Economic Analysis for the Lead-Based 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. Small 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 Governments.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 – Environmental 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 Exhibits 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 through 2025 (millions of 2014$) ...................................ES-6

Exhibit ES-4: Pre- and Post-training Notification Cost Savings for Regulatory Options Over a Ten 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)accreditation .........................3-1

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$) ................................................................................................................................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 Seeking 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 Regulatory 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 and Recurring 

Notification Submissions via the CDX (2014$)................................................................3-21

Exhibit 3-14: Post-training Notification Cost Savings for Regulatory Options Over a Ten Year Period, 

2016 through 2025 (2014$)...............................................................................................3-24
iii

Exhibit 3-15: Pre- and Post-training Notification Cost Savings for Regulatory Options Over a Ten Year 

Period, 2016 through 2025 (2014$)...................................................................................3-27

Exhibit 3-16: Total and Annualized Industry Cost Savings 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 the Final Rule ...........7-3

Exhibit 7-2: Incremental RRP Training Provider Total Burden Hours for the Final Rule, Scenario I....7-4

Exhibit 7-3: Loaded RRP Training Provider Wage Rates........................................................................7-5

Exhibit 7-4: RPP Incremental Training Provider Cost for the Final Rule, Scenario 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 Final 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 Summary

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

for Lead-based Paint Poisoning Prevention in Certain Residential Structures, codified at 40 CFR part 745

under the authority of TSCA §402(a) and §402(c). This report estimates the changes in compliance costs 

due to the final rule that amends the Lead-Based Paint (LBP) Activities rule for lead abatement and 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 for the renovator refresher 

training course, and revise the notification requirements for training providers.

The rule removes the multi-jurisdiction 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 lead-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 modifies 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-on 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

Recertification 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. This would allow renovators to 

take some or all of their refresher 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 hands-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 hands-on component required at repeating intervals.

Options 3 and 4 include sub-options that vary both the length of time for which refresher training without a 

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

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

Multijurisdiction 

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, as previously noted,

renovators could still choose 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 if the hands-on requirement is removed. Scenarios 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 percent of the active stock of 

renovators will always choose to take their refresher training in person. Exhibit ES-2 presents the number of 

renovators seeking 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 recertifications 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 numbers of renovators are in the online 

and in-person training cohorts (see Section 3.2.5 and Appendix B for a more detailed explanation of this 

effect). As a result, the number of total annual 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 class.
ES-3

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

Scenario I: 50% 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 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 Cycles1 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 Cycles1 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 Cycles1 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 without 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, they will save an average of $144 per person.

Depending on the regulatory 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 (see 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 renovators 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 (see 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 (millions 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 Cycles1 $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 Cycles1 $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 Cycles1 $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, training providers currently accredited for the renovator 

refresher training course are expected to offer online refresher training courses. This would involve 
ES-7

licensing an existing online course or developing a new course, and applying to EPA for accreditation to 

teach an online course. Training 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 costs, which 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 400 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 $38,000 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. Training 

providers would not be required to submit pre-training notifications for online training courses that have no 

in-person component, and would only be required to submit post-training notifications 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 notifications is estimated to decrease by 3,000 to 17,000 per year, 

depending on the option and scenario. The change in the annual number of post-training notifications 

ranges from a reduction of 4,200 to an increase of 3,200, depending on the option and scenario. The final 

rule, Option 4(c), is estimated to reduce the total number of pre-notifications 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 without 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 posttraining notification, but the time required to do this is negligible. The 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. 

Lastly, the 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 Cycles1 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 Cycles1 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 Cycles1 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 cost savings of the final rule and its 

major components. Estimates in both exhibits 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 Cycles2 $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 Cycles2 $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 Cycles2 $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, 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 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 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 volume of business, or other means. Although some accredited training providers 

may lose market share to other 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 an online refresher 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 training component. Renovators who are eligible 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 convenience 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 Paint (LBP) 

Activities 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 curriculum, and revise the notification requirements for training 

providers. This chapter provides background information on EPA’s LBP regulations, 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-jurisdiction Registration Fee

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 

regulations (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 Training for Renovators

In 2008, EPA issued a final rule under the authority of §402(c)(3) of TSCA 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 appropriate 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 (see 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); see Exhibit 1-1)).

