# Cross-Media Electronic Reporting Rule (CROMERR) Cost Benefit Analysis

Final

November 17, 2004

### ii EXECUTIVE SUMMARY

Backgr ound of the Rule

On August 31, 2001, the proposed Cross-Media Electronic Reporting and Records Rule was published in the Federal Register. As proposed, the rule was intended to provide a uniform legal framework for paperless electronic reporting and record-keeping, including electronic signature/certification, across the Environmental Protection Agency’s (EPA’s) environmental programs. Based on public comment, however, EPA is now finalizing only the electronic reporting (ER) components of the proposed rule and deferring further action on the ER-keeping components until a later time. As currently drafted, the final ER rule will:



### ■ Modify the current Code of Federal Regulations (CFR) requirements to remove any obstacles to electronic reporting



### ■ Provide general, performance-based criteria for acceptable electronic reporting systems



### ■ Specify that acceptable electronic reports must by submitted using EPA’s Central Data Exchange (CDX), or comparable systems certified to satisfy the performance-based criteria



### ■ Establish the process for EPA oversight of electronic reporting under authorized state, tribal, or local government programs, including special streamlined procedures for EPA approval of modifications or revisions to authorized programs to allow for electronic reporting. The final ER rule is intended to make electronic reporting as simple, efficient, and cost-effective as possible for regulated companies, while ensuring that a transition from paper to electronic reporting does not compromise EPA’s compliance and enforcement programs. Consequently, the regulatory strategy is to impose as few specific requirements as possible and to keep those requirements neutral with respect to technology, so the rule will pose no obstacles to adopting new technologies as they emerge. Electronic document submission will be totally voluntary; EPA will not require the submission of electronic documents in lieu of paper documents. EPA will only begin to accept direct submission of an electronic document once EPA has provided public notice that its electronic document receiving system is prepared to receive the document in electronic form. For regulated entities that choose to submit electronic documents directly to EPA, the rule wouldrequire that these documents be submitted to a centralized Agency-wide electronic documentreceiving system, called the CDX, or to alternative systems designated by the Administrator. Regulated entities that wish to submit electronic documents directly to EPA will satisfy the requirements in the rule by successfully submitting their reports to the CDX. The rule also establishes provisions for regulated entities to comply with identity-proofing procedures, as applicable. Methodology In preparing this analysis, EPA developed a computer model that estimates the annual costs to EPA, State/Locals, and facilities under the final Cross-Media Electronic Reporting Rule (CROMERR) and CDX, as well as under an alternative scenario. The model then compares the annual costs under both scenarios to assess the cost impact of CROMERR and CDX.
The two scenarios modeled were:



### ■ A “Baseline” scenario, in which EPA would enable electronic reporting through an approach other than CROMERR and CDX.



### ■ A “To Be” scenario, in which EPA enables electronic reporting under CROMERR and CDX.

### iii Table ES-1 summarizes the scope of activities examined in the model. 

### Table ES-1. Activities Examined in the Model under “Baseline” and “To Be”

“Baseline” “To Be”

EPA Establish program portals and rules enabling automation Establish the CDX and CROMERR

Automate individual information collections according to the time frames in Appendix II for “Baseline” Automate individual collections according to the time frames in Appendix II for “To Be” and issue Federal Register notice for each collection Maintain Help Desk* Process paperwork under electronic signature Review/approve State/Locals Program modification requests* Process electronic and paper submittals from direct reporters*

State/Locals
Upgrade receiving systems and prepare/submit program modification application to EPA program areas Upgrade receiving systems and prepare/submit consolidated modifica tion applicat ion to EPA

Process paperwork under electronic signature agreement Direct Reporters (facilities that report directly to EPA) Register with each program’s gateway, call the program’s Help Desk, and obtain digital signature certificate, as applicable Register with CDX, call the CDX Help Desk, and obtain digital signature certificate, as applicable Process paperwork under electronic signature agreement Perform extensible markup language (XML) or flat file mapping, if applicable* Report to EPA by paper or electronic method* Indirect Reporters (i.e., facilities that report to the States/Locals)
Report to EPA by paper or electronic signature agreement Process paperwork under electronic signature agreement

* Same under “Baseline” and “To Be” 

### In developing the model, EPA identified the primary activities that EPA, State/Locals, and facilities would take under the “Baseline” and “To Be” scenarios as summarized above. For each activity, EPA estimated four basic parameters that govern the total annual costs to them, respectively:



### ■ Unit costs



### ■ Labor hour burden

### iv 

### ■ Time frame of activity



### ■ Number of entities performing the activity EPA entered these parameters into the model’s spreadsheets for all activities taken by EPA, State/Locals, and facilities. The spreadsheets then applied equations to these parameters to estimate the annual costs to these entities, respectively, across all activities in each year of the modeling period. Finally, the model discounted these costs to 2003 levels based on both a 7 percent discount rate and a 3 percent discount rate, as recommended by the Office of Management and Budget (OMB) guidelines. Refer to Table III-1 in Appendix III of this document for a summary of the data and assumptions used in estimating the cost impacts to government and facilities in the model. Conclusion/Findings In this analysis, the "To Be" scenario represents the costs actually incurred to date under the rulemaking and CDX, as well as the expected costs going forward. As shown in Table ES-2, EPA estimates that the total cumulative costs incurred by EPA, State/Locals, and fac ilities under "To Be" from 2003 to 2012 would be higher than their costs incurred under "Baseline" over the same period. The estimated total incremental costs under "To Be" range from $34.4 million to $41.7 million, depending on the discount rate used. Throughout this analysis, in the Tables and discussion, the dollars referred to are 2003 dollars.



### Table ES-2. A Comparison of Total Cumulative Costs under "To Be" Relative to "Baseline" Between 2003 and 2012* (in millions of dollars)

Entity Cumulative Costs** Baseline To Be Difference in Cumulative Costs To Be Relative to Baseline Difference in Cumulative Costs To Be Relative to Baseline Discounted at 7% Rate Difference in Cumulative Costs To Be Relative to Baseline Discounted at 3% Rate EPA $ 703.78 $ 618.02 ($85.76) ($64.44) ($75.41)

State/Locals $ 76.29 $ 149.04 $72.75 $57.19 $65.20

Facilities $7039.34 $7101.31 $61.97 $41.61 $51.93

Total $7819.41 $7868.37 $48.96 $34.36 $41.72

*Cost savings shown in parentheses.
**Not discounted.



### Limitations of the Analysis The following paragraphs describe the model’s primary limitations.



### ■ Annual Implementation Rate. The costs presented in Table ES-2 reflect an annual implementation rate for electronic reporting of 30 percent of facilities during the first year of an information collection’s automation start date. The annual implementation rate is assumed to be 10 percent per annum for the rest of the modeling years. EPA notes that these rates are a simplifying assumption, since they likely will vary depending on many factors. Because of this, EPA has performed sensitivity runs based on different implementation rates. Refer to Section 4.0 for the results of these sensitivity runs.



### ■ “Baseline” Automation Start Dates. EPA believes that, under “Baseline”, EPA would generally be less expedient in promulgating rules that would allow for automation. The model assumes that, in comparison to the automation start dates under “To Be”, information

### v collections under “Baseline” would be delayed by 2 years. EPA notes, however, that its assumption of a 2-year delay is speculative.



### ■ Scaling Factors. The model examines the cost impacts associated with direct reporters in submitting paper and electronic reports to EPA under “Baseline” and “To Be” (i.e., facilities that report directly to EPA). As explained in Appendix VII, EPA reviewed each information collection, extracted the hour burden, and attempted to determine the percent of hours associated only with direct reporters. To do so, EPA developed scaling factors based on state authorization assumptions. The scaling factors were then applied to the hour burden of each collection, as described in Appendix VII.



### ■ EPA notes, however, that these scaling factors are based on the highly simplified assumption that authorized states collect all the information under their programs. This is not necessarily the case (e.g., where states are authorized for only portions of an EPA program, or where EPA shares program administration with states).



### ■ Upgrade Costs. In estimating upgrade costs to State/Locals, EPA examined the state summary table in Appendix V. EPA attempted to identify State/Locals receiving systems that would not satisfy CROMERR standards (e.g., copy of record requirements). Although EPA believes its estimates are reasonable, the Agency notes that they are highly speculative, since State/Locals-specific factors (e.g., enforcement priorities, state resources, etc.) will determine each State/Locals’ need for upgrading its systems.

### vi 

## Table of Contents

List of Exhibits.............................................................................................................vi i List of Tables ...............................................................................................................vi i 1.0 Introduction.........................................................................................................1 1.1 Background ................................................................................................................. 1 1.1.1 Summary of the Rule ...........................................................................................1 1.2 Problem Statement ......................................................................................................2 1.3 Consideration of Alternatives ...........................................................................................3 1.4 Other CROMERR Goals .............................................................................................5 1.5 Document Organization...............................................................................................6 2.0 Methodology and A ssumption s.........................................................................7
2.1 Introduction............................................................................................................... ..7 2.1.1 Summary of “Baseline” and “To Be” Scenarios ...................................................7 2.2 Development/Operation of the Model........................................................................10 2.3 Model Data and Assumptions ....................................................................................15 2.3.1 EPA...................................................................................................................15 2.3.2 State and Local Environmental Programs...........................................................22 2.3.3 Facilities ............................................................................................................26 2.3.4 Electronic Signature Agreement.........................................................................28 3.0 Conclusions and Findings ...............................................................................34
3.1 Total Costs ................................................................................................................ 34 3.2 EPA........................................................................................................................ ...34 3.3 State/Locals............................................................................................................... 34 3.4 Facilities................................................................................................................. ...35 4.0 Sensitivity Analysis ..........................................................................................37 5.0 Qualitative Benefits of CROMERR and CDX...................................................39 5.1 Summary of Other Impacts........................................................................................39 6.0 Limitations of the Anal ysis ..............................................................................41 Appendix I. Information Collections To Be Automated by EPA ...............................................43 Appendix II. Information Collections Under Which Direct Reporting Will Occur .....................51 Appendix III. Summary of the Model Data and Assumptions....................................................56 Appendix IV. Labor Rates Used in the Analysis.......................................................................64 Appendix V. State Survey Data.................................................................................................6 6 Appendix VI. State Contacts .................................................................................................73 Appendix VII. Burden Hours and Costs to Direct Reporters......................................................74 Appendix VIII. Multi-Media Reporting Sca ling Factor .............................................................81 Appendix IX. Number of Direct Reporters...............................................................................82

### vii 

### Appendix X. XML and Flat File Usage.....................................................................................84 Appendix XI. Industry Consultations ........................................................................................86 Appendix XV. Acronyms and Terms ........................................................................................91 Appendix XV. Acronyms and Terms ........................................................................................91

List of Exhibits
Exhibit 2-1. Activities Examined in th e Model under “Baselin e” and “T o Be” .............................10 Exhibit 2-2. Inputs and Outputs of the M odel ............................................................................ 11 Exhibit 2-3. Hour ly Labor Costs ................................................................................................ 12 Exhibit 2-4. Example of Timeframe of Ac tivities for OSWER Under “Baseline”..........................14 Exhibit 2-5. Other Model Operating Pa rameters........................................................................15



### List of Tables
Table ES-1. Activities Examined in the Model under “Baseline” and “To Be” ...........................iii Table ES-2. A Comparison of Total Cumulative Costs under "To Be" Relative to "Baseline" Between 2003 and 2012* (in milli ons of dollars)................................................................iv Table 2-1. Model Inputs: Portal and Rule Development ............................................................16 Table 2-2. Model Inputs: Developing Automated Collections ...................................................16 Table 2-3. Model Inputs: EPA Help Desk Costs........................................................................17 Table 2-4. Model Inputs: Program Modification Applications...................................................17 Table 2-5. Model Inputs: CDX Development and Maintenance Costs (in millions of dollars)...18 Table 2-6. Model Input: CROMERR Development Costs .........................................................18 Table 2-7. Model Input: Developing Automated Collections.....................................................19 Table 2-8. Model Inputs: Help Desk .........................................................................................19 Table 2-9. Implementation of Electronic Signature Agreement Provisions ................................19 Table 2-10. Model Inputs: Program Modification Applications .................................................22 Table 2-11. Authorized State EPAs and State/Locals Jurisdictions............................................22 Table 2-12. Model Inputs: State/Locals Receiving Systems Upgrades and Modification Application under “Baseline” ............................................................................................23 Table 2-13. Model Inputs: State/Locals Receiving Systems Upgrades and Modification Applications under “To Be” ..............................................................................................24 Table 2-14. State/Locals Implementation of Electronic Signature Agreement Provisions for Submissions by Indirect Reporters ....................................................................................25 Table 2-15. Number of Facility and Employee Registrants under “Baseline”* ..........................27 Table 2-16. Number of Facility and Employee Registrants under “To Be”* ..............................27 Table 2-17. Model Input: Registration and Help Desk...............................................................28 Table 2-18. Digital Signature Certification Costs ......................................................................28 Table 2-19. Model Input: Electronic Signature Agreement Costs ..............................................28 Table 2-20. Annual Number of Facility and Employee Registrants that Become Subject to Identity Proofing Requirements, by Firm Size ...................................................................30 Table 2-21. Direct/Indirect Reporters Implementation of Electronic Signature Agreement Provisions with Burden Assumptions ................................................................................31 Table 3-1. Total Cost Impacts un der o Be”* (in millio ns of dollars) .......................................34

### viii 

### A Comparison of Total Cumulative Costs under "To Be" Relative to "Baseline" Between 2003 and 2012* (in millions of dolla rs)

...................................................................................... 34 Table 4-1. A Comparison of Total Cumulative Costs under “To Be” Relative to “Baseline” Between 2003 and 2013* at Different Annual Automation Rates (in millions of dollars)...38 Table I-1. Information Collections To Be Automated*..............................................................43 Table II-1. Information Collections Under Which Direct Reporting Will Occur* ......................52 Table III-1. Summary of the Mode l Data and Assumptions* .....................................................56 Table IV-1. Labor Rates and We ight for EPA Employees .........................................................64 Table IV-2. Labor Rates and Weight for State/Locals Employees .............................................65 Table IV-3. Labor Rates and Weig ht for Facility Employees.....................................................65 Table V-1. State Overview...................................................................................................... ..68 Table V-2. Existing State Receiving Systems ............................................................................68 Table V-3. Planned State Receiving Systems ............................................................................69 Table V-4. Summary of State/Locals System Upgrade Costs Per Receiving System ..................71 Table V-5. Annual Number of State/Locals Receiving System Employee Registratants Under “Baseline”..................................................................................................................... ....71 Table V-6. Annual Number of State/Locals Receiving System Employee Registrants under “To Be”*........................................................................................................................... .......72 Table V-7. Upgrade Costs Per State/Locals Receiving System under Electronic Signature Agreement Provisions .......................................................................................................72 Table VI-1. State Survey Contacts ............................................................................................73 Table VII-1. Scaling Factors ................................................................................................... ..74 Table VII-2. Annual Burden Ho urs to Direct Reporters*...........................................................74 Table VIII-1. Facility Count................................................................................................... ...81 Table IX-1. Scaling Factors.................................................................................................... ...82 Table IX-2. Direct Reporte rs and Registrants* ..........................................................................83 Table X-1. Number of Companies Implementing XML/Flat File under “Baseline” ...................84 Table X-2. Number of Companies Implementing XML/Flat File under “To Be”.......................84

