seeking
Recertification (2014$)

................................ ................................ ................................ ....... C

- 6

Exhibit C

- 7: Option 4(b)

- Ten Year Net Present Value and Annualized Costs for Renovators Seeking
Recertification (2014$)

................................ ................................ ................................ ....... C

- 7

Exhibit C

- 8: Option 4(c)

- Ten Year Net Present Value and Annualized Costs for Renovators Seeking
Recertification (2014$)

................................ ................................ ................................ ....... C

- 8

Exhibit C

- 9: Option 4(d)

- Ten Year Net Present Value and Annualized Costs for Renovators Seeking

Recertification (2014$)

................................ ................................ ................................ ....... C

- 9

### ES

- 1 

# Executive Summar y

The United States Environmental Protection Agency (EPA) is promulgating amendments to the regulations

for Lead

- b ased Paint Poisoning Prevention in Certain Residential Structures , codified at 40 CFR part 745

un der the author ity of TSCA §402(a) and §402( c ). This report estimates the changes in compliance costs

due to the final rule that amends the L ead

- B ased P aint (LBP) A ctivities rule for lead abatement and the

R enovation, R epair and P ainting ( RRP) rule

. These amendments eliminate EPA’s multi

- jurisdiction

registration fee in the abatement program

, amend the hands

- on requirement for the renovator refresher

training course , and revise the notification requirements for training providers

.

The rule removes the multi

- jurisdicti on registration fee that individuals and firms pay for certification or

recertification and that training programs pay for accreditation or reaccreditation in the lead abatement

program

. Under the existing regulations, there is a $35 fee for each additional EPA

- administered

jurisdiction for which organizations apply to perform LBP abatement activities or to provide lead abatement

training

. In a typical year, individuals, firms, and training providers apply to perform l ead

- based paint

activities or provide training in a total of 431 additional EPA

- administered jurisdictions

. Removing the $35

fee will result in total estimated cost savings of approximately $15,000 per year to these entities

.

The rule also mod ifies the refresher training course requirements for renovators under the RRP rule

. Under

the existing rule, both the initial and refresher renovator training courses must include a classroom

component (which may be taken in person or online) and a hands

- o n component (which must be taken in

person).

Existing RRP Rule Refresher Training Requirements

Training Component Existing Rule

Classroom component Can be taken either in person or online

Hands

- on component Must be taken in person

Re certification is valid for 5 years



### This report analyzes four primary options to amend the refresher training course requirements so that

hands

- on training would not be required every time the training is taken. Th is would allow renovators to

take some or all of their re fresher training solely by taking an online training course (although they can

always choose to take training in person with a hands

- on component ) . The four options analyzed are:

Option 1: Refresher training without a hands

- on component valid for 5 years ;

Option 2: Refresher training without a hands

- on component valid for 5 years

, refresher training

with a h ands

- on component required every other recertification period ;

Option 3: Refresher training without a hands

- on component valid for a shorter time frame ; and

Option 4: Refresher training without a hands

- on component valid for a shorter time frame ; refresher training with a h ands

- on component required at repeating intervals

.
Options 3 and 4 include sub

- options that vary both the length of time for wh ich refresher training withou t a

hands

- on component is valid and the number of training cycles in which ha nds

- on training must be taken.

These training options and alternatives, as well as the other amendments that affect costs, are summarized

in Exhibit ES

- 1

.

### ES

- 2 Exhibit ES

- 1 : Regulatory Options

Option Period for which

r efresher training

with hands

- on component is valid Period for which

r efresher training

without hands

- on component is valid Number of training

cycles in which

hands

- on training

must be taken Multi

jurisdiction

registration

fee removed Changes to

notification

requirements for

training providers

Existing rule 5 years Not allowed 1 

###  

Option 1 5 years 5 years 0  

Option 2 5 years 5 years 2  

Option 3(a) 5 years 2 years 0  

Option 3(b) 5 years 3 years 0  

Option 4(a) 5 years 2 years 2  

Option 4(b) 5 years 2 years 3  

Option 4(c) 1 5 years 3 years 2  

Option 4(d) 5 years 3 years 3  

1 The final rule is Option 4(c)



### Renovator training and certification became mandatory in 2010 and a large number of renovators were

trained that year, with smaller numbers becoming trained in each subsequent year. By 2015, approximately

500,000 renovators were certified. In the baseline, a steady state average of 100,000 renovators (one fifth of

the 500,000 certified renovators) are assumed to be trained each year over the ten year time frame

considered in the analysis

. There are 30,000 trained renovators assumed to exit the industry each year, and

they are replaced by new entrants to the industry who take the 8

- hour initial training course. Thus

, a steady

state average of 70,000 renovators are estimated to take the refresher training course each year.

Amending the refresher training course hands

- on requirement is expected to make online renovator

refresher training more attractive to training providers and renovators. However, a s previously n oted

,

renovators could still cho o se to take training in person with the hands

- on component. This analysis

considers three different scenarios for the number of renovators that will choose to take the online refresher

training course i f the hands

- on require ment is removed

. S cenarios I

, II , and III assume that 50 percent , 75

percent , and 90 percent of the active stock of renovators , respectively, will choose to take the online

refresher training course when eligible

. (Note that under Options 2 and 4, renovators who choose to take the

refresher training course without a hands

- on component when eligible will have to take hands

- on training in

a subsequent training cycle

. ) This means that 50 percent , 25 percent , or 10 per cent of the active stock of

renovators will always choose to take their refresher training in person. Exhibit ES

- 2 presents the number of

renovators s eeking initial and refresher training each year, rounded to the nearest thousand.

Note that the scenario percentages correspond to the percent of the active stock of renovators choosing the

online refresher training course, not the percent of recertifica tions attained via the online refresher training

course relative to all recertifications per year. Because online training requires more frequent

recertifications for Options 3 and 4, online training is associated with a greater number of recertifications

per year than in

- person training for those options, even when equal number s of renovators are in the online

and in

- person training cohorts (s ee Section 3. 2.5 and Appendix B for a more detailed explanation of this

effect)

. As a result, t he number of total a nnual trainings increases from 100,000 per year in the baseline to

between 110,000 and 118,000 per year under the final rule (Option 4(c)) , because the certification from

taking an online class is valid for 3 years, compared to 5 years for an in

- person cla ss

.

### ES

- 3 Exhibit ES

- 2 : Expected Number of Renovators Seeking Training Each Year (rounded to the nearest thousand)

Scenario I: 50% of Active Stock Choose s Online Refresher Training

Option Initial

Training

due to

Turnover Renovator Always

Chooses In

- person Refresher Training Renovator Chooses Online Refresher Training Total

Refresher

Training Total

Annual

Training Cycle with

Hands

- on Cycle w/out

Hands

- on Sub

- Total

Option 1 30,000 35,000

- 35,000 35,000 70,000 100,000

Option 2 30,000 35,000 14,000 21,000 35,000 70,000 100,000

Option 3

(a) 2 Yr. Interval 30,000 35,000

- 88,000 88,000 123,000 153,000

(b) 3 Yr. Interval 30,000 35,000

- 58,000 58,000 93,000 123,000

Option 4

(a) 2 Yr. Interval & 2 Cycles 30,000 35,000 24,000 27,000 51,000 86,000 116,000

(b) 2 Yr. Interval & 3 Cycles 30,000 35,000 18,000 43,000 61,000 96,000 126,000

(c) 3 Yr. Interval & 2 Cycles 1 30,000 35,000 20,000 25,000 45,000 80,000 110,000

(d) 3 Yr. Interval & 3 Cycles 30,000 35,000 13,000 36,000 49,000 84,000 114,000

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Option Initial

Training

due to

Turnover Renovator Always

Chooses In

- person

Refresher Training Renovator Chooses Online Refresher Training Total

Refresher

Training Total

Annual

Training Cycle with

Hands

- on Cycle w/out

Hands

- on Sub

- Total

Option 1 30,000 18,000

- 53,000 53,000 70,000 100,000

Option 2 30,000 18,000 22,000 31,000 53,000 70,000 100,000

Option 3

(a) 2 Yr. Interval 30,000 18,000

- 131,000 131,000 149,000 179,000

(b) 3 Yr. Interval 30,000 18,000

- 88,000 88,000 105,000 135,000

Option 4

(a) 2 Yr. Interval & 2 Cycles 30,000 18,000 36,000 41,000 77,000 95,000 125,000

(b) 2 Yr. Interval & 3 Cycles 30,000 18,000 27,000 65,000 91,000 109,000 139,000

(c) 3 Yr. Interval & 2 Cycles 1 30,000 18,000 30,000 37,000 67,000 85,000 115,000

(d) 3 Yr. Interval & 3 Cycles 30,000 18,000 20,000 54,000 74,000 92,000 122,000

### ES

- 4 Scenario III: 90% of Active Stock Chooses Online Refresher Training

Option Initial

Training

due to

Turnover Renovator Always

Chooses In

- person Refresher Training Renovator Chooses Online Refresher Training Total

Refresher

Training Total

Annual

Training Cycle with

Hands

- on Cycle w/out

Hands

- on Sub

- Total

Option 1 30,000 7,000

- 63,000 63,000 70,000 100,000

Option 2 30,000 7,000 26,000 37,000 63,000 70,000 100,000

Option 3

(a) 2 Yr. Interval 30,000 7,000

- 158,000 158,000 165,000 195,000

(b) 3 Yr. Interval 30,000 7,000

- 105,000 105,000 112,000 142,000

Option 4

(a) 2 Yr. Interval & 2 Cycles 30,000 7,000 43,000 49,000 93,000 100,000 130,000

(b) 2 Yr. Interval & 3 Cycles 30,000 7,000 32,000 78,000 110,000 117,000 147,000

(c) 3 Yr. Interval & 2 Cycles 1 30,000 7,000 36,000 44,000 81,000 88,000 118,000

(d) 3 Yr. Interval & 3 Cycles 30,000 7,000 24,000 65,000 89,000 96,000 126,000

1 The final rule is Option 4(c).

### ES

- 5 Refresher Training under Existing Rule and Amended Final Rule

– Option 4(c)

Requirements Existing Rule Minor Amendments Final Rule

Hands

- on component Required every training cycle Required every other training cycle

Renovator certification period 5 years 5 years for training with hands

- on component 3 years for training without hands

- on component

Pre

- training notifications Required for all classes Not required for online classes

Post

- training notifications Within 10 business days Monthly for online classes



### Allowing refresher training to be taught without the hands

- on component will reduce average costs for

training providers by $45 per student. Some or all of these savings may be passed on to the students in the

form of lower tuition. Refresher training wi thout a hands

- on component can be taken entirely online.

Because renovators taking a course entirely online will avoid the time and associated expenses needed to

travel to a training site, t hey will save an average of $144 per person.

Depending on the regu latory option and the scenario, amending the hands

- on training requirement is

estimated to reduce the total costs of recertification by between approximately $0. 6 million and $ 12

. 2

million per year (s ee Exhibit ES

- 3 )

. The revisions to the hands

- on requirements in the final rule

(Option 4(c)) reduces costs by $1. 9 million to $3.4 million per year . Costs decrease despite the fact that the

total number of r enovators receiving training each year increases (due to the shorter certification period for

online training) , because training without a hands

- on component is less expensive, particularly if it is taken

online (s ee Exhibit ES

- 3 )

.

### ES

- 6 Exhibit ES

- 3 : Summary of Total Costs and Cost Savings for Refresher Training Regulatory Options Over a

Ten Year Period, 2016 through 2025 ( mill ions of 2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Option 

### Cost of Regulatory Options Cost Savings of Regulatory Options

Net Present Value Annualized

Costs

(3% and 7%) Net Present Value Annualized Cost

Savings

( 3% and 7%) 3% 7% 3% 7%

Option 1 $97.6 $80.3 $11.4 $69.9 $57.6 $8.2

Option 2 $134.3 $110.6 $15.7 $33.2 $27.3 $3.9

Option 3

(a) 2 Yr. Interval $152.1 $125.3 $17.8 $15.4 $12.7 $1.8

(b) 3 Yr. Interval $129.3 $106.5 $15.2 $38.2 $31.4 $4.5

Option 4

(a) 2 Yr. Interval & 2 Cycles $162.7 $134.0 $19.1 $4.8 $4.0 $0.6

(b) 2 Yr. Interval & 3 Cycles $159.9 $131.7 $18.7 $7.6 $6.2 $0.9

(c) 3 Yr. Interval & 2 Cycles 1 $151.4 $124.6 $17.7 $16.1 $13.3 $1.9

(d) 3 Yr. Interval & 3 Cycles $143.9 $118.5 $16.9 $23.6 $19.4 $2.8

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Option 

### Cost of Regulatory Options Cost Savings of Regulatory Options

Net Present Value Annualized

Costs

(3% and 7%) Net Present Value Annualized Cost

Savings

( 3% and 7%) 3% 7% 3% 7%

Option 1 $76.1 $62.7 $8.9 $91.4 $75.2 $10.7

Option 2 $117.7 $96.9 $13.8 $49.8 $41.0 $5.8

Option 3

(a) 2 Yr. Interval $144.4 $118.9 $16.9 $23.1 $19.0 $2.7

(b) 3 Yr. Interval $110.3 $90.8 $12.9 $57.2 $47.1 $6.7

Option 4

(a) 2 Yr. Interval & 2 Cycles $160.3 $132.0 $18.8 $7.2 $5.9 $0.8

(b) 2 Yr. Interval & 3 Cycles $156.1 $128.6 $18.3 $11.4 $9.4 $1.3

(c) 3 Yr. Interval & 2 Cycles 1 $143.3 $118.0 $16.8 $24.2 $19.9 $2.8

(d) 3 Yr. Interval & 3 Cycles $132.1 $108.7 $15.5 $35.4 $29.2 $4.2

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Option 

### Cost of Regulatory Options Cost Savings of Regulatory Options

Net Present Value Annualized

Costs

(3% and 7%) Net Present Value Annualized Cost

Savings

( 3% and 7%) 3% 7% 3% 7%

Option 1 $63.3 $52.1 $7.4 $104.2 $85.8 $12.2

Option 2 $107.8 $88.7 $12.6 $59.7 $49.2 $7.0

Option 3

(a) 2 Yr. Interval $139.8 $115.1 $16.4 $27.7 $22.8 $3.2

(b) 3 Yr. Interval $98.8 $81.4 $11.6 $68.7 $56.6 $8.1

Option 4

(a) 2 Yr. Interval & 2 Cycles $158.9 $130.8 $18.6 $8.6 $7.1 $1.0

(b) 2 Yr. Interval & 3 Cycles $153.9 $126.7 $18.0 $13.6 $11.2 $1.6

(c) 3 Yr. Interval & 2 Cycles 1 $138.5 $114.0 $16.2 $29.0 $23.9 $3.4

(d) 3 Yr. Interval & 3 Cycles $125.0 $102.9 $14.7 $42.5 $35.0 $5.0

1 The final rule is Option 4(c).



### If the hands

- on training requirement is revised

, t raining providers currently accredited for the renovator

refresher training course are expected to offer online refresher training course s

. This would involve

### ES

- 7 licensing an existing online course or developing a ne w course, and applying to EPA for accreditation to

teach an online course. T raining providers that currently offer both in

- person courses and courses with an

online component typically charge the same tuition for both types of classes, suggesting that the cost to

offer the classroom component of the training online is similar to the cost of offering it in person. The

tuition that training providers currently charge for in

- person courses recoups the costs they incur to provide

those courses

, and the tuition for the online class will do the same. The training provider expenses to license

or develop an online course and obtain an additional accreditation are not considered separately in

estimating social costs because doing so would double

- count these cost s , wh ich are already accounted for in

the tuition that renovators pay

.

EPA will incur additional costs because the Agency must review and process applications submitted by

training providers to become accredited for an online course

. It is assumed that 40 0 training providers

would apply for an online refresher training course accreditation as a result of the final rule

. Reviewing and

processing the additional accreditation applications is estimated to cost the EPA over $ 3 8 ,000 per year

.

Under the existing rule, training providers are required to submit notifications before and after each training

course. The rulemaking changes the notification requirements for online refresher training courses . T raining

providers would not be required to submit pre

- training notification s for online training courses that have no

in

- person component

, and would only be required to submit post

- training notification s for such courses

once a month via EPA’s Central Data Exchange (CDX) , an online data portal

. Exhibit ES

- 4 presents the

annual reduction in pre

- and post

- training notifications, as well as the total cost savings for each regulatory

option. The number of pre

- training notification s is estimated to decrease by 3 ,000 to 1 7 ,000 per year

, depending on the option and scenario. The change in the annual number of post

- training notification s

ranges from a reduction of 4

, 2 00 to an increase of 3

, 2 00 , d epending on the option and scenario

. The final

rule

, Option 4 ( c)

, is estimated to reduce the total number of pre

- notification s by 4,100 to 7,300 per year, and

to increase the total number of post

- training notifications by 1,000 to 2,700 per year. 1 

### The change in

notification costs for the final rule ranges from an increase of $22,000 per year to a savings of $23,000 per

year. But w ithout the amendment to post

- training notification requirements, training providers would

submit a total of 5,600 additional post

- training notifications per year , which would cost $90,000 per year.

The rule requires training providers to include the expiration date of the renovator’s certification in the post

training notification, but the time required to do this is negligible

. T he rule also clarifies the requirements

for post

- training notifications for in

- person training courses. Training providers are already required to

submit post

- training notifications for renovator training. The rule’s correction to the regulatory text

( c larif ying that the notifications must be submitted no later than ten business days following course

completion ) may affect the timing of when the notification s are submitted , but not the cost of compliance.

Lastly, t he rule adds clarifying language explaining that training providers must follow the regulations

. This

does not affect the cost of compliance because it does not change any requirements for accredited training

providers , and the analysis assumes that training providers already comply with the regulations

.

1 

### Although the rule allows less frequent post

- training notifications for online classes , the annual number of

notifications increases because more renovators are trained per year than under the baseline due to the shorter

certification period for training without a hands

- on component.

### ES

- 8 Exhibit ES

- 4 : Pre

- and Post

- training Notification Cost Savings for Regulatory Options Over a Ten Year Period, 2016 through 2025 (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Option Reduction in

Pre

- training

Notifications Reduction in

Post

- training

Notifications Total Reduction

in Notifications Annualized

Cost Savings

3% Annualized

Cost Savings

7% NPV of

Savings 3% NPV of

Savings 7%

Option 1 9,660 200 9,860 $54,575 $54,529 $465,537 $382,989

Option 2 5,682

- 1,859 3,823 $114 $68 $974 $478

Option 3

(a) 2 Yr. Interval 9,660 200 9,860 $54,575 $54,529 $465,537 $382,989

(b) 3 Yr. Interval 9,660 200 9,860 $54,575 $54,529 $465,537 $382,989

Option 4

(a) 2 Yr. Interval & 2 Cycles 3,019

- 3,238

- 219

- $36,355

- $36,401

- $310,115

- $255,665

(b) 2 Yr. Interval & 3 Cycles 4,759

- 2,337 2,422

- $12,516

- $12,562

- $106,762

- $88,230

(c) 3 Yr. Interval & 2 Cycles 1 4,082

- 2,687 1,395

- $21,793

- $21,839

- $185,897

- $153,388

(d) 3 Yr. Interval & 3 Cycles 5,979

- 1,705 4,274 $4,190 $4,144 $35,743 $29,106

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Option Reduction in

Pre

- training

Notifications Reduction in

Post

- training

Notifications Total Reduction

in Notifications Annualized

Cost Savings

3% Annualized

Cost Savings

7% NPV of

Savings 3% NPV of

Savings 7%

Option 1 14,490 2,700 17,190 $120,701 $120,655 $1,029,605 $847,431

Option 2 8,523

- 388 8,135 $39,023 $38,977 $332,875 $273,759

Option 3

(a) 2 Yr. Interval 14,490 2,700 17,190 $120,701 $120,655 $1,029,605 $847,431

(b) 3 Yr. Interval 14,490 2,700 17,190 $120,701 $120,655 $1,029,605 $847,431

Option 4

(a) 2 Yr. Interval & 2 Cycles 4,528

- 2,456 2,072

- $15,679

- $15,725

- $133,744

- $110,446

(b) 2 Yr. Interval & 3 Cycles 7,139

- 1,105 6,034 $20,064 $20,018 $171,151 $140,599

(c) 3 Yr. Interval & 2 Cycles 1 6,123

- 1,631 4,492 $6,148 $6,102 $52,445 $42,858

(d) 3 Yr. Interval & 3 Cycles 8,968

- 158 8,810 $45,109 $45,063 $384,790 $316,504

### ES

- 9 Scenario III: 90% of Active Stock Chooses Online Refresher Training

Option Reduction in

Pre

- training

Notifications Reduction in

Post

- training

Notifications Total Reduction

in Notifications Annualized

Cost Savings

3% Annualized

Cost Savings

7% NPV of

Savings 3% NPV of

Savings 7%

Option 1 17,388 4,200 21,588 $160,388 $160,342 $1,368,144 $1,126,176

Option 2 10,228 494 10,722 $62,351 $62,305 $531,868 $437,605

Option 3

(a) 2 Yr. Interval 17,388 4,200 21,588 $160,388 $160,342 $1,368,144 $1,126,176

(b) 3 Yr. Interval 17,388 4,200 21,588 $160,388 $160,342 $1,368,144 $1,126,176

Option 4

(a) 2 Yr. Interval & 2 Cycles 5,434

- 1,988 3,446

- $3,290

- $3,336

- $28,064

- $23,430

(b) 2 Yr. Interval & 3 Cycles 8,566

- 366 8,200 $39,585 $39,539 $337,670 $277,706

(c) 3 Yr. Interval & 2 Cycles 1 7,347

- 997 6,350 $22,908 $22,862 $195,411 $160,574

(d) 3 Yr. Interval & 3 Cycles 10,762 770 11,532 $69,645 $69,599 $594,087 $488,835

1 The final rule is Option 4(c).

### ES

- 10 Exhibit ES

- 5 presents estimates for the net present value and annualized social cost savings associated with

the implementation of the regulatory options

. Exhibit ES

- 6 presents the c ost s avings of the f inal rule and its

major components. Estimates in both e xhibits are discounted at rates of 3 and 7 percent

.