EPA manages the RRP program 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 Wisconsin are authorized to administer their own programs in lieu of the federal 

program. The final rule applies 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 costs to industry associated with the multi-jurisdiction registration fee include a $35 fee for each 

additional EPA-administered jurisdiction 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 refresher 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 regulatory 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 license an existing online course 

or develop a new course, and apply to EPA for accreditation to teach an online course. Training 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 costs, 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 analysis 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 the 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 Chapter 2. Chapter 3 includes the economic 

analysis of cost savings 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 impacts are described in Chapter 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

The multi-jurisdiction registration fee amendment may affect individuals, firms, and training providers 

regulated by the Lead-based Paint Activities rule, with the exception of non-profit training providers 

(which are exempt from the fee). The 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 Program (FLPP) 

database (U.S. EPA 2014a).

Exhibit 2-1 presents the number of all applications submitted by individuals and firms engaging in leadbased paint activities, and all training providers offering lead-based paint activities training courses, from 

2011 through 2013 (not just those applying to work in 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 Sought

Individuals 5,127 864

Firms 1,780 403

Training Providers (for-profit) 23 27

The RRP rule required 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 2009-10

through 2014. Column 1 of Exhibit 2-2 lists the year the certification was issued, Column 2 lists number 

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

certifications under EPA’s April 2015 extension rule.

2 The 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; see Exhibit 2-2). In the 

baseline scenario, the 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; see 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 2014 and 2015, rounded to the nearest ten thousand (30,000; see Exhibit 2-2). 

Thus, the number of renovators seeking refresher training each year equals 70,000 (100,000 - 30,000; see 

 

2 On April 8, 2015 EPA published a rule extending 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 received 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 Certifications under the RRP Program Rule from 2009-10 through 2014 

and Expiring Certifications Under the Extension Rule

Year Certified Number of Initial

Certifications Expiration Year Number of ExpiringCertifications

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 ≈500,000 ≈500,000

Average Certifications per Year ≈100,000

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 assumptions 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 sought 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 cyclicality 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 analysis. 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 

relatively 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 seeks 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 presents

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

renovator refresher training course amendment. Section 3.3 presents 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-jurisdiction Registration Fee Amendment

If jurisdictions are eliminated, regulated entities will no longer have to send 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 able 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 

which 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 average annual costs borne by regulated entities 

are summarized in the last column 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 

Annual

Individuals 864 288 $10,080

Firms 403 134 $4,690

Training Providers (for-profit) 27 9 $315

Total 431 $15,085

Exhibit 3-2 presents the ten year net present value and annualized cost savings under the final rule for 

individuals and firms applying for (re)certification, and training providers applying for (re)accreditation.

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 Amendment

Costs and incremental 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 hands-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. Each 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). Option 1 allows renovators to take a refresher 

training course without a hands-on training component. Renovators 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. Options 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 options 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 hands-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 renovator 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 assumed 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 

choose 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 

hands-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 training; 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 will 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 

hands-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: Refresher training course requires 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 renovators who took hands-on training in the previous training cycle but choose to take 

training in person again.

2 Course without hands-on component: Refresher training course requires only a classroom course component. Refresher training without a hands-on training component

is assumed to be taken online with one exception. For 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 an online course could still choose to take a course in person.

4 The final rule is Option 4(c).
3-5

Note that it 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 

training 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 savings 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 without the hands-on component.

The refresher training course tuitions are estimated for three types of refresher training courses: an 

in-person course with a hands-on training component (under the baseline and Options 2 through 4); an inperson 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 providers offering refresher and/or initial renovator training. 

The tuition data and summary statistics can be found in Appendix A.

A renovator is currently able to enroll in an in-person refresher training course, which consists of a

classroom and a hands-on training component. (The 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 recently. Therefore, this analysis does not reflect any online refresher training in the 

baseline.

4

) The mean tuition for an in-person refresher course is $136.97 (see Appendix A). 

The procedure to estimate the tuition for the in-person course without a hands-on component (under 

Option 1) relies on the current mean tuition for initial and refresher training courses, 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 who 

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 option 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 steps 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 training 

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 lower 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 Estimate In-person Classroom Refresher Training

Course Tuition (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 Hands-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 Course $56.93 (B) - (D)

(F) Incremental costs of 2 hours of hands-on training $108.08 (C) - (E)

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

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

(I) Classroom 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 training. 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 without hands-on $91.61

Online course $91.61

3.2.3 Travel Cost

Travel cost consists of the cost for a renovator to travel to the training site, incidental expenses, and the 

value of the time spent traveling 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 the average distance 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 were 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 Dataset (ESRI 2005) was selected as the Network Dataset input.