### 1 

### 1.0 Introduction 1.1 Backgr ound 1.1.1 Summary of the Rule
EPA is finalizing a rule, referred to as the Cross-Media Electronic Reporting and Records Rule(CROMERR), to allow electronic reporting to EPA by permitting the use of electronic documentreceiving systems to receive electronic documents in satisfaction of certain document submission requirements in EPA’s regulations. In addition, states, tribes, and local jurisdictions will be able to seek EPA approval to accept electronic documents to satisfy reporting requirements under authorized or delegated environmental programs that they administer. In this analysis, EPA refers to these regulators collectively as State/Locals . This rule includes criteria against which a State/Locals electronic document-receiving system will be evaluated before EPA can approve changes to the authorized program that allows electronic reporting. Electronic document submission will be totally voluntary. EPA will not require the submission of electronic documents in lieu of paper documents. EPA will only begin to accept direct submission of an electronic document once EPA has provided public notice that its electronic document receiving system is prepared to receive the document in electronic form. For regulated entities that choose to submit electronic documents directly to EPA, the rule would require that these documents be submitted to a centralized Agency-wide electronic document receiving system, Central Data Exchange (CDX), or to alternative systems designated by the Administrator. Regulated entities that wish to submit electronic documents directly to EPA will satisfy the requirements in the rule by successfully submitting their reports to the CDX. Many facilities submit documents directly to State/Locals that are approved, authorized, or delegated to administer a federal environmental program on EPA’s behalf or to administer an environmental program in lieu of the federal regulatory program. The rule provides for EPA approval of changes to authorized State/Locals programs to provide for electronic reporting, and EPA approval will be based largely on an assessment of the State/Locals’ electronic documentreceiving system that will be used to implement the electronic reporting provisions. For this purpose, this rule includes performance-based criteria that EPA will use to determine that an electronic document-receiving system is acceptable. To implement electronic reporting under authorized State/Locals programs, EPA is creating an optional streamlined procedure that State/Locals may use to revise their programs to incorporate electronic reporting. The rule also includes special provisions for existing state electronic reporting systems in place at the time of publication of this rule. In addition, regulated entities reporting electronically to EPA or State/Locals must comply with the identity-proofing provisions of the rule, as applicable. An electronic document must bear the valid electronic signature of a signatory if that signatory would be required under the EPA or State/Locals environmental program to sign the paper document for which the electronic document substitutes unless the program makes special provisions to accept a handwritten signature on a separate paper submission, as specified. In the case of an electronic document that must bear electronic signatures of individuals, each signatory must sign either an electronic signature agreement or a subscriber agreement with respect to the electronic signature device used to create their electronic signature on the electronic document. The rule further requires that, for each electronic signature device used to create an electronic signature on the document, the identity of the individual uniquely entitled to use the device and their relation to any entity for which they will sign electronic documents must be determined with legal certainty by EPA or State/Locals, as applicable. In the case of priority reports, this determination must be made before the electronic document is received, by means of:

### 2 

### ■ Identifiers or attributes that are verified by attestation of disinterested individuals to be uniquely true of the individual in whose name the application is submitted, based on information or objects of independent origin, at least one item of which is not subject to change without governmental action or authorization.



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



### ■ Completion and submittal of a subscriber agreement directly to the receiving agency. A subscriber agreement is an electronic signature agreement signed by an individual in ink on paper. The agreement is signed by the individual with respect to an electronic signature device that the individual will use to create their electronic signatures requiring such individual to protect the electronic signature device from compromise; to promptly report to the agency or agencies relying on the electronic signatures created any evidence discovered that the device has been compromised; and to be held as legally bound, obligated, and responsible by the electronic signatures created as by a handwritten signature.



### ■ Designation of a local registration authority (LRA). The LRA is an individual who is authorized by EPA or the state to issue an agreement collection certification. An agreement collection certification is a signed statement by which an LRA certifies that a subscriber agreement has been received from a registrant; the agreement has been stored in a manner that prevents authorized or unauthorized access to these agreements by anyone other that the local registration authority; and that the local registration authority has no basis to believe that any of the collected agreements have been tampered with or prematurely destroyed.

1.2 Problem Statement 

### The primary purpose of CROMERR is to set standards for electronic reporting as it is implemented by State, Tribal or local governments administer environmental programs under EPA authorization or delegation. EPA has been motivated to set such standards primarily by considering:

■ The roles that many electronically submitted documents would likely play in environmental program management, including compliance monitoring and enforcement;



### ■ EPA’s statutory obligation to ensure that authorized or delegated programs maintain the enforceability of environmental law and regulations; and



### ■ The consequent need to ensure that enforceability is not compromised as authorized or delegated program make the transition from paper to electronic submission of compliance- or enforcement-related documents. Concerning this last point, in many respects electronic submission enhances a document’s utility for environmental programs: it significantly reduces the resources and time involved in making the content available to its users, and can greatly facilitate data quality assurance and analysis. Nonetheless, the federal government’s experience with prosecuting computer-related crimes has shown us that electronic submissions may also be open to challenge, primarily with respect to their authenticity – and particularly where they are used to establish the actions and intentions of the submitters. We have to consider such uses in the case of environmental reporting, especially where

### 3 electronic submissions are made to report on an entity’s compliance status and where the submission includes a responsible individual’s certification to the truth of what is reported. For such cases, EPA has identified a programmatic need to be able to authenticate the submission content and the certification – for example, to be able to address issues of fraud or false reporting where they arise – and it is primarily to address this problem of authentication that EPA is setting standards for electronic reporting through CROMERR.
The point of these standards is to assure the authenticity of electronic documents submitted in lieu of paper reports, so that they are able to play the same role as their paper counterparts in providing evidence of what was reported and of what an identified individual certified to with respect to the report. For example, in the case of paper submissions, the evidence surrounding a handwritten signature is normally sufficient to demonstrate that the signature is authentic and rebut any attempt by the signatory to repudiate it – and EPA intends the CROMERR standards ensure that electronic signatures have a corresponding level of non-repudiation. Since these evidentiary issues typically arise in the context of judicial or other legal proceedings, electronic documents need to have the same “legal dependability” as their paper counterparts. The over-arching standard here is that any electronic document used as evidence to prosecute an environmental crime or to enforce against a civil violation must have no less evidentiary value than its paper equivalent. For example, where there is a question of deliberate falsification of compliance data, whether the submission was electronic or paper, it must be possible to establish the signatory’s identity beyond a reasonable doubt. Hence, in general, the goal of the CROMERR standards is to ensure that a system used to receive electronic documents is capable of reliably generating evidence for use in private litigation, in civil enforcement proceedings, and in criminal proceedings in which the standard for conviction is proof beyond a reasonable doubt that the electronic document was actually signed by the individual identified as the signatory and that the data it contains was not submitted in error.

1.3 Consideration of Alternatives EPA considered both a more stringent and a less stringent alternative to the regulatory approach taken in final CROMERR. The more stringent alternative is reflected in the electronic provisions published, August 31, 2001, in the Notice of Proposed Rulemaking for CROMERR. The proposed version of CROMERR is more stringent by virtue of setting much more prescriptive, detailed requirements that acceptable electronic document receiving systems would have to satisfy. For example, proposed §3.2000(d) set very specific requirements for submitter identity management that a system would have to satisfy, including detailed requirements for renewal of registration and revocation of registration under specified circumstances. Again, §3.2000(e) set very detailed requirements for the signature/certification scenario that a system would have to provide for, specifying the exact sequence of steps to be followed in electronically signing a submission, and requiring such features as on-screen, scroll-

### 4 through presentation of the data to be submitted for review of the signatory prior to signing (§3.2000(e)(1)(i)). EPA received significant public comment on this approach, both from States and from regulated companies, and there were at least three closely related themes. The first was that such prescriptive requirements would greatly limit the flexibility of States to implement electronic reporting in cost-effective way. Many of the comments pointed that such requirements would render the investments that States had already made in electronic reporting infrastructure virtually worthless, would prohibit their use of COTS products, and would require, instead, the development of very costly customized systems that might be both difficult and expensive to operate and maintain. The second theme was that many of the requirements – especially those specifying the signature/certification scenario – were simply not appropriate to many cases where electronic reporting would occur. Some commenters cited examples where very large data files would be transferred, rendering on-screen review impractical; others pointed out that company business processes involved in internal review, approval and certification of regulatory submissions was simply not compatible with the specified scenario. Third and finally, many of these commenters expressed skepticism that these very detailed requirements represented the only possible approach to ensuring the legal dependability of electronic submissions and signatures. In considering such comments, EPA has concluded that, given our inexperience with electronic reporting, we simply lack a basis for certainty that any particular set of function-based requirements at the level of specificity reflected in proposed CROMERR is (or is not) necessary for legally dependable electronic submissions. Given the evidently high cost – to both States and regulated entities – that such requirements would impose, we decided it would be better to focus on criteria that directly articulate these basic issues, that is, the underlying goal of assuring legal dependability, including the authenticity of electronic documents and the nonrepudiation of electronic signatures. Accordingly, we are setting standards in terms of general system performance goals that are less stringent by virtue of allowing much greater flexibility in how such goals are met in specific implementations.
In writing these general performance goals, EPA also considered a less stringent alternative that would have refrained from specifying performance in terms of establishing the identity of an individual to whom a signature device or credential (e.g. a PIN, password, or PKI certificate) is issued. With reference to the final CROMERR provisions, this less stringent alternative would have omitted §3.2000(b)(5)(vii) identity-proofing provisions. In terms of regulatory impact, this would be a significant reduction in stringency, insofar as most of CROMERR’s burden on regulated entities is associated with have to register to obtain a signature device or credential, and any identity-proofing requirement raises at least the aggregate burden substantially. EPA rejected this alternative, because we believe that it would seriously – perhaps fatally – undermine the rule’s ability to assure the legal dependab ility of electronic submissions. It is a basic principle of electronic authentication (E-authentication) – whether in the context of validating an individual’s signature, or for other purposes – that our confidence that the individual being authenticated is who we believe him or her to be depends critically on the degree of trust we can place in the

### 5credential the individual presents. Trust is largely a function of the identityproofing process conducted when the individual registered for the credential in the first place – the process must have been sufficiently stringent and credible. If we did not establish with sufficient certainty who this individual was when we issued the credential, then we cannot be certain who is using the credential in a specific instance where it is presented. Where thecredential is used to create an electronic signature, then, inadequate identityproofing would mean that we cannot be certain who the signatory is – that is, no specific individual would be bound with any certainty by the signature – and this would render the signature virtually worthless for any legal purpose. In view of this, EPA felt that, notwithstanding the cost, it was necessary to specify that identity proofing be conducted. Additionally, for electronic documents of particular legal importance to environmental programs – identified as the “priority reports” – we felt that is was necessary to specify, at least to a degree, how the identity proofing had to be performed. We believe we need this additional specification for cases where signatory identity may be a legal issue, so that we are assured that electronic reporting implementations give us clear and predictable methods to establish this identity that conform to the standard practices of electronic commerce.

1.4 Other CROMERR Goals EPA also envisions that the goals of the CROMERR and CDX will:



### ■ Reduce the cost and burden of data transfer and maintenance for all parties to the data exchanges;



### ■ Improve the data and the various business processes associated with its use in ways that may not be reflected directly in cost reduction (e.g., through improvements in data quality), and the speed and convenience with which data may be transferred and used.



### ■ Maintain the level of corporate and individual responsibility and accountability for electronic reports and records that currently exists in the paper environment. The intended effect of this regulation is to permit use of electronic technologies in a manner that is consistent with EPA’s overall mission and that preserves the integrity of the Agency’s compliance and enforcement activities. Concerning the third goal, the Agency continues to believe that it is essential that EPA continue to ensure sufficient personal and corporate responsibility and accountability in the submission of electronic reports and the maintenance of electronic records; otherwise, EPA places at risk the continuing viability of self-monitoring and self-reporting that provides the framework for compliance under most of our environmental programs. In recent years, electronic reporting and record-keeping have had strong mandate in federal policy and law. The Government Paperwork Elimination Act (GPEA) of 1998, Public Law 105- 277, requires that agencies be prepared to allow electronic reporting and record-keeping under their regulatory programs by October 21, 2003. Given the enormous strides in data transfer and management technologies since 1990, particularly in connection with the Internet, replacing paper with electronic data transfer now promises increased productivity across almost all facets of business and government. In short, the purpose of the rule is to permit the use of a technology that was not contemplated when most existing EPA regulations were written, without undermining in any way the integrity of environmental compliance documents or the ability of EPA to carry out its statutory

### 6 environmental and health protection mandate. The rule will permit regulated industry, EPA, and State/Locals to operate with greater flexibility in ways that improve both efficiency and the speed of regulatory processes. At the same time, it ensures that individuals will assign the same level of importance to affixing their electronic signatures (and to the documents to which the signature attests) as they currently do to a handwritten signature.