Exhibit ES

- 5 : Total and Annualized Social Cost Savings of Minor Amendments Rule

Over 10 Years ( millions of 2014$) 1

Scenario I : 50% of Active Stock Chooses Online Refresher Training

Option Net Present Value Annualized Cost Savings

3% 7% 3% 7%

Option 1 $70.2 $57.8 $8.2 $8.2

Option 2 $33.0 $27.1 $3.9 $3.9

Option 3

(a ) 2 Yr. Interval $15.6 $12.9 $1.8 $1.8

(b) 3 Yr

. Interval $38.4 $31.6 $4.5 $4.5

Option 4

(a ) 2 Yr. Interval & 2 Cycles $4.3 $3.5 $0.5 $0.5

(b) 2 Yr. Interval & 3 Cycles $7.3 $6.0 $0.9 $0.9

(c) 3 Yr. Interval & 2 Cycles 2 $15.7 $13.0 $1.8 $1.8

(d) 3 Yr. Interval & 3 Cycles $23.5 $19.3 $2.8 $2.7

Scenario II : 75% of Active Stock Chooses Online Refresher Training

Option Net Present Value Annualized Cost Savings

3% 7% 3% 7%

Option 1 $92.2 $75.9 $10.8 $10.8

Option 2 $49.9 $41.1 $5.8 $5.8

Option 3

(a ) 2 Yr. Interval $23.9 $19.7 $2.8 $2.8

(b) 3 Yr

. Interval $58.1 $47.8 $6.8 $6.8

Option 4

(a ) 2 Yr. Interval & 2 Cycles $6.9 $5.7 $0.8 $0.8

(b) 2 Yr. Interval & 3 Cycles $11.3 $9.3 $1.3 $1.3

(c) 3 Yr. Interval & 2 Cycles 2 $24.0 $19.8 $2.8 $2.8

(d) 3 Yr. Interval & 3 Cycles $35.6 $29.3 $4.2 $4.2

Scenario III : 90% of Active Stock Always Online Refresher Training

Option Net Present Value Annualized Cost Savings

3% 7% 3% 7%

Option 1 $105.4 $86.8 $12.4 $12.4

Option 2 $60.1 $49.4 $7.0 $7.0

Option 3

(a ) 2 Yr. Interval $28.8 $23.7 $3.4 $3.4

(b) 3 Yr

. Interval $69.9 $57.5 $8.2 $8.2

Option 4

(a ) 2 Yr. Interval & 2 Cycles $8.4 $6.9 $1.0 $1.0

(b) 2 Yr. Interval & 3 Cycles $13.8 $11.3 $1.6 $1.6

(c) 3 Yr. Interval & 2 Cycles 2 $29.0 $23.9 $3.4 $3.4

(d) 3 Yr. Interval & 3 Cycles $42.9 $35.3 $5.0 $5.0

1 Cost savings reflect the sum of the changes to the multi

- jurisdiction fees, online refresher training, and training

notification requirements.

2 The final rule is Option 4(c).

### ES

- 11 Exhibit ES

- 6 : Itemized Total and Annualized Cost Savings of the Final Rule Over 10

Years ( thousands of 2014$)

Amendment Item Net Present Value Annualized Cost Savings

3% 7% 3% 7%

Multi

- jurisdiction Registration Fee $129 $106 $15 $15

Option 4(c)

- Scenario I

Renovator Refresher Training Course $16,127 $13,279 $1,891 $1,891

Pre

- training Notifications $187 $154 $22 $22

Post

- training Notifications

- $373

- $307

- $44

- $44

Option 4(c)

- Scenario II

Renovator Refresher Training Course $24,190 $19,917 $2,836 $2,836

Pre

- training Notifications $280 $231 $33 $33

Post

- training Notifications

- $228

- $188

- $27

- $27

Option 4(c)

- Scenario III

Renovator Refresher Training Course $29,028 $23,901 $3,403 $3,403

Pre

- training Notifications $336 $277 $39 $39

Post

- training Notifications

- $141

- $116

- $17

- $17

Agency Cost Savings

- $325

- $274

- $38

- $39

Total Cost Savings

Option 4(c)

- Scenario I $15,745 $12,958 $1,846 $1,845

Option 4(c)

- Scenario II $24,046 $19,792 $2,819 $2,818

Option 4(c)

- Scenario III $29,027 $23,894 $3,402 $3,401



### The rule allows training providers (many of which are small businesses) additional flexibility in how they

offer training. Online training is already allowed for the classroom component of both initial and refresher

training, and training providers can choose whether or not to offer it. The amended rule still allows training

providers to choose what type of training to offer because they can continue to offer refresher training with

a hands

- on component, beg in offering online training without the hands

- on component, or offer both types

of training.

Training providers that voluntarily choose to start offering online refresher training courses would incur

additional costs for some activities (e.g., applying for a new accreditation), but they would reduce other

expenses (e.g., supplies for the hands

- on training component). Because there is no requirement mandating

that training providers offer an online refresher training course, training providers will not choos e to offer

online training unless the savings from doing so exceed the costs or if they can recover their costs through

tuition charges, increased volume of business, or other means. Although some accredited training providers

may lose market share to othe r training providers that are more competitive in the online training market

, that would be an indirect impact not a direct cost of complying with the rule.

The rule will reduce compliance costs for renovators. Renovators that take a n online re fresher training

course without the hands

- on training component will save the time and expense needed to travel to a

training facility . And training providers may pass along to renovators some of the savings from offering

classes without the hands

- on train ing component. Renovators who are e ligible to take an online refresher

training course without the hands

- on training component will have the flexibility to choose whether to

continue taking the class with the hands

- on training component or to trade the con venience and savings of

taking an online course without the hands

- on training component in exchange for a shorter recertification

period.

### 1

- 1 

# 1. Introduction

This report assesses the cost savings expected to result from amendments to EPA’s Lead

- based P aint (LBP)

A ctivities rule and to the Renovation, Repair and Painting (RRP) rule. These amendments eliminate EPA’s

multi

- jurisdiction registration fee in the abatement program

, amend the hands

- on requirement from the

renovator refresher training course curricu lum , and revise the notification requirements for training

providers

. This chapter provides background information on EPA’s LBP r egulations

, a brief summary of

the methodology used in the analysis, and a description of the organization of the remainder of this report.



## 1.1 Regulatory and Programmatic Background

1.1.1 Abatement Multi

- j urisdiction Registration F ee



### In 1996 EPA promulgated final regulations for Lead

- based Paint Activities under TSCA § 402(a) that

govern LBP inspections, lead hazard screens, risk assessments, and lead abatements in target housing and

child

- occupied facilities (61 FR 45778 , codified at 40 CFR part 745 )

. On June 9th, 1999, EPA amended the

r egulations (64 FR 31092) to include a fee schedule for individuals and firms seeking EPA ( re ) certification

and for training programs seeking EPA ( re ) accreditation

. The fee schedule created a multi

- jurisdiction

registration fee of $35 per discipline for each additional EPA

- administered jurisdiction (e.g., a state) in

which an individual, firm, or training program applies for ( re ) certification or (re) accreditation (40 CFR

§745.238 (c)(3))

. For purposes of this multi

- jurisdiction registration fee, an EPA

- administered jurisdiction

is an individual state without an authorized program or all tribes without authorized programs in a given

EPA Region

. The EPA

- administered jurisdictions for the lead abatement program are :

• States

– Alaska, Arizona, Florida, Idaho, Montana, Nevada, New Mexico, New York, South

Carolina, South Dakota, and Wyoming;

• U.S. territories

– American Samoa, Guam, and the Northern Marianas; and

• Tribal lands

– tribal lands except the Bois Forte Band, Cherokee Nation, Lower Sioux Nation, and

Upper Sioux Community

. All other states, U.S. territories, as well as the Cherokee Nation, Lower Sioux Nation, and Upper Sioux

Community

, have EPA

- authorized LBP abatement programs ( U.S. EPA 2014b )

.

1.1.2 Hands

- on Refresher T raining for Renovators



### In 2008

, EPA issued a final r ule under the authority of §402(c)(3) of TS CA to address LBP hazards created

by RRP activities that disturb LBP in target housing and child

- occupied facilities (73 FR 21692)

. To

become a certified renovator, an individual must successfully complete an appr opriate training course

accredited by EPA (40 CFR §745.90)

. Individuals who have not previously been trained must complete an

initial training course lasting a minimum of eight hours, including a minimum of two hours of hands

- on training (s ee Exhibit 1

- 1 ) . To maintain renovator certification, an individual must complete a refresher

training course from an accredited training provider within five years of completing the initial training

course

. The rule requires renovator refresher training courses to last a minimum of four hours (40 CFR

§745.225 (e)(2)) and include a hands

- on training component ( 40 CFR §745.225 (e)( 3 ) ; s ee Exhibit 1

- 1 ) ).

EPA manages the RRP progr am in most areas of the country . However, the states of Alabama, Delaware,

Georgia, Iowa, Kansas, Massachusetts, Mississippi, North Carolina, Oklahoma, Oregon, Rhode Island,

Utah, Washington, and W isconsin are authorized to administer their own p rograms in lieu of the federal

program. The final rule appl ies only in states that do not have authorized programs and therefore the scope

of this analysis includes only those states

.

### 1

- 2 Exhibit 1

- 1 : Assumed Duration of Existing RRP Training Courses

Training Components Initial Training Refresher Training

Classroom ( Can be taken either in person or online ) 6 hours 3 hours

Hands

- on ( Must be taken in person ) 2 hours 1 hour

Total 8 hours 4 hours

Note: Unlike the initial training course, there is no mandatory duration for the hands

- on component of the refresher

training course. The hands

- on portion of the initial course must be at least 2 hours, which is 25 percent of the total 8

hours of training. So for the refresher course, the hands

- on component is assumed to be 1 hour, which is 25 percent of

the 4 hour duration of the refresher course.



## 1.2 Summary of Analytic Approach

This analysis seeks to quantify, to the extent possible, the changes in social costs due to this rule

. The

baseline c ost s to industry associated with the multi

- jurisdiction registration fee include a $35 fee for each

additional EPA

- administered jurisdictio n for which organizations apply to perform lead

- based paint

abatement activities or to provide lead abatement training. The cost savings to industry for eliminating the

fee is the amount in fees that they would no longer be required to pay.

Offering refres her courses without a hands

- on training component reduces the training providers’ costs,

since they may be able to teach classes with a larger student

- to

- teacher ratio , they do not have to purchase

hands

- on training course supplies (such as EPA

- recognized test kits, disposable plastic drop cloths, tape,

electrostatically charged cleaning cloths, disposable wet cleaning wipes, garbage bags, and so on) for each

student in every class , and there may be savings in travel and facility rental costs for traveling training

.

Costs to renovators associated with the refresher training course currently include course tuition and the

travel cost to a training site to receive hands

- on training. Recertification costs are estimated to decrease

under each of the four regula tory options being considered. For those renovators choosing to take refresher

training online, tuition costs may be reduced and travel costs are reduced or eliminated.

In order to offer online refresher training courses , training providers would licens e an exis ting online course

or develop a new course, and apply to EPA for accreditation to teach an online course. T raining providers

that currently offer both in

- person courses and courses with an online component typically charge the same

tuition for both types of classes, suggesting that the cost to offer the classroom component of the training

online is similar to the cost of offering it in person. The tuition that training providers currently charge for

in

- person courses recoups the costs they incur to provide those courses and the tuition for the online class

will do the same. The training provider expenses to license or develop an online course and obtain an

additional accreditation are not considered separately in estimating social costs because doing so would

double

- count these cost s , which are already accounted for in the tuition that renovators pay

.

The analysis also presents estimates for the changes in the notification costs incurred by training providers.

As a simplifying assumption, the analysi s simply estimates incremental costs or savings associated with the

change in training provider notifications and adds or subtracts them to or from the other incremental cost

changes to estimate the total incremental savings due to the rule. However, the training costs are estimated

based on current tuition costs, and that tuition is designed to cover the training provider’s costs (including

the existing notification requirements). Thus, the actual incremental costs for the rule are less than the sum

of th e estimated training and notification costs because all of the costs or savings associated with the change

in training provider notifications may not be incremental.

### 1

- 3 

## 1.3 Organization of This Report

The entities affected by the amendments are characterized in C hapter 2

. Chapter 3 includes the economic

analysis of cost saving s to regulated entities. Agency costs are discussed in Chapter 4

. A summary of the

total social cost savings is provided in Chapter 5 . Chapter 6 describes the impact on small entities. Several

additional impact s are described in Chapt er 7 . Cited references are listed in Chapter 8

. Appendix A contains

the tuition data for renovator initial and refresher training courses that were used in the analysis

. Appendix

B details the methods used to estimate the number of individuals seeking recertification for each of the

regulatory options. Appendix C presents detailed exhibits of renovator training costs for each of the

regulatory options. Note that all dollar values in this analysis are reported in 2014 dollars.

### 2

- 1 

# 2. Affected Entities

T he multi

- jurisdiction registration fee amendment may affect individual s , firm s

, and training providers

regulated by the L ead

- based Paint A ctivities rule , with the exception of non

- profit training providers

(which are exempt from the fee )

. T he renovator refresher training course amendment directly affects

individuals who must take a training course to comply with the RRP rule

. The number of entities affected

under both amendments is estimated from data in EPA’s Federal Lead

- based Paint Progra m (FLPP)

database ( U.S. EPA 2014a )

.

Exhibit 2

- 1 presents the number of all applications submitted by individuals and firms engaging in lead

based paint activities, and all training providers offering lead

- based paint activities training courses

, from

2011 through 2013 (not just those applying to work i n additional jurisdictions)

. Exhibit 2

- 1 also presents

the number of additional jurisdictions in which individuals and firms are sought (re)certification and

training providers are sought (re)accreditation

.

Exhibit 2

- 1 : Lead

- based Paint Activities Individuals and Firms Applying for (Re)certification

and Training Providers Applying for (Re)accreditation from 2011

- 2013

Applicant Total Number of Applications Additional Jurisdictions Sou ght

Individuals 5,127 864

Firms 1,780 403

Training Providers (for

- profit) 23 27



### The RRP rule require d that, starting in 2010, all regulated renovations disturbing LBP must be performed

by renovators who have taken an initial 8

- hour training course (including 2 hours of hands

- on training)

. Renovators must take a 4

- hour refresher training course ( which currently includes a required hands

- on component) every five years. Exhibit 2

- 2 presents the number of renovator certifications from 20 09

- 10

through 201 4

. Column 1 of Exhibit 2

- 2 lists the year the certification wa s issued , C olumn 2 lists number

of initial certifications, Column 3 lists the year of expiration, and Column 4 lists the number of expiring

certifications u nder EPA’s April 2015 e xtension rule

. 2 

### T he number of certifications was highest in 2010

because that was the year that the renovator training requirement became effective

.

The active stock of certified renovators is assumed to equal the total number of renovators certified from

2009 through 2014, rounded to the nearest hundred thousand (500,000 renovators ; s ee Exhibit 2

- 2 )

. In the

baseline scenario, t he total number of renovators taking initial or refresher training each year is assumed

to equal the average number of renovators certified each year from 2009

- 10 through 2014, rounded to the

nearest hundred thousand (100,000 renovators ; s ee Exhibit 2

- 2 ). Some trained renovators exit the industry

each year, and are replaced by new entrants to the industry who take the 8

- hour initial training course.

The number of renovators seeking initial training each year is assumed to equal the average number of

renovators certified in 2 01 4 and 201 5 , rounded to the nearest ten thousand (30,000; s ee Exhibit 2

- 2 ).

Thus, the number of renovators seeking refresher training each year equals 70,000 (100,000

- 30,000 ; s ee

2 

### On April 8 , 2015 EPA published a rule extend ing the certification dates for renovators with expiring certifications

(80 FR 20444). Renovators who received certification on or before March 31, 2010 now have until March 31,

2016, to get recertified. Renovators who re ceived certification between April 1, 2010 and March 31, 2011, have

one year added to their 5

- year certification.

### 2

- 2 Exhibit ES

- 5 ). These estimates represent a steady state average over the ten year analytical time frame in

the analysis.

Exhibit 2

- 2 : Renovator Initial Cer tifications under the RRP Program Rule from 20 09

- 10 through 2014

and Expiring Certifications Under the Extension Rule

Year Certified Number of Initial

Certifications Expiration Year Number of Expiring

Certifications

2009

- 10 358,932 2015

-

2011 52,180 2016 388,703

2012 39,587 2017 61,996

2013 29,293 2018 29,293

2014 30,848 2019 30,848

Active Stock of Certified Renovators ≈ 5 0 0, 000 ≈ 5 0 0, 000

Average C ertifications per Year ≈ 10 0

, 000



### Exhibit 2

- 3 : Steady State Average Number of Renovator Certifications from 2016 through 2025

Active Stock of Certified Renovators ≈500,000

(Re)certifications per Year (= new certifications + recertifications) ≈100,000

New Certifications per Year ≈30,000

Recertifications per Year ≈70,000



### Note that this analysis makes the simplifying assumption s that the active stock of renovators is constant

under the baseline and all of the options, and that the same number of renovators seeks initial certification

and recertification each year. In reality, one could expect that the number of recertifications might follow

a cyclical pattern, at least initially. For example, a large number of renovators so ught initial certification

during the first year that the rule went into effect. Thus, one might expect a large number of

recertifications 5 years after that first wave of initial certifications (assuming recertification is required

every 5 years). The cyc licality might be expected to decline over time, as more firms leave the market and

are replaced by new firms each year. While it would be possible to model this type of cyclicality for the

economic analysis, it would add significant complexity to the anal ysis . More importantly, modeling

cyclicality would make the relative costs of the options sensitive to the timeframe selected for the analysis

unless a very long timeframe were selected , such as 50 years. For example, an option would tend to look

relativel y more attractive if the analysis timeframe ended right before a large wave of recertifications and

relatively less attractive if the analysis timeframe ended right after a large wave of recertifications. Thus,

assuming that the same number of renovators s eeks initial certification and recertification each year

provides a more accurate comparison of the options and also simplifies the analysis.

### 3

- 1 

# 3. Industry Cost Savings

This chapter presents estimates of the cost savings associated with the final rule . Section 3.1 present s

estimates for the multi

- jurisdiction registration fee amendment and Section 3.2 presents estimates for the

renovator refresher training course amendment. Section 3.3 pre sents the estimates for the notification

amendment. Total cost savings of both amendments are summarized in Section 3.3.4

. A ten year analytical period is used

. Net present value and annualized costs and savings are presented for this time

period using 3 and 7 percent discount rates

.



## 3.1 Abatement Multi

- j urisdiction Registration Fee A mendment

If jurisdictions are eliminated, regulated entities will no longer have to s end an application and fees to

EPA for the purpose of adding additional EPA

- administered state jurisdictions to their certification or

accreditation. Once a regulated entity applies and is approved in the Lead

- based Paint Activities program,

they will be a ble to work in any EPA

- administered state , territory, or tribal land

. EPA’s multi

- jurisdiction

registration fee data for 2011 through 2013 are presented in Exhibit 3

- 1

. Column 2 and Column 3 of

Exhibit 3

- 1 present the total and annual average number of additional EPA

- administered jurisdictions for

wh ich organizations applied to perform lead

- based paint activities or provide training from 2011 through

2013 , respectively

. Note that non

- profit training programs are excluded from the analysis because they are

exempt from the multi

- jurisdiction registration fee. The a verage annual costs borne by regulated entities

are summarized in the last c olumn of Exhibit 3

- 1 and are calculated by applying the $35 multi

- jurisdiction

registration fee to Column 3

. Removing the multi

- jurisdiction fee would save individuals, firms, and

training providers a combined $15,085 per year.

Exhibit 3

- 1 : Annual Multi

- jurisdiction Registration Fees for Individuals and Firms

Applying for (Re)certification, and Training Providers Applying for (Re)accreditation

Applicant Additional Jurisdictions

Total Annual Fees 2011

- 2013 Average

Annua l

Individuals 864 288 $10,080

Firms 403 134 $4,690

Training Providers (for

- profit) 27 9 $315

Total 431 $15,085



### Exhibit 3

- 2 present s the ten year net present value and annualized cost savings under the final rule for

i ndividuals and f irms a pplying for ( r e)certification, and t raining p roviders a pplying for ( r e)accr editation

. The cost savings are discounted using rates of 3 and 7 percent.

### 3

- 2 Exhibit 3

- 2 : Ten Year Net Present Value and Annualized Cost Savings for Individuals and Firms Applying

for (Re)certification, and Training Providers Applying for (Re)accreditation (2014$)

Period Additional

Jurisdictions Unit

Incremental

Cost Savings Incremental

Cost Savings Discounted Incremental

Cost Savings

3% 7%

2016 431 $35 $15,085 $14,646 $14,098

2017 431 $35 $15,085 $14,219 $13,176

2018 431 $35 $15,085 $13,805 $12,314

2019 431 $35 $15,085 $13,403 $11,508

2020 431 $35 $15,085 $13,012 $10,755



# ⁞

2025 (year 10 ) 431 $35 $15,085 $11,225 $7,668

Net Present Value $128,678 $105,951

Annualized Cost Savings $15,085 $15,085



## 3.2 Renovator Refresher Training Course A mendment

Costs and i ncremental training cost savings include tuition and travel cost

. The cost of the time spent on

training activities is not affected because the rule does not change the duration of the refresher training

course.

3.2.1 Training Options



### Under the existing rule, both the initial and refresher renovator training courses consist of both a

classroom and a hands

- on component. The classroom component can be taken in person or online,

whereas the h ands

- on component must be taken in person. Removing or amending the hands

- on requirement is expected to make online renovator refresher training more attractive to training providers

and renovators. 3 

### Four regulatory options (some of which include sub

- options) were considered to amend

this requirement, as depicted in Exhibit 3

- 3 and Exhibit 3

- 4

. E ach option provides renovators with an

alternative refresher training course that either partially or completely removes the hands

- on training

requirement. Options that maintain a hands

- on training requirement only require renovators to take

hands

- on training to become recertified according to the length of time for which the refresher training

course is valid and the training cycle requirements associated with each option

. The options vary based on

the length of time for which refresher training without a hands

- on training component is valid (2, 3, or 5

years, depending on the option) and the number of training cycles in which hands

- on training must be

taken (every second cycle, every third cycle, or never). Op tion 1 allows renovators to take a refresher

training course with out a hands

- on training component . R enovators would only be required to take a

course with a classroom component every five years to maintain a valid certification , and the classroom

component could be taken entirely online

. O ption s 2 through 4 allow renovators to take a refresher

training course without a hands

- on training component on a periodic basis; the length of time such

training would be valid for depends on the option. These o ptions would also require renovators to take

3 

### There may be less incentive for training providers to offer an online option

– or for renovators to take advantage of

it

– if there is a ha nds

- on training requirement. If the renovator and/or the instructor are traveling to the training

site, they are incurring the travel costs whether or not the classroom portion is taken in person or online. If the

hands

- on requirement is removed the renova tor can take the entire refresher course online, eliminating these travel

costs. This makes online training more attractive to both the renovator and the training provider.

### 3

- 3 refresher training with a hands

- on component after a certain number of training cycles; such training

would be valid for five years

. The training frequencies are depicted in Exhibit 3

- 4

. When hands

- on training is not required, many renovators are assumed to become recertified remotely, solely by taking the

refresher training course online

. However, some renovators are assume d to choose to take an in

- person training course , even when they would be eligible for an online course.