11 The average 

 

8 The cost of providing 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-to1 for the rest of the in-person classroom course. The tuition 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) for 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 possible 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 FLPP.

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 1st, 2014 (IRS 2013). The total roundtrip cost of travel is estimated to be 

$43.68 (2 * 39 miles * $0.56 = $43.68). Expenses comprise the cost of lunch and are estimated using the 

Meals and Incidental Expenses Breakdown published by the General Services Administration. These 

expenses 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 previous 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 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 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 and 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 2012 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 $47.61 for renovators. Based on the 1.8 hour 

duration of a roundtrip to the training site, the 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 classes, 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 without 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 (see Exhibit 2-2). To estimate the number of renovators expected to 

seek recertification each year under the regulatory options, it is assumed 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 

approximates the number of initial certifications in 2013 and 2014 (see 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 

choice 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 depends on the length of time and number of training cycles for which the course 

without 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 recertifications 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) * PREC5Y = 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 become recertified given a 

5-year training cycle (70%).

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 course, (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, whether 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, training 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 training 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 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 numbers 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 renovators 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 30 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 course 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 renovator 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 Scenario 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 under 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 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 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 Cycles1 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 Cycles1 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 Cycles1 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 presents a summary of the net present value and annualized costs and cost savings under 

Options 1 through 4, over a ten year period from 2016 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 Regulatory 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 Cycles1 $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 Cycles1 $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 Regulatory 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 Cycles1 $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 course. 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 business 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 submitted via U.S. 

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

3.3.2 Pre-training Notification Amendment

Under the amended rule, EPA is removing the requirement for training providers to submit pre-training 

notifications for online courses without a hands-on training component. Therefore, online training results 

in a reduction in the number of pre-training notifications that must be submitted. The number of 

pre-training notifications is estimated using FLPP pre-training notification and renovator certification 

data. The total number of pre-training notifications is estimated as the sum of original, update, and 

cancelation pre-training notifications. Because the number of courses offered (and thus the number of 

pre-training notifications) depends on the annual number of certifications, and the estimated annual

number of renovator recertifications varies by option, the number of original pre-training notifications 

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

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

notifications, which is equal to 5 (based on FLPP data for the RRP program from 2012 to 2014). The 

number of cancelation pre-training notifications is equal to 25 percent of the number of original 

pre-training notifications, and the number of update pre-training notifications is equal to 13 percent of the 

number of original pre-training notifications (FLPP data from 2012 to 2014). Thus, given the 70,000 

baseline number of annual recertifications, there would be 19,320 total annual pre-training notifications:

(70,000 / 5) * (100% + 25% + 13%) = 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 notifications due 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 percent.) 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 notifications 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 percent, 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 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 Renovators 

Choosing In-person 

Refresher Training

Reduction in

Pre-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 Cycles1 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 

Pre-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 Cycles1 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 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 Renovators 

Choosing In-person 

Refresher Training

Reduction in 

Pre-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 Cycles1 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 Notification Amendment

There are two changes to the rule that have competing effects on the notification burden: (1) options that 

require more frequent refresher training result in more post-training notifications, which increases posttraining 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 

notification 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 providers will be allowed to submit post-training notifications for their 

online courses 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 

notifications. Exhibit 3-12 presents the initial burden associated with enrolling in the CDX system and the 

recurring burden associated with employee turnover and compromised or surrendered electronic 

signatures. 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

Activity

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, $26.79 and $53.66, respectively (see 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 offering 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 Signature1 $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 notifications 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 2012 to 2014. Because the number of classes offered (and thus the number of 

post-training notifications) depends on the annual number of certifications, and the estimated annual

number of renovator recertifications varies by option, the number of post-training notifications needs to 

be estimated as a function of the number of renovator certifications. The first step is to calculate the ratio 

of the number of renovator certifications to the number of courses. The number of courses is equal to the 

number of original pre-training notifications minus cancelation pre-training notifications. The average 

number of renovator certifications per course from 2012 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 accreditation 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 notifications (35,000 / 7 = 5,000). 

The number of post-training notifications associated with online recertifications is equal to the product of 

the number of training providers offering online recertifications and the number of annual submissions. 