1.5 Document Organization The remainder of this document is organized as follows:



### ■ Section 2.0 - Methodology and Assumptions



### ■ Section 3.0 - Conclusions and Findings



### ■ Section 4.0 - Sensitivity Analysis



### ■ Section 5.0 - Qualitative Benefits of CROMERR and CDX



### ■ Section 6.0 - Limitations of the Analysis

### 7 

### 2.0 Methodology and Assumptions
2.1 Introduction 2.1.1 Summary of “Baseline” and “To Be” Scenarios
In preparing this analysis, EPA developed a computer model that estimates the annual costs to EPA, State/Locals, and facilities under the final CROMERR and CDX, as well as under an alternative scenario. The model then compares the annual costs under both scenarios to assess the cost impact of CROMERR and CDX. As described earlier, the CROMERR and CDX would have the primary effect of allowing facilities to report electronically to EPA under its information collections, as provided by GPEA. The rule would also require State/Locals to upgrade their receiving systems to meet the CROMERR standards, if needed, and apply for EPA program modification approval. EPA chose a 10-year period for the regulatory impact analysis, because we believe that this is roughly the time frame for EPA and our authorized or delegated State, Tribal and local government programs to achieve full implementation of electronic reporting under CROMERR. Accordingly, looking at the out-years beyond the 10-year time frame would not provide any additional analytic information about CROMERR’s impacts. As a first step in developing the model, EPA surveyed its program offices to identify the specific information collections they intend to automate under GPEA, as well as the anticipated year each collection will be automated (i.e., the automation start date). In total, the programs identified 137 information collections to be automated. These collections are identified in Appendix I, along with their expected automation start date. 1 

### Note that each collection in Appendix I is identified by the title of its corresponding Information Collection Request (ICR). That is, under the 1995 Paperwork Reduction Act (PRA), EPA is required to prepare ICRs for all of its information collections. The ICRs in Appendix I estimate the annual hour burden to EPA and facilities under the collections and were, therefore, used as a basis for developing the model. In addition, during the Summer of 2002, EPA spoke with regulators in 15 states to learn about their progress in automating their collections. EPA found that each of these states has at least one existing or planned receiving system for collecting electronic information from facilities. EPA, therefore, believes that State/Locals are developing electronic receiving systems irrespective of CROMERR. CROMERR would have little cost impact on them, except to require (1) upgrades to their receiving systems, if necessary, to meet the rule’s standards at 40 CFR 3.2000; (2) EPA program modification approval of their receiving systems in accordance with 40 CFR 3.1000 2 

### ; (3) and development/implementation of the identity-proofing provisions. From this, EPA concluded that the model should examine cost impacts to State/Locals only in upgrading their systems, applying to EPA for program modification approval, and carrying out electronic signature agreement provisions. The model should not examine their costs for originally developing the systems or receiving/processing submittals from facilities using these systems. They would have incurred these costs irrespective of EPA’s actions. In regard to fac ilities, the final rule and CDX would affect those facilities that report directly to EPA (also referred to as direct reporters in this document) in that electronic reporting would now be available. The final rule and CDX would not impact facilities in reporting under State/Locals collections (also referred to as indirect reporters ), except to require them to comply with its identity-proofing requirements. Therefore, EPA has concluded that the model should examine

1 Note that EPA removed some of these collections from this analysis (e.g., collections administered completely at the State/Loc als level). 2 It should also be noted that CROMERR does not require State/Locals to provide for electronic reporting. Therefore, any automation taking place at the State/Locals level would be completely voluntary.

### 8 the costs to direct reporters for all activities associated with paper and electronic reporting (e.g., registering with the CDX, complying with identity-proofing provisions, and submitting electronic documents to the CDX under EPA’s information collections). The model should examine cost impacts to indirect reporters only for the identity-proofing provisions. Note that the rule provides considerable flexibility for regulatory agencies to decide on the most appropriate identity-proofing approach for their receiving systems and electronic signature devices. EPA expects that many State/Locals will r equire regulated entities to submit subscriber agreements or designate an LRA. Other State/Locals (e.g., those implementing Public Key Infrastructure) may, at their own initiative, implement other approaches, e.g., approaches that involve the use of identifiers or attributes. In this Cost Benefit Analysis (CBA), EPA makes the simplifying assumption that all regulatory agencies will require submittal of subscriber agreements or use of an LRA. In this regard, the CBA estimates costs to all direct and indirect reporters for carrying out the rule’s provisions for subscriber agreements and LRAs. Based on the above research and assumptions, EPA-developed and estimated cost impacts under two scenarios:



### ■ An “Baseline” scenario, in which EPA would enable electronic reporting through an approach other than CROMERR and CDX 3

.


### ■ A “To Be” scenario, in which EPA enables electronic reporting under CROMERR and CDX.
2.1.1.1 “Baseline” In developing the “Baseline” scenario, EPA envisions that it would have pursued electronic reporting through an alternate approach were it not for CROMERR and CDX. The GPEA of 1998 requires the Agency to allow electronic reporting by 2003. In addition, EPA is firmly committed to reducing burden under its information collections, not only as part of its own internal agenda, but also in response to Congressional mandates (e.g., the 1995 PRA) and stakeholder requests. Therefore, it is reasonable to assume that EPA would have pursued automation even in the absence of CROMERR and the CDX and that a “no-action” alternative (i.e., where EPA takes no action to automate its collections) is not realistic. In the absence of an Agency-wide rule and portal, EPA envisions that it would have enabled automation on a piecemeal basis across, and even within, program areas. Individual programs would be responsible for developing their own portals for receiving electronic information and publishing rules amending their regulations (e.g., to allow for the use of electronic signatures in lieu of handwritten signatures). EPA estimates that nine Agency program areas would have developed portals and rules. 4

3 As mentioned above, the “Baseline” scenario does not involve reporting to the CDX. It is important to note that EPA views the CDX

and CROMERR as the outcomes of the Agency’s longstanding effort to enable uniform electronic reporting across the Agency. Their development has been inextricably intertwined, in that the CDX’s reporting process and technology standards haveinfluenced EPA’s research and analysis performed on behalf of the rule. CROMERR codifies standards for electronic documentsreceiving systems operated by authorized state and local governmental entities. These standards, as a practical (but not legal) matter, have defined the requirements of CDX. In this regard, EPA views the historical development of the CDX and CROMERR as inextricably related and, therefore, does not include the CDX as part of the “Baseline” scenario.

4 In general, EPA expects that the standards established under EPA’s rules under the “Baseline” scenario would be comparable in scope and stringency to CROMERR and the CDX. The CROMERR and CDX reflect EPA’s programmatic goals , the existing capabilities of electronic systems, as well as EPA’s deliberations with its stakeholders. Under “Baseline”, EPA would have encountered these same issues in establishing its portals and rules. Therefore, the model assumes that, under “Baseline”, EPA’s gateways and rulemakings would be comparable in scope and stringency to the CDX and CROMERR. Note, however, that the model differs in its examination of electronic signature agreement costs under “Baseline” and “To Be”. Under “Baseline”, the mo del assumes registrants would follow relatively simple procedures for preparing and keeping records of an agreement. Under “To Be”, the model examines in significantly greater detail all of the activities that EPA, State/Locals, and facilities would take in p reparing, keeping records of, and submitting/processing subscriber agreements and other paperwork.

### 9 In addition, EPA envisions that it would have automated the same collections under “Baseline” and “To Be”. As described earlier, EPA polled the programs to identify the information collections they intend to automate in compliance with GPEA. In total, 137 collections were identified, as listed in Appendix I. Note that, for purposes of this analysis, EPA subsequently reviewed and modified this list by removing certain collections that are outside the scope of this analysis. Based on this review, EPA produced a revised list of information collections, as shown in Appendix II. The appendix also describes EPA’s rationale for eliminating them. In total, the model examines 68 information collections under “Baseline” and “To Be”. The model also assumes the Agency will convert its collections to an electronic format (e.g., preparation of Web forms, schemas, etc.) by the automation start dates in Appendix II for “Baseline”. The model assumes that, after EPA publishes its rules enabling automation under “Baseline”, authorized State/Locals would upgrade their receiving systems to satisfy the rule’s standards, as necessary. They would also prepare and submit modification requests to the EPA programs, as applicable. In addition, direct reporters would register with a program’s receiving system, obtain an electronic signature certificate, if required, and begin to report electronically by Web form, XML, or flat file. The model examines paper and electronic reporting to the CDX throughout the modeling period under the 68 collections. Facilities reporting to State/Locals (i.e., indirect r eporters) would be required to prepare and keep a handwritten electronic signature agreement on site for each employee who reports to the State/Locals receiving system.
2.1.1.2 “To Be” Under “To Be”, CROMERR would provide for uni form receiving system standards for the CDX and other approved EPA systems. The model assumes EPA began development of the CDX and CROMERR in 2000 and publishes the final CROMERR in 2003. The model also assumes the Agency will convert its collections to an electronic format (e.g., preparation of Web forms, schemas, etc.) by the automation start dates in Appendix II for “To Be”. The model assumes that EPA would issue a notice in the Federal Register announcing the availability of electronic reporting for each collection. The model assumes that authorized State/Locals would begin to upgrade their receiving systems to satisfy CROMERR, as necessary, and prepare their program modification requests to EPA, once CROMERR is published. Note that CROMERR gives State/Locals the option of either submitting a consolidated application to EPA or separate applications to each EPA program, as applicable. The model assumes that State/Locals would submit a consolidated application, because it would streamline the application-preparation process. State/Locals also will implement the rule’s electronic signature agreement provision (e.g., receiving, processing, and keeping records of submittals from indirect reporters). In addition, direct reporters would register with the CDX, obtain an electronic signature certificate, if required, and begin to report electronically by Web form, XML, or flat file. Finally, the model assumes that all direct and indirect reporters would comply with the rule’s electronic signature agreement requirements. Refer to Appendix III for a full description of these activities. Exhibit 2-1 summarizes the broad activities examined in the model for “Baseline” and “To Be”.

“Baseline” “To Be”

### 10 “Baseline” “To Be”

EPA
Establish program portals and rules enabling automation Establish the CDX and CROMERR

Automate individual information collections according to the time frames in Appendix II for “Baseline” Automate individual collections according to the time frames in Appendix II for “To Be” and issue Federal Register notice for each collection
Maintain Help Desk*
Process paperwork under electronic signature
Review/approve State/Locals Program modification requests*
Process electronic and paper submittals from direct reporters*



### State/Locals
Upgrade receiving systems and prepare/submit program modification application to EPA program areas Upgrade receiving systems and prepare/submit consolidated modifica tion applicat ion to EPA

Process paperwork under electronic signature agreement
Direct Reporters (facilities that report directly to EPA)
Register with each program’s gateway, call the program’s Help Desk, and obtain digital signature certificate, as applicable Register with CDX, call the CDX Help Desk, and obtain digital signature certificate, as applicable
Process paperwork under electronic signature agreement

Perform XML or flat file mapping, if applicable*
Report to EPA by paper or electronic method*
Indirect Reporters (i.e., facilities that report to the States/Locals)
Report to EPA by paper or electronic signature agreement Process paperwork under electronic signature agreement

*Same under “Baseline” and “To Be” Exhibit 2-1. Activities Examined in the Model under “Baseline” and “To Be”



### 2.2 Development/Operation of the Model In developing the model, EPA identified the primary activities that EPA, State/Locals, and facilities would take under the “Baseline” and “To Be” scenarios as summarized above. For

### 11 each activity, EPA estimated four basic parameters that govern the total annual costs to them, respectively:



### ■ Unit costs



### ■ Labor hour burden



### ■ Time frame of activity



### ■ Number of entities conducting activity EPA entered these parameters into the model’s spreadsheets for all activities taken by EPA, State/Locals, and facilities. The spreadsheets were then used to apply equations to these parameters to estimate the annual costs to these entities, respectively, across all activities in each year of the modeling period. In general, the model used straightforward calculations to estimate the cost impacts to these entities (e.g ., annual number of entities performing an activity multiplied by its unit cost equals the total annual cost for activity). In certain cases, the equations were more complex. In these cases, the equations are presented in Appendix XII to this analysis. Exhibit 2-2 illustrates the basic inputs of the model.

Exhibit 2-2. Inputs and Outputs of the Model 

### Unit Costs . Unit costs include labor, capital, and maintenance costs associated with activities examined in the model. In regard to labor costs, the model drew from two sources of labor costs for the calculations.



### ■ Average hourly labor costs associated with facility reporting under EPA’s information collections. These costs were obtained from the specific ICRs associated with each collection and include overhead and fringe as applicable, as described in the ICRs.



### ■ Average hourly labor costs associated with all other activities in the model. EPA developed standard hourly labor rates for EPA, State/Locals, and facility employees. These costs include overhead and fringe. Refer to Appendix IV for information on how EPA derived these hourly rates.

### 12 Type of Personnel Hourly Labor Rate

EPA $41.68/hr

State/Local $30.42/hr

Facility $39.23/hr

Exhibit 2-3. Hourly Labor Costs 

### The model also examines the capital (i.e., start-up) and maintenance costs associated with each activity. These costs vary by activity and are presented in Section 2.3 as specific to the activity and in the appendices, as applicable.
Labor Hour Burden . For each activity, EPA estimated the labor hour burden and entered it into the model as a basic input assumption.



### ■ In regard to EPA, the model includes labor hours for providing Help Desk support, reviewing State/Locals program modification applications, and implementing electronic signature agreement provisions. EPA used its best judgment in estimating the time associated with these activities. The model also includes labor hours for EPA to receive and process both paper and electronic submittals from direct reporters. These hours were obtained from the 68 information collections in Appendix II. Note that the appendix does not show hours for EPA labor. 5



### ■ State/Locals labor hours are primarily associated with preparation/submittal of program modification applications to EPA and implementing electronic signature agreement provisions. EPA consulted regulators in 15 states in estimating the hour burden for many of these activities. Refer to Appendix V for additional information on EPA’s analysis of these data and Appendix VI for the names of EPA’s contacts. The labor hours for direct reporters are drawn primarily from the 68 information collections in Appendix II, which estimate the total annual hour burden to facilities under the information collections being automated. EPA reviewed each ICR and extracted the hours associated with document preparation and submittal and entered them into the model, as appropriate. Appendix VII describes in more detail how EPA derived these labor hours.



### ■ In addition, EPA used its best judgment to estimate the hour burden for direct and indirect reporters to carry out the electronic signature agreement provisions under the CDX and rule.
Time Frame of Activities. The model examines costs to EPA, State/Locals, and facilities from 2000 to 2012. Note, however, that the model results presented in Section 3.0 of this document address the period 2003 through 2012 only. That is, this document examines those cost impacts incurred in, and subsequent to, 2003. Throughout this analysis, in the Tables and discussion, the dollars referred to are 2003 dollars. The model accounts for the time value of money expended during the period by discounting the annual costs to 2003 levels using both a 7 percent discount rate and a 3 percent discount rate, as recommended by the Office of Management and Budget (OMB) guidelines.

5 The hours for EPA labor are not shown in the appendix due to space constraints. The CROMERR model, as well as the cost estimates in this CBA, include EPA labor hours.