Exhibit 3

- 3 : Regulatory Options

Option Period for which

refresher training

with hands

- on
component is valid Period for which

refresher training

without hands

- on component is valid Number of training

cycles in which

hands

- on training

must be taken

Existing rule 5 years Not allowed 1

Option 1 5 years 5 years 0

Option 2 5 years 5 years 2

Option 3(a) 5 years 2 years 0

Option 3(b) 5 years 3 years 0

Option 4(a) 5 years 2 years 2

Option 4(b) 5 years 2 years 3

Option 4(c) 5 years 3 years 2

Option 4(d) 5 years 3 years 3

1 The final rule is Option 4(c).



### Amending the hands

- on training requirement is expected to make online renovator refresher training more

attractive to training providers and renovators, but renovators eligible to take an online course could still

ch o ose to take training in person with a hands

- on training component. This analysis considers three

different scenarios for the number of renovators that will choose to take online refresher training if the

h ands

- on requirement is removed:

Scenario I 50 percent of eligible renovators will take online refresher training ;

Scenario II 75 percent of eligible renovators will take online refresher t raining; and

Scenario III 90 percent of eligible renovators will take online refresher training.

This means that 50 percent

, 25 percent , or 10 percent , respectively, of renovators wi ll choose to take all of

their training in person. In addition, under Options 2 and 4, renovators who chose to take training without

a hands

- on component will have to take hands

- on training in a subsequent training cycle.

### 3

- 4 Exhibit 3

- 4 : Refresher Training Requirements Under Regulatory Options

Year Baseline Option 1 Option 2 Option 3 ( a ) Option 3 ( b ) Option 4 ( a ) Option 4 ( b ) Option 4 ( c ) Option 4 ( d )

1 With

h ands

- on Without

hands

- on Without

hands

- on Without

hands

- on Without

hands

- on Without

hands

- on Without

hands

- on Without

hands

- on Without

hands

- on

2

3 Without

hands

- on With

hands

- on Without

hands

- on

4 Without

hands

- on With

hands

- on Without

hands

- on

5 Without

hands

- on With

hands

- on

6 With

hands

- on Without

hands

- on With

hands

- on

7 Without

hands

- on Without

hands

- on With

hands

- on

8 Without

hands

- on

9 Without

hands

- on Without

hands

- on

10 Without

hands

- on With

hands

- on Without

hands

- on

11 With

hands

- on Without

hands

- on Without

hands

- on

1 Course with hands

- on component : R efr esher training course requir es both a classroom and a hands

- on course component. With the exception of Option 1, in

- person training is assumed to include a hands

- on training component even for those renovator s who took hands

- on training in the previous training cycle but choose to take

trai ning in person again

.

2 Course without hands

- on component : R efresher training course requir es only a classroom course component. Refresher t raining without a hands

- on training component

i s assumed to be taken online with one exception . F or Option 1, the hands

- on training component is never required, so training providers are assumed to stop offering it

to students who wish to take the training in person. Thus, under Option 1

, both the in

- person and online refresher training courses are assumed to be limited to the

classroom training component

.

3 Under Options 1 through 4, renovators eligible to take a n online course could still choose to take a course in person

.

4 The final rule is Option 4(c).

### 3

- 5 Note that i t is assumed that all in

- person refresher training courses under Options 2 through 4 would

include a hands

- on training component

. Under these options

, it would be possible for training providers to

offer two versions of in

- person refresher training, one with a hands

- on component and one without.

However, this would increase the number of different types of courses each training provider would offer

and reduce class size , making the classes less profitable for the training provider . Instead, it is assumed

that training providers would simplify their course offerings by including a hands

- on training component

with all in

- person refresher training courses

. Under Option 1 it is assumed that all in

- person courses

would be limited to a classroom component, and would not have a hands

- on training component.

3.2.2 Tuition



### It is expected to be less costly for training providers to offer the refresher training course without the

hands

- on training component, because they would not have to purchase supplies needed for the hands

- on

trainin g modules and instructors would not be limited by the six to one student

- teacher ratio requirement

for the hands

- on portion of the training course , and there may be savings in travel and facility rental costs

for traveling training . Therefore, the rule is expected to lower training provider costs. To quantify the

change in costs, the tuition of a refresher training course without the hands

- on training component is

estimated. Thus, the expected change in tuition is used to estimate training provider cost sav ings per

refresher training course offered. Though tuition is the vehicle by which training provider cost savings are

estimated, training providers would not necessarily pass any or all cost savings on to renovators taking the

refresher training course wit hout the hands

- on component.

T he refresher training course tuition s are estimated for three types of refresher training course s : an

in

- person course with a hands

- on training component ( under the baseline and Options 2 through 4) ; an in

person course without a hands

- on training component (under Option 1); and an online course without a

hands

- on training component (under Options 1 through 4)

. Estimates are based on tuition data collected

from the websites of a sample of training provide rs offering refresher and/or initial renovator training

. T he t uition data and summary statistics can be found in Appendix A

.

A renovator is curren tly able to enroll in an in

- person refresher training course

, which consists of a

classroom and a hands

- on training component

. ( T he existing rule allows training providers to offer a training course in which the classroom course component is taken online and the hands

- on component is

taken in

- person

. While online versions of the classroom component for the 8

- hour initial training course

have been available for some time , no training providers were accredited for an online refresher training

course until re cently. Therefore, this analysis does not reflect any online refresher training in the

baseline

. 4 

### ) The mean tuition for an in

- person refresher course is $13 6

. 97 (see Appendix A )

.

The procedure to estimate the tuition for the in

- person course without a hands

- on component (under

Option 1 ) re lies on the current mean tuition for initial and refresher training course s , and the current mean

4 

### The number and variety of refresher training courses has been more limited than initial training courses because

renovators will not need to be recertified until 2016. The refresher course has so far only been offered to

renovators with prior lead

- safety training in order to receive certification under the RRP rule, or to renovators w ho

chose to take their refresher training ahead of schedule. In 2016, when the refresher training course is in its highest

demand, training providers may offer the course more frequently and some additional training providers might

have offered an online o ption even without the changes to the hands

- on requirement.

### 3

- 6 tuition for the hands

- on component of an initial training course. The estimated tuition for an in

- person

refresher course with no hands

- on component is $91.61

. The s teps taken to produce this estimate are

detailed in Exhibit 3

- 5

.

It is assumed that the tuition for an online course is the same as an in

- person course without the hands

- on requirement because training providers currently tend to charge the same tuition for initial t raining

courses whether the classroom component is taught in

- person or online. 5 

### (From the sample of training

provider course tuitions, five training providers listed tuitions for both in

- person and online initial

classroom training on their websites. Four of the five training providers offered both versions of the

course for the same tuition. 6 

### ) However, it is worth noting that the online course could be less expensive.

For example, lower overhead costs may allow training providers to offer the course at a l ower price, or

new firms that have a competitive advantage in providing online courses may begin offering the renovator

refresher training course. 7



### Exhibit 3

- 5 : Procedure to E stimate I n

- person C las sroom R efresher T raining

C ourse T uition (2014$)

Estimation Steps Value Formula

Tuition data (mean)

(A) Current Initial Training Course Tuition $217.01

(B) Current Refresher Training Course Tuition $136.97

(C) Current H ands

- on Training Course Tuition (2 hours) $165.01

Derived estimates

(D) Cost of 3 classroom hours and 1 hands

- on training hour $80.04 (A )

- (B)

(E) Fixed cost of Initial C ourse $56.93 (B)

- (D)

(F) Incremental costs of 2 hours of hands

- on training $108.08 (C)

- (E)

(G) H ands

- on training cost per hour $54.04 (F) ÷ 2

(H) Cost of 3 classroom hours $26.00 (D)

- (G)

(I) Class room cost per hour $8.67 (H) ÷ 3

In

- person classroom refresher training course Tuition

( 4 hours ) $91.61 (E) + [4 * (I)]

Note: Unlike the initial training course, there is no mandatory duration for the hands

- on training component

of the refresher course. The hands

- on portion of the initial training course must be at least 2 hours, which is

25 percent of the total 8 hours of traini ng . So for the refresher course, the hands

- on training component is

assumed to be 1 hour, which is 25 percent of the 4 hour duration of the refresher training course.



### Exhibit 3

- 6 presents a summary of the estimated refresher training course tuitions

. The difference

between the tuition for the current refresher training course ($136.97) and the refresher training course

5 

### Unlike for the refresher training course, training providers have been offering the classroom portion of the initial

renovator training course online for some time.

6 

### (1) AEHS, Inc.

- $179.99 (online) and $200 (in

- person); (2) National Econ Corporation

- $185 (both in

- person and

online); (3) The Westside Environmental Plan of Action Committee, LLC (WEPAC)

- $250 (both);

(4) TORF Environmental Management

- $250 (both); and (5) American Indoor Air Quality Assessment Service,

Ltd

- $250 (both).

7 

### Currently, many online courses for initial training are developed by third party firms and are offered by training

providers who package the course with their hands

- on training course.

### 3

- 7 without a hands

- on training component ($91.61) is $45.36. This $45.36 in savings results from decreases

in the cost of supplies and instruction if the hands

- on training requirement is removed. 8



### Exhibit 3

- 6 : Summary of Refresher Course Tuitions (2014$)

Course Tuition

In

- person course with hands

- on $136.97

In

- person course with out hands

- on $91.61

Online course $91.61



### 3.2.3 Travel Cost



### T ravel cost consist s of the cost for a renovator to travel to the training site, incidental expenses, and the

value of the time spent travel ing to and from the training site

.

Travel Distance and Trip Duration



### RPP certification data extracted from EPA’s FLPP database were used to identify the addresses of

renovators and the training facility where they took their training class . The dataset consisted of 512,737

student

- facility pairs. The Environmental Systems Resource Institute ’s (ESRI’s) ArcMap 10.2.1 was used

to estimate t he average dist ance a student travels to a training facility and the average duration of the trip

( ESRI 2013 )

. The addresses were geocoded using the ArcMap 10.2.1 Geocode Addresses tool , with

ESRI’s StreetMap North America Address Locator ( ESRI 2005 )

. Student

- facility pairs that could not be

geocoded or could not be geocoded at the street address level (e.g., they could only be geocoded by zip

code) were dropped from the dataset. The resulting dataset contained 316,346 student

- facility pairs. From

the 316,346 pairs, a random sample of 10,000 student

- facility pairs was drawn using SAS Software 9.4

( SAS Institute Inc. 2015 )

. Travel distance and trip duration were estimated using the ArcMap 10.2.1

Network Analyst extension. The analysis resulted in distance and duration estimates for 9,990

student

- facility pairs. 9 

### Student

- facility pairs where the distance between student and facility was

estimated to be zero w ere dropped from the analysis

. 10 

### The final dataset from which average travel

distance and trip duration were estimated consisted of 9,865 student

- facility pairs. ESRI’s StreetMap

North America Network D ataset ( ESRI 2005 ) was selected as the Network Dataset input

. 11 

### The average

8 

### The cost of prov iding instruction decreases if the hands

- on training component is removed because the

recommended student teacher ratio is 6

- to

- 1 for the hands

- on training component of the course, compared to 25

- to

1 for the rest of the in

- person classroom course. The tui tion for the hands

- on training component also covers the

cost of various supplies (such as EPA

- recognized test kits, disposable plastic drop cloths, tape, electrostatically

charged cleaning cloths, disposable wet cleaning wipes, garbage bags, and so on) fo r each student

.

9 

### The most likely reason why Network Analyst can fail to identify a route between two points is contiguity of the

input Network Dataset. For example, Hawaii and the continental U.S. are not connected by a road network.

However, it is possi ble to have two points that appear to be connected by a contiguous road network not to be

because of data quality issues such as a gap between the line segments forming the road network.

10 

### Some of the student

- facility pairs shared the same address in F LPP.

11 

### The tool used to estimate travel distance and trip duration requires a Network Dataset as an input.

### 3

- 8 one

- way distance a student travels to a training facility was estimated to be 39 miles and the average

one

- way duration of the trip a student takes to a training facility was estimated to be 54 minutes. 12



### Estimated Costs



### The estimated cost of driving to and from the training facility relies on the distance of the roundtrip and

the Standard Mileage Rates published by the Internal Revenue Service ( IRS ) . The IRS published a rate of

$0.56 per mile

, effective January 1 st 

### , 2014 ( IRS 2013 )

. The total roundtrip cost of travel is estimated to be

$ 43.68 (2 * 39 miles * $0.56

= $43.68)

. E xpenses comprise the cost of lunch and are estimated using the

Meals and Incidental Expenses Breakdown published by the G eneral S ervices A dministration

. These

e xpenses are estimated to be $14.17 and are calculated by averaging the six tiers of lunch reimbursement

rates representing the lower 48 states ( GSA 2014 )

. 13



### The duration of the roundtrip to the training site and the average renovator wage rate are used to estimate

the cost of renovators’ time to travel to a training site

. The wage rate assigned to renovators is derived

with methods and from sources identical to or similar to those used in pr evious ICR renewals and

economic analyses for EPA’s RRP program. A renovator’s fully loaded wage rate incorporates wages and

salaries , benefits, and overhead. A renovator’s wages and salaries are represented by the mean hourly

wage rate of First

- Line Super visors of Construction Trades and Extraction Workers , published by the

Bureau of Labor Statistics (BLS)

- Occupational Employment Statistics (OES)

. T he mean hourly wage

rate inflated to 2014 dollars is $ 31

. 12 for First Line Supervisors of Construction Trades and Extraction

Workers ( BLS 2012 ; BLS 2014 )

. The base wage rate is inflated to 2014 dollars by applying the

Consumer Price Index (CPI) for All Urban Consumers published by the Bureau of Labor Statistics ( BLS

2014 )

. The September 2013 release of the BLS Employer Costs for Employee Compensation (ECEC)

data indicates that wages an d salaries constitute 69.1 percent of total employee compensations for civilian

workers , implying a wage multiplier of 1.45 to account for benefits ( BLS 2013 )

. An overhead of 8.3

percent is derived from the 201 2 publication of the Cost of Doing Business ( NAHB Business

Management & Information Technology 2012 ) . By combining 1.45 and 8.3 percent , a multiplier of 1.53

is used to estimate a fully loaded hourly wage rate of $4 7

. 6 1 for renovators

. B ased on the 1.8 hour

duration of a roundtrip to the training site, t he average cost of travel time for a renovator attending

training is estimated to be $ 85

. 70

.

Exhibit 3

- 7 summarizes the components of the travel cost to attend in

- person training

.

Exhibit 3

- 7 : Average Renovator Travel Cost (2014$)

Category Cost

Mileage Cost $43.68

Expenses (lunch) $14.17

Cost of Travel Time $85.70

Travel Cost $143.55

12 

### To the extent that students who would otherwise have to travel the longest distances to training facilities are more

likely to choose online classe s, the savings due to the rule may be underestimated.

13 

### Some training providers include lunch in the price of the tuition they charge for a training class. Thus, not all

renovators will incur additional lunch expenses.

### 3

- 9 3.2.4 Total Cost of Refresher Training



### Exhibit 3

- 8 presents a summary of the estimated refresher training costs, which includes course tuition

and the total cost of travel

.

Exhibit 3

- 8 : Summary of Refresher Training Costs (2014$)

Course Tuition Travel Cost Total Cost

In

- person course with hands

- on $136.97 $143.55 $280.52

In

- person course with out hands

- on $91.61 $143.55 $235.16

Online course $91.61 $0.00 $91.61



### 3.2.5 Number of Individuals Seeking Renovator Recertification



### Renovator training and certification for persons conducting covered renovation activities became

mandatory in 2010, and a large number of renovators were trained that year

. By 2015, approximately

500, 000 renovators were certified (s ee Exhibit 2

- 2 ). To estimate the number of renovators expected to

seek recertification each year under the regulatory options, it is a ssumed that the active stock of certified

renovators is 500,000. It is assumed that 30,000 renovators, or 6 percent of the active stock, drop out of

the active stock each year and are replaced by newly certified renovators. 14 

### The assumed dropout rate

approx imates the number of initial certifications in 2013 and 2014 (s ee Exhibit 2

- 2 ) . Renovators are

recertified at a rate that maintains an active stock of 500,000 renovators. Given these assumptions, the

number of recertifications reaches a constant value, at which point the stock (total number of certified

renovators) of renovators is equal to the active stock of renovators, 500,000.

Because the regulatory options have different training intervals and cycle requirements for hands

- on training, the methodology to calculate the number of renovators taking the in

- person course (either by

c hoice or as part of the periodic hands

- on requirement stipulated in the option ) and the online course

differs by option. The annual number of renovators that are required to take a course with a hands

- on training component depend s on the length of time and number of training cycles for which the course

with out a hands

- on training component is valid

. The annual number of renovators taking the in

- person course by choice is the same for each option , although it varies by scenario (10 percent , 25 percent , or 50

percent )

. The derivation of estimates for annual recertifications for the existing rule is described in Part

(A) . The derivation of estimates for annual recertifi cations for the rule amendment options is discussed in

Part (B) and described in detail in Appendix B

. The total number of renovators expected to seek refresher

training each year beginning in 2016 is presented in Exhibit 3

- 9 for each regulatory option.

(A) Existing Rule

- Number of Individuals Seeking Recertification



### Renovator Always Chooses In

- person Refresher Training

Baseline : Refresher training course with hands

- on training valid for 5 years

The following equation is used to estimate the steady state number of renovators taking the refresher

training course with hands

- on training every 5

- year training cycle:

InP = (S / 5) * PREC 5Y = 70,000 renovators

14 

### This analysis subsequently refers to trained renovators exiting the active stock and being replaced by new entrants

as the “turnover” in the industry.

### 3

- 10 where,

InP = The number renovators taking the refresher course with hands

- on training in the steady

state

,

S = The active stock of certified renovators (500,000), and

PREC5Y = The percent of renovators with expiring certifications that becom e recertified given a

5

- year training cycle (7 0 % )

. 15



### (B) Rule Amendment Options

- Number of Individuals Seeking Recertification



### The total number of renovators seeking refresher training is estimated under three scenarios: (I) 50

percent of the active stock of renovators choose the online refresher training cour se, (II) 75 percent of the

active stock of renovators choose the online refresher training course, and (III) 90 percent of the active

stock of renovators choose the online refresher training course (see Exhibit 3

- 9 ). A series of equations are

solved to estimate the steady state number of renovators taking the refresher training course for the rule

amendment options. Each equation is presented in Appendix B

. Under the rule amendments, it is assumed

that a portion of renovators seeking recertification will always choose to travel to the training facility to

become recertified, whe ther hands

- on training is required or not, and a portion of renovators seeking

recertification will choose to take the refresher training course online to become recertified, avoiding

travel when possible. It is also assumed that for most of the options, t raining providers offering in

- person training would always include a hands

- on component. One exception is that under Option 1, training

providers are not expected to offer a refresher training course with hands

- on training because renovators

would never be required to take hands

- on training to become recertified. Therefore, under Option 1,

renovators opting to travel to the training facility would take the refresher training course without

hands

- on training. Finally, since they are already traveling to a tr aining facility, it is assumed that

renovators taking training with a hands

- on component take the classroom portion in person as well, rather

than taking a hybrid with the classroom portion online and the hands

- on portion in person.

Though the total number of renovators seeking refresher training is estimated under three scenarios, the

scenario percentages correspond to the percent of the active stock of renovators choosing the online

refresher training course not the percent of recertifications attai ned via the online refresher training course

relative to all recertifications per year. Because online training requires more frequent recertifications for

Options 3 and 4, online training is associated with a greater number of recertifications per year th an

in

- person training for those options, even when equal number s of renovators are in the online and

in

- person training cohorts

.

For example, under each option, the initial cohort of renovators with expiring certifications is composed

of approximately 350, 000 individuals. 16 

### Scenario I assumes that 50 percent of the initial cohort ( 175,000

renovators ) always selects the in

- person refresher training course and 50 percent of the initial cohort

selects the online refresher training course. Under Option 4(a), the cohort that selects the online refresher

15 

### The percent of renovators with expiring certifications that become recertified is calculated by assuming that 6

percent of certified reno vators drop out of the industry each year and are replaced by new entrants. Over a 5

- year training cycle, 30 percent of certified renovators drop out and the remaining 70 percent are recertified.

16 

### There are 500,000 renovators in the active stock. Since 3 0 percent of them drop out over a 5 year period and 70

percent are recertified

, 350,000 renovators (= 70% * 500,000) out of the active stock get recertified over 5 years.

### 3

- 11 training course will have to be recertified after two years by taking the in

- person refresher training course,

which will be valid for five years. Ignoring turnover, each renovator in this cohort would take the

refresher training course twice in seven years. Thus, the 175,000 renovators selecting the online refresher

training cour se would account for a total enrollment of 350,000 students over seven years. On average,

50,000 ( = 350,000 students / 7 years) renovators from the cohort that selects the online refresher training

course would take the refresher training course each year.

Under Option 4(a), the cohort that always selects the in

- person refresher training course will have to be

recertified after five years by again taking the in

- person refresher training course, which will be valid for

five years. Ignoring turnover, each reno vator in this cohort would take the refresher training course twice

in ten years. Thus, the 175,000 renovators always selecting the in

- person refresher training course would

account for a total enrollment of 350,000 students over ten years. On average, 35, 000 renovators

( = 350,000 renovators / 10 years) from the cohort that always selects the in

- person refresher training

course would take the refresher training course each year. Therefore, even though each cohort is

composed of 175,000 renovators under Scena rio I , on average, a greater number of renovators from the

cohort selecting the online refresher training course are recertified each year (50,000 compared to

35,000) . Due to turnover, the actual number of renovators choosing online refresher training each year is

estimated to be 51,406 rather than 50,000 u nder Option 4(a) , Scenario I.

Summary of Average Annual Refresher Training Attendance



### The total number of renovators expected to seek refresher training each year beginning in 2016 is

presented in Exhibit 3

- 9 for each regulatory option and scenario

.