Four hundred training providers are assumed to offer online refresher training courses. Under the 

amended rule they would only be required to submit post-training notifications once a month (i.e., 12 

times a year). Thus, training providers are estimated to submit 4,800 post-training notifications per year 

for online classes regardless of which 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 days23:

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/notification). 

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. The 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 because this requirement is already accounted for in a previous economic 

analyses and Information 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-training 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 that “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 for renovator or dust sampling technician courses, the notification must 

include a digital photograph of the student. 
3-23

number of post-training notifications. For example, Option 4(c), Scenario I, is associated with a reduction 

of 14,789 renovators taking the in-person refresher 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 post-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 refresher 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, Scenario I) relative to the 

number of post-training notifications represented in the baseline. Column 4 equals the reduction in posttraining 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 in burden equal to -1,612 hours (i.e., an increase in burden):

-1,612 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 and 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. Each 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 notifications 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 percent of 

post-training notifications faxed * $0.10 cost per post-training notification faxed.

Column 7 and Column 8 are equal to the annualized cost savings, which account for CDX costs, 

discounted using rates 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 rates 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 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 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 Cycles1 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 Cycles1 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 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 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 Cycles1 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 

amendments 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 

$160,388 (annualized using a rate of 3 percent; see 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 Cycles1 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 Cycles1 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 Cycles1 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 10 year period from 2016 through 2025, and are discounted using 

rates 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 Cycles1 $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 Cycles1 $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 Cycles1 $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 training 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 than 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 form of fees paid to the third-party firms to develop and administer the online courses. 

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 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. 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 or other means.

Many 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 providers 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 reviewing 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 Writing Information Collection Requests, published in 2009 (U.S. EPA 2009).

Exhibit 4-1: EPA Wage Rate

Labor 

Category Date

Base

Wage1

Fringe Benefits and 

Overhead Multiplier2

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-VAWV-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 

2016 through 2025, under the final rule. Costs 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 2016. If most training 

providers begin offering refresher training only online, 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 accreditation 

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 analysis 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 training 

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 Agency 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 2016 to 2025. Estimates 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 Cycles1 $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 Cycles1 $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 Cycles1 $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 governments. In some instances, agencies 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 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, 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 without 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 an 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 volume of business, or other means. Although some 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 registration 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 required 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 completing 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 Paperwork 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 regulatory 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 information.

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 wish 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 students 

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 accredited 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. Therefore, they would incur an 

incremental 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 would 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 burden associated with the changes to the pre-training 

notification and pre-training re-notification requirements 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 required to do this is negligible. The 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. Furthermore, 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. (Less information needs to be provided for an expedited online 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 hour 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 

complete 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 final 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 fringe benefits 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). The 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

Accreditation1,2

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

1Burden hour estimates 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 approved 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

Wage1

Fringe 

Benefits

Benefits

(% of 

Wage)1

Overhead

(% of 

Wage)2

Wage 

Multiplier

Loaded 

Wages3

(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 6,366 hours in 

Year 1 and 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. Training 

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 estimate 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 without 

the hands-on component. Renovators taking the refresher training course online without the hands-on 

component will avoid the time and associated expenses 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 component 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 the 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 the 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 Activity

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 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 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 loaded hourly wage rate of $47.61 for renovators 

(see Exhibit 7-7).

Exhibit 7-7: Loaded Renovator Wage Rates

Labor 

Category

Occupation 

Category (BLS)1 Date

Base 

Wage1

Fringe 

Benefits

Benefits

(% of 

Wage)2

Overhead

(% of 

Wage)3

Wage 

Multiplier

Loaded 

Wages4

(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.com®.

4 Wage rates are rounded to the closest penny.

Exhibit 7-8 presents the incremental cost of renovator burden associated taking the refresher training 

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: Incremental 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 for both RRP training providers and 

renovators. The bottom line annual aggregate burden is estimated 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 

Respondents1

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 described in UMRA, 2 U.S.C. 1531–1538. Therefore, this action is not subject to the 

requirements 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 in 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., 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.