### 13 In comparison with “To Be”, EPA expects that the rollout of automation under “Baseline” would be generally less expedient. The offices would have resolved issues on a piecemeal fashion. Lessons learned in one office might not be shared across initiatives, resulting in reinventing the wheel. In this regard, the model assumes that the automation start dates of information collections under “Baseline” would be delayed by 2 years in comparison with “To Be”. Exhibit 2-4 provides an example of how the model examines EPA, State/Locals, and facility activities over the modeling period under “Baseline”. The exhibit illustrates Office of Solid Waste and Emergency Response’s (OSWER’s) collections as the example .6



### . The model assumes that OSWER portal and rule development would last 3 years, until 2005. It also assumes OSWER would convert its information collections to electronic format over 2 years, from 2003 to 2005. In 2005, OSWER’s information collections would be available for electronic reporting. In addition, State/Locals would begin upgrading and preparing/submitting their program modification requests to EPA upon finalization of OSWER’s rule in 2005. Direct reporters would submit reports to OSWER by paper until its information collections are automated. Direct reporters would then gradually implement electronic reporting, beginning in 2005, based on the model’s annual implementation rate. Indirect reporters would not be affected by the EPA actions, except that they would be required to comply with the rule’s electronic signature agreement provisions once their State/Locals submits the program modification application to EPA, (i.e., in 2007.) The sequence of activities for EPA, State/Locals, and facilities shown in Exhibit 2-4 pertains to OSWER’s regulatory programs under “Baseline”. However, the model follows a comparable sequencing approach in estimating the timeframe for all EPA, State/Locals, and facility activities under all EPA programs under “Baseline” and “To Be”. For example, the model assumes that each information collection under “Baseline” and “To Be” will take 2 years to be automated and that electronic reporting under the collection will commence at the end of the 2-year period and increase incrementally based on the model’s annual implementation rate. It also assumes that State/Locals under “Baseline” and “To Be” will take 2 years to develop their program modification applications. The model assumes that some State/Locals will submit their applications 2 years after promulgation of the electronic reporting rule (e.g., CROMERR). The remaining State/Locals will submit their applications in later years, based on the assumptions laid out in Section 2.3.

6 Note that the same approach was taken for all programs and collections.

### 14 2000 2001 2002 2003 2004 2006 2007 2008 2009 2010 2011 2012 2005

OSW ER develops portals and

rulemakings

OSW ER develops web forms, XML

schemas, etc.

Direct reporters report to OSWER by paper only States/locals upgrade their receiving systems and

apply for program modification approval
Indirect reporters comply with electronic signature agreement

Direct reporters gradually transition from paper to electronic reporting OSW ER Automation Start Date = 2005

Exhibit 2-4. Example of Timeframe of Activities for OSWER Under “Baseline”



### Number of Entities Performing the Activity. In developing the model, EPA estimated the number of entities performing each activity. The numbers of entities per activity vary by activity in the model and are discussed in Section 2.3. Refer to Table 2-10 for the universe of State/Locals jurisdictions, Table 2-12 for facility registrants to EPA’s gateways under “Baseline”, and Table 2-13 for facility registrants to the CDX under “To Be”. Exhibit 2-5 summarizes other key model operating parameters.

Parameter Description

Annual Implementation Rate for Electronic Reporting The annual implementation rate is the rate at which direct reporters would adopt electronic reporting each year under each information collection. The costs reflect a 30-percent first-year implementation rate and a 10-percent rate per annum thereafter. The model applies this rate to derive the total annual costs associated with both paper and electronic submittals, as well as the number of registrants each year. The implementation rate was applied on a collection-by-collection basis, based on the collection’s automation start date under “Baseline” and “To Be”. An information collection’s automation start date determines the percentage of facilities and submittals that will be automated by the end of the modeling period. As an example, information collections with an automation start date of 2003 would be automated in the 2003 to 2005 timeframe under “Baseline” and “To Be”.

### 15 Parameter Description

Electronic Reporting Savings Rate The model assumes that electronic reporters would save time and costs in relation to submittal of paper documents. The model assumes that facilities that report by Web form would save 10 percent of the hours and costs per document preparation and submittal and that facilities that report by XML or flat file would save 25 percent. Web Form Usage Rate The model assumes that 94 percent of direct reporters reporting electronically would use a Web form. The model assumes no hardware or software costs in reporting by Web form. XML or Flat File Usage Rate The model assumes that the remaining 6 percent of electronic reporters would use XML or flat file reporting. Refer to Appendix X for additional information on the XML and flat file usage and cost assumptions. Aggregate Annual Change in Total Hour Burden The model assumes that, each year, the total aggregate hour burden under all 68 information collections decreases by 1 percent per year. This rate is based on EPA’s review of the historical growth trends of the 68 collections.

Exhibit 2-5. Other Model Operating Parameters



### 2.3 Model Data and Assumptions This section describes the activities EPA, State/Locals, and facilities are expected to take under the “Baseline” and “To Be” scenarios. It also describes the unit costs, hour labor burden, and timeframe of activities, as applicable. All costs presented in this chapter are undiscounted. Refer to Table III-1 of Appendix III of this document for a summary of the data and assumptions used in estimating the cost impacts to government and facilities in the model.
2.3.1 EPA

2.3.1.1 “Baseline” Development of Program Portals and Rules . Under the “Baseline” scenario, EPA assumes that nine program areas would each develop a portal for receiving electronic submissions and exchanging information with co-regulators. The programs also would incur annual maintenance costs for these portals following portal development. EPA also assumes each program would establish a rulemaking enabling electronic reporting. All model input assumptions for these activities are shown in Table 2-1.

### 16 

### Table 2-1. Model Inputs: Portal and Rule Development

Portal Development Program Areas

Development Period Total Cost/Portal Annual Portal Maintenance Costs* Total Cost/Rule*

2000-2002 $6,200,000 $ 2,100,000 $ 1,500,000

OAR-OAQPS 2000-2002 $6,200,000 $ 2,100,000 $ 1,500,000

OPPTS-TSCA 1999-2001 $6,200,000 $ 2,100,000 $ 1,500,000

OPPTS-FIFRA 1999-2001 $6,200,000 $ 2,100,000 $ 1,500,000

OSWER-OSW 2003-2005 $6,200,000 $ 2,100,000 $ 1,500,000

OSWER-CEPPO 2003-2005 $6,200,000 $ 2,100,000 $ 1,500,000

OSWER-CERCLA 2003-2005 $6,200,000 $ 2,100,000 $ 1,500,000

OW-NPDES 1998-2000 $6,200,000 $ 2,100,000 $ 1,500,000

OW-SDW 2003-2005 $6,200,000 $ 2,100,000 $ 1,500,000
* Annual maintenance costs are incurred following the portal development period. ** The rulemaking costs for each program are incurred during the portal development period.



### Development of Automated Collections . The model assumes information collections would be automated according to the automation start dates presented in Appendix II for “Baseline”. EPA would incur costs for converting each collection to an electronic format (e.g., developing Web form, and XML schema, etc.). Table 2-2 presents the model’s input assumptions, which were used to cost out EPA’s development of the 68 collections. 

### Table 2-2. Model Inputs: Developing Automated Collections

Number of Information Collections Cost per Collection Development Period

Conversion of Collections to Electronic Format 68 $ 200,000 2 years



### Help Desk. The model assumes that each registrant to a program’s gateway would need to contact the program for assistance. Further, EPA has determined that facilities are subject to 1.3 EPA programs, on average. 7 

### EPA assumes that each program’s portal would be different in regard to registration and use. Therefore, the model assumes that, on average, each employee registrant would make 1.3 calls to EPA’s Help Desk. The model estimates the costs to EPA for handling these calls. Refer to Tables 2-15 and 2-16 for the number of employee registrants expected to contact EPA each year.

7 Refer to Appendix VIII for EPA’s calculation of this estimate.

### 17 Table 2-3 presents the model’s input assumptions, which were used in conjunction with the EPA labor costs in Exhibit 2-3 and number of employee registrants in Tables 2-15 and 2-16, in order to estimate EPA’s costs per year.


### Table 2-3. Model Inputs: EPA Help Desk Costs

Annual Number of Calls Time/Call

Varies* 6 minutes

* Based on the annual number of employee registrants in Table 2-13. 

### Review of State/Locals Program Modification Applications . The model estimates costs to EPA for reviewing State/Locals program modification requests. Based on the discussion in Appendix V, the model estimates that each authorized state environmental protection agency would submit three program modification applications to EPA, on average (i.e., one application for each receiving system). The other authorized State/Locals jurisdictions (e.g., county governments) would submit one application to EPA, on average. Table 2-4 presents the model’s input assumptions, which were used in conjunction with the EPA labor rates in Exhibit 2-3, to estimate the annual costs to EPA. 

### Table 2-4. Model Inputs: Program Modification Applications

Agencies EPA Hours per Application Review Number Applications Submitted per Agency Number of Applications Received and Time frame

42 from stat e EPAs in 2007

3 from state EPAs /yr in 2008 to 2011 State EPAs 80 3

2 from stat e EPAs in 2012

111 from other State/Locals jurisdictions in 2007 All Other State/Locals Jurisdictions* 80 1

27 from other State/Locals jurisdictions/yr in 2008 to 2012
* Includes tribes, county air programs, publicly owned treatment works (POTWs), state health departments, and state oil and gas agencies. 

### Processing of Paper/Electronic Submittals. The model assumes EPA would incur annual costs for processing paper and electronic submittals from direct reporters under all of the collections. Refer to Appendix VII for the model’s equation for deriving EPA’s annual costs .8


### 2.3.1.2 “To Be” Development/Maintenance of the CDX. Table 2-5 presents the total annual estimated CDX development and maintenance costs. This includes, among other things, upgrading the CDX to implement the electronic signature agreement requirements (e.g., upgrading the CDX to control

8 Note that Appendix VII discusses EPA’s approach for estimating costs to direct reporters in submitting information under the collections. However, EPA took an identical approach for estimating costs to EPA in processing the submittals under them. Refer to Figure VII-1 for the equation used in the model to estimate EPA costs in processing paper and electronic submittals under each of the collections.

### 18 registrants' access into their CDX accounts and data flows pending EPA receipt/approval of the agreement or notification of certification). The model assumes EPA would incur development and maintenance costs over the duration of the modeling period. Table 2-5 presents all of the model’s inputs. 

### Table 2-5. Model Inputs: CDX Development and Maintenance Costs (in millions of dollars)

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012
Development $3.8 $4.4 $6.6 $10.9 $10.9 $11.2 $8.9 $6.6 $6.6 $6.6 $6.6 $6.6 $6.6

Maintenance $0.4 $1.5 $1.3 $3.1 $3.1 $3.3 $3.6 $3.9 $3.9 $3.9 $3.9 $3.9 $3.9

Total $4.2 $5.9 $7.9 $13.4 $14.0 $14.5 $12.5 $10.5 $10.5 $10.5 $10.5 $10.5 $10.5



### Development of CROMERR. Table 2-6 presents all model inputs for estimating costs to EPA in developing CROMERR. The table also presents EPA’s costs for preparing for implementation of the electronic signature agreement provisions. The model assumes EPA would need to develop a process and procedures to implement the requirement for the electronic signature agreements, the agreement collection certifications, and related submittals. EPA will need to consider, among other things, appropriate routing, processing, and records management of the submittals when received by EPA; what the staff assignments and responsibilities will be; what policies and criteria will govern the review and approval process for the agreements; LRA applications; and certifications. Finally, the model assumes that EPA would prepare a brief guidance to assist registrants, local authorities, and EPA Help Desk staff in resolving questions or problems associated with the requirement. This could be in the form of a simple fact sheet or a question-and-answer document. EPA will need to purchase file cabinets for storing submittals under the electronic signature provision. 

### Table 2-6. Model Input: CROMERR Development Costs
Development Period Total Development Costs Development of CROMERR 2000-2003 $1,547,502 Planning/Development for Implementation of Electronic Signature Agreement Provisions 2003-2004 $17,334

Purchase of File Cabinets for Storing Electronic Signature Agreement and Certification Submittals 2003-2012 $8,996



### Development of Automated Collections. The model assumes information collections would be automated according to the automation start dates presented in Appendix II for “To Be”. EPA would incur costs for converting their collections to an electronic format (e.g., developing Web form, and XML schema, etc.). EPA would also issue a Federal Register notice announcing the availability of electronic reporting of each collection. Table 2-7 presents the model’s input assumptions.

### 19 

### Table 2-7. Model Input: Developing Automated Collections

Number of Information Collections Cost per Collection Development Period

Conversion of Collections to Electronic Format 68 $200,000 2 years

Development of Federal Register Notice 68 $300,000 1 year



### Help Desk. The model assumes that each registrant to the CDX would need to contact the program for assistance, and that EPA would incur costs for handling these calls. Refer to Tables 2-15 and 2-16 for the number of employee registrants expected to contact EPA each year. Table 2-8 presents the model’s input assumptions, which were used in conjunction with the EPA labor rates in Exhibit 2-3 and the number of employee registrants in Tables 2-15 and 2-16, in order to estimate costs to EPA. 

### Table 2-8. Model Inputs: Help Desk

Annual Number of Calls Time/Call

Varies* 8 minutes

* Based on the annual number of employee registrants in Tables 2-15 and 2-16. 

### Implementation of Electronic Signature Agreement Provisions . The model assumes that EPA will receive and process the subscriber agreements, certifications, and related documents submitted by small and medium-size/large direct reporters under the CDX’s electronic signature agreement provisions. These activities are described in Table 2-9, along with the burden assumptions for each submittal received by the Agency. Refer to Table 2-20 for the number of small and medium-size/large firms that will submit the paperwork each year. 

### Table 2-9. Implementation of Electronic Signature Agreement Provisions
Wet-Ink Signature Agreement Burden Hrs/Submittal O&M costs Annual Number of Submittals

Receive, process, review, approve, and file new subscriber agreements 0.17 $0.00 Varies annually.*

Receive, process, review, approve, and file new electronic agreements (employee turnover) 0.17 $0.00 Varies annually.** Based on an assumption that registrants of small firms will submit new wet-ink agreements due to employee turnover. Receive, process, review, approve, and file wet-ink signature agreement renewals 0.17 $0.00 Varies annually.** Model assumes small firms will renew their wet-ink agreements every 2 years by submitting a new wet-ink agreement. LRA Notification of Registered Users

### 20 Wet-Ink Signature Agreement Burden Hrs/Submittal O&M costs Annual Number of Submittals

Receive application to designate first-time local authority 0.5 $0.00 Varies annually.***

Receive, store, process, and review notification of registered users 0.17 $0.00 Varies annually.***

Receive application to designate local authority (local authority turnover) 0.5 $0.00 Varies annually.  The model assumes EPA will receive applications from some medium-size and large firms to designate a replacement local authority as a result of local authority turnover (e.g., if original local authority leaves the firm or transfer to another position).
Receive, process, review, and approve updated notification of certificate (employee turnover) 0.17 $0.00 Varies annually.** ** The model assumes each local authority will update their certifications as needed due to employee turnover. Updates will be made electronically via the CDX. EPA will need to review and validate these updates and reflect them in the appropriate CDX accounts.