### 3

- 12 Exhibit 3

- 9 : Expected Number of Renovators Seeking Refresher Training Each Year

Scenario I: 50% of Active Stock Always Choose s Online Refresher Training

Option Renovator Always

Chooses In

- person

Refresher Training Renovator Chooses Online Refresher Training Total

Refresher

Training Cycle with

Hands

- on Cycle w/out

Hands

- on Sub

- Total

Option 1 35,000

- 35,000 35,000 70,000

Option 2 35,000 14,412 20,588 35,000 70,000

Option 3

(a ) 2 Yr. Interval 35,000

- 87,500 87,500 122,500

(b) 3 Yr. Interval 35,000

- 58,333 58,333 93,333

Option 4

(a ) 2 Yr. Interval & 2 Cycles 35,000 24,063 27,343 51,406 86,406

(b) 2 Yr. Interval & 3 Cycles 35,000 17,757 43,108 60,865 95,865

(c) 3 Yr. Interval & 2 Cycles 1 35,000 20,211 24,648 44,859 79,859

(d) 3 Yr. Interval & 3 Cycles 35,000 13,338 36,103 49,441 84,441

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Option Renovator Always

Chooses In

- person

Refresher Training Renovator Chooses Online Refresher Training Total

Refresher

Training Cycle with

Hands

- on Cycle w/out

Hands

- on Sub

- Total

Option 1 17,500

- 52,500 52,500 70,000

Option 2 17,500 21,618 30,882 52,500 70,000

Option 3

(a ) 2 Yr. Interval 17,500

- 131,250 131,250 148,750

(b) 3 Yr. Interval 17,500

- 87,500 87,500 105,000

Option 4

(a ) 2 Yr. Interval & 2 Cycles 17,500 36,094 41,015 77,109 94,609

(b) 2 Yr. Interval & 3 Cycles 17,500 26,635 64,663 91,298 108,798

(c) 3 Yr. Interval & 2 Cycles 1 17,500 30,317 36,972 67,289 84,789

(d) 3 Yr. Interval & 3 Cycles 17,500 20,007 54,155 74,162 91,662

Scenario III: 90% of Active Stock Always Online Refresher Training

Option Renovator Always

Chooses In

- person

Refresher Training Renovator Chooses Online Refresher Training Total

Refresher

Training Cycle with

Hands

- on Cycle w/out

Hands

- on Sub

- Total

Option 1 7,000

- 63,000 63,000 70,000

Option 2 7,000 25,941 37,059 63,000 70,000

Option 3

(a ) 2 Yr. Interval 7,000

- 157,500 157,500 164,500

(b) 3 Yr. Interval 7,000

- 105,000 105,000 112,000

Option 4

(a ) 2 Yr. Interval & 2 Cycles 7,000 43,313 49,218 92,531 99,531

(b) 2 Yr. Interval & 3 Cycles 7,000 31,962 77,595 109,557 116,557

(c) 3 Yr. Interval & 2 Cycles 1 7,000 36,380 44,367 80,747 87,747

(d) 3 Yr. Interval & 3 Cycles 7,000 24,009 64,985 88,994 95,994

1 The final rule is Option 4(c).

### 3

- 13 3.2.6 Total Renovator Training Costs



### Exhibit 3

- 10 present s a summary of the net present value and annualized cost s and cost savings under

O ption s 1 through 4 , over a ten year period from 201 6 through 2025 , for in

- person and online training.

The costs are discounted using rates of 3 and 7 percent. See Appendix C for detailed exhibits presenting

baseline training costs and training costs associated with Options 1 through 4.

### 3

- 14 Exhibit 3

- 10 : Summary of Total Costs and Cost Savings for Refresher Training Reg ulatory Options Over a Ten Year Period, 2016 through 2025 (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Option Cost of Regulatory Options Cost Savings of Regulatory Options

Net Present Value Annualized Costs

(3% and 7%) Net Present Value Annualized Cost

Savings

( 3% and 7%) 3% 7% 3% 7%

Option 1 $97,559,503 $80,328,351 $11,436,950 $69,942,972 $57,589,506 $8,199,450

Option 2 $134,326,135 $110,601,187 $15,747,121 $33,176,340 $27,316,670 $3,889,279

Option 3

(a) 2 Yr. Interval $152,128,277 $125,259,080 $17,834,075 $15,374,198 $12,658,777 $1,802,325

(b) 3 Yr. Interval $129,335,670 $106,492,148 $15,162,086 $38,166,805 $31,425,709 $4,474,314

Option 4

(a) 2 Yr. Interval & 2 Cycles $162,698,648 $133,962,491 $19,073,245 $4,803,827 $3,955,366 $563,155

(b) 2 Yr. Interval & 3 Cycles $159,928,657 $131,681,742 $18,748,518 $7,573,818 $6,236,115 $887,882

(c) 3 Yr. Interval & 2 Cycles 1 $151,375,213 $124,639,024 $17,745,793 $16,127,262 $13,278,833 $1,890,607

(d) 3 Yr. Interval & 3 Cycles $143,880,394 $118,467,954 $16,867,172 $23,622,081 $19,449,903 $2,769,228

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Option Cost of Regulatory Options Cost Savings of Regulatory Options

Net Present Value Annualized Costs

(3% and 7%) Net Present Value Annualized Cost

Savings

( 3% and 7%) 3% 7% 3% 7%

Option 1 $76,130,568 $62,684,236 $8,924,825 $91,371,907 $75,233,621 $10,711,575

Option 2 $117,737,966 $96,942,854 $13,802,481 $49,764,509 $40,975,003 $5,833,919

Option 3

(a) 2 Yr. Interval $144,441,178 $118,929,692 $16,932,913 $23,061,297 $18,988,165 $2,703,487

(b) 3 Yr. Interval $110,252,659 $90,779,616 $12,924,975 $57,249,816 $47,138,241 $6,711,425

Option 4

(a) 2 Yr. Interval & 2 Cycles $160,295,930 $131,984,145 $18,791,573 $7,206,545 $5,933,712 $844,827

(b) 2 Yr. Interval & 3 Cycles $156,141,334 $128,563,342 $18,304,527 $11,361,141 $9,354,515 $1,331,873

(c) 3 Yr. Interval & 2 Cycles 1 $143,312,780 $118,000,593 $16,800,630 $24,189,695 $19,917,264 $2,835,770

(d) 3 Yr. Interval & 3 Cycles $132,069,746 $108,743,326 $15,482,604 $35,432,729 $29,174,531 $4,153,796

### 3

- 15 Exhibit 3

- 10 : Summary of Total Costs and Cost Savings for Refresher Training Reg ulatory Options Over a Ten Year Period, 2016 through 2025 (2014$)

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Option Cost of Regulatory Options Cost Savings of Regulatory Options

Net Present Value Annualized Costs

(3% and 7%) Net Present Value Annualized Cost

Savings

( 3% and 7%) 3% 7% 3% 7%

Option 1 $63,273,206 $52,097,767 $7,417,550 $104,229,269 $85,820,090 $12,218,850

Option 2 $107,784,096 $88,747,057 $12,635,584 $59,718,379 $49,170,800 $7,000,816

Option 3

(a) 2 Yr. Interval $139,828,918 $115,132,059 $16,392,215 $27,673,557 $22,785,798 $3,244,185

(b) 3 Yr. Interval $98,802,695 $81,351,968 $11,582,690 $68,699,780 $56,565,889 $8,053,710

Option 4

(a) 2 Yr. Interval & 2 Cycles $158,855,099 $130,797,798 $18,622,664 $8,647,376 $7,120,059 $1,013,736

(b) 2 Yr. Interval & 3 Cycles $153,868,636 $126,692,054 $18,038,098 $13,633,839 $11,225,803 $1,598,302

(c) 3 Yr. Interval & 2 Cycles 1 $138,474,352 $114,016,738 $16,233,419 $29,028,123 $23,901,119 $3,402,981

(d) 3 Yr. Interval & 3 Cycles $124,983,854 $102,908,959 $14,651,921 $42,518,621 $35,008,898 $4,984,479

1 The final rule is Option 4(c).

### 3

- 16 

## 3.3 RRP Training Provider Notification Amendment

3.3.1 Background



### Training providers are currently required to provide EPA with notifications regarding renovator training

courses (40 CFR 745.225). EPA must receive a pre

- training notification at least 7 business days prior to

the start date of any renovator training cours e. The training provider must notify EPA of any changes to

the date of the training course . If the new start date for the training course is prior to the original date,

EPA must receive an updated notification at least 7 business days prior to the new start date. If the new

start date for the training course is after the original date, EPA must receive an updated notification at

least 2 bus iness days prior to the new start date. If the training course is canceled, EPA must receive an

updated notification at least 2 business days prior to the original start date. After the completion of the

training course

, the training provider must provide EPA with a list of the students who passed the course

along with a digital photo of each student . EPA must receive this post

- training notification no later than

10 business days after the completion of the training course

. The notifications can be submitte d via U.S.

Postal Service, fax, commercial delivery service, hand delivery, or by using EPA’s CDX.

3.3.2 Pre

- training N otification Amendment



### Under the amended rule

, EPA is removing the requirement for training providers to submit pre

- training

notification s for o nline courses without a hands

- on training component

. Therefore, online training results

in a reduction in the number of pre

- training notification s that must be submitted. The number of

pre

- training notification s is estimated using FLPP pre

- training notific ation and renovator certification

data. The total number of pre

- training notification s is estimated as the sum of original, update, and

cancelation pre

- training notification s. Because the number of courses offered (and thus the number of

pre

- training notif ication s) depends on the annual number of certifications , and the estimated annual

number of renovator recertifications varies by option, the number of original pre

- training notification s

needs to be estimated as a function of the annual number of renovato r certifications. The first step is to

calculate the ratio of the number of renovator certifications to the number of original pre

- training

notification s , which is equal to 5 ( based on FLPP data for the RRP program from 2012 to 2014 )

. The

number of c ancelation pre

- training notification s is equal to 2 5 percent of the number of original

pre

- training notification s

, and the number of update pre

- training notification s is equal to 1 3 percent of the

number of original pre

- training notification s (FLPP data fr om 2012 to 2014) . Thus, given the 70,000

baseline number of annual recertifications, there would be 1 9

, 320 total annual pre

- training notification s:

(70,000 / 5) * (1 00% + 25 % + 1 3 %) = 19,320

.

Exhibit 3

- 11 presents the cost savings for the pre

- training notification amendment under the different

options

. Column 2 is equal to the reduction in the total number of recertifications requiring hands

- on training ( the baseline (70,000)

- [ Column 2 + Column 3 of Exhibit 3

- 9 ] ) . Column 3 is equal to the

estimated reduction in the number of pre

- training notification s d ue to the amendment

. 17



### Column 4 is equal to the associated reduction in burden hours . It takes a clerical worker 0 .2 hours to

prepare and submit a pre

- training notification ( U.S. EPA 2011 )

. Column 5 is equal to the total cost

savings associated with reductions in burden , where the total cost of the burden is equal to the total

burden multiplied by the loaded wage rate of an RPP training provider clerical worker ($26.79 per hour,

17 

### For example, the 9,660 in the third column of Exhibit 3

- 11 for Option 1, Scenario I is calculated as

35,000 / 5 * (100% + 25% + 13%).

### 3

- 17 see Exhibit 7

- 3 for the derivation of the wage rate). Column 6 is equal to total cost savings of materials.

According to the FLPP pre

- training notification data from 2014, 91.6 percent of pre

- training notifications

were submitted via CDX and 8.4 percent were faxed. (Less than 1 percent of pre

- training notifications

were mailed and less than 1 percent were hand delivered, thus both methods of delivery were assumed to

be 0 pe rcent.) Each pre

- training notification submitted by fax requires a document to be printed, which is

assumed to be equivalent to the cost of a photocopy ($0.10 per pre

- training notification ( U.S. EPA

2011 ) ) 18 

### . There is no cost of material for pre

- training notification s submitted via CDX. Column 7 is equal

to the total annual cost savings and Column 8 and Column 9 are equal to the net present value of cost

savings discounted using rates of 3 and 7 per cent, respectively.

18 

### For example, the $81 in the sixth column of Exhibit 3

- 11 for Option 1, Scenario I is calculated as

9,660 * 8.4% * $0.10.

### 3

- 18 Exhibit 3

- 11 : Pre

- training N otification Cost Savings for Regulatory Options Over a Ten Year Period, 201 6 through 202 5 (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Option Reduction in Renovators

Choosing In

- person Refresher Training Reduction in

P re

- training

Notifications Burden

Savings Labor

Savings Materials

Savings Annualized

Savings

(3% and 7%) NPV of

Savings 3% NPV of

Savings 7%

Option 1 35,000 9,660 1,932 $51,758 $81 $51,839 $442,197 $364,095

Option 2 20,588 5,682 1,136 $30,433 $48 $30,481 $260,009 $214,086

Option 3

(a ) 2 Yr. Interval 35,000 9,660 1,932 $51,758 $81 $51,839 $442,197 $364,095

(b) 3 Yr

. Interval 35,000 9,660 1,932 $51,758 $81 $51,839 $442,197 $364,095

Option 4

(a ) 2 Yr. Interval & 2 Cycles 10,937 3,019 604 $16,181 $25 $16,206 $138,240 $113,824

(b) 2 Yr. Interval & 3 Cycles 17,243 4,759 952 $25,504 $40 $25,544 $217,896 $179,410

(c) 3 Yr. Interval & 2 Cycles 1 14,789 4,082 816 $21,861 $34 $21,895 $186,769 $153,781

(d) 3 Yr. Interval & 3 Cycles 21,662 5,979 1,196 $32,041 $50 $32,091 $273,743 $225,394

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Option Reduction in Renovators

Choosing In

- person Refresher Training Reduction in

P re

- training

Notifications Burden

Savings Labor

Savings Materials

Savings Annualized

Savings

(3% and 7%) NPV of

Savings 3% NPV of

Savings 7%

Option 1 52,500 14,490 2,898 $77,637 $122 $77,759 $663,300 $546,147

Option 2 30,882 8,523 1,705 $45,677 $72 $45,749 $390,248 $321,322

Option 3

(a ) 2 Yr. Interval 52,500 14,490 2,898 $77,637 $122 $77,759 $663,300 $546,147

(b) 3 Yr

. Interval 52,500 14,490 2,898 $77,637 $122 $77,759 $663,300 $546,147

Option 4

(a ) 2 Yr. Interval & 2 Cycles 16,406 4,528 906 $24,272 $38 $24,310 $207,369 $170,743

(b) 2 Yr. Interval & 3 Cycles 25,865 7,139 1,428 $38,256 $60 $38,316 $326,843 $269,116

(c) 3 Yr. Interval & 2 Cycles 1 22,183 6,123 1,225 $32,818 $51 $32,869 $280,379 $230,858

(d) 3 Yr. Interval & 3 Cycles 32,493 8,968 1,794 $48,061 $75 $48,136 $410,610 $338,087

### 3

- 19 Exhibit 3

- 11 : Pre

- training N otification Cost Savings for Regulatory Options Over a Ten Year Period, 201 6 through 202 5 (2014$)

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Option Reduction in Renovators

Choosing In

- person Refresher Training Reduction in

P re

- training

Notifications Burden

Savings Labor

Savings Materials

Savings Annualized

Savings

(3% and 7%) NPV of

Savings 3% NPV of

Savings 7%

Option 1 63,000 17,388 3,478 $93,176 $146 $93,322 $796,056 $655,455

Option 2 37,059 10,228 2,046 $54,812 $86 $54,898 $468,291 $385,581

Option 3

(a ) 2 Yr. Interval 63,000 17,388 3,478 $93,176 $146 $93,322 $796,056 $655,455

(b) 3 Yr

. Interval 63,000 17,388 3,478 $93,176 $146 $93,322 $796,056 $655,455

Option 4

(a ) 2 Yr. Interval & 2 Cycles 19,687 5,434 1,087 $29,121 $46 $29,167 $248,800 $204,857

(b) 2 Yr. Interval & 3 Cycles 31,038 8,566 1,713 $45,891 $72 $45,963 $392,074 $322,825

(c) 3 Yr. Interval & 2 Cycles 1 26,620 7,347 1,469 $39,355 $62 $39,417 $336,235 $276,849

(d) 3 Yr. Interval & 3 Cycles 38,991 10,762 2,152 $57,652 $90 $57,742 $492,551 $405,556

1 The final rule is Option 4(c)

### 3

- 20 3.3.3 Post

- training N otification Amendment



### There are two changes to the rule that have competing effects on the notification burden: (1) options that

require mo re frequent refresher training result in more post

- training notifications, which increases post

trai ning notification burden; and (2) post

- training notification burden is reduced because training

providers will be allowed to submit post

- training notifications for their online courses once per month.

Under some option/scenario combinations, these effects produce a net reduction in post

- training

notification burden while under other option /scenario combinations , including the final rule

– Option

Option 4 ( c)

– these effects produce a net increase in the post

- training notification burden . Since the total

noti fication burden for pre

- and post

- training notifications combined is reduced

, the tables present the

burden changes in terms of the burden reduction. Thus, a negative burden reduction indicates an increase

in burden. 19



### Under the amended rule, training pro viders will be allowed to submit post

- training notification s for their

online course s once per month instead of after each course, although they will be required to submit them

via the CDX. 20 

### Allowing post

- training notifications to be submitted once per month is expected to reduce

training provider burden and material costs associated with preparing and submitting post

- training

notification s. Exhibit 3

- 12 presents th e initial burden associated with enrolling in the CDX system and the

recurring burden associated with employee turnover and compromised or surrendered electronic

signa tures. For this analysis, managerial and technical worker classes have been combined into the

professional worker class to be consistent with economic analyses and ICRs related to the RRP rule.

Exhibit 3

- 12 : Initial and Recurring Burden Associated with Submitting Notifications via the CDX

Act ivity Per Activity Burden Hours Number of

Annual Activities Total Burden (hours) Clerical Professional

(a) (b) (c) (d) = (c)* [ (a)+(b) ]

1 . CDX Electronic Reporting (First Year)

CDX Registration 0.00 0.84 1.00 0.84

Electronic Subscriber Agreements 0.00 0.25 1.00 0.25

Help Desk 0.00 0.34 1.00 0.34

Problem Resolution 0.00 1.00 0.03 0.03

2 . CDX Electronic Reporting (Subsequent Years)

CDX Registration 0.00 0.84 0.10 0.08

Electronic Subscriber Agreements 0.00 0.25 0.10 0.03

Help Desk 0.00 0.34 0.10 0.03

Report Compromised Signature 0.00 0.40 0.01 0.00



### Exhibit 3

- 13 presents the net present value and annualized costs of using the CDX to submit notifications.

Column 2 and Column 3 of Exhibit 3

- 13 are calculated by taking the product of the clerical and

professional burden and their wage rates , $2 6.79 and $53.66, respectively (s ee Exhibit 7

- 3 for the

19 

### Since the increase in burden is due to an increase in the number of renovators trained, this increase in post

- training

notification burden should not cause o ffering training to become unprofitable for training providers.

20 

### If this change were not made, training providers offering online refresher training would have to comply with the

existing regulations, which require submitting a post

- training notification within 10 business days of when a

renovator took their class.

### 3

- 21 derivation of the wage rates) . Column 4 is equal to the product of training providers offering online

courses ( 400 ) and 8

. 4 percent

- the percent of training providers that currently do not submit notifications

via the CDX. 21



### Exhibit 3

- 13 : Net Present Value and Annualized Costs Over a Ten Year Period of Initial and Recurring

Notification Submissions via the CDX (2014$)

Activity Per Activity Cost Number of

Firms Total Costs Clerical Professional

1. CDX Electronic Reporting (First Year)

CDX Registration $0 $45 34 $1,530

Electronic Subscriber Agreements $0 $13 34 $442

Help Desk $0 $18 34 $612

Problem Resolution $0 $54 1 $54

Subtotal $2,638

2. CDX Electronic Reporting (Subsequent Years)

CDX Registration $0 $45 3 $135

Electronic Subscriber Agreements $0 $13 3 $39

Help Desk $0 $18 3 $54

Report Compromised Signature 1 $0 $21 1 $21

Subtotal $249

NPV

3% $4,443

7% $3,982

Annualized Cost

3% $521

7% $567

1 Number of firms is rounded up to one.



### The number of post

- training notification s associated with in

- person recertifications is equal to the number

of in

- person courses, which is estimated using FLPP pre

- training notification and certification data for the

RRP program from 20 12 to 2014. Because the number of classes offered (and thus the number of

post

- training notification s) depends on the annual number of certifications , and the estimated annual

number of renovator re certifications varies by option, the number of post

- training notification s needs to

be estimated as a function of the number of renovator certifications . The first step is to calculate the rat io

of the number of renovator certifications to the number of course s

. The number of courses is equal to the

number of original pre

- training notification s minus cancelation pre

- training notification s. The average

number of renovator certifications per cour se from 20 12 to 2014 is 7

. That is, the average class size is 7

21 

### Four hundred training providers is an approximation that is based on the total number of training providers

accredited to teach the initial and refresher training courses and the number of training providers that are not

expected to renew their current acc reditation or apply for an accreditation to teach the refresher training course.

While some training providers that are currently accredited for the refresher course may not choose to become

accredited for an online refresher course, these may be offset by new entrants (that are not currently accredited)

who may apply for accreditation to provide an online refresher course.

### 3

- 22 students. Thus, given 35 ,000 certifications, there would be 5

, 000 courses and therefore 5

, 000

post

- training notification s ( 35 ,000 / 7 = 5,000 )

.

The number of post

- training notification s associated with online recertifications is equal to the product of

the number of training providers offering online recertifications and th e number of annual submissions.

Four hundred training providers are assumed to offer online refresher training course s . Under the

amended rule they would only be required to submit post

- training notification s once a month (i.e., 12

times a year ) . Thus, training providers are estimated to submit 4

, 8 00 post

- training notification s per year

for online classes regardless of w hich regulatory option is selected (12 * 400 = 4,800 )

. 22 

### Without the

amendment to post

- training notification requirements, training providers would submit approximately

10,400 post

- training notification per year, or 5,600 additional notifications per year. This is estimated by

assuming that 400 training providers would submit online post

- training notifications every 14 days 23 

### :

Online post

- training notifications = 400 training providers * � 365 day

year

14 day

submission �

= 10,400 submission

year .



### Assuming each post

- training notification takes a clerical worker 0.6 hours to prepare and submit at a

loaded wage rate of $26.79 per hour, the amendment would save training providers approximately

$90,000 per year ($90,000 ≈ $26.79 /hr * 5,600 notifications/yr * 0.6 hours/not ification )

.

The rule requires training providers to include the expiration date of the renovator’s certification in the

post

- training notification, but the time required to do this is negligible. T he rule also clarifies the

requirements for post

- training notifications for in

- person training courses. Training providers are already

required to submit post

- training notifications for renovator training. 24 

### The correction to the regulatory text

clarifies that the notifications must be submitted no later than ten business days following course

completion. The amendment may affect the timing of when the notifications are submitted, but not the

cost of compliance. Thus, and b ecause this requirement is already accounted for in a previous economic

analyses and Informat ion Collection Requests (ICRs) for the lead program, there is no incremental

burden

, cost , or impact estimated

.

Exhibit 3

- 14 presents the cost savings of the changes to the post

- training notification requirements.