7.3 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 national 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 

the 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 jurisdictions 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 training 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, November 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 potential to influence the regulation. This final rule does not establish an 

environmental standard intended to mitigate health or safety risks. Therefore, this action is not subject to 

the requirements of Executive Order 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 involve 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 activities 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 still 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/current/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) (2005). 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, from http://www.irs.gov/2014-Standard-Mileage-Rates-for-Business,-Medical-andMoving-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 Inc. (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 Analysis 

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-Based 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

Company1,2 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 Harbor3 $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

Company1,2 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

Company1,2 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

Company1,2 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 Tennessee $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 training providers offer price reductions, such as 

coupon codes or specials, discounts for students taking multiple different classes, discounts for multiple students from a firm 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 addition, some training providers include lunch in the price of the tuition they 

charge for a training class. 

2 Some training providers are listed more than once because they offer training in multiple locations and the tuition differs by location. 

3 Initial hands-on training course tuition is derived by taking the tuition for the initial online classroom and hands-on training 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 component 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 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) * PREC5Y * (100% - EPCT)

where, 

InP = The number renovators taking the refresher training 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, renovators 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.

For 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 renovators taking the refresher training course online to become 

recertified is estimated according to the following equation:

E = (S / 5) * PREC5Y * (EPCT)

where, 

E = The number of renovators taking the refresher training course online, 

S = The active stock 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 taking the online training course 

every other training cycle under option 2:

InP = (PREC2nd * EPCT * I) / (100% - PREC2nd),

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,

PREC2nd =The percent of renovators with expiring certifications that become recertified 

for the second time given two 5-year recertifications periods 

((PREC2nd = 70% * 70% = 49%),

EPCT = The 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 renovators choose online refresher training) 

under Option 2, 

InP = (49% * 50% * 30,000) / (100% – 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, Scenario 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 assumed 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 training 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 35,000, more renovators take the online 

training without hands-on training (20,588) than take the in-person training with handson training (14,412) in an average year because renovators drop out of the active stock 

over time. For example, more renovators will 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 * PREC5Y) / 2,

Where, 

E = The number 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 according 

to the following equation:

E = (S * EPCT * PREC5Y) / 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 certifications 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 

training course every other training cycle:

InP = (PREC2nd * EPCT * I) / (100% - PREC2nd),

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,

PREC2nd = The percent of renovators with expiring certifications that become recertified 

for the second time given one 5-year recertification period (PREC5Y = 70%)

and one 2-year recertification period 

(PREC2Y = [100% - (((100% - PREC5Y) / 5) * 2)])

(PREC2nd = PREC5Y * PREC2Y = 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 renovators choose online refresher training) 

under Option 4(a),

InP = (61.6% * 50% * 30,000) / (100% - 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 

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%),

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 certifications 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 each 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 always 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 training 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 renovators 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 stock 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 renovators 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 refresher 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 choose 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 training 

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 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 24,063 27,343

• Option 4(b) Equations (2 year interval and 3 cycles):

InP = (PREC3rd * EPCT * I) / (100% - PREC3rd)

E = ((PREC5Y * EPCT * I) + (PREC5Y * InP) - InP) / (100% - PREC2Y)

PREC3rd = The percent of renovators becoming recertified for the third time 

given one 5-year recertification period and two 2-year recertification 

periods 

(PREC3rd = PREC5Y * PREC2Y * PREC2Y = 54.2%)

• Option 4(c) Equations (3 year interval and 2 cycles):

InP = (PREC2nd * EPCT * I) / (100% - PREC2nd)

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))

PREC2nd = The percent of renovators becoming recertified for the second time 

given one 5-year recertification period and one 3-year recertification 

period 

(PREC2nd = PREC5Y * PREC3Y = 57.4%)

• Option 4(d) Equations (3 year interval and 3 cycles):

InP = (PREC3rd * EPCT * I) / (100% - PREC3rd)
B-7

E = ((PREC5Y * EPCT * I) + (PREC5Y * InP) - InP) / (100% - PREC3Y)

PREC3rd = The percent of renovators becoming recertified for the third time 

given one 5-year recertification period and two 3-year recertification 

periods 

(PREC3rd = PREC5Y * PREC3Y * PREC3Y = 47.1%)
C-1

Detailed Exhibits of Total Renovator Training Costs

Exhibit C-1 presents 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 2016

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 through 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$)

Baseline1 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 presents 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 2016

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 Recertification (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 presents 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 component required every other training cycle), over a ten year period from 2016

through 2025, for in-person and online training. The costs are discounted using rates of 3 and 7 

percent.
C-3

Exhibit C-3: Option 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 2016 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 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 $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 2016 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-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 $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