Receive notification of breach of storage security and take appropriate follow-up action 1 $10.00 Varies annually.  A local authority is required to ensure the security of the wet-ink agreements in storage. If security is breached, the local authority will notify EPA. EPA will receive these notifications and take appropriate action. The model assumes 1 percent of medium-size and large firms experience a breach annually. Receive, process, review, and approve updated notification of certificate (breach of security) 0.17 $0.00 Varies annually.** ** In response to a breach, each local authority will collect newly signed wet-ink agreements from employees and will store the signed agreements on-site. Local authorities will t hen s end EPA the information required to update the CDX security profiles (list of employees, data flows for which each is authorized to represent the company, other pertinent information).
Receive, process, review, approve, and 0.5 $0.00 Varies annually.**** Each local authority is expected to renew their

### 21 Wet-Ink Signature Agreement Burden Hrs/Submittal O&M costs Annual Number of Submittals

file application renewals designation every 2 years. EPA will receive, review, and approve/deny the application and notify the local authority. Ongoing Management Identify and resolve problems 1 $10.00 Varies annually based on the total number of direct facility and employee registrants to the CDX. The model assu mes EPA will periodically encounter problems that require resolution. The model includes $10 per long-distance call to a facility to resolve the problem. The model assumes 3 percent of registrants will be involved in a problem that must be resolved annually. Respond to information requests 1.5 $0.00 Varies annually based on the total number of direct facility and employee registrants to the CDX. The model assu mes EPA will respond to FOIA requests, management inquiries, internal requests, and budget updates related to wet-ink-on-paper signature agreements to support the process. The model assume s that EPA will respond to information requests involving 3 percent of registrants’ accounts each year.
* Based on the number of small direct reporter employees registering with the CDX each year. Refer to Table 2-20 for the annual number of small direct reporter employee registrants. ** Based on the number of small direct reporter facility employees that have registered with the CDX. Refer to Table 2-20 for t he annual number of small direct reporter employee registrants. *** Based on the number of medium-size and large direct reporter employees registering with the CDX each year. Refer to Table 2

- 20 for assumptions on the annual number of medium-size and large employee registrants. **** Based on the number of medium-size and large direct reporter employees that have registered with the CDX. Refer to Table 2

- 20 for assumptions on the annual number of medium-size and large employee registrants. 

### Review of State/Locals Program Modification Applications. The model estimates costs to EPA for reviewing program modifications from State/Locals. The model estimates that each authorized state EPA (i.e., state environmental protection agency) would submit one consolidated program modification application to EPA, on average. The other authorized State/Locals jurisdictions would submit one application to EPA, on average. Table 2-10 presents the model’s input assumptions, which were used in conjunction with the EPA labor rates in Exhibit 2-3, to estimate costs to EPA.

### 22 

### Table 2-10. Model Inputs: Program Modification Applications

Agencies EPA Hours per Application Review Number Applications Submitted per Agency Number of Applications Received and Time frame

42 from stat e EPAs in 2005

3 from state EPAs /yr in 2006 to 2009 State EPAs 160 1

2 from stat e EPAs in 2010 111 from other State/Locals jurisdictions in 2005 All Other State/Locals Jurisdictions* 80 1 27 from other State/Locals jurisdictions/yr in 2008 to 2010 22 from other State/Locals jurisdictions in 2011 21 from other State/Locals jurisdictions in 2012
* Includes tribes, county air programs, publicly owned treatment works (POTWs), state health departments, and state oil and gas agencies. 

### 2.3.2 State and Local Environmental Programs
Table 2-11 presents the total universe of authorized state environmental protection agencies and other authorized State/Locals jurisdictions. The model examines these State/Locals’ costs under “Baseline” and “To Be” for:



### ■ Upgrading their receiving systems.



### ■ Applying to EPA for program modification approval. 

### Table 2-11. Authorized State EPAs and State/Locals Jurisdictions

Entity Total Universe

State EPA 56

Tribes 20

County Air Programs 40

POTWs 412

State Health Department 22

State Oil and Gas Agencies 19



### Based on EPA’s best judgment, the model assumes that these agencies would upgrade their systems and apply for program modifications according to the following frequency:



### ■ Seventy-five percent of state EPAs within the first 2 years of promulgation of EPA’s rules, and 5 percent annually thereafter.



### ■ Forty-five percent of tribes within the first 2 years of EPA rule promulgation, and 10 percent annually thereafter.

### 23 

### ■ Ten percent of POTWs within the first 2 years of EPA rule promulgation, and 5 percent annually thereafter.



### ■ Seventy-five percent of all other State/Locals jurisdictions within the first 2 years of EPA rule promulgation, and 5 percent annually thereafter.
2.3.2.1 “Baseline” Table 2-12 presents the model inputs for the number of State/Locals upgrading their receiving systems and developing/submitting their program modification applications under “Baseline”. Based on the discussion in Appendix V, the model assumes each state environmental protection agency would spend 180 hours in preparing/submitting each program application, and that each would submit three applications (i.e., one for each receiving system). The model assumes each of the other State/Locals jurisdictions would spend 180 hours in preparing/submitting one application. The model applies the data in Table 2-12 to these hourly estimates and the hourly State/Locals labor costs in Exhibit 2-3 in order to estimate annual costs to State/Locals in preparing/submitting their applications. In addition, the model estimates upgrade costs to State/Locals based on the data in Table 2-12 and the upgrade assumptions in Appendix V, Table V-4. 

### Table 2-12. Model Inputs: State/Locals Receiving Systems Upgrades and Modification Application under “Baseline”

Universe Timeframe* Number of Agencies Number of Receiving Systems

2006 and 2007 42 126

2007 and 2008 3 9

2008 and 2009 3 9

2009 and 2010 3 9

2010 and 2011 3 9 State EPA

2011 and 2012 2 6

2006 and 2007 111 111

2007 and 2008 27 27

2008 and 2009 27 27

2009 and 2010 27 27

2010 and 2011 27 27 All other agencies

2011 and 2012 27 27
* Time frame pertains to agency’s development of their program modification requests and performance of startup upgrades to the ir receiving systems. It does not apply to their ongoing maintenance of their upgraded systems, because these costs would be incurred annually following the startup upgrade. 

### 2.3.2.2 “To Be” Table 2-13 presents the model inputs for State/Locals upgrades to their receiving system and development/submittal of their program modification applications under “To Be”. Based on the discussion in Appendix V, the model assumes each state environmental protection agency would spend 245 hours in preparing/submitting a consolidated modification application to EPA. In addition, EPA assumes that 10 percent of states adopting CROMERR annually will conduct a

### 24 rulemaking, incurring an additional 120 hours and $20,000 in contractor costs to support rule development. The model assumes each of the other State/Locals jurisdictions would spend 210 hours in preparing/submitting one application. The model applies the data in Table 2-13 to these hourly estimates and the hourly State/Locals labor costs in Exhibit 2-3 in order to estimate annual costs to State/Locals in preparing/submitting their applications. In addition, the model estimates upgrade costs to State/Locals based on the data in Table 2-13, in conjunction with the upgrade assumptions in Appendix V, Tables V-4 and V-7. 

### Table 2-13. Model Inputs: State/Locals Receiving Systems Upgrades and Modification Applications under “To Be”

Universe Timeframe* Number of Agencies** Number of Receiving Systems

2004 and 2005 42 126
2005 and 2006 3 9
2006 and 2007 3 9
2007 and 2008 3 9
2008 and 2009 3 9
2009 and 2010 2 6 State EPA

2010 and 2011 0 0

2004 and 2005 111 111

2005 and 2006 27 27

2006 and 2007 27 27

2007 and 2008 27 27

2008 and 2009 27 27 All other agencies

2009 and 2010 27 27

2010 and 2011 22 22

2011 and 2012 21 21
*Time frame pertains to Agency’s development of their program modification requests and performance of startup upgrades to the ir receiving systems. It does not apply to their ongoing maintenance of their upgraded systems, because these costs would be incurred annually following the startup upgrade. **In both Tables 2-12 and 2-13, the “Number of Agencies” column refers to the number of agencies implementing electronic reporting. The total of agencies in this column is 43 less in Table 2-12 than in Table 2-13, because Table 2-12 reflects the Baseline (or “As Is” model) while 2-13 reflects CROMERR. Under the Baseline model, implementation begins two years later than under CROMERR, so – for the same 2004 - 2012 period – fewer systems (i.e. two years worth) implement under the Baseline than under CROMERR. That is, starting two years earlier, implementation under CROMERR reaches 43 more systems by 2012 than under the Baseline. 

### In addition, the model assumes that State/Locals will receive and process the subscriber agreements, certifications and related documents submitted by indirect reporters under the rule’s electronic signature agreement provisions. These activities are described in Table 2-14,

### 25 along with the burden assumptions for each submittal received by the State/Locals. Refer to Table 2-20 for the number of small and medium-size/large firms that will submit the paperwork each year and a description of their activities. 

### Table 2-14. State/Locals Implementation of Electronic Signature Agreement Provisions for Submissions by Indirect Reporters
Wet-Ink Signature Agreement Burden Hrs/Submittal O&M Costs Annual Number of Submittals

Receive, process, review, approve, and file new subscriber agreements 0.17 $0.00 Varies annually.*

Receive, process, review, approve, and file new electronic agreements (employee turnover) 0.17 $0.00 Varies annually.** Based on an assumption that registrants ofsmall firms will submit new wetink agreements due to employee turnover. Receive, process, review, approve, and file wet-ink signature agreement renewals 0.17 $0.00 Varies annually.** Model assumes small firms will renew their wet-ink agreements every 2years by submitting a new wetink agreement. LRA Notification of Registered Users Receive application to designate first-time local authority 0.50 $0.00 Varies annually.***

Receive, store, process and review notification of registered users 0.17 $0.00 Varies annually.***

Receive application to designate local authority (local authority turnover) 0.50 $0.00 Varies annually. The model assumes State/Locals will receive applications from some medium-size and large firms to designate a replacement local authority as a result of local authority turnover (e.g., if original local authority leaves the firm or transfer to another position). Receive, process, review, and approve updated notification of certificate (employee turnover) 0.17 $0.00 Varies annually.** ** The model assumes each local authority will update their certifications as needed due to employee turnover. Updates will be made electronically via the State/Locals. The State/Locals will need to review and validate these updates and reflect them in the appropriate accounts. Receive notification of breach of storage security and take appropriate follow-up action 1 $10.00 Varies annually.**** A local authority is required to ensure the security of the wet-ink agreements in storage. If security is breached, the local authority will notify the State/Locals. The State/Locals will receive these notifications and take appropriate action. The model assumes 1 percent of medium-size and large firms experience a breach annually. Ongoing Management Identify and resolve problems 1 $10.00 Varies annually based on the

### 26 Wet-Ink Signature Agreement Burden Hrs/Submittal O&M Costs Annual Number of Submittals

total number of direct facility and employee registrants to the CDX. The model assumes the State/Locals will periodically encounter problems that require resolution. The model includes $10 per long-distance call to a facility to resolve the problem. The model assumes 3 percent of registrants will be involved in a problem that must be resolved annually. Respond to information requests 1.5 $0.00 Varies annually based on the total number of direct facility and employee registrants to the State/Locals system. The model assumes the State/Locals will respond to FOIA requests, management inquiries, internal requests, and budget updates related to wet-ink-on-paper signature agreements to support the process. The model assumes that EPA will respond to information requests involving 3 percent of registrants’ accounts each year. * Based on the number of small direct reporter employees registering with the State/Locals systems each year. Refer to Table 2- 20 for the annual number of small direct reporter employee registrants. ** Based on the number of small direct reporter facility employees that have registered with the State/Locals systems. Refer to Table 2-20 for the annual number of small direct reporter employee registrants. *** Based on the number of medium-size and large direct reporter employees registering with the State/Locals systems each year. Refer to Table 2-20 for assumptions on the annual number of medium-size and large employee registrants. **** Based on the number of medium-size and large direct reporter employees that have registered with the State/Locals systems. Refer to Table 2-20 for assumptions on the annual number of medium-size and large employee registrants. 

### 2.3.3 Facilities
As described in Appendix IX, EPA estimated the total number of facilities that will need to register with EPA's receiving systems under “Baseline” and “To Be”. EPA also estimated the number of employees within these facilities that will perform the registration process. EPA generally believes that the majority of facilities (89 percent) will be small (i.e., fewer than 20 employees); the remainder (11 percent) are considered medium-size or large. EPA estimates that small facilities will designate three employees and medium-size and large facilities will designate six, on average. For both “Baseline” and “To Be”, the model applied the annual implementation rate, described in Exhibit 2-5, to the total number of registering employees (shown in Table IX-2 of Appendix IX) in order to estimate the annual number of employee registrants per year. The model took into account the automation start date of each collection under each scenario, as well as the number of direct reporters subject to these collections, in determining the number of registrants in each year. In general, EPA does not expect that registrants will incur any notable costs in registering or reporting electronically, except for the activities listed in Exhibit 2-1. In particular, EPA does not expect registrants to buy a personal computer or Internet access in order to report electronically. EPA assumes that facilities will pursue electronic r eporting only if they already have, or plan to

### 27 purchase, computer capabilities as part of their normal business practices. Therefore, the model does not include costs to them for buying a computer or Internet access. Tables 2-15 and 2-16 present the annual number of facility and employee registrants to EPA under “Baseline” and “To Be” during 2003 through 2012. 

### Table 2-15. Number of Facility and Employee Registrants under “Baseline”*

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012
Facilities 1,467 1,320 14,551 4,863 4,996 3,783 3,405 3,064 2,758 2,484
Employee Registrants 4,885 4,396 48,455 16,194 16,637 12,597 11,339 10,203 9,184 8,265

*Table includes rounding error.


### Table 2-16. Number of Facility and Employee Registrants under “To Be”*

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012
Facilities 14,830 8,302 5,221 3,986 3,588 3,229 2,906 2,615 2,354 2,118
Employee Registrants 49,384 27,646 17,386 13,273 11,948 10,753 9,677 8,708 7,839 7,053

* Table includes rounding error. 