Column 2 is equal to the reduction in the total number of recertifications requiring hands

- on training

(baseline

- [ Column 2 + Column 3 of Exhibit 3

- 9 ] ). Column 3 is equal to the estimated reduction in the

22 

### The 4,800 post

- training notifications associated with online refresher training courses is equivalent to the number

of post

- training notifications associated with 33,600 renovators taking the in

- person refresher training course

(33,600 = 7 renovators per class * 4,800 classes). Therefore, an option must result in a reduction of more than

33,600 renovators taking the in

- person refresher training course for the number of post

- training notifications to

decline thirdrelative to the baseline. Assuming that all 400 training providers offering refresher training will also

offer an online class may overestimate the burden and cost of post

- traini ng notifications.

23 

### The regulatory requirement to submit a notification within 10 business days after completion of the course is

equivalent to 14 calendar days when accounting for weekends.

24 

### The existing regulatory text at 40 CFR 745.225(c)(14) states th at “ The training manager must provide notification

following completion of renovator, dust sampling technician, or lead

- based paint activities courses” and

745.225(c)(14)(ii)(D)(6) requires that f or renovator or dust sampling technician courses, the notifi cation must

include a digital photograph of the student

.

### 3

- 23 number of post

- training notification s. For example, Option 4(c) , Scenario I, is associated with a reduction

of 14,789 renovators taking the in

- person refr esher training course with the hands

- on training component :

14,789 = 70,000 (baseline)

- [35,000 + 20,211 from Exhibit 3

- 9 ].

This equates to a reduction of 2,113 po st

- training notifications associated with the in

- person refresher

training course :

2,113 post

- training notifications or courses = 14,789 renovators / 7 students per course.

However, there are 4,800 additional post

- training notifications associated with re fresher training courses

taught online. Thus, the net reduction in post

- training notifications is equal to

- 2,687 ( i.e., there is a net

increase of 2,687 post

- training notifications compared to the baseline ) . As illustrated in Exhibit 3

- 14

, some options result in additional post

- training notifications (e.g., Option 4 ( c ) , Scenario I) while other

options result in a reduction in post

- training notifications (e.g., Option 1, Scenar io I) relative to the

number of post

- training notifications represented in the baseline

. Column 4 equal s the reduction in post

training notification burden. Note that the burden and associated costs of enrollment into the CDX are

only included in the last four columns. It takes a clerical worker an average of 0

. 6 hours to prepare and

submit a post

- training notification ( U.S. EPA 2011 )

. Thus, Option 4(c), Scenario I, is associated with a

reduction i n burden equal to

- 1,612 hours (i.e., an increase in burden) :

- 1

, 61 2 tot. reduction in burden =

- 2,687 post

- training notifications * 0

. 6 hours of burden.

Column 5 is equal to the total cost savings of the reductions in burden, where the total cost of the burden

is equal to the total reduction in burden multiplied by the loaded wage rate of an RPP training provider

clerical worker ($26.79 per hour, see Exhibit 7

- 3 for the derivation of the wage rate). Column 6 is equal to

total cost savings of materials. According to the FLPP pre

- training notification data from 2014, 91.6

percent of pre

- training notifications were submitted via CDX a nd 8.4 percent were faxed. (Less than 1

percent of pre

- training notifications were mailed and less than 1 percent were hand delivered, so the

analysis makes the simplifying assumption that pre

- training notifications are either submitted via CDX or

faxed. E ach post

- training notification submitted by fax requires a document to be printed, which is

assumed to be equivalent to the cost of a photocopy ($0.10 per post

- training notification ( U.S. EPA

2011 ) ). There is no cost of material for post

- training notification s submitted via CDX. Thus, Option 4(c),

Scenario I, is associated with a reduction in the cost of materials equal to $18:

$18

= 2,113 reduction in in

- person post

- training notifications * 8.4 pe rcent of

post

- training notifications faxed * $0.10 cost per post

- training notification faxed.

Column 7 and Column 8 are equal to the annual ized cost savings

, which account for CDX costs,

discounted using rate s of 3 and 7 percent, respectively. Column 9 and Column 10 are equal to the net

present value of savings, including CDX costs, discounted using rate s of 3 and 7 percent, respectively.

When training providers submit notifications via CDX, it also reduces the time and expense needed for

EPA to enter the information into the FLPP database

.

### 3

- 24 Exhibit 3

- 14 : Post

- training N otification Cost Savings for Regulatory Options Over a Ten Year Period, 2016 through 2025 (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Option Reduction in Renovators

Choosing In

- person Refresher Training Reduction in

Post

- training

Notifications Burden

Savings Labor

Savings Materials

Savings Annualized

Savings w/

CDX

, 3% Annualized

Savings w/

CDX

, 7% NPV of

Savings

w/

CDX

, 3% NPV of

Savings

w/

CDX

, 7%

Option 1 35,000 200 120 $3,215 $42 $2,736 $2,690 $23,340 $18,894

Option 2 20,588

- 1,859

- 1,115

- $29,871 $25

- $30,367

- $30,413

- $259,035

- $213,608

Option 3

(a ) 2 Yr. Interval 35,000 200 120 $3,215 $42 $2,736 $2,690 $23,340 $18,894

(b) 3 Yr

. Interval 35,000 200 120 $3,215 $42 $2,736 $2,690 $23,340 $18,894

Option 4

(a ) 2 Yr. Interval & 2 Cycles 10,937

- 3,238

- 1,943

- $52,053 $13

- $52,561

- $52,607

- $448,355

- $369,489

(b) 2 Yr. Interval & 3 Cycles 17,243

- 2,337

- 1,402

- $37,560 $21

- $38,060

- $38,106

- $324,658

- $267,640

(c) 3 Yr. Interval & 2 Cycles 1 14,789

- 2,687

- 1,612

- $43,185 $18

- $43,688

- $43,734

- $372,666

- $307,169

(d) 3 Yr. Interval & 3 Cycles 21,662

- 1,705

- 1,023

- $27,406 $26

- $27,901

- $27,947

- $238,000

- $196,288

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Option Reduction in Renovators

Choosing In

- person Refresher Training Reduction in

Post

- training

Notifications Burden

Savings Labor

Savings Materials

Savings Annualized

Savings w/

CDX

, 3% Annualized

Savings w/

CDX

, 7% NPV of

Savings

w/

CDX, 3% NPV of

Savings

w/

CDX, 7%

Option 1 52,500 2,700 1,620 $43,400 $63 $42,942 $42,896 $366,305 $301,284

Option 2 30,882

- 388

- 233

- $6,242 $37

- $6,726

- $6,772

- $57,373

- $47,563

Option 3

(a ) 2 Yr. Interval 52,500 2,700 1,620 $43,400 $63 $42,942 $42,896 $366,305 $301,284

(b) 3 Yr

. Interval 52,500 2,700 1,620 $43,400 $63 $42,942 $42,896 $366,305 $301,284

Option 4

(a ) 2 Yr. Interval & 2 Cycles 16,406

- 2,456

- 1,474

- $39,488 $20

- $39,989

- $40,035

- $341,113

- $281,189

(b) 2 Yr. Interval & 3 Cycles 25,865

- 1,105

- 663

- $17,762 $31

- $18,252

- $18,298

- $155,692

- $128,517

(c) 3 Yr. Interval & 2 Cycles 1 22,183

- 1,631

- 979

- $26,227 $27

- $26,721

- $26,767

- $227,934

- $188,000

(d) 3 Yr. Interval & 3 Cycles 32,493

- 158

- 95

- $2,545 $39

- $3,027

- $3,073

- $25,820

- $21,583

### 3

- 25 Exhibit 3

- 14 : Post

- training N otification Cost Savings for Regulatory Options Over a Ten Year Period, 2016 through 2025 (2014$)

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Option Reduction in Renovators

Choosing In

- person Refresher Training Reduction in

Post

- training

Notifications Burden

Savings Labor

Savings Materials

Savings Annualized

Savings w/

CDX

, 3% Annualized

Savings w/

CDX

, 7% NPV of

Savings

w/

CDX, 3% NPV of

Savings

w/

CDX, 7%

Option 1 63,000 4,200 2,520 $67,511 $76 $67,066 $67,020 $572,088 $470,721

Option 2 37,059 494 296 $7,930 $44 $7,453 $7,407 $63,577 $52,024

Option 3

(a ) 2 Yr. Interval 63,000 4,200 2,520 $67,511 $76 $67,066 $67,020 $572,088 $470,721

(b) 3 Yr

. Interval 63,000 4,200 2,520 $67,511 $76 $67,066 $67,020 $572,088 $470,721

Option 4

(a ) 2 Yr. Interval & 2 Cycles 19,687

- 1,988

- 1,193

- $31,960 $24

- $32,457

- $32,503

- $276,864

- $228,287

(b) 2 Yr. Interval & 3 Cycles 31,038

- 366

- 220

- $5,894 $37

- $6,378

- $6,424

- $54,404

- $45,119

(c) 3 Yr. Interval & 2 Cycles 1 26,620

- 997

- 598

- $16,020 $32

- $16,509

- $16,555

- $140,824

- $116,275

(d) 3 Yr. Interval & 3 Cycles 38,991 770 462 $12,377 $47 $11,903 $11,857 $101,536 $83,279

1 The final rule is Option 4(c).

### 3

- 26 3.3.4 Summary of Notification Cost Savings



### Exhibit 3

- 15 presents a summary of pre

- and post

- training notification cost savings associated with the

amendment s to the training provider notification requirements. Depending on the option and scenario, the

effect of these changes is estimated to range from an increase in costs of $36,355 to a cost savings of

$1 60,388 ( annualized using a rate of 3 percent ; s ee Exhibit 3

- 15 ). For the final rule, Option 4(c), the result

is estimated to range from an increase in costs of $21,793 per year to a cost savings of $22,908 per year

.

### 3

- 27 Exhibit 3

- 15 : Pre

- and Post

- training Notification Cost Savings for Regulatory Options Over a Ten Year Period, 2016 through 2025 (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Option Reduction in

Pre

- training

Notifications Reduction in

Post

- training

Notifications Total Reduction

in Notifications Annualized

Cost Savings

3% Annualized

Cost Savings

7% NPV of

Savings

3% NPV of

Savings 7%

Option 1 9,660 200 9,860 $54,575 $54,529 $465,537 $382,989

Option 2 5,682

- 1,859 3,823 $114 $68 $974 $478

Option 3

(a) 2 Yr. Interval 9,660 200 9,860 $54,575 $54,529 $465,537 $382,989

(b) 3 Yr. Interval 9,660 200 9,860 $54,575 $54,529 $465,537 $382,989

Option 4

(a) 2 Yr. Interval & 2 Cycles 3,019

- 3,238

- 219

- $36,355

- $36,401

- $310,115

- $255,665

(b) 2 Yr. Interval & 3 Cycles 4,759

- 2,337 2,422

- $12,516

- $12,562

- $106,762

- $88,230

(c) 3 Yr. Interval & 2 Cycles 1 4,082

- 2,687 1,395

- $21,793

- $21,839

- $185,897

- $153,388

(d) 3 Yr. Interval & 3 Cycles 5,979

- 1,705 4,274 $4,190 $4,144 $35,743 $29,106

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Option Reduction in

Pre

- training

Notifications Reduction in

Post

- training

Notifications Total Reduction

in Notifications Annualized

Cost Savings

3% Annualized

Cost Savings

7% NPV of

Savings

3% NPV of

Savings 7%

Option 1 14,490 2,700 17,190 $120,701 $120,655 $1,029,605 $847,431

Option 2 8,523

- 388 8,135 $39,023 $38,977 $332,875 $273,759

Option 3

(a) 2 Yr. Interval 14,490 2,700 17,190 $120,701 $120,655 $1,029,605 $847,431

(b) 3 Yr. Interval 14,490 2,700 17,190 $120,701 $120,655 $1,029,605 $847,431

Option 4

(a) 2 Yr. Interval & 2 Cycles 4,528

- 2,456 2,072

- $15,679

- $15,725

- $133,744

- $110,446

(b) 2 Yr. Interval & 3 Cycles 7,139

- 1,105 6,034 $20,064 $20,018 $171,151 $140,599

(c) 3 Yr. Interval & 2 Cycles 1 6,123

- 1,631 4,492 $6,148 $6,102 $52,445 $42,858

(d) 3 Yr. Interval & 3 Cycles 8,968

- 158 8,810 $45,109 $45,063 $384,790 $316,504

### 3

- 28 Exhibit 3

- 15 : Pre

- and Post

- training Notification Cost Savings for Regulatory Options Over a Ten Year Period, 2016 through 2025 (2014$)

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Option Reduction in

Pre

- training

Notifications Reduction in

Post

- training

Notifications Total Reduction

in Notifications Annualized

Cost Savings

3% Annualized

Cost Savings

7% NPV of

Savings

3% NPV of

Savings 7%

Option 1 17,388 4,200 21,588 $160,388 $160,342 $1,368,144 $1,126,176

Option 2 10,228 494 10,722 $62,351 $62,305 $531,868 $437,605

Option 3

(a) 2 Yr. Interval 17,388 4,200 21,588 $160,388 $160,342 $1,368,144 $1,126,176

(b) 3 Yr. Interval 17,388 4,200 21,588 $160,388 $160,342 $1,368,144 $1,126,176

Option 4

(a) 2 Yr. Interval & 2 Cycles 5,434

- 1,988 3,446

- $3,290

- $3,336

- $28,064

- $23,430

(b) 2 Yr. Interval & 3 Cycles 8,566

- 366 8,200 $39,585 $39,539 $337,670 $277,706

(c) 3 Yr. Interval & 2 Cycles 1 7,347

- 997 6,350 $22,908 $22,862 $195,411 $160,574

(d) 3 Yr. Interval & 3 Cycles 10,762 770 11,532 $69,645 $69,599 $594,087 $488,835

1 The final rule is Option 4(c).

### 3

- 29 

## 3.4 Total Industry Cost Savings

The net present value and annualized industry cost savings for the amended rule are summarized in

Exhibit 3

- 16

. These savings reflect a 1 0 year period from 201 6 through 20 25 , and are discounted using

rate s of 3 and 7 percent

.

Exhibit 3

- 16 : Total and Annualized Industry Cost Savings Over 10 Years (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Option Net Present Value Annualized Cost Savings

3% 7% 3% 7%

Option 1 $70,537,187 $58,078,446 $8,269,110 $8,269,064

Option 2 $33,305,992 $27,423,099 $3,904,478 $3,904,432

Option 3

(a ) 2 Yr. Interval $15,968,413 $13,147,717 $1,871,985 $1,871,939

(b) 3 Yr

. Interval $38,761,020 $31,914,649 $4,543,974 $4,543,928

Option 4

(a ) 2 Yr. Interval & 2 Cycles $4,622,390 $3,805,652 $541,885 $541,839

(b) 2 Yr. Interval & 3 Cycles $7,595,734 $6,253,836 $890,451 $890,405

(c) 3 Yr. Interval & 2 Cycles 1 $16,070,043 $13,231,396 $1,883,899 $1,883,853

(d) 3 Yr. Interval & 3 Cycles $23,786,502 $19,584,960 $2,788,503 $2,788,457

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Option Net Present Value Annualized Cost Savings

3% 7% 3% 7%

Option 1 $92,530,190 $76,187,003 $10,847,361 $10,847,315

Option 2 $50,226,062 $41,354,713 $5,888,027 $5,887,981

Option 3

(a ) 2 Yr. Interval $24,219,580 $19,941,547 $2,839,273 $2,839,227

(b) 3 Yr

. Interval $58,408,099 $48,091,623 $6,847,211 $6,847,165

Option 4

(a ) 2 Yr. Interval & 2 Cycles $7,201,479 $5,929,217 $844,233 $844,187

(b) 2 Yr. Interval & 3 Cycles $11,660,970 $9,601,065 $1,367,022 $1,366,976

(c) 3 Yr. Interval & 2 Cycles 1 $24,370,818 $20,066,073 $2,857,003 $2,856,957

(d) 3 Yr. Interval & 3 Cycles $35,946,197 $29,596,986 $4,213,990 $4,213,944

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Option Net Present Value Annualized Cost Savings

3% 7% 3% 7%

Option 1 $105,726,091 $87,052,217 $12,394,323 $12,394,277

Option 2 $60,378,925 $49,714,356 $7,078,252 $7,078,206

Option 3

(a ) 2 Yr. Interval $29,170,379 $24,017,925 $3,419,658 $3,419,612

(b) 3 Yr

. Interval $70,196,602 $57,798,016 $8,229,183 $8,229,137

Option 4

(a ) 2 Yr. Interval & 2 Cycles $8,747,990 $7,202,580 $1,025,531 $1,025,485

(b) 2 Yr. Interval & 3 Cycles $14,100,187 $11,609,460 $1,652,972 $1,652,926

(c) 3 Yr. Interval & 2 Cycles 1 $29,352,212 $24,167,644 $3,440,974 $3,440,928

(d) 3 Yr. Interval & 3 Cycles $43,241,386 $35,603,684 $5,069,209 $5,069,163

1 The final rule is Option 4(c).

### 3

- 30 

## 3.5 Other Industry Costs

3.5.1 Abatement Multi

- jurisdiction Registration Fee Amendment



### EPA does not anticipate other direct or indirect impacts resulting from the final rule that would cause

entities regulated under the abatement program to experience increases or reductions in their costs

.

3.5.2 Renovator Refresher Training Course Amendment



### Individual t raining providers offering RRP training courses could be negatively impacted by the final rule

if (1) their profit margins are lower for the online course , or ( 2 ) they lose market share with the

introduction of the online course

.

Under the regulatory options , a much larger portion of renovators are expected to enroll in the online

refresher training course t han the online component of the initial training course . This is because

renovators would not have to travel or travel as frequently to a training facility if the hands

- on refresher

training requirement were amended

. (By contrast, renovators taking the initial training course will still

have to travel to take the hands

- on portion.) If training providers do not develop their own online course

, they must contract a third

- party firm to offer the course online. In this scenario, training providers will

incur costs in the for m of fees paid to the third

- party firm s to develop and administer the online course s

. At the same time

, offering refresher courses without a hands

- on training component reduces the training

providers’ costs, since they may be able to teach classes with a l arger student

- to

- teacher ratio , they do not

have to purchase hands

- on training course supplies (such as EPA

- recognized test kits, disposable plastic

drop cloths, tape, electrostatically charged cleaning cloths, disposable wet cleaning wipes, garbage bags,

and so on) for each student in every class, and there may be savings in travel and facility rental costs for

traveling training

. T raining providers will not choose to offer online training unless the savings from

doing so exceed the costs or if they can recover their costs through tuition charges or other means.

M any uncertainties and data gaps exist about the extent to which individual training provider profit

margins might change

. Some training providers may exit the market, others may add market share, and

new entrants might also seek training provider accreditation. While there would not be a net loss to the

economy if market shares shift , training providers unable to compete in the online market might

experience reduced profits. Alternatively, if many renovators choose to take refresher training from the

provider of their initial training, there may be little change in market shares.

### 4

- 1 

# 4. Agency Costs

EPA will incur costs resulting from the new rule associated with reviewing the expedited online course

applications submitted by training pro viders to attain accreditation. It is estimated to take an average of 4

hours apiece for an Agency employee to review each of the 400 applications

. The base wage rate of the

federal government employee re viewing applications is taken from the 2014 General Schedule (GS)

Locality Pay Table for Washington

- Baltimore

- Northern Virginia , published by the Office of Personnel

Management (OPM) . A loaded wage rate of $78.13 is then derived by applying a 1.6 fringe benefits and

overhead multiplier to the base wage rate of a GS

- 13 Step 5 government employee ( see Exhibit 4

- 1 )

( OPM 2014 )

. The 1.6 fringe benefits and overhead multiplier is taken from the ICR Handbook

- EPA’s

Guide to Writi ng Information Collection Requests , published in 2009 ( U.S. EPA 2009 )

.

Exhibit 4

- 1 : EPA Wage Rate

Labor

Category Date Base

Wage 1 Fringe Benefits and

Overhead Multiplier 2 Loaded

Wages

(a) (b) ( c )=(a)*(b)

GS

- 13 Step 5 1/14 $48.83 1.6 $78.13

1 Office of Personal Management (2014). 2014 General Schedule (GS) Locality Pay

Tables: WASHINGTON

- BALTIMORE

- NORTHERN VIRGINIA, DC

- MD

- VA

WV

- PA. SALARY TABLE 2014

- DCB

.

2 U.S. EPA (2009). "ICR Handbook

- EPA’s Guide to Writing Information Collection

Requests."



### Exhibit 4

- 2 presents net present value and annualized cost accrued by EPA over a ten year period from

201 6 through 20 25

, under the final rule. C osts are discounted using rates of 3 and 7 percent. It is not

known how many training providers will only offer refresher training online and how many will maintain

dual accreditations (one for in

- person training and one for online training). Therefore, it is unknown

whether there will be a change in the number of reaccreditation applications after 201 6

. If most training

providers begin offering refresher training only onl ine

, EPA’ s work load for reviewing accreditation

applications would not change much in future years since the training providers would be substituting an

online accreditation for one that is in

- person

. Conversely, if most training providers begin offering

refresher training online in addition to the in

- person course, EPA’s work load for reviewing accreditatio n applications would increase and remain higher in future years. To produce more conservative cost

estimates, it is assumed that training providers maintain accreditation for both the online and in

- person refresher training courses. As a result, the analys is considers EPA’s costs for reviewing additional

accreditation applications through 2025. Course accreditation is valid for four years, thus it is assumed

that each of the 400 training providers will apply for reaccreditation of their online refresher tra ining

course in 2020 and 2024.

### 4

- 2 Exhibit 4

- 2 : Ten Year Net Present Value and Annualized Cost to EPA Under the Final Rule
(2014$)

Application

Review Costs Hours per

Application Cost per

Application
($78.13/hour) Applications

Reviewed Total Cost Discounted Total Cost

3% 7%

2016 4 $312.52 400 $125,008 $121,367 $116,830

2020 4 $312.52 400 $125,008 $107,833 $89,129

2024 4 $312.52 400 $125,008 $95,808 $67,996

Net Present Value $325,008 $273,955

Annualized Cost $38,101 $39,005

### 5

- 1 

# 5. Social Cost Savings

The estimated total social cost savings is equal to the sum of industry cost savings less A gency costs.

Exhibit 5

- 1 presents the net present value and annualized equivalent value of expected cost savings to

society over a ten year period ranging from 201 6 to 20 25

. Estima tes are discounted using rates of 3 and 7

percent

.