### 2.3.3.1 “Baseline” and “To Be” Registration and Help Desk . The model assumes that, under “Baseline”, each employee registrant in Table 2-15 will register with 1.3 EPA receiving systems, on average. 9 

### The model assumes each employee registrant will need to call the EPA Help Desk each time they register. The model assumes that, under “To Be”, each employee registrant will register with the CDX once. It also assumes each employee registrant will call the Help Desk once. Table 2-17 presents model inputs for registration and Help Desk costs under “Baseline” and “To Be”. They were used in conjunction with the number of employee registrants in Table 2-15 and 2-16, as well as the facility labor costs in Exhibit 2-3, to estimate registration and Help Desk costs to facilities under “Baseline” and “To Be”. EPA performed consultations with the industry representatives in Appendix XI in developing these estimates.

9 This 1.3-estimate is based on EPA’s analysis of facility data in its Envirofacts database, as described in Appendix VIII.

### 28 

### Table 2-17. Model Input: Registration and Help Desk
Activity Annual Number of Emplo yee Registrants Time/Registrant

Registration Varies annually* 3 minutes under “Baseline” and “To Be” Help Desk Varies annually* 6 minutes under “Baseline”8 minutes under To Be * Based on the annual number of employee registrants in Table 2-15 for “Baseline” and 2-16 for “To Be”. 

### Digital Signature Certification and Re-Certification . The model assumes that 20 percent of employee registrants would be required to submit enforcement-sensitive information to EPA. To preserve the integrity of the data submitted, the model assumes that these registrants would need to obtain and install a digital electronic signature certificate on their browser. EPA estimates that a registrant would need 30 minutes to obtain and install the certificate. The registrants would need to renew their registration with EPA every 2 years. Table 2-18 presents model inputs, which were used in conjunction with the facility labor rates in Exhibit 2-3 and the number of employee registrants in Table 2-15 or 2-16, in order to estimate costs for digital signature certifications. 

### Table 2-18. Digital Signature Certification Costs

Number of Registrants Requiring Digital Certificate Time/Certificate

Varies annually* 30 minutes

* Based on 20 percent of the annual number of employee registrants in Table 2-15 or 2-16. 

### 2.3.4 Electronic Signature Agreement

2.3.4.1 “Baseline” Under “Baseline”, fac ilities reporting to State/Locals receiving systems (i.e., indirect reporters) must ensure that their employees sign an electronic signature agreement. The annual number of facility employee registrants to State/Locals receiving systems is presented in Table V-5 of Appendix V. The model assumes that each employee would take 10 minutes to prepare, sign, and keep records of the signature agreement, on average. Refer to Appendix V for additional information on how EPA derived the number of employees registering with State/Locals systems. Table 2-19 presents the hour burden per employee registrant, which the model applied to the annual number of registrants in Table V-5 of Appendix V and the facility labor costs in Exhibit 2- 3, in order to estimate total costs to them. 

### Table 2-19. Model Input: Electronic Signature Agreement Costs

Number of Registrants Time/Registrant

Varies* 10 minutes

* Based on the annual number of employee registrants, as shown in Table V-5 of Appendix V.

### 29 2.3.4.2 “To Be” Under “To Be”, the model assumes that fac ilities that report to both EPA and State/Locals receiving systems must comply with the electronic signature agreement requirement for both EPA and the State/Locals systems. The model also assumes that fac ilities subject to multiple State/Locals receiving systems must comply with the requirement for each system. The model assumes that each indirect reporter reports to, on average, 2.5 State/Locals systems. Table 2-20 presents the annual number of direct and indirect reporting facilities and their employees that are expected to register with EPA or State/Locals receiving systems and become subject to the identity-proofing requirements. However, note that, in regard to compliance with the electronic signature agreement requirements, the model makes a number of additional assumptions to estimate the annual number of employees and facilities that will submit subscriber agreements, LRA certifications, and other paperwork to the CDX and State/Locals systems. The model assumes that small firms (i.e., 20 or fewer employees) would opt to have each of their employee registrants submit the wet-ink agreement directly to EPA or State/Locals. Specifically, the model assumes that a registrant would log onto the agency's receiving system, create an account, and generate a signature (e.g., PIN or password). They would then prepare and submit the subscriber agreement to the receiving agency and keep it on file. The agency would conduct a review of the agreement and, if accepted, open the system’s account so that the registrant can begin use. Employee registrants would renew their agreements every 2 years. The model assumes that small firms have, on average, three employee registrants each. In addition, the model assumes an annual employee turnover rate of 10 percent. The model assumes that medium- to large-sized firms would exercise the local authority option under EPA and State/Locals systems. The model assumes that the local authority would be an official designated by their entity to act in that capacity. To be designated as a local authority, the official must submit to EPA or State/Locals, a notarized affidavit of identity, as well as a written authorization from their entity that they are authorized to issue agreement collection certifications on its behalf. After being designated, the official would compile wet-ink signature agreements from their employee registrants, prepare an agreement collection certification, and store the documents in a secured location. The official would then electronically submit a notification to the receiving agency for review and approval. The agency would conduct a review of the notification and, if accepted, open the acco unts so that the registrants can begin use. In addition, the model assumes an annual employees and local authority turnover rate of 10 percent. The model assumes that medium- and large-sized firms own on average, three facilities, each of which has six employee registrants. Hence, medium- and large-sized firms are assumed to have, on average, 18 employee registrants each. Table 2-20 presents the annual number of direct and indirect facility and employee registrants, by firm size, that become subject to the electronic signature agreement requirements.

### 30 

### Table 2-20. Annual Number of Facility and Employee Registrants that Become Subject to Identity Proofing Requirements, by Firm Size

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

Direct Reporters

Small Facilities 13,199 7,388 4,647 3,548 3,193 2,874 2,586 2,327 2,095 1,885

Small Facility Employee Registrants 39,597 22,164 13,941 10,644 9,579 8,622 7,758 6,981 6,285 5,655

Medium/LargeSize Facilities 1,631 914 574 438 395 355 320 288 259 233

Medium/LargeSize Facility Employee Registrants 9,786 5,484 3,444 2,628 2,370 2,130 1,920 1,728 1,554 1,398

Indirect Reporters

Small Facilities - - 130.888 30,540 27,486 24,738 22,263 20,037 18,034 16,231

Small Facility Employee Registrants - - 392,664 91,620 82,458 74,214 66,789 60,111 54,102 48,693

Medium/LargeSize Facilities - - 16,177 3,775 3,397 3,058 2,752 2,477 2,229 2,006

Medium/LargeSize Facility Employee Registrants - - 97,062 22,650 20,382 18,348 16,512 14,862 13,374 12,036



### XML and Flat File Mapping Costs . The model estimates XML and flat file mapping costs to the registrants shown in Table X-1 or X-2 of Appendix X for “Baseline” or “To Be”, respectively. Refer to the Appendix X for additional model assumptions. Reporting to EPA by Paper and Electronic Methods . The model estimates the total costs to direct reporters in preparing and submitting documents by paper and electronically. Refer to Appendix VII for the model’s equations in calculating these costs. Table 2-21 presents the activities and burden assumptions associated with direct and indirect reporter compliance with the electronic signature agreement requirements. These burden assumptions were multiplied by the facility employee labor rates shown in Exhibit 2-3 and the number of employee registrants in Table 2-20 in order to estimate costs to them. Note that all employee registrants in small firms are expected to submit a subscriber agreement when they register. Medium- and large-size firms are expected to designate a local registration authority that will collect and store subscriber agreements from the firm’s employees, prepare an agreement collection certification, and send a certification of receipt and secure storage to a receiving agency.

### 31 

### Table 2-21. Direct/Indirect Reporters Implementation of Electronic Signature Agreement Provisions with Burden Assumptions

Facilities Hour Burden Capital/O&M Cost Number of Submittals

Prepare, submit, and file wet-ink signature agreements 0.25 $2.50 Varies annually.* Each small firm will submit wet-ink agreements for their employees using certified mail. This includes all new registrants in 2003 through 2012 ($2.50/submittal). It also includes registrants that had registered with EPA or State/Locals system prior to publication of the final rule. The model assumes these registrants would have to submit their wet-ink agreements in 2004.

Prepare, submit, and file new wet-ink signature agreements (employee turnover) 0.25 $2.50 Varies annually.** Small firms must submit a new wet-ink signature agreement when it replaces an existing employee registrant (due to employee turnover).

Renew wet-ink signature agreements 0.25 $2.50 Varies annually.** Employee registrants at small firms must renew their signature agreements every 2 years.
Develop a plan/processto collect and store wetink signature agreements, designate local authority, and submit application material 12 $5.00 Varies annually.* Medium-size and large firms will develop a plan/process to comply with the requirement, identify who their local authority should be, and submit application materials to EPA or State/Locals to designate a local authority. The application must establish the identity of the individual by notarized affidavit and include written statement that the individual is authorized by the regulated entity to issue an agreement certificate on its behalf. This includes all new registrants in 2003 through 2012. It also includes registrants that had r egistered wi th EPA or State/Locals system prior to publication of the final rule. The model assumes these registrants would have to submit their applications in 2004. Model includes $2.50 for notary public and $2.50 for certified mail delivery.
Obtain legal counsel 1 $0.00 Varies annually.* Each medium-size and large firm will obtain legal counsel in establishing a process.

Register local authority with CDX or State/Locals system 0.183 $0.00 Varies annually.* Each local authority will establish an account at the CDX or State/Locals system so that they can

### 32 Facilities Hour Burden Capital/O&M Cost Number of Submittals

transmit submittals electronically. The local authority will also ask questions of the identity-proofing requirement when they call the CDX or State/Locals Help Desk.
Prepare/send wet-ink signature agreement to local authority 0.25 $0.37 Varies annually.* All employee registrants within a medium-size or large firm must prepare and submit wet-ink agreements to the local authority. The model assumes the local authority is at an offsite local (e.g., headquarters office).

Prepare local authority certification and submit notification of certificate 1 $0.00 Varies annually.* Each local authority will store the signed agreements on-site. Local authorities w ill then s end EPA the information required to update the CDX security profiles (list of employees, data flows for which each is authorized to represent the company, other pertinent information). EPA will receive/process the security information and review it for completeness and acceptability.
Prepare/send new agreements to local authority (employee turnover) 0.25 $0.37 Varies annually.** New wet-ink signature agreements will be prepared and sent by new employee registrants who replace an existing employee registrant who is leaving the company (employee turnover). The agreements will be sent to their local authority for record keeping.
Submit updated notification of certificate (employee turnover) 0.08 $0.00 Varies annually.** When the local authority receives the new wet-ink agreement from the replacement employee, they will file the agreement on site and electronically submit an updated notification of certificate to EPA or State/Locals system (employee turnover).

Redesignate local authority and send application material (local authority turnover) 1 $5.00 Varies annually.** Some local authorities will leave the firm (or current position/role) and have to be replaced. Their firm must identify a new local authority and submit a new application to EPA or State/Locals agency to designate him.

Register new local authority 0.183 $0.00 Varies annually.** The replacement local authority must register with the CDX in order to submit updates to the certification electronically.

### 33 Facilities Hour Burden Capital/O&M Cost Number of Submittals

Report breach of storage security 0.5 $0.00 Varies annually.** Some firms will experience a breach of security of their stored agreements. The local authority must report such breach. The model assumes 1 percent of medium-size and large firms will experience a breach annually.
Prepare/send wet-ink signature agreement to local authority (breach of security) 0.25 $0.37 Varies annually.** All employee registrants must prepare and submit a new wet-ink agreement to the local authority.

Prepare and submit notification of certificate (breach of security) 0.08 $0.00 Varies annually.** When the local authority receives the new wet-ink agreements from the employees, they will file the agreement on-site and electronically submit an updated notification of certificate to EPA or State/Locals system (employee turnover).

Renew local authority designation 1 $5.00 Varies annually.** The local authority must renew their designation every 2 years by resubmitting the application to EPA or State/Locals. Model includes $2.50 for notary public and $2.50 for certified mail delivery.

Identify and resolve problems 1 $0.00 Varies annually.** Some small, mediumsize, and large firms will have to work with EPA or State/Locals to resolve problems involving their agreements or certifications. The model assumes 3 percent of registrants will be involved in a problem that must be resolved annually.
*Based on the annual number of direct or indirect reporter employees registering with the CDX and/or State/Locals receiving sys tem each year. **Based on the number of direct and indirect reporter employees that have already registered with the CDX and/or State/Locals receiving systems each year.

### 34 

### 3.0 Conclusions and Findings
3.1 Total Costs In this analysis, the "To Be" scenario represents the costs actually incurred to date under the rulemaking and CDX, as well as the expected costs going forward. As shown in Table 3-1, EPA estimates that the cumulative costs incurred by EPA, State/Locals, and facilities under "To Be" from 2003 to 2012 would be higher than their cumulative costs incurred under "Baseline" over the same period. The estimated total incremental costs under "To Be" range from $34.4 million to $41.7 million, depending on the discount rate used. (Refer to Appendix XII for summary tables of the total annual costs to EPA, State/Locals, and facilities under "Baseline" and "To Be". The costs in Table 3-1 are based on the tables in the appendix. The tables in the appendix are not discounted, however.) 

### Table 3-1. Total Cost Impacts under To Be”* (in millions of dollars) A Comparison of Total Cumulative Costs under "To Be" Relative to "Baseline" Between 2003 and 2012* (in millions of dollars)

Entity **Cumulative Costs Baseline To Be Difference in Cumulative Costs To Be Relative to Baseline Difference in Cumulative Costs To Be Relative to Baseline Discounted at 7% Rate Difference in Cumulative Costs To Be Relative to Baseline Discounted at 3% Rate EPA $ 703.78 $ 618.02 ($85.76) ($64.44) ($75.41)

State/Locals $ 76.29 $ 149.04 $72.75 $57.19 $65.20

Facilities $7039.34 $7101.31 $61.97 $41.61 $51.93

Total $7819.41 $7868.37 $48.96 $34.36 $41.72

*Cost savings shown in parentheses.
**Not discounted.



### 3.2 EPA EPA estimates an overall cost savings to EPA from 2003 to 2012 under "To Be" relative to "Baseline." As shown in Table 3-1, these estimated savings range from $64.4 million to $75.4 million, depending on the discount rate used. Under both "Baseline" and "To Be," EPA must develop receiving systems and rules to allow for automated submittals. However, EPA would develop one gateway and rule under "To Be," instead of nine rules and gateways under "Baseline." In this regard, CROMERR/CDX would be more efficient than the approach under "Baseline," where nine programs would have to enable automation on a more piecemeal basis, which is less efficient.
3.3 State/Locals EPA estimates that State/Locals will incur greater costs between 2003 and 2012 under "To Be" than "Baseline." As shown in Table 3-1, cumulative incremental costs to State/Locals under "To Be" are estimated to range from $57.2 million to $65.2 million, depending on the discount rate used. As an initial point, it is important to understand that the State/Locals’ costs estimated in the model for both "Baseline" and "To Be" are solely those costs that result from EPA's rules.