Exhibit 5

- 1 : Total and Annualized Social Cost Savings Over 10 Years (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Option Net Present Value Annualized Cost Savings

3% 7% 3% 7%

Option 1 $70,212,179 $57,804,491 $8,231,009 $8,230,059

Option 2 $32,980,984 $27,149,144 $3,866,377 $3,865,427

Option 3

(a ) 2 Yr. Interval $15,643,405 $12,873,762 $1,833,884 $1,832,934

(b) 3 Yr

. Interval $38,436,012 $31,640,694 $4,505,873 $4,504,923

Option 4

(a ) 2 Yr. Interval & 2 Cycles $4,297,382 $3,531,697 $503,784 $502,834

(b) 2 Yr. Interval & 3 Cycles $7,270,726 $5,979,881 $852,350 $851,400

(c) 3 Yr. Interval & 2 Cycles 1 $15,745,035 $12,957,441 $1,845,798 $1,844,848

(d) 3 Yr. Interval & 3 Cycles $23,461,494 $19,311,005 $2,750,402 $2,749,452

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Option Net Present Value Annualized Cost Savings

3% 7% 3% 7%

Option 1 $92,205,182 $75,913,048 $10,809,260 $10,808,310

Option 2 $49,901,054 $41,080,758 $5,849,926 $5,848,976

Option 3

(a ) 2 Yr. Interval $23,894,572 $19,667,592 $2,801,172 $2,800,222

(b) 3 Yr

. Interval $58,083,091 $47,817,668 $6,809,110 $6,808,160

Option 4

(a ) 2 Yr. Interval & 2 Cycles $6,876,471 $5,655,262 $806,132 $805,182

(b) 2 Yr. Interval & 3 Cycles $11,335,962 $9,327,110 $1,328,921 $1,327,971

(c) 3 Yr. Interval & 2 Cycles 1 $24,045,810 $19,792,118 $2,818,902 $2,817,952

(d) 3 Yr. Interval & 3 Cycles $35,621,189 $29,323,031 $4,175,889 $4,174,939

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Option Net Present Value Annualized Cost Savings

3% 7% 3% 7%

Option 1 $105,401,083 $86,778,262 $12,356,222 $12,355,272

Option 2 $60,053,917 $49,440,401 $7,040,151 $7,039,201

Option 3

(a ) 2 Yr. Interval $28,845,371 $23,743,970 $3,381,557 $3,380,607

(b) 3 Yr

. Interval $69,871,594 $57,524,061 $8,191,082 $8,190,132

Option 4

(a ) 2 Yr. Interval & 2 Cycles $8,422,982 $6,928,625 $987,430 $986,480

(b) 2 Yr. Interval & 3 Cycles $13,775,179 $11,335,505 $1,614,871 $1,613,921

(c) 3 Yr. Interval & 2 Cycles 1 $29,027,204 $23,893,689 $3,402,873 $3,401,923

(d) 3 Yr. Interval & 3 Cycles $42,916,378 $35,329,729 $5,031,108 $5,030,158

1 The final rule is Option 4(c).

### 6

- 1 

# 6. Small Entity Impact Analysis

The Regulatory Flexibility Act (RFA) of 1980, amended by the Small Business Regulatory Enforcement

Fairness Act (SBREFA) of 1996, requires regulators to assess the effects of regulations on small entities

including businesses, nonprofit organizations, and gov ernments. In some instances, agen cies are also

required to examine regulatory alternatives that may reduce adverse economic effects on significantly

impacted small entities. The RFA requires agencies to prepare an initial and final regulatory flexibility

analysis for each rule unless the Agency certifies that the rule will not have a significant economic impact

on a substantial number of small entities.

The rule allows training providers (many of which are small businesses) additional flexibility in how they

offer training. Online trainin g is already allowed for the classroom component of both initial and refresher

training, and training providers can choose whether or not to offer it. The amended rule still allows

training providers to choose what type of training to offer because they ca n continue to offer refresher

training with a hands

- on component, begin offering online training without the hands

- on component, or

offer both types of training.

Training providers that voluntarily choose to start offering online refresher training withou t a hands

- on component would incur costs for some activities (e.g., applying for a new accreditation) but they would

reduce other expenses (e.g., supplies for the hands

- on training). Because there is no requirement

mandating that training providers offer a n online refresher course, training providers will not choose to

offer online training unless the savings from doing so exceed the costs, or if they can recover their costs

through tuition charges, increased volum e of business, or other means. Although som e accredited training

providers may lose market share to other training providers that are more competitive in the online

training market, this would be an indirect impact not a direct cost of complying with the rule

.

Eliminating multi

- jurisdiction registr ation fees saves money for entities that wish to perform LBP

activities in multiple jurisdictions. The rule requires training providers to include the expiration date of

the renovator’s certification in the post

- training notification, but the time req uired to do this is negligible.

The clarification in the rule that post

- training notifications must be submitted no later than ten business

days following course completion may affect the timing of when the notifications are submitted, but not

the cost of compl eting and submitting them. The changes in this action to the regulatory language on the

training provider applications is a clarification of the existing requirement , not a new requirement.

### 7

- 1 

# 7. Other Impact Analyses

Several statutes and executive orders (EOs) pertain to the final rule

. This chapter presents

statements discussing unfunded mandates, environmental justice, children’s health, and

paperwork burden, among others.



## 7.1 Paperwork Reduction Act

The Paperwo rk Reduction Act of 1995 (PRA) (superseding the PRA of 1980), as implemented by

the Office of Management and Budget (OMB), requires that agencies submit a supporting

statement to OMB for any information collection that solicits the same data from more than nine

parties. The PRA seeks to ensure that Federal agencies balance their need to collect information

with the paperwork burden imposed on the public by the collection. The definition of

“information collection” includes activities required by regulations such as permit development,

monitoring, recordkeeping, and reporting. The term “burden” refers to the “time, effort, or

financial resources” the public expends to provide information to or for a Federal agency, or to

otherwise fulfill statutory or regulat ory requirements. PRA paperwork burden is measured in

terms of annual time and financial resources the public devotes to meet one

- time and recurring

information requests (44 U.S.C. 3502(2); 5 C.F.R. 1320.3(b)). Information collection activities

may include :

• reviewing rule requirements;

• using technology to collect, process, and disclose information;

• adjusting existing practices to comply with requirements;

• searching data sources;

• completing and reviewing the response; and

• transmitting or disclosing informati on.

Agencies must provide information to OMB on the parties affected, the annual reporting burden,

and the annual cost of responding to the information collection.

7.1.1 Industry Burden

RPP Training Provider Burden



### Currently accredited training providers that wi sh to add an already reviewed and accepted RRP

online course from another training provider to their training curriculum are eligible for an

expedited online course approval

. All requests to add an already

- reviewed online course

curriculum to an already

- accredited training providers' record must include a cover letter; a

training provider application to amend their accreditation; and an online course quality control

(QC) plan

. The QC plan must address issues such as how the trainer will ensure that studen ts

successfully complete the online modules and the online course module final assessment

. Training providers that are already accredited are not charged a fee when adding an

already reviewed online course curriculum.

Training providers currently accredite d for the renovator refresher training course are assumed to

apply for an online refresher training course accreditation if the hands

- on requirement is removed

or amended in accordance with the proposed regulatory options

. T herefore

, they would incur an

in cremental paperwork burden. Training providers applying for accreditation incur a one

- time

burden associated with becoming familiar with the new rule’s requirements, as well as the burden

of completing the accreditation application. Training providers woul d also incur an incremental

burden associated with training course notifications. They would incur a recurring burden

### 7

- 2 associated with pre

- training notifications, pre

- training re

- notifications, and post

- training

notifications. (Note that the recurring burde n associated with the changes to the pre

- training

notification and pre

- training re

- notification requirement s is always negative, indicating a

reduction in annual burden.) Training providers who do not currently submit notifications via the

CDX would incur the initial and recurring burden associated with registration and ongoing

administrative activities.

The rule requires training providers to include the expiration date of the renovator’s certification

in the post

- training notification, but the time requir ed to do this is negligible. T he rule also

clarifies the requirements for post

- training notifications for in

- person training courses. Training

providers are already required to submit post

- training notifications for renovator training. The

rule’s correction to the regulatory text (clarifying that the notifications must be submitted no later

than ten business days following course completion) may affect the timing of when the

notifications are submitted, but not the cost of compliance. Fu rthermore, the burden and cost of

this requirement was already accounted for in previous Information Collection Requests (ICRs)

for the lead program

.

There are assumed to be 400 training providers with accredited renovator refresher training

programs. It is estimated that renovation training providers will spend half as long on becoming

accredited for an online refresher training course as on initial accreditation for an initial training

course

. (L ess information needs to be provided for an expedited onli ne course application, given

that the training provider has already been accredited for an in

- person course. ) Burden for the

initial accreditation of an initial renovation training course is taken from the previously approved

ICR (EPA No. 1715.13)

. Burden h our estimates were rounded to one decimal place for this ICR.

The resulting burden is estimated to be 4 hours for training providers to familiarize themselves

with the rule requirements ; 4.8 hours to complete the accreditation statement; and 5 hours to

co mplete the Quality Control Plan (see Exhibit 7

- 1 )

. Exhibit 7

- 2 presents estimates of total

burden for each activity for the first three years of the f inal rule. These estimates are based on

Scenario I (50% of the active stock of renovators chooses online refresher training), which yields

a conservative estimate of reporting and recordkeeping burden.

Wage rates for each category of personnel are derived with methods and from sources either

identical or very similar to those used in previous ICRs and economic analyses

. Loaded wage

rates of $53.66 and $26.79 represent training provider wages for professional and clerical

workers, respectively

. Wage and frin ge benefit s data are taken from the Employer Cost for

Employee Compensation data series published by the Bureau of Labor Statistics ( BLS 2013 )

. Both the professional and clerical base wage rates are inflated to 2014 dollars by applying the CPI

for All Urban Consumers published by the Bureau of Labor Statistics ( BLS 2014 )

. The overhead

data is taken from Wage Rates for Economic Analyses of The Toxics Release Inventory Program

( U.S. EPA 2002 )

. Th e overhead loading factor is added to the benefits loading factor, and the

total is then applied to the base wage to derive the fully loaded wage. See Exhibit 7

- 3 for a

detailed derivation of the training provider loaded wage rates.

### 7

- 3 Exhibit 7

- 1 : Incremental RRP Training Provider Burden Hours per Activity for the Final Rule , Scenario I

Activity Number of

Respondents Number of Activities per Respondent Reporting Hours per Activity

Year 1 Year 2 Year 3 Professional Clerical Total

Accreditation 1 ,2

Rule Familiarization 400 1.00 0.00 0.00 4.00 0.00 4.00

Accreditation Statement 400 1.00 0.00 0.00 3.80 1.00 4.80

Quality Control Plan 400 1.00 0.00 0.00 4.00 1.00 5.00

CDX Electronic Reporting

CDX Registration 34 1.00 0.10 0.10 0.84 0.00 0.84

Electronic Subscriber Agreements 34 1.00 0.10 0.10 0.25 0.00 0.25

Help Desk 34 1.00 0.10 0.10 0.34 0.00 0.34

Problem Resolution 34 0.03 0.00 0.00 1.00 0.00 1.00

Report Compromised Signature 34 0.00 0.01 0.01 0.40 0.00 0.40

Notification

Pre

- training Notification 400

- 7.40

- 7.40

- 7.40 0.00 0.20 0.20

Pre

- training Renotification 400

- 2.81

- 2.81

- 2.81 0.00 0.20 0.20

Post

- training Notification and

Digital Photo 400 6.72 6.72 6.72 0.00 0.60 0.60

1 Burden hour esti mates per activity for an expedited online course application are assumed to be half the burden in the previously approved ICR EPA No. 1715.13. The hour

estimates were rounded to one decimal place for this ICR.

2 Number of activities are from the previously appr oved ICR EPA No. 1715.13.

### 7

- 4 Exhibit 7

- 2 : Incremental RRP Training Provider Total Burden Hours for the Final Rule , Scenario I

Activity Number of

Respondents Burden per Respondent Total Burden

Year 1 Year 1 Year 1 Year 1 Year 2 Year 3 Average

Accreditation

Rule Familiarization 400 4.000 0.000 0.000 1,600.00 0.00 0.00 533.33

Accreditation Statement 400 4.800 0.000 0.000 1,920.00 0.00 0.00 640.00

Quality Control Plan 400 5.000 0.000 0.000 2,000.00 0.00 0.00 666.67

CDX Electronic Reporting

CDX Registration 34 0.840 0.084 0.084 28.56 2.86 2.86 11.43

Electronic Subscriber

Agreements 34 0.250 0.025 0.025 8.50 0.85 0.85 3.40

Help Desk 34 0.340 0.034 0.034 11.56 1.16 1.16 4.63

Problem Resolution 34 0.030 0.000 0.000 1.02 0.00 0.00 0.34

Report Compromised Signature 34 0.000 0.004 0.004 0.00 0.14 0.14 0.09

Notification

Pre

- training Notification 400

- 1.480

- 1.480

- 1.480

- 592.00

- 592.00

- 592.00

- 592.00

Pre

- training Renotification 400

- 0.562

- 0.562

- 0.562

- 224.80

- 224.80

- 224.80

- 224.80

Post

- training Notification and

Digital Photo 400 4.032 4.032 4.032 1,612.80 1,612.80 1,612.80 1,612.80

Total Burden 6,365.64 801.01 801.01 2,655.89

### 7

- 5 Exhibit 7

- 3 : Loaded RRP Training Provider Wage Rates

Labor

Category Occupation

Category (BLS) 1 Date Base

Wage 1 Fringe

Benefit s Benefit s (% of

Wage) 1 Overhead

(% of

Wage) 2 Wage

Multiplier Loaded

Wages 3

(a) (b) (c)

=(b)/(a) (d) (e)

=1+(c)+(d) (f)

=(a)*(e)

Professional Professional

and related 9/12 $ 33.96 $ 13.92 41% 17% 1.58 $53.66

Clerical Office and

administrative

support 9/12 $ 16.64 $7. 32 44% 17% 1.61 $26.79

1 Bureau of Labor Statistics (BLS). (2013, Dec. 11). "Employer Costs for Employee Compensation

- September 2013."

Private industry workers, goods

- producing and service

- producing.

2 U.S. EPA (2002). Wage Rates for Economic Analyses of The Toxics Release Inventory Program, U. S. Environmental

Protection Agency, Office of Environmental Information, Environmental Analysis Division, Analytical Support Branch.

3 Wage rates are rounded to the closest penny

.



### As shown in Exhibit 7

- 2

, training providers would incur an incremental burden of 6,36 6 hours in

Year 1 an d an incremental burden of 801 hours in Year 2 and Year 3

. Exhibit 7

- 4 presents the

incremental costs to training providers associated with training program accreditation. T raining

providers would incur incremental costs of $298,677 in Year 1 and incremental costs of $21,574

in Year 2 and Year 3

. 25 

### Wage rates of $53.66 and $26.79 are applied to the professional and

clerical hour burdens, respectively , to calculate costs

.

25 

### The cost of training providers becoming accredited is incorporated into the tuition they charge their

students, so the labor cost of the accreditation is not listed separately in the social cost e stimate for the

rule. But since the activity involves disclosing information, it is accounted for separately as part of the

paperwork burden analysis.

### 7

- 6 Exhibit 7

- 4 : RPP Incremental Training Provider Cost for the Final Rule , Scenario I (2014$)

Activity Reporting Costs per Activity Total Costs

Professional
($53.66/hour) Clerical
($26.79/hour) Total Year 1 Year 2 Year 3 Average

Accreditation

Rule Familiarization $214.64 $0.00 $214.64 $85,856.00 $0.00 $0.00 $28,618.67

Accreditation Statement $203.91 $26.79 $230.70 $92,280.00 $0.00 $0.00 $30,760.00

Quality Control Plan $214.64 $26.79 $241.43 $96,572.00 $0.00 $0.00 $32,190.67

CDX Electronic Reporting

CDX Registration $45.07 $0.00 $45.07 $1,532.38 $153.24 $153.24 $612.95

Electronic Subscriber Agreements $13.42 $0.00 $13.42 $456.28 $45.63 $45.63 $182.51

Help Desk $18.24 $0.00 $18.24 $620.16 $62.02 $62.02 $248.07

Problem Resolution $53.66 $0.00 $53.66 $54.73 $0.00 $0.00 $18.24

Report Compromised Signature $21.46 $0.00 $21.46 $0.00 $7.30 $7.30 $4.87

Notification

Pre

- training Notification $0.00 $5.36 $5.36

- $15,865.60

- $15,865.60

- $15,865.60

- $15,865.60

Pre

- training Renotification $0.00 $5.36 $5.36

- $6,024.64

- $6,024.64

- $6,024.64

- $6,024.64

Post

- training Notification and

Digital Photo $0.00 $16.07 $16.07 $43,196.16 $43,196.16 $43,196.16 $43,196.16

Total Costs $298,677.47 $21,574.11 $21,574.11 $113,941.90

### 7

- 7 Renovators



### As a result of the rule, many renovators are expected to take the refresher training course online witho ut

the hands

- on component . Renovators taking the refresher training course online without the hands

- on component will avoid the time and associated expe nses needed to travel to and from a training facility.

An average of 9,859 additional renovators are predicted to be recertified per year by taking the refresher

training course (see Exhibit 7

- 5 ). As a result of renovators taking the refresher training course entirely

online, the number of renovators traveling to and from a training facility to take the refresher training

course with the hands

- on compon ent is predicted to decline by 14,789 (see Exhibit 7

- 5 ). Predictions of the

number of renovators being recertified each year are based on data from th e FLPP database

.

Exhibit 7

- 5 presents burden hours per activity and Exhibit 7

- 6 presents respondent burden hours per

activity and the change in total burden hours per year. The duration of refresher training course is 4 hours

and the average duration of a roundtrip to t he training facility is 1.8 hours. For each of the 14,789

renovators taking the refresher training class online, burden will decrease by 1.8 hours by avoiding travel

time. As presented in Exhibit 7

- 6 , the annual incremental burden for all renovators covered by this ICR is

estimated to be 12,816 hours.

Exhibit 7

- 5 : Renovator Recertification Burden per Act ivity

Activity Number of

Respondents Number of

Activities per

Renovator Reporting

Hours per

Activity

Recertification

Refresher Training Course 9,859 1.00 4.00

Travel 14,789 1.00

- 1.80



### Exhibit 7

- 6 : Change in Total Renovator Recertification Burden

Activity Number of

Respondents Burden per

Respondent Change in

Total Burden

Recertification

Refresher Training Course 9,859 4.00 39,436.00

Travel 14,789

- 1.80

- 26,620.20

Total Burden 12,815.80



### Wage rates for renovators are derived with methods and from sources either identical or very similar to

those used in previous ICRs and economic analyses. A renovator’s wages and salaries are represented by

the mean hourly wage rate of First

- Line Supervisors of Construction Trades and Extraction Workers,

published by the Bureau of Labor Statistics (BLS)

- Occupational Employment Statistics (OES). The

mean hourly wage rate inflated to 2014 dollars is $31.12 for First Line Supervisors of Constru ction

Trades and Extraction Workers ( BLS 2012 ; BLS 2014 ) . The base wage rate is inflated to 2014 dollars by

applying the Consumer Price Index (CPI) for All Urban Consumers published by the Bureau of Labor

Statistics ( BLS 2014 ) . The September 2013 release of the BLS Employer Costs for Employee

Compensation (ECEC) data indicates that wa ges and salaries constitute 69.1 percent of total employee

compensations for civilian workers, implying that benefits are approximately equal to 45 percent of

wages ( BLS 2013 ) . An overhead of 8.3 percent is derived from the 2012 publication of the Cost of Doing

### 7

- 8 Business ( NAHB Business Management & Information Technology 2012 ) . By combining 1, 45, and 8.3

percent, a multiplier of 1.53 is used to estimate a fully load ed hourly wage rate of $47.61 for renovators

(see Exhibit 7

- 7 ).

Exhibit 7

- 7 : Loaded Renovator Wage Rat es

Labor

Category Occupation

Category (BLS) 1 Date Base

Wage 1 Fringe

Benefits Benefits

(% of

Wage) 2 Overhead

(% of

Wage) 3 Wage

Multiplier Loaded

Wages 4

(a) (b) (c)

=(b)/(a) (d) (e)

=1+(c)+(d) (f)

=(a)*(e)

Professional Professional

and related 3/12 $31.12 $13.92 45% 8.3% 1.53 $47.61

1 Bureau of Labor Statistics (BLS). (2012, Mar. 29, 2013). "Occupational Employment Statistics

- Occupational Employment and Wages, May

2012, 47

- 1011 First

- Line Supervisors of Construction Trades and Extraction Workers."

2 Bureau of Labor Statistics (BLS). (2013, Dec. 11). "Employer Costs for Employee Compensation

- September 2013." Civilian workers.

3 NAHB Business Management & Information Technology (2012). Cost of Doing Business Study, 2012 Edition, NAHB BuilderBooks.c om®.

4 Wage rates are rounded to the closest penny.



### Exhibit 7

- 8 presents the incremental cost of renovator burden associated taking the refresher tra ining

course and travel. Renovators would incur incremental costs equal to $610,131 per year. The renovator

wage rate of $47.61 is applied to the renovator burden to calculate costs.

Exhibit 7

- 8 : Increment al Renovator Cost for the Final Rule, Scenario I, (2014$)

Activity Reporting Costs

per Activity Change in Total Costs

Recertification

Refresher Training Course $190.44 $1,877,547.96

Travel

- $85.70

- $1,267,417.30

Total Costs $610,130.66



### Summary of Annual Respondent Burden and Costs



### Exhibit 7

- 9 presents bottom line burden and cost estimates f or both RRP training providers a n d

renovators. The bottom line annual aggregate burden is estimate d to be 15,472 hours. The annual

aggregate cost associated with this burden is estimated to be $724,073.

### 7

- 9 Exhibit 7

- 9 : Annual Incremental Respondent Burden and Cost Summary

Activity Number of

Respondents Number of Small

Respondents 1 Responses per

Respondent Total Annual

Number of

Responses Burden per

Response Total

Annual

Burden Total Annual

Costs

RRP Training Providers

Accreditation

Rule Familiarization 400 376 0.33 133.33 4.00 533.33 $28,618.67

Accreditation Statement 400 376 0.33 133.33 4.80 640.00 $30,760.00

Quality Control Plan 400 376 0.33 133.33 5.00 666.67 $32,190.67

CDX Electronic Reporting

CDX Registration 34 32 0.40 13.60 0.84 11.43 $612.95

Electronic Subscriber

Agreements 34 32 0.40 13.60 0.25 3.40 $182.51

Help Desk 34 32 0.40 13.60 0.34 4.63 $248.07

Problem Resolution 34 32 0.01 0.34 1.00 0.34 $18.24

Report Compromised

Signature 34 32 0.01 0.23 0.39 0.09 $4.87

Notification

Pre

- training Notification 400 376

- 7.40

- 2,960.00 0.20

- 592.00

- $15,865.60

Pre

- training Renotification 400 376

- 2.81

- 1,124.00 0.20

- 224.80

- $6,024.64

Post

- training Notification and

Digital Photo 400 376 6.72 2,688.00 0.60 1,612.80 $43,196.16

Total RRP Training Providers 2,655.89 $113,941.90

Renovators

Recertification

Refresher Training Course 9,859 9,267 1.00 9,859 4.00 39,436 $1,877,547.96

Travel 14,789 13,902 1.00 14,789

- 1.80

- 26,620

- $1,267,417.30

Total Renovators 12,815.80 $610,130.66

Total 15,471.69 $724,072.56

1 Consistent with the currently approved ICR ( EPA ICR No. 2507.01 , OMB Control No: 2070

- 0195) , 94% of affected entities are assumed to be small entities ( U.S. EPA 2015 )

.

### 7

- 10 

## 7.2 Unfunded Mandates Reform Act

Title II of the Unfunded Mandates Reform Act of 1995 (UMRA), 2 U.S.C. 1531

- 1538, directs agencies to

assess the effects of significant regulatory actions that impose Federal mandates on State, local, and tribal

governments, and the private sector

. This action does not contain an unfunded mandate of $100 million or

more as descri bed in UMRA, 2 U.S.C. 1531

– 1538. T herefore, this action is not subject to the

requirement s of UMRA sections 202 or 205.

This action is also not subject to the requirements of UMRA section 203 because it contains no regulatory

requirements that might significantly or uniquely affect small governments. The rule amendments do not

preempt regulations by states, territories, or tribal governments that have their own authorized lead

programs, so those jurisdictions are not required to change their programs. Those training providers (both

those i n the private sector

, as well as State, local or tribal governments) that choose to offer online

refresher renovator training would incur costs for some activities ( e.g., applying for a new accreditation)

but they would reduce other expenses ( e.g., supplie s for the hands

- on training). However, there is no

requirement mandating that training providers offer an online refresher course. So training providers will

not choose to offer online training unless the savings of doing so exceed the costs

, or if they ca n recover their costs through tuition charges or other means.



## 7.3 Executive Order 13132

– Federalism

Executive Order 13132 (64 FR 43255, August 10, 1999) applies to policies that have substantial direct

effects on the States, on the relationship between the na tional government and the States, or on the

distribution of power and responsibilities among the various levels of government. This final rule does

not have substantial direct effects on the States, on the relationship between the national government and

t he States, or on the distribution of power and responsibilities among the various levels of government

. The rule amendments do not preempt regulations by states, territories, or tribal governments that have

their own authorized lead programs, so those juri sdictions are not required to change their programs.

Government entities can serve as training providers, and those training providers that choose to offer

online refresher renovator training would incur costs for some activities ( e.g., applying for a new

accreditation) but they would reduce other expenses ( e.g., supplies for the hands

- on training). However,

there is no requirement mandating that training providers offer an online refresher course. So training

providers will not choose to offer online train ing unless the savings of doing so exceed the costs, or if

they can recover their costs through tuition charges or other means.



## 7.4 Executive Order 13175

– Consultation and Coordination with Indian Tribal

Governments

Executive Order 13175 (65 FR 67249, Novembe r 9, 2000) directs agencies to consult and collaborate

with tribal officials in Federal policy decisions that have tribal implications

. This final rule does not have

tribal implications

. The rule amendments do not preempt regulations by tribal governments that have their

own authorized lead programs, so those jurisdictions are not required to adopt these amendments. Tribal

governments can serve as training providers, and those training providers that choose to offer online

refresher renovator training would incur costs for some activities ( e.g., applying for a new accreditation)

but they would reduce other expenses ( e.g., supplies for the hands

- on training). However, there is no

requirement mandating that training providers offer an online refresher course. So training providers will

not choose to offer online training unless the savings of doing so exceed the costs, or if they can recover

their costs through tuition charges or other means.

### 7

- 11 

## 7.5 Executive Order 13045

- Children’s Health

Executive Order 13045 (62 FR 19885, April 23, 1997) applies to rules that are economically significant

and that concern health or safety risks that EPA has reason to believe may disproportionately affect

children. This final rule is not an economically significant regulatory action as defined by Executive

Order 12866 . Furthermore, EPA interprets Executive Order 13045 as applying only to those regulatory

actions that concern health or safety risks, such that the analysis required under section 5

- 501 of the

Executive Order has the pot ential to influence the regulation. This final rule does not establish an

environmental standard intended to mitigate health or safety risks. Therefore, t his action is not subject to

the requirements of Executive Orde r 13045.



## 7.6 Executive Order 13211

– Energy Supply, Distribution, or Use

Executive Order 13211 (66 FR 28355, May 22, 2001) addresses actions that effect the supply,

distribution, or use of energy. This final rule is not likely to have any adverse effect on the supply,

distribution, or use of energy

.



## 7.7 National Technology Transfer and Advancement Act

Section 12(d) of NTTAA, 15 U.S.C. 272 note, directs agencies to use voluntary consensus standards in

their regulatory activities unless to do so would be inconsistent with applicable law or otherwise

impractical. Voluntary consensus standards are technical standards ( e.g. , materials specifications, test

methods, sampling procedures, and business practices) that are developed or adopted by voluntary

consensus standards bodies

. This final rule does not i nvolve technical standards.



## 7.8 Executive Order 12898

– Environmental Justice

Executive Order 12898 (59 FR 7629, February 16, 1994) establishes federal executive policy on

environmental justice

. Its main provision directs federal agencies, to the greatest extent practicable and

permitted by law, to make environmental justice part of their mission by identifying and addressing, as

appropriate, disproportionately high and adverse human health or environmental effects of their programs,

policies, and activitie s on minority populations and low

- income populations in the United States

.

This action does not directly affect the level of protection provided to human health or the environment.

The rule removes multi

- jurisdiction fees for the LBP Activities program, revises the hands

- on requirement for refresher renovator training, and changes the notification requirements for training

providers . However, renovators will still be required to take an 8 hour initial training that includes a

hands

- on component; they will still have to take regular refresher training; the refresher training will have

to include a hands

- on component every other training cycle; refresher training without a hands

- on component will only be valid for three years; and renovators will s till have to comply with the work

practice requirements for renovation, repair or painting activities that disturb lead

- based paint.

### 8

- 1 

# 8. References

Bureau of Labor Statistics (BLS). (2012, Mar. 29, 2013). "Occupational Employment Statistics

- Occupational Employment and Wages, May 2012, 47

- 1011 First

- Line Supervisors of

Construction Trades and Extraction Workers." Retrieved Jan. 30, 2014, from

http://www.bls.gov/oes/curre nt/oes471011.htm#(2)

.

Bureau of Labor Statistics (BLS). (2013, Dec. 11). "Employer Costs for Employee Compensation

- September 2013." Retrieved Jan. 30, 2014, from

http://www.bls. gov/news.release/archives/ecec_12112013.pdf

.

Bureau of Labor Statistics (BLS). (2014). "Consumer Price Index

- All Urban Consumers, U.S. City

Average (2004 to 2014)." CUSR0000SA0 Retrieved Mar. 21, 2014.

Environmental Systems Resource Institute (ESRI) (20 05). StreetMap North America (ESRI Data).

Redlands, CA.

Environmental Systems Resource Institute (ESRI) (2013). ArcMap 10.2.1. Redlands, CA, ESRI.

Internal Revenue Service (IRS). (2013, Dec. 6). "2014 Standard Mileage Rates." Retrieved Mar. 19,

2014, fro m http://www.irs.gov/2014

- Standard

- Mileage

- Rates

- for

- Business,

- Medical

- and

Moving

- Announced

.

NAHB Business Management & Information Technology (2012). Cost of Doing Business Study, 2012

Edition , NAHB BuilderBooks.com®.

Office of Personal Management (OPM) (2014). 2014 General Schedule (GS) Locality Pay Tables:

WASHINGTON

- BALTIMORE

- NORTHERN VIRGINIA, DC

- MD

- VA

- WV

- PA. SALARY

TABLE 2014

- DCB

SAS Institute In c. (2015). SAS Software 9.4. Cary, NC, SAS Institute Inc., 2002

- 2012.

U.S. EPA (2002). Wage Rates for Economic Analyses of The Toxics Release Inventory Program, U.S.

Environmental Protection Agency, Office of Environmental Information, Environmental Analys is

Division, Analytical Support Branch.

U.S. EPA (2009). "ICR Handbook

- EPA’s Guide to Writing Information Collection Requests."

U.S. EPA (2011). ICR 1715.13: TSCA Sections 402 and Section 404 Training, Certification,

Accreditation and Standards for Lead

- B ased Paint Activities and Renovation, Repair, and

Painting. Washington, DC.

U.S. EPA (2014a). "Federal Lead

- Based Paint Program (FLPP) Database."

U.S. EPA. (2014b, Jan. 15). "Lead

- Based Paint Activities Professionals." Retrieved Mar. 7, 2014, from

http://www2.epa.gov/lead/lead

- based

- paint

- activities

- professionals#map

.

U.S. EPA (2015). Information Collection Request supporting statement: Lead Training, Certification

, Accreditation and Authorization Activities. EPA ICR No. 2507.01, OMB Control No. 2070

- 0195.

Washington, DC.

### 8

- 2 U.S. General Services Administration (GSA). (2014, Jan. 14). "Meals and Incidental Expenses (M&IE)

Breakdown." Retrieved Jan. 30, 2014, from www.gsa.gov/mie

.

### A

- 1 

## Training Courses Tuition Data

Exhibit A

- 1 : Sample of Renovation (Re)certification Training Courses

Company 1, 2 Initial Training Refresher

Training

Complete Hands

- on Complete

1

- 4ABE.com $225.00 $150.00

1st All Around Company $300.00 $180.00

AAA Construction School, Inc. $225.00 $139.00

ACC Environmental Consultants, Inc. $200.00 $100.00

ACC Environmental Consultants, Inc. $225.00 $130.00

Access Training $195.00 $150.00

Accredited Environmental Solutions $295.00 $195.00

AEHS, Inc. $140.00

AEHS, Inc. $200.00

Airtek Environmental Corp. $275.00

Alchemy Lead Management $175.00 $125.00

American Indoor Air Quality Assessment Service, Ltd $250.00

AMWS / 1st All Around Company $300.00 $180.00

Analytical Testing and Consulting Services, Inc. $150.00

Apex Lead Solutions, L.L.C. $275.00

Benchmark Environmental Training $165.00

Benchmark Environmental Training $200.00

Building Performance Center $195.00

BWI Lead Safety RRP Institute $160.00

Calypso Continuing Education $250.00 $125.00

Cardno ATC $225.00 $135.00

CDS Inspections & Beyond $175.00 $98.00

CEI CNY Environmental Institute $150.00 $135.00

CEI CNY Environmental Institute $175.00

CES Environmental & Safety Training Center $290.00 $200.00

Chem Scope $180.00 $125.00

Childhood Lead Action Project $175.00

Churchill Environmental $110.00

Community College of Allegheny County $249.00 $149.00

Contractor Training via Contractor Harbor 3 $160.04

ConTrax LLC $125.00 $99.00

ConTrax LLC $199.00

Cornerstone Training Institute $195.00 $135.00

Criterion Environmental Training $225.00 $215.00

Criterion Environmental Training $325.00

Derby City Safety $225.00 $125.00

ENCORP $131.25 $56.25

ENCORP $175.00 $75.00

ENCORP $90.00

Environmental Compliance Management Corporation $150.00

Environmental Education $145.00

Environmental Management Institute $280.00 $180.00

Environmental Management, Inc $285.00

Environmental Solutions Association $250.00 $195.00

### A

- 2 Exhibit A

- 1 : Sample of Renovation (Re)certification Training Courses

Company 1, 2 Initial Training Refresher

Training

Complete Hands

- on Complete

ERC Lead Inc $275.00

ETC Training Services Group $125.00 $100.00

EverGreen Environmental Health & Safety, Inc $195.00 $130.00

Evergreen Safety Council $240.00

Ferguson: UAMS $150.00

Fibertec Industrial Hygiene Services, Inc $175.00 $100.00

Flatly Read LLC $150.00

Florida State College at Jacksonville $175.00 $100.00

Fuss & O'Neill EnviroScience, LLC $190.00 $100.00

GEBCO Associates, LP $220.00 $200.00

Global Green Property Solutions, LLC $195.00 $90.00

Globeteck Group, Inc. $309.00

Glynite Construction Services $150.00 $100.00

Glynite Construction Services $200.00 $125.00

Great Lakes Safety Training Center $180.00

Greentree Environmental Services, Inc. $225.00 $165.00

Greentree Environmental Services, Inc. $250.00 $175.00

Greenville Technical College $215.00 $150.00

Hazard Management Services, Inc $120.00

High Environmental Health & Safety Consulting Services Ltd. $275.00 $195.00

Highland Environmental Institute $250.00 $200.00

Ideal Environmental Engineering, Inc $275.00 $180.00

Industrial Hygiene Resources, Ltd $250.00 $150.00

Ingraham Environmental $225.00

Inspection Associates Independent Services $175.00 $100.00

Institute for Environmental Education, Inc. $179.00 $150.00

Institute for Environmental Education, Inc. $195.00

Institute of Environmental Management and Technology, Inc $195.00 $145.00

Jackson

- Morris Environmental Technology and Consulting, LLC $245.00 $125.00

L.G. White Safety Corporation $200.00

Lake States Environmental, Ltd. $225.00 $150.00

Lawrence Training School $180.00

Lead Experts $189.00 $95.00

Lead Renovator Training, LLC $200.00 $150.00

Lead Safe, LLC $150.00 $115.00

LeadSmart $225.00 $125.00

LeadSmart $150.00

LeadSmart $155.00

Leadtec Services, Inc. $100.00

LEW Corporation $200.00 $120.00

Lianna Development Corporation Training Program (LDCTP) $190.00 $100.00

Los Angeles Trade Technical College $150.00

MDK Technology $195.00 $100.00

Michigan Builders Test School / Michigan Institute of Real Estate $195.00 $99.00

Middle Tennessee State University $100.00

Midwest Environmental Consulting, LLC $195.00 $95.00

### A

- 3 Exhibit A

- 1 : Sample of Renovation (Re)certification Training Courses

Company 1, 2 Initial Training Refresher

Training

Complete Hands

- on Complete

Midwest Training Institute $175.00 $100.00

Miller Environmental Group $225.00

Mohawk Valley Community Action Agency, Inc $180.00 $120.00

NATEC International, Inc $170.00 $105.00

NATEC International, Inc $190.00 $120.00

National Econ Corporation $185.00 $135.00

New York Environmental Training Institute $275.00 $150.00

New York State Weatherization Directors Assoc. $250.00

North Star Center for Human Development $160.00 $110.00

Northern Environmental Consultants, LLC $295.00 $145.00

Northern Environmental Consultants, LLC $185.00

Northern Environmental Consultants, LLC $200.00

Northwest Independent Contractors Association (NICA) $250.00 $200.00

Northwest Independent Contractors Association (NICA) $295.00

Northwest Independent Contractors Association (NICA) $300.00

NVL Laboratories $250.00 $150.00

OAI, Inc $200.00

Occupational Training & Supply, Inc. $300.00 $127.00

Occupational Training and Supply OTS $301.00 $152.00

Oklahoma Association of Community Action Agencies $200.00 $120.00

Omaha Healthy Kids Alliance $175.00 $100.00

Pathways

- VA, Inc. $199.00

Petroleum & Automation Consultants $250.00 $125.00

Positive Energy Environmental Services $199.00

Public Health and Safety Inc. $260.00

Quality Environmental Solutions & Technologies, Inc $250.00 $175.00

Real Estate Training for U $270.00 $220.00

Rental Property Owners Association $150.00 $125.00

Resolution, Inc. $225.00 $95.00

RGA Environmental, Inc $225.00 $195.00

RGA Environmental, Inc $275.00

S&R Environmental Consulting, Inc $190.00

Santa Fe Community College $225.00

SCS Engineers $249.00 $89.00

Southwest Missouri Safety Company, LLC $225.00 $95.00

Sun City Analytical, Inc $275.00 $275.00

Technical Environmental Services, Inc $200.00

TES, LLC (Tennessee Environmental Services) $150.00

The Environmental Institute $250.00 $125.00

The Western Regional Lead Training Center $217.00

The Westside Environmental Plan of Action Committee, LLC (WEPAC) $225.00

Think People, Inc $300.00

Titan Environmental Services, Inc. $150.00 $99.00

TORF Environmental Management $250.00

Truckee Meadows Community College $195.00 $95.00

TSC Training Academy, LLC $285.00 $150.00

### A

- 4 Exhibit A

- 1 : Sample of Renovation (Re)certification Training Courses

Company 1, 2 Initial Training Refresher

Training

Complete Hands

- on Complete

UNC

- Chapel Hill, NC Occupational Safety and Health Education and Research

Center $195.00

United Parents Against Lead's (UPAL's) Community Training Center $200.00

University of Illinois

- Hazardous Materials Training Program $259.00

University of Tenn es see $200.00

University of Utah (Rocky Mountain Center for Occupational and Environmental

Health) $195.00

Unlimited Choices $200.00 $125.00

Vortex, Inc $200.00 $125.00

Weecycle Environmental Consulting $200.00

Weecycle Environmental Consulting $250.00

WeL Support Services LLC $199.00

West Virginia University Safety and Health Extension $250.00

Windy Ridge Enterprises, LLC $200.00 $150.00

Wisdom and Associates, Inc. $350.00 $225.00

Wunderlin Environmental Training Services LLC $209.00 $99.00

ZOTA Safety Services, LLC $199.00 $135.00

Number of Courses 138 3 97

Mean $217.01 $165.01 $136.97

Median $200.00 $160.04 $127.00

Minimum $100.00 $140.00 $56.25

Maximum $350.00 $195.00 $275.00

Standard Deviation $47.25 $27.84 $38.93

1 The values listed here represent the basic tuition costs reported by training providers

. Some t raining providers offer price reductions, such as

coupon codes or specials, discounts for students taking multiple different classes, discounts for multiple students from a fi rm taking the same

course, referral discounts, and discounts (or even free training) for members of the training organization or area residents

. Thus, the average

tuition actually paid may be less than the estimates here. In ad dition, some training providers include lunch in the price of the tuition they

charge for a training class.

2 Some t raining providers are listed more than once because they offer training in multiple locations and the tuition differs by loca tion.

3 Initial hands

- on training course tuition is derived by taking the tuition for the initial online classroom and hands

- on t raini ng course and

subtracting the online classroom component ($160.04 = $199.99

- $39.95). The online classroom component was developed by a third

- party

firm, Contractor Harbor.

### B

- 1 

## Rule Amendment Options

- Derivation of Estimates for the

Number of Individuals Seeking Recertification

Because the regulatory options have different training intervals and cycle requirements for

hands

- on training, the methodology to calculate the number of renovators taking the in

- person course (either by choice or as part of the periodic hands

- on training requirement stipulated in the

option) and the online course differs by option. The annual number of renovators that are required

to take a course with a hands

- on training compone nt depends on the length of time and number of

training cycles for which the course without a hands

- on training component is valid. A series of

equations are solved to estimate the steady state number of renovators taking the refresher

training course for the rule amendment options. These equations are presented in this appendix.

(i) Renovator Always Chooses In

- person Refresher Training

Option 1

- 4: Refresher training course with hands

- on training valid for 5 years

For Options 1 through 4, the following eq uation is used to estimate the steady state number of

renovators taking the refresher training course with hands

- on training every 5

- year training cycle:

InP = (S / 5) * PREC 5Y * (100%

- EPCT)

where,

InP = The number renovators taking the refresher traini ng course with hands

- on training

in the steady state,

S = The active stock of certified renovators (500,000),

PREC5Y = The percent of renovators with expiring certifications that become recertified

given a 5

- year training cycle (70%), and

EPCT = The online refresher training course scenario percentage (50%, 75%, or 90%).

Thus, for Scenario I (50% of the active stock of renovators choose online refresher training),

InP = (500,000 / 5) * 70% * (100%

- 50%) = 35,000

.

Note that under Option 1, renovator s take the refresher training course without the hands

- on training component whether they travel to the training facility or take the course online because it

is assumed that the refresher hands

- on training component is not offered by training providers.

F or the other options, the in

- person course is assumed to always include the hands

- on component.

(ii) Renovator Chooses Online Refresher Training

Option 1: Refresher training course without hands

- on training valid for 5 years

Under Option 1, the number of r enovators taking the refresher training course online to become

recertified is estimated according to the following equation:

E = (S / 5) * PREC 5Y * (EPCT)

where,

E = The number of renovators taking the refresher training course online,

S = The active st ock of certified renovators (500,000),

### B

- 2 PREC5Y = The percent of renovators with expiring certifications that become recertified

given a 5

- year training cycle (70%), and

EPCT = The online refresher training course scenario percentage (50%, 75%, or 90%).

Option 2: Refresher training without hands

- on valid for 5 years; Hands

- on required every 2

cycles

The following equation is used to estimate the steady state number of renovators taking the

refresher training course in person among those individuals takin g the online training course

every other training cycle under option 2:

InP = ( PREC 2nd 

### * EPCT * I) / (1 00%

- PREC 2nd 

### )

,

where,

InP = The number of renovators taking the refresher training course in person (hands

- on cycle) among those individuals taking the online training course every other

training cycle,

PREC 2nd 

### =The percent of renovators with expiring certifications that become recertified

for the second time given two 5

- year recertifications periods

(( PREC 2nd 

### = 70 % * 70% = 49%),

EPCT = The online refres her training course scenario percentage (50%, 75%, or 90%),

and

I = The number of initial certifications each year (30,000).

Thus, for Scenario I (50 percent of the active stock of renovators choose online refresher training)

under Option 2,

InP = (49% * 50% * 30,000 ) / (1 00%

– 49% ) = 14,412

.

The following equation is used to estimate the number of renovators taking the refresher training

course online:

E = ((PREC5Y * EPCT * I) + (PREC5Y * InP)

- InP) / (100%

- PREC5Y),

where,

E

= 

### The number of renovators taking the refresher training course online (no hands

- on cycle),

InP = The number of renovators taking the refresher training course in person (hands

- on cycle) among those individuals taking the online training course every other

training cycle,

PREC5Y = The percent of renovators with expiring certifications that become recertified

given a 5

- year training cycle (70%),

EPCT = The online refresher training course scenario percentage (50%, 75%, or 90%),

and

I = The number of initial certifications each year ( 30,000)

### B

- 3 Thus, for Scenario I (50 percent of the active stock of renovators choose online refresher training)

under Option 2,

E = ((70% * 50% * 30,000) + (70% * 14,412)

- 14,412) / (100%

- 70%)) =

20,588.

Therefore, in the steady state under Option 2

, Scen ario I:

 One fifth of the active stock of 500,000 renovators (100,000 renovators) will have an

expiring recertification in a given year. Seventy percent of them (70,000 per year) are

estimated to seek recertification and the balance of 30,000 per year are a ssumed to exit

the industry and be replaced by newly certified renovators who take initial training. Of

the 70,000 renovators per year estimated to seek recertification, 50 percent (35,000 per

year) are assumed to always choose the in

- person refresher trai ning course under this

scenario.