### 35 Specifically, the model examines State/Locals’ costs for complying with EPA rule requirements for upgrading their electronic receiving systems to meet EPA standards, applying to EPA for approval of their program changes, and administering electronic signature agreement provisions as applicable. The model does not consider the potential savings (e.g., efficiencies) to State/Locals in processing electronic submittals from indirect reporters, as these impacts are considered outside the scope of this analysis. One of the primary reasons for the greater costs under "To Be" is that State/Locals would be required to comply with more robust electronic signature agreement requirements than under "Baseline." Under "Baseline," it is assumed State/Locals would require indirect reporters to prepare and keep electronic signature agreements on site. Because State/Locals would not collect them, there is negligible cost to them under this requirement. Under "To Be," State/Locals need to perform significantly more activities. They must plan for implementation of the signature agreement provisions (e.g., develop systems for processing the paperwork) and carry out implementation activities (e.g., working with entities to designate an LRA, processing/filing agreements and other submittals received, and upgrading their receiving systems as appropriate). In addition, the model assumes that EPA would be more efficient in promulgating CROMERR under "To Be" than it would under "Baseline" in promulgating its program rules enabling automation. This greater efficiency leads to the earlier publication of CROMERR under "To Be" than publication of the program rules under "Baseline." Because of its earlier publication, CROMERR would prompt State/Locals to begin upgrading their systems and applying for EPA program modification approval sooner under "To Be" (i.e., beginning in 2004) than under "Baseline" (i.e., beginning in 2006). Once they finalize their initial system upgrades and submit their applications to EPA, they would begin to incur annual maintenance costs for their systems. In this regard, the model estimates State/Locals' upgrade and application costs under "To Be" for the period 2004 through 2012 (i.e., a 9-year period). The model estimates State/Locals' upgrade and application costs under "Baseline" for the period 2006 through 2012 (i.e., a 7-year period). As such, the cumulative costs to State/Locals under "To Be" involve a greater number of years than the cumulative costs for "Baseline." As a consequence, the cumulative costs under "To Be", including the cumulative discounted costs shown in Table 3-1, are greater.
3.4 Facilities EPA estimates that facilities will incur greater costs between 2003 and 2012 under "To Be" than "Baseline." As shown in Table 3-1, incremental costs to facilities under "To Be" are estimated to range from $41.6 million to $51.9 million, depending on the discount rate used. The model examines cost impacts to both direct and indirect facility reporters. The model examines costs to direct and indirect reporters using different assumptions because they would be affected differently under EPA’s regulatory actions. With regard to direct reporters under “Baseline” and “To Be”, it is assumed the EPA’s rulemaking and other actions would enable them to report electronically to EPA under existing information collections, as an alternative to paper-based reporting. Direct reporters also would be subject to specific other requirements as applicable (e.g., registration with EPA receiving system). Therefore, the model estimates costs to direct reporters under “Baseline” and “To Be” for both (1) the ongoing reporting to EPA electronically and by paper and (2) compliance costs with specified other requirements. In this respect, the model assumes that direct reporters will incur some efficiencies and other benefits under "To Be" relative to “Baseline”. First, the model assumes they would have to register only once with the CDX under "To Be" because the gateway is Agency-wide. Under

### 36 "Baseline", they may need to register with multiple program gateways, because the programs would have separate gateways. Second, the model assumes that, by and large, direct reporters would begin reporting electronically to EPA sooner under “To Be” than “Baseline”. The model assumes that the Agency would be more efficient in establishing CROMERR and the CDX under “To Be” than in establishing program-specific rules and gateways under “Baseline”. Hence the model assumes the Agency would automate a number of its information collections sooner under “To Be”. This would allow direct reporters to begin experiencing the savings/efficiencies of electronic reporting sooner. However, the model assumes that direct reporters would not be required to comply with electronic signature agreement requirements under “Baseline”. By contrast, it assumes that direct reporters must comply with robust electronic signature agreement requirements under "To Be". They must conduct a number of activities under these requirements (e.g., prepare/submit agreement paperwork or implement an LRA approach). Despite the signature agreement costs under “To Be”, the model assumes that direct reporters would experience a net cumulative cost savings under “to Be” in comparison with “Baseline” during the period 2003 through 2012. (Note that Table 3-1 does not break out the respective cost impacts for direct-versus-indirect reporters. Rather, it shows only the combined cost of impacts during the period.) With regard to direct reporters under “Baseline” and “To Be”, it is assumed that EPA’s rulemaking actions would have no effect on indirect reporter costs, except to require State/Locals to impose electronic signature agreement provisions on them. It is assumed that the pace of State/Locals electronic reporting initiatives would not be affected by EPA’s regulatory actions and that indirect reporters would, therefore, implement electronic reporting on a schedule that is independent of EPA’s regulations. Hence, the model examines the costs to indirect reporters for complying with EPA electronic signature requirements. It does not examine their cost savings/efficiencies in reporting electronically tp State/Locals receiving systems on an ongoing basis because these impacts are considered outside the scope of this analysis. In this respect, the model assumes that the electronic signature provisions under "To Be" would be significantly more robust than under "Baseline." Under "Baseline," they would only prepare and keep records of an electronic signature agreement on site. Under "To Be," they must implement significantly more activities (e.g., prepare/submit electronic signature agreements or implement LRA approach, report to State/Locals as specified). The more robust electronic signature agreement provisions under "To Be" result in incremental costs to indirect reporters in comparison with "Baseline". Table 3-1 shows that the combined cumulative costs to direct and indirect reporters under “To Be” are higher than their combined cumulative costs under “Baseline”. Specifically, the cost savings to direct reporters under “To Be” as described above are more than offset by the incremental costs to indirect reporters under the signature agreement requirements of “To Be”.

### 37 

### 4.0 Sensitivity Analysis Based on past data on the CDX, the Agency estimates that 30 percent of facilities would implement electronic reporting during the first year of an information collection’s automation start date. The annual implementation rate is assumed to be 10 percent per annum during the rest of the modeling years. The model applies this rate to derive the total annual costs associated with both paper and electronic submittals, as well as the number of registrants each year. The implementation rate was applied on a collection-by-collection basis, based on the collection’s automation start date under “Baseline” or “To Be”. An information collection’s automation start date determines the percentage of facilities and submittals that will be automated by the end of the modeling period. As an example, information collections with an automation start date of 2003 would see 73 percent automation by the end of 2012. The majority of collections would be automated in the 2003 to 2005 timeframe under “Baseline” and “To Be”. EPA notes, however, that these rates are speculative and subject to wide variation. Therefore, EPA performed sensitivity analyses to assess cost impacts using two different implementation rate scenarios:



### ■ Scenario 1. An annual implementation rate of 25 percent for the first year in which an information collection is automated and 8.5 percent annually thereafter. As a basis of comparison to the annual implementation rate above (i.e., 30/10), an information collection with an automation start date of 2003 would see 66 percent automation by the end of 2012.



### ■ Scenario 2. An annual implementation rate of 45 percent for the first year in which an information collection automates and 15 percent annually thereafter. As a basis of comparison to the annual implementation rate above (i.e., 30/10), an information collection with an automation start date of 2003 would see 87 percent automation by the end of 2012. Table 4-1 compares the overall cumulative costs to EPA, State/Locals, and facilities under “To Be” relative to “Baseline” under the three different implementation rate scenarios. The results suggest that the overall costs to these entities are sensitive to the annual implementation rate. For example, the annual implementation rates under Scenario 2 are 50 percent higher than the rates used in this analysis (i.e., 30/10). However, the costs under Scenario 2 are almost 70 percent higher than that of the modeled scenario.

### 38 

### Table 4-1. A Comparison of Total Cumulative Costs under “To Be” Relative to “Baseline” Between 2003 and 2013* at Different Annual Automation Rates (in millions of dollars)

Entity Difference in Cumulative Costs with Implementation Rates at 25% and 8.5%

(Scenario 1) Difference in Cumulative Costs with Implementation Rates at 30% and 10% Difference in Cumulative Costs with Implementation Rates at 45% and 15%

(Scenario 2)
EPA ($64.55) ($64. 44) ($64.25)

States/Locals $53.36 $57.19 $67.31

Facilities $36.48 $41.61 $55.11

Total $25.30 $34.36 $58.17

* Seven percent discount rate used. Cost savings shown in parentheses.

### 39 

### 5.0 Qualitative Benefits of CROMERR and CDX 5.1 Summary of Other Impacts The preceding analysis in Sections 2.0 and 3.0 of this memorandum examines the cost burden to EPA, State/Locals, and facilities solely with developing and implementing the identity-proofing requirement. The analysis does not consider other impacts, such as the following:



### ■ The identity-proofing requirement will most likely discourage a number of facilities from choosing electronic reporting over paper reporting for certain information collections. Under the requirement, facilities would incur upfront and ongoing compliance costs (e.g., establishing a local authority, preparing the wet-ink-on-paper signature agreements, renewing the wet-ink-on-paper signature agreements). These compliance costs will partially or fully offset the cost savings that some facilities would expect from reporting electronically. This is particularly true for one-time and infrequent collections, as well as voluntary collections (e.g., surveys). As a result, a number of facilities will determine that electronic reporting under such collections is not cost effective or is simply inconvenient and opt for paper reporting. In the end, these facilities will not incur the burden savings/efficiencies associated with electronic reporting; rather, they will incur the higher burden associated with paper reporting.



### ■ CSC has not performed any in-depth quantitative analysis to determine what the cost impacts would be. However, a review of the CROMERR CBA spreadsheets suggest that a 1-percent decrease in facilities' annual automation rate with the CDX would translate into $2 million or more in incremental costs to facilities annually. This suggests that costs under theCDX are highly influenced by minor changes in the automation rate and that the identityproofing requirement could have a significant cost impact beyond the cost estimates presented in Section 3.0 of this document. Impacts to facilities reporting to State/Locals receiving systems would likely be similar.



### ■ Along these same lines, the identity-proofing requirement will likely discourage State/Locals from automating some of their information collections. This is partly because some State/Locals government offices will not want to incur the burden of planning for, and implementing the requirement, as it will require ongoing resources (e.g., receiving, processing, filing wet-ink-on-paper signature agreements). As described earlier in this analysis, some states may also need to conduct rulemakings to implement the requirement. Further, State/Locals will recognize that it would not be cost effective for facilities to report electronically under some collections (e.g., one-time collections, surveys), and therefore, the State/Locals will not automate them in the first place. Implementing electronic reporting under CROMERR and CDX will result in a number of important benefits that cannot readily be quantified. Some of the benefits are described below:



### ■ More accurate data. Replacing paper forms with electronic forms will result in more accurate data. Electronic forms can perform real-time edit checks that will reduce the number of input errors. These checks can range from simple verification of valid date formats to complex validations of proper nomenclature and limits of chemicals emitted into the environment. Other aspects of data accuracy include: Duplication of data entry efforts. As they receive paper submissions, environmental agencies often key or scan in the data. That duplicative effort can result in data errors. These errors can cause confusion because the agency could act on information that is different from what the submitter believes was submitted.

### 40 – Time required for remediation. When data errors are detected by agencies, remedial action must be undertaken. These remedial actions require participation by both the submitter and the receiving agencies, and are extremely time-consuming. – Effect of inaccurate data. If the data that passes through agency systems is inaccurate and made publicly available, it creates additional costs and inefficiencies and could lead to more significant problems, such as enforcement actions. The effect of inaccurate data has reached a point that EPA has initiated a data-correction effort. This initiative uses Help Desk personnel to receive calls, take complaints, and oversee corrective action.



### ■ Data becomes available more quickly. The process of creating, mailing, receiving, entering, verifying, and correcting paper reports consumes both resources and time. This delays the ability of EPA to analyze data and make it available to the public.



### ■ More Enforcement Certainty . The purpose of CROMERR is primarily to ensure that as State, Tribal or local governments implement electronic reporting for the EPA-authorized or delegated programs they administer, the electronic documents that receive are as legally dependable as their paper counterparts, especially for purposes of providing evidence in the context of legal proceedings of who attested by signature to the truth and accuracy of what data. The requirements set by CROMERR are specifically designed to provide for this legal dependability, and they will do so by providing:

– standards for valid electronic signatures and authentic electronic documents – to be admitted as evidence in a judicial proceeding, electronic signatures and documents may need to be shown to satisfy standards of validity and authenticity. Absent clearly identifiable standards, it may be difficult to environmental litigators to make such a showing. CROMERR will provide such standards.

– assurance that electronic documents can be authenticated – to provide evidence of what an individual submitted and/or attested to, there must be clear and straightforward methods of showing that the electronic document an environmental agency received is in fact what the individual submitted. CROMERR requirements for electronic document receiving systems will ensure that these systems receive and maintain electronic documents so as to ensure that such authentication methods are available.

– assurance that electronic signatures resist repudiation by the signatory – in at least some enforcement proceedings, a critical issue is whether a particular individual is responsible for the content of a submitted document, and the issue turns on whether that individual was the signatory of the certification statement. If the individual in question is able to repudiate his or her electronic signature – that is, successfully deny that it was his or hers -- then the enforcement case may collapse. CROMERR requirements for electronic signatures, and for the identity proofing needed to issue a signature device or credential, are designed to ensure that signatories are not able to repudiate signatures that they create, that is, that there is sufficient evidence to show when an individual has created a signature. By providing for these and other facets of an electronic document’s legal dependability, CROMERR provides certainty that EPA and its authorized or delegated programs can continue

### 41 to ensure compliance with environmental laws and statutes by being able to hold individuals responsible for being truthful when they report on their companies’ compliance status. By the same token, CROMERR also provides certainty that when EPA or its authorized or delegated programs discover actionable cases of false or fraudulent reporting that they will have the documentary evidence they need to bring such cases into court. 

### 6.0 Limitations of the Analysis The following paragraphs describe the model’s primary limitations.



### ■ Information Collections under the National Emissions Standards for Hazardous Air Pollutants (NESHAPS). The model examines only one information collection under NESHAPS, (i.e., the NESHAPS collection on radionuclides). EPA intends to use this collection as a model for incorporating additional NESHAPS collections into the CDX over the coming years. At present, however, the inclusion of these additional collections into the CDX is in a state of flux, and therefore, they have not been examined in the model. It is important to note, however, that insofar as additional NESHAPS collections are incorporated into the CDX during the modeling period, the model's results do not reflect their associated costs or benefits.