 The other fifty percent (35,000) choose the online refresher training course. However, as

shown in Exhibit B

- 1 , within that group of 3 5,000, more renovators take the online

training without hands

- on training (20,588) than take the in

- person training with hands

on training (14,412) in an average year because renovators drop out of the active stock

over time. For example, more renovators w ill have dropped out of the active stock 10

years after their initial training compared to 5 years after their initial training (and they

would take the online course without hands

- on training 5 years after their initial training

and the hands

- on in

- person course 10 years after their initial training).

Exhibit B

- 1 : Option 2, Scenario I

- 50% of Active Stock Chooses Online

Refresher Training

Initial

Certifications (I) Renovator Always

Chooses In

- person Refresher Training Renovator Chooses Online Refresher Training

Cycle with

Hands

- on
(InP) Cycle w/out Hands

- on
(E)

30,000 35,000 14,412 20,588



### Option 3: Refresher training without hands

- on valid for 2 or 3 years

Under Option 3(a) (online course recertification valid for 2 years ), the number of renovators

taking the online refresher training course to become recertified is estimated according to the

following equation:

E = (S * EPCT * PREC 5Y) / 2,

Where,

E = The n umber renovators taking the refresher training course online,

S = The active stock of certified renovators (500,000)

PREC5Y = The percent of renovators with expiring certifications that become recertified

given a 5

- year training cycle (70%), and

EPCT = The online refresher training course scenario percentage (50%, 75%, or 90%).

### B

- 4 Under Option 3(b) (online course recertification valid for 3 years ), the annual number of

renovators taking the online refresher training course to become recertified is estimated ac cording

to the following equation:

E = (S * EPCT * PREC 5Y) / 3,

where,

E = The number renovators taking refresher training course online,

S = The active stock of certified renovators (500,000)

PREC5Y = The percent of renovators with expiring certificatio ns that become recertified

given a 5

- year training cycle (70%), and

EPCT = Online refresher training course scenario percentage scenario percentage (50%,

75%, or 90%).

Option 4: Cyclical hands

- on requirement; online course training valid for 2 or 3 years

The methodology for estimating the steady state number of recertifications for Options 4(a)

through 4(d) is similar to that of Option 2. Because the methodology is essentially the same for

Option 4(a) through Option 4(d), only the methodology for Option 4( a) will be described in

detail; however the equations for Options 4(b) through 4(d) are provided following Exhibit B

- 2

.

The following equation is used to estimate the steady state number of renovators taking the

refresher training course in person (hands

- on cycle) among those individuals taking the online

tra ining course every other training cycle:

InP = ( PREC 2nd 

### * EPCT * I) / (100%

- PREC 2nd 

### ),

where,

InP = The number of renovators taking the refresher training course in person (hands

- on cycle) among those individuals taking the online training course every o ther

training cycle,

PREC 2nd 

### = The percent of renovators with expiring certifications that become recertified

for the second time given one 5

- year recertification period ( PREC 5Y = 7 0% )

and one 2

- year recertification period

( PREC 2Y = [100%

- (((100%

- PREC 5Y) / 5) * 2)])

( PREC 2nd 

### = PREC 5Y * PREC 2Y = 61.6%),

EPCT = Online refresher training course scenario percentage (50%, 75%, or 90%), and

I = The number of initial certifications each year (30,000).

Thus, for Scenario I (50 percent of the active stock of re novators choose online refresher training)

under Option 4(a),

InP = (61.6% * 50% * 30,000 ) / (1 00%

- 61.6% ) = 24,063

.

The following equation is used to estimate the number of renovators taking the refresher training

course online under Option 4(a):

E = ((PREC5Y * EPCT * I) + (PREC5Y * InP)

- InP) / (100%

- PREC2Y),

### B

- 5 where,

E

= 

### The number of renovators taking the refresher training course online (no hands

- on cycle),

InP = The number of renovators taking the refresher training course in person (hands

- on

cy cle) among those individuals taking the online training course every other

training cycle,

PREC5Y = The percent of renovators with expiring certifications that become recertified

given a 5

- year training cycle (70%),

PREC2Y = The percent of renovators with expiring certifications becoming recertified

given a two year recertification period

( PREC2Y = [100%

- (((100%

- PREC5Y ) / 5) * 2] = 88%),

EPCT = Online refresher training course scenario percentage (50%, 75%, or 90%), and

I = The number of initial certi fications each year (30,000).

Thus, for Scenario I (50 percent of the active stock of renovators choose online refresher training)

under Option 4(a),

E = ((70% * 50% * 30,000) + (70% * 24,063)

- 24,063) / (100%

- 88%)) =

27,343.

In the steady state under Option 4(a) and what is termed the 50 percent scenario, the total number

of renovators choosing online refresher training each year (51,406) is greater than 50 percent of

the total number of renovators taking refresher training ea ch year (86,406). This is because

renovators choosing online refresher training must be recertified more frequently. For example, a

renovator choosing online refresher training must take the training course twice every seven

years, whereas a renovator alwa ys choosing the in

- person refresher training course must only take

the training course once every five years. However, 50 percent of the active stock of recertified

renovators is recertified by taking the refresher training course online every other traini ng cycle.

• The total number of recertified renovators that become recertified by taking online

refresher training is equal to 120,315 (24,063 renovators per year taking the in

- person training course, which is valid for five years) plus 54,686 (27,343 renova tors per year

taking the online training, which is valid for two years), which equals 175,000 when

rounded to the ten thousand digit. The active stock of recertified renovators is equal to

350,000 (70 percent recertification rate for the 500,000 active sto ck of renovators). Thus,

50 percent of the recertified renovators take the online refresher training course

((175,000 / 350,000)*100 = 50%).

• Under Option 4(a) Scenario I, approximately 23 percent or 116,406 renovators out of the

active stock of 500,000 ren ovators will have an expiring recertification in a given year.

Approximately 74 percent or 86,406 of them are estimated to seek recertification and the

balance of 30,000 are assumed to leave the industry and be replaced by newly certified

renovators.

o While 50 percent of the active stock chooses online refresher training, the

number of renovators in this group accounts for a higher percentage of the total

number of renovators seeking refresher training in a given year because

### B

- 6 renovators choosing online refre sher training must be recertified more frequently

compared to renovators always choosing in

- person refresher training. Of the

86,406 renovators estimated to seek recertification in a given year:

 Approximately 41 percent (35,000) are assumed to always choos e the

in

- person refresher training course and

 Approximately 59 percent (51,406) choose the online refresher training

course training cycle. However, as shown in Exhibit B

- 2

, in an average

year, more renovators take the online training course without hands

- on training (27,343) than take the in

- person training with hands

- on training

(24,063) because renovators drop out of the active stock over time. For

example, more renovators will have dropped out of the active stock 7

years after their initial training compared to 5 years after their initial

training (and they would take the online course without hands

- on trainin g 5 years after their initial training and the hands

- on in

- person course 7

years after their initial training).

Exhibit B

- 2 : Option 2, Scenario

- 50 % of Active Stock Chooses Online

Refresher Trainin g

Initial

Certifications (I) Renovator Always

Chooses In

- person
Refresher Training Renovator Chooses Online Refresher Training

Cycle with

Hands

- on

(InP) Cycle w/out Hands

- on
(E)

30,000 35,000 24,063 27,343



### • Option 4(b) Equations (2 year interval and 3 cycles):

InP = (PREC 3rd 

### * EPCT * I) / (100%

- PREC 3rd 

### )

E = ((PREC5Y * EPCT * I) + (PREC5Y * InP)

- InP) / (100%

- PREC2Y)

PREC 3rd 

### = The percent of renovators becoming recertified for the third time

given one 5

- year recertification period and two 2

- ye ar recertification

periods

( PREC 3rd 

### = PREC 5Y * PREC 2Y * PREC 2Y = 54.2%)

• Option 4(c) Equations (3 year interval and 2 cycles):

InP = ( PREC 2nd 

### * EPCT * I) / (100%

- PREC 2nd 

### )

E = ((PREC5Y * EPCT * I ) + (PREC5Y * InP)

- InP) / (100%

- PREC3Y)

PREC3Y = The percent of renovators becoming recertified given a 3

- year recertification period (100

- (((100

- PREC5Y) / 5) * 3))

PREC 2nd 

### = The percent of renovators becoming recertified for the second time

given one 5

- year recertification period and one 3

- year recerti fication

period

( PREC 2nd 

### = PREC 5Y * PREC 3Y = 57.4%)

• Option 4(d) Equations (3 year interval and 3 cycles):

InP = (PREC 3rd 

### * EPCT * I) / (100%

- PREC 3rd 

### )

### B

- 7 E = ((PREC5Y * EPCT * I) + (PREC5Y * InP)

- InP) / (100%

- PREC3Y)

PREC 3rd 

### = The percent of renovators becoming recertified for the third time

given one 5

- year recertification period and two 3

- year recertification

periods

( PREC 3rd 

### = PREC 5Y * PREC 3Y * PREC 3Y = 47.1%)

### C

- 1 

## Detailed Exhibits of Total Renovator Training Costs

Exhibit C

- 1 present s the net present value and annualized costs under the baseline (refresher

training with the hands

- on component valid for 5 years) , over a ten year period from 201 6

through 2025. The costs are discounted using rates of 3 and 7 percent. The estimates in Exhibit

C

- 1 are used to estimate cost savings for Options 1 t hrough 4, presented in Exhibit 3

- 10

. Exhibit

C

- 2 through Exhibit C

- 9 present the net present value and annualized costs for Options 1 through

4.

Exhibit C

- 1 : Baseline

- Ten Year Net Present Value and Annualized

Costs for Renovators Seeking Recertification (2014$)

Baseline 1 In

- person Training with

a Hands

- on Component

Net Present Value

3% $167,502,475

7% $137,917,857

Annualized Costs (3% and 7%) $19,636,400

1 It is estimated that 70,000 renovators seek refresher training each year under the baseline

training schedule.



### Exhibit C

- 2 present s the net present value and annualized costs under Option 1 (refresher training

course without the hands

- on component valid for 5 years) , over a ten year period from 201 6

through 2025

, for in

- person and online training

. The costs are discounted using rates of 3 and 7

percent.

### C

- 2 Exhibit C

- 2 : Option 1

- Ten Year Net Present Value and Annualized Costs for

Renovators Seeking Recertifica tion (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In

- person Refresher Training Online Refresher

Training No

Hands

- on Cycle Total

Refresher

Training

Net Present Value

3% $70,208,687 $27,350,816 $97,559,503

7% $57,808,290 $22,520,061 $80,328,351

Annualized Costs

(3% and 7%) $8,230,600 $3,206,350 $11,436,950

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In

- person

Refresher Training Online Refresher

Training No

Hands

- on Cycle Total

Refresher

Training

Net Present Value

3% $35,104,344 $41,026,224 $76,130,568

7% $28,904,145 $33,780,091 $62,684,236

Annualized Costs

(3% and 7%) $4,115,300 $4,809,525 $8,924,825

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In

- person Refresher Training Online Refresher

Training No

Hands

- on Cycle Total

Refresher

Training

Net Present Value

3% $14,041,737 $49,231,469 $63,273,206

7% $11,561,658 $40,536,109 $52,097,767

Annualized Costs

(3% and 7%) $1,646,120 $5,771,430 $7,417,550



### Exhibit C

- 3 present s the net present value and annualized costs under Option 2 (refresher training

course without the hands

- on component valid for 5 years; refresher training course with the

hands

- on com ponent required every other training cycle) , over a ten year period from 201 6

through 2025 , for in

- person and online training. The costs are discounted using rates of 3 and 7

percent.

### C

- 3 Exhibit C

- 3 : Op tion 2

- Ten Year Net Present Value and Annualized Costs for Renovators Seeking Recertification (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In

- person Refresher Training Renovator Chooses Online Refresher Training Total

Refresher

Training Cycle with

Hands

- on Cycle w/out

Hands

- on Sub

- Total

Net Present Value

3% $83,751,237 $34,486,367 $16,088,531 $50,574,898 $134,326,135

7% $68,958,928 $28,395,316 $13,246,943 $41,642,259 $110,601,187

Annualized Costs

(3% and 7%) $9,818,200 $4,042,854 $1,886,067 $5,928,921 $15,747,121

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In

- person Refresher Training Renovator Chooses Online Refresher Training Total

Refresher

Training Cycle with

Hands

- on Cycle w/out

Hands

- on Sub

- Total

Net Present Value

3% $41,875,619 $51,729,550 $24,132,797 $75,862,347 $117,737,966

7% $34,479,464 $42,592,975 $19,870,415 $62,463,390 $96,942,854

Annualized Costs

(3% and 7%) $4,909,100 $6,064,281 $2,829,100 $8,893,381 $13,802,481

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In

- person

Refresher Training Renovator Chooses Online Refresher Training Total

Refresher

Training Cycle with

Hands

- on Cycle w/out

Hands

- on Sub

- Total

Net Present Value

3% $16,750,247 $62,074,024 $28,959,825 $91,033,849 $107,784,096

7% $13,791,786 $51,110,387 $23,844,884 $74,955,271 $88,747,057

Annualized Costs

(3% and 7%) $1,963,640 $7,276,969 $3,394,975 $10,671,944 $12,635,584



### Exhibit C

- 4 and Exhibit C

- 5 present the net present value and annualized costs under Option 3(a)

and 3(b) (refresher training course without the hands

- on component valid for 2 or 3 years) , over a

ten year period from 20 1 6 through 2025 , for in

- person and online training. The costs are discounted using rates of 3 and 7 percent.

### C

- 4 Exhibit C

- 4 : Option 3(a)

- Ten Year Net Present Value and Annualized Costs

for Renovators S eeking Recertification (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In

- person Refresher Training Online Refresher

Training Cycle

w/out Hands

- on Total

Refresher

Training

Net Present Value

3% $83,751,237 $68,377,040 $152,128,277

7% $68,958,928 $56,300,152 $125,259,080

Annualized Costs

(3% and 7%) $9,818,200 $8,015,875 $17,834,075

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In

- person Refresher Training Online Refresher

Training Cycle

w/out Hands

- on Total

Refresher

Training

Net Present Value

3% $41,875,619 $102,565,559 $144,441,178

7% $34,479,464 $84,450,228 $118,929,692

Annualized Costs

(3% and 7%) $4,909,100 $12,023,813 $16,932,913

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In

- person Refresher Training Online Refresher

Training Cycle

w/out Hands

- on Total

Refresher

Training

Net Present Value

3% $16,750,247 $123,078,671 $139,828,918

7% $13,791,786 $101,340,273 $115,132,059

Annualized Costs

(3% and 7%) $1,963,640 $14,428,575 $16,392,215

### C

- 5 Exhibit C

- 5 : Option 3(b)

- Ten Year Net Present Value and Annualized Costs for Renovators Seeking Recertification (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In

- person Refresher Training Online Refresher

Training Cycle

w/out Hands

- on Total

Refresher

Training

Net Present Value

3% $83,751,237 $45,584,433 $129,335,670

7% $68,958,928 $37,533,220 $106,492,148

Annualized Costs

(3% and 7%) $9,818,200 $5,343,886 $15,162,086

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In

- person Refresher Training Online Refresher

Training Cycle

w/out Hands

- on Total

Refresher

Training

Net Present Value

3% $41,875,619 $68,377,040 $110,252,659

7% $34,479,464 $56,300,152 $90,779,616

Annualized Costs

(3% and 7%) $4,909,100 $8,015,875 $12,924,975

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In

- person Refresher Training Online Refresher

Training Cycle

w/out Hands

- on Total

Refresher

Training

Net Present Value

3% $16,750,247 $82,052,448 $98,802,695

7% $13,791,786 $67,560,182 $81,351,968

Annualized Costs

(3% and 7%) $1,963,640 $9,619,050 $11,582,690



### Exhibit C

- 6

, Exhibit C

- 7

, Exhibit C

- 7 , and Exhibit C

- 7 present the net present value and

annualized costs under Option 4 (cyclical hands

- on training requirement; refresher training course

without the hands

- on component valid for 2 or 3 years) , over a ten year period from 201 6 through

2025 , for in

- person and online training. The costs are discounted using rates of 3 and 7 percent.

### C

- 6 Exhibit C

- 6 : Option 4(a)

- Ten Year Net Present Value and Annualized Costs for Renovators Seeking Recertification (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In

- person Refresher Training Renovator Chooses Online Refresher Training Total

Refresher

Training Cycle with

Hands

- on Cycle w/out

Hands

- on Sub

- Total

Net Present Value

3% $83,751,237 $57,580,172 $21,367,239 $78,947,411 $162,698,648

7% $68,958,928 $47,410,248 $17,593,315 $65,003,563 $133,962,491

Annualized Costs

(3% and 7%) $9,818,200 $6,750,153 $2,504,892 $9,255,045 $19,073,245

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In

- person Refresher Training Renovator Chooses Online Refresher Training Total

Refresher

Training Cycle with

Hands

- on Cycle w/out

Hands

- on Sub

- Total

Net Present Value

3% $41,875,619 $86,369,062 $32,051,249 $118,420,311 $160,295,930

7% $34,479,464 $71,114,387 $26,390,294 $97,504,681 $131,984,145

Annualized Costs

(3% and 7%) $4,909,100 $10,125,089 $3,757,384 $13,882,473 $18,791,573

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In

- person Refresher Training Renovator Chooses Online Refresher Training Total

Refresher

Training Cycle with

Hands

- on Cycle w/out

Hands

- on Sub

- Total

Net Present Value

3% $16,750,247 $103,643,353 $38,461,499 $142,104,852 $158,855,099

7% $13,791,786 $85,337,659 $31,668,353 $117,006,012 $130,797,798

Annualized Costs

(3% and 7%) $1,963,640 $12,150,163 $4,508,861 $16,659,024 $18,622,664

### C

- 7 Exhibit C

- 7 : Option 4(b)

- Ten Year Net Present Value and Annualized Costs for Renovators Seeking Recertification (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In

- person Refresher Training Renovator Chooses Online Refresher Training Total

Refresher

Training Cycle with

Hands

- on Cycle w/out

Hands

- on Sub

- Total

Net Present Value

3% $83,751,237 $42,490,592 $33,686,828 $76,177,420 $159,928,657

7% $68,958,928 $34,985,820 $27,736,994 $62,722,814 $131,681,742

Annualized Costs

(3% and 7%) $9,818,200 $4,981,194 $3,949,124 $8,930,318 $18,748,518

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In

- person Refresher Training Renovator Chooses Online Refresher Training Total

Refresher

Training Cycle with

Hands

- on Cycle w/out

Hands

- on Sub

- Total

Net Present Value

3% $41,875,619 $63,734,692 $50,531,023 $114,265,715 $156,141,334

7% $34,479,464 $52,477,744 $41,606,134 $94,083,878 $128,563,342

Annualized Costs

(3% and 7%) $4,909,100 $7,471,650 $5,923,777 $13,395,427 $18,304,527

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In

- person Refresher Training Renovator Chooses Online Refresher Training Total

Refresher

Training Cycle with

Hands

- on Cycle w/out

Hands

- on Sub

- Total

Net Present Value

3% $16,750,247 $76,481,630 $60,636,759 $137,118,389 $153,868,636

7% $13,791,786 $62,973,293 $49,926,975 $112,900,268 $126,692,054

Annualized Costs

(3% and 7%) $1,963,640 $8,965,980 $7,108,478 $16,074,458 $18,038,098

### C

- 8 Exhibit C

- 8 : Option 4(c)

- Ten Year Net Present Value and Annualized Costs for Renovators Seeking Recertification (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In

- perso n Refresher Training Renovator Chooses Online Refresher Training Total

Refresher

Training Cycle with

Hands

- on Cycle w/out

Hands

- on Sub

- Total

Net Present Value

3% $83,751,237 $48,362,750 $19,261,226 $67,623,976 $151,375,213

7% $68,958,928 $39,820,826 $15,859,270 $55,680,096 $124,639,024

Annualized Costs

(3% and 7%) $9,818,200 $5,669,590 $2,258,003 $7,927,593 $17,745,793

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In

- person Refresher Training Renovator Chooses Online Refresher Training Total

Refresher

Training Cycle with

Hands

- on Cycle w/out

Hands

- on Sub

- Total

Net Present Value

3% $41,875,619 $72,545,322 $28,891,839 $101,437,161 $143,312,780

7% $34,479,464 $59,732,224 $23,788,905 $83,521,129 $118,000,593

Annualized Costs

(3% and 7%) $4,909,100 $8,504,525 $3,387,005 $11,891,530 $16,800,630

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In

- person Refresher Training Renovator Chooses Online Refresher Training Total

Refresher

Training Cycle with

Hands

- on Cycle w/out

Hands

- on Sub

- Total

Net Present Value

3% $16,750,247 $87,053,429 $34,670,676 $121,724,105 $138,474,352

7% $13,791,786 $71,677,880 $28,547,072 $100,224,952 $114,016,738

Annualized Costs

(3% and 7%) $1,963,640 $10,205,318 $4,064,461 $14,269,779 $16,233,419

### C

- 9 Exhibit C

- 9 : Option 4(d)

- Ten Year Net Present Value and Annualized Costs for Renovators Seeking Recertification (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In

- person Refresher Training Renovator Chooses Online Refresher Training Total

Refresher

Training Cycle with

Hands

- on Cycle w/out

Hands

- on Sub

- Total

Net Present Value

3% $83,751,237 $31,916,400 $28,212,757 $60,129,157 $143,880,394

7% $68,958,928 $26,279,262 $23,229,764 $49,509,026 $118,467,954

Annualized Costs

(3% and 7%) $9,818,200 $3,741,576 $3,307,396 $7,048,972 $16,867,172

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In

- person Refresher Training Renovator Chooses Online Refresher Training Total

Refresher

Training Cycle with

Hands

- on Cycle w/out

Hands

- on Sub

- Total

Net Present Value

3% $41,875,619 $47,874,600 $42,319,527 $90,194,127 $132,069,746

7% $34,479,464 $39,418,894 $34,844,968 $74,263,862 $108,743,326

Annualized Costs

(3% and 7%) $4,909,100 $5,612,364 $4,961,140 $10,573,504 $15,482,604

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In

- person Refresher Training Renovator Chooses Online Refresher Training Total

Refresher

Training Cycle with

Hands

- on Cycle w/out

Hands

- on Sub

- Total

Net Present Value

3% $16,750,247 $57,450,956 $50,782,651 $108,233,607 $124,983,854

7% $13,791,786 $47,303,855 $41,813,318 $89,117,173 $102,908,959

Annualized Costs

(3% and 7%) $1,963,640 $6,735,005 $5,953,276 $12,688,281 $14,651,921