### ■ Annual Implementation Rate. The costs presented in Sections 2.0 and 3.0 reflect an annual implementation rate for electronic reporting of 30 percent of facilities during the first year of an information collection’s automation start date. The annual implementation rate is assumed to be 10 percent per annum for the rest of the modeling years. EPA notes that these rates are a simplifying assumption, since they likely will vary greater depending on many factors. Because of this, EPA has performed sensitivity runs based on different implementation rates.



### ■ “Baseline” Automation Start Dates. EPA believes that, under “Baseline”, EPA would generally be less expedient in promulgating rules that would allow for automation. The model assumes that, in comparison to the automation start dates under “To Be”, information collections under “Baseline” would be delayed by 2 years. For example, the model assumes that, under “To Be”, the OSWER's Notification Form would be automated in 2003. As such, the model assumes that it would be automated in 2005 under “Baseline”. EPA notes, however, that its assumption of a 2-year delay is speculative. In terms of the regulatory impact analysis, changes in our assumptions about the “Baseline” (or “As Is”) automation start date would affect the outcome as follows, based on Appendix XII Tables XII-5 and XII-8 and assuming that the period of analysis remained 2004 - 2012, . If we moved the assumed start date forward two years, to 2004, then the “Baseline” costs to facilities would decrease by approximately $56 million, while the Baseline costs to states would increase by approximately $16 million, yielding a net “Baseline” cost decrease of approximately $40 million. If we moved the assumed start date back two years, to 2008, then the “Baseline” costs for facilities would increase by approximately $30 million, while the “Baseline” costs to states would decrease by approximately $16 million, yielding a net “Baseline” cost increase of approximately $14 million. In general then, it appears that moving the assumed Baseline automation start date forward lowers the net Baseline costs to the benefit of facilities but not states, while moving the assumed date back raises the net Baseline costs to the detriment of facilities but not states.



### ■ Scaling Factors. The model examines the cost impacts associated with direct reporters in submitting paper and electronic reports to EPA under “Baseline” and “To Be”. As explained

### 42 in Appendix IV, EPA reviewed each information collection, extracted the hour burden, and attempted to determine the percent of hours associated only with direct reporters. To do so, EPA developed "scaling factors" based on state authorization assumptions. The scaling factors were then applied to the hour burden of each collection, as described in Appendix VII. EPA notes, however, that these scaling factors are based on the highly simplified assumption that authorized states collect all the information under their programs. This is not necessarily the case, e.g., where states are authorized for only portions of an EPA program, or where EPA shares program administration with states.



### ■ Upgrade Costs. In estimating upgrade costs to State/Locals, EPA examined the state summary table (Table V-7, State Overview) in Appendix V. EPA attempted to identify State/Locals receiving systems that would not satisfy CROMERR standards (e.g., copy of record requirements). Although EPA believes its estimates are reasonable, it notes that they are highly speculative, since State/Locals-specific factors (e.g., enforcement priorities, state resources, etc.) will determine the State/Locals’ need for upgrading its systems.

### 43 

### Appendix I. Information Collections To Be Automated by EPA
Table I-1. Information Collections To Be Automated*

Office Name ICR Title ICR Number Automation Date
OAR EPA Indoor Environmental Quality, Occupant Questionnaire 1619.03 9/30/99

OARM General Administrative Requirements for Assistance Programs 938.08 9/1/2000

OEI Toxic Chemical Release Reporting, Recordkeeping, Supplier Notification and Petitions 1363.11 9/1/2000

OARM General Administrative Requirements for Assistance Programs 938.08 9/30/2000

OARM General Administrative Requirements for Assistance Programs 938.08 9/30/2000

OARM General Administrative Requirements for Assistance Programs 938.08 9/30/2000

OAR Acid Rain Program under Title IV of the CAA Amendments of 1990 1633.12 10/30/2000

OAR Acid Rain Program under Title IV of the CAA Amendments of 1990 1633.12 10/30/2000

OAR Acid Rain Program under Title IV of the CAA Amendments of 1990 1633.12 10/30/2000

OAR Acid Rain Program under Title IV of the CAA Amendments of 1990 1633.12 10/30/2000

OW Clean Water Needs Survey 318.09 12/31/2000

OPPTS TSCA Section 12(b) Notification of Chemical Exports 795.10 9/30/2001
OPPTS Partial Updating of TSCA Inventory Data Base; Production and Site Reports 1011.05 9/30/2001

OA Amendment to Regulatory Reinvention Pilot Projects (Project XL) ICR; New York State 1755.06 10/30/2001

OGC National Roster of Environmental Dispute Resolution and Consensus Building 1888.01 10/30/2001

OAR Acid Rain Program under Title IV of the CAA Amendments of 1990 1633.12 5/1/2002

OPPTS Voluntary Cover Sheet for TSCA Submissions 1780.02 9/1/2002

### 44 Office Name ICR Title ICR Number Automation Date
OARM General Administrative Requirements for Assistance Programs 938.08 9/30/2002

OARM General Administrative Requirements for Assistance Programs 938.08 9/30/2002

OW Questionnaire for Operations and Maintenance, Biosolids Use, Combined Sewer Over 1287.06 9/30/2002

OW CWA State Revolving Fund Program 1391.06 9/30/2002
OW National Water Quality Inventory Reports (TMDL Final Rule: Clean Water Act Section 1560.06 9/30/2002

OW Drinking Water State Revolving Fund Program (DWSRF) 1803.03 9/30/2002
OAR Acid Rain Program under Title IV of the CAA Amendments of 1990 1633.12 10/30/2002

OAR NESHAPS: Radionuclides 1100.11 12/31/2002

OARM General Administrative Requirements for Assistance Programs 938.08 9/30/2003

OARM General Administrative Requirements for Assistance Programs 938.08 9/30/2003

OARM General Administrative Requirements for Assistance Programs 938.08 9/30/2003

OARM General Administrative Requirements for Assistance Programs 938.08 9/30/2003

OARM General Administrative Requirements for Assistance Programs 938.08 9/30/2003

OARM General Administrative Requirements for Assistance Programs 938.08 9/30/2003

OARM General Administrative Requirements for Assistance Programs 938.08 9/30/2003

OW Water Alliances for Voluntary Efficiency (WAVE) Program 1654.03 9/30/2003

OAR IAQ Practices in Large Buildings Survey 1917.01 9/30/2003
OW National Program to Regulate Nondomestic Discharges to Municipal Sanitary Sewer 2.09 10/31/2003

OAR Importation Requirements for Importation of 10.09 10/31/2003

### 45 Office Name ICR Title ICR Number Automation Date
Nonconforming Vehicles
OAR Motor Vehicle and Non-Road Engine Exclusion Determination 12.11 10/31/2003

OW Modification of Secondary Treatment Requirements for Discharges into Marine Water 138.06 10/31/2003

OAR Investigations into Possible Noncompliance of Motor Vehicle with Federal Emission 222.05 10/31/2003

OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 10/31/2003

OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 10/31/2003

OW Applications for NPDES Discharge Permits and the Sewage Sludge 226.15 10/31/2003

OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 10/31/2003

OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 10/31/2003

OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 10/31/2003

OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 10/31/2003

OW Application for NPDES Discharge Permits and the Sewage Sludge Management Permits 226.15 10/31/2003

OW Application for NPDES Discharge Permits and the Sewage Sludge Management Permits 226.15 10/31/2003

OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 10/31/2003

OW NPDES DMR ICR 229.15 10/31/2003
OSWER Notification of Regulated Waste Activity 261.13 10/31/2003

OSWER RCRA Hazardous Waste Permit Application and Modification, Part A 262.09 10/31/2003

OW Revision to the Existing Variance and Exemptions Rule to Comply with the Safe Dr 270.41 10/31/2003

### 46 Office Name ICR Title ICR Number Automation Date
OAR Emission Defect Information and Voluntary Emission Recall Reports 282.12 10/31/2003

OAR Registration of Fuels and Fuel Additives 309.10 10/31/2003
OAR Registration of Fuels and Fuel Additives 309.10 10/31/2003
OAR Registration of Fuels and Fuel Additives 309.10 10/31/2003
OAR Registration of Fuels and Fuel Additives: Requirements for Manufacturers 309.10 10/31/2003

OAR Registration of Fuels and Fuel Additives 309.10 10/31/2003
OAR Registration of Fuels and Fuel Additives 309.10 10/31/2003
OAR Registration of Fuels and Fuel Additives 309.10 10/31/2003
OW UIC Program 370.18 10/31/2003
OW UIC Program 370.18 10/31/2003
OW UIC Program 370.18 10/31/2003
OW UIC Program 370.18 10/31/2003
OW UIC Program 370.18 10/31/2003
OW UIC Program 370.18 10/31/2003
OW UIC Program 370.18 10/31/2003
OW UIC Program 370.18 10/31/2003
OW UIC Program 370.18 10/31/2003
OW UIC Program 370.18 10/31/2003
OW UIC Program 370.18 10/31/2003
OW UIC Program 370.18 10/31/2003
OW UIC Program 370.18 10/31/2003
OW UIC Program 370.18 10/31/2003
OW UIC Program 370.18 10/31/2003
OW UIC Program 370.18 10/31/2003

### 47 Office Name ICR Title ICR Number Automation Date
OW UIC Program 370.18 10/31/2003
OW UIC Program 370.18 10/31/2003
OW UIC Program 370.18 10/31/2003
OW UIC Program 370.18 10/31/2003
OW UIC Program 370.18 10/31/2003
OW UIC Program 370.18 10/31/2003
OW UIC Program 370.18 10/31/2003
OW UIC Program 370.18 10/31/2003
OW UIC Program 370.18 10/31/2003

OSWER Requirements for Generators, Transporters and Disposers under the RCRA Hazardous 801.14 10/31/2003

OW Construction Grants Program 827.05 10/31/2003

OARM General Administrative Requirements for Assistance Programs 938.08 10/31/2003

OW Water Quality Standards Regulation 988.08 10/31/2003

OARM Oral and Written Purchase Orders 1037.06 10/31/2003

OARM IFBs and RFPs 1038.10 10/31/2003

OARM IFBs and RFPs 1038.10 10/31/2003
OARM Monthly Pr ogress Reports (EPA contra cts office) 1039.09 10/31/2003

OSWER Application for Reimbursement to Local Governments for Emergency Response toHaz 1425.05 10/31/2003

OSWER EPA Worker Protection Standard for Hazardous Waste Operations & Emergency Response 1426.05 10/31/2003

OAR Recordkeeping and Periodic Reporting of the Production, Import, of Ozone-Depletion 1432.21 10/31/2003

OAR Modifications to Standards and Requirements for Reformulated and Conventional Ga 1591.14 10/31/2003

OAR Modifications to Standards and Requirements for Reformulated and Conventional Ga 1591.14 10/31/2003

### 48 Office Name ICR Title ICR Number Automation Date
OAR Servicing of Motor Vehicle Air Conditioners 1617.03 10/31/2003
OAR National Recycling and Emissions Reduction Program 1626.07 10/31/2003
OAR Compression Ignition Non-Road Engine Certification Application 1684.05 10/31/2003

OAR Certification and Averaging, Banking, and Trading for Nonroad Spark Ignition Eng 1695.07 10/31/2003

OAR Fuels and Fuel Additives Registration Regulations: Health Effects Protocols (40C 1696.03 10/31/2003

OSWER Reporting and Recordi ng Requirement s under EPA’s Wastewise Program 1698.04 10/31/2003

OAR Retrofit/Rebuild Requirements for 1993 and Earlier Model Year Urban Buses 1702.03 10/31/2003

OAR Spark Ignition Marine Engine Application for Emission Certification and Participation 1722.03 10/31/2003

OAR Marine Engine Manufacturers Production Line Testing Reporting and Recordkeeping 1725.03 10/31/2003

OAR Marine Engine Manufacturer In-Use Emission Testing Program and Recordkeeping Req 1726.03 10/31/2003

OAR Information Requirements for Locomotives and Locomotive Engines 1800.02 10/31/2003

OW National Health Protection Survey of Beaches 1814.02 10/31/2003
OW Phase II of the NPDES Stormwater Program (Final Rule ICR) 1820.02 10/31/2003

OW Consumer Confidence Reports 1832.02 10/31/2003
OW Notice of Intent for Storm Water discharges Associated with Construction Activity 1842.02 10/31/2003

OW Revisions to UIC Regulations for Class V Injection Wells; Final Rule ICR 1874.02 10/31/2003

OW Unregulated Contaminants Monitoring Regulation 1882.02 10/31/2003
OW Final National Primary Drinking Water Regulations; Interim Enhanced Surface Water 1895.02 10/31/2003

OW Final National Primary Drinking Water Regulations; Stage 1 Disinfectants/Disinfe 1896.03 10/31/2003

### 49 Office Name ICR Title ICR Number Automation Date
OW Public Water System Supervision Program Public Notification Requirements (Final 1898.02 10/31/2003

OARM Synopses of Proposed Contract Actions and Market Research Activity 1910.01 10/31/2003

OW National Primary Drinking Water Regulations for Lead and Copper; Final Rule 1912.01 10/31/2003

OAR Alternate Threshold for Low Annual Reportable Amounts; Toxic Chemical Reporting 1704.05 10/31/2003

OAR Exclusion Determinations for New Non-road Sparkignited Engines at and Below 20 1852.02 11/1/2003

OAR Acid Rain Program under Title IV of the CAA Amendments of 1990 1633.12 12/1/2003

OAR Acid Rain Program under Title IV of the CAA Amendments of 1990 1633.12 12/31/2003

OW Beach Closing Survey Report on the Great Lakes 994.05 10/30/2003
OAR Transition Program for Equipment Manufacturers, 40 CFR Part 89.101 1862.02 10/31/2003

OAR EPA's Natural Gas STAR Program 1763.03 10/31/2003
OAR Motor Vehicle Emission and Fuel Economy Compliance; Light Duty Vehicles; Light Duty Trucks and Motorcycles 783.42 2004

OPPTS TSCA Section 402/404 Training, Certification, Accreditation and Standards for Lead-Based Paint Activities 1715.03 2004

OAR Acid Rain Program under Title IV of the CAA Amendments of 1990 1633.12 12/1/2005

OAR Acid Rain Program under Title IV of the CAA Amendments of 1990 1633.12 12/31/2005

OPPTS Request for Contractor Access to TSCA Confidential Business Information 1250.06 2005

OPPTS Correction of Misreported Chemical Substances on the Toxic Substances Control Act 1741.03 2005

### 50 Office Name ICR Title ICR Number Automation Date
OPPTS Pre-Manufacture Review Reporting and Exemption Requirements for New Chemical 574.11 2005

OPPTS PCBs: Consolidated Reporting and Recordkeeping Requirements 1446.07 2005

OPPTS PCBs: Consolidated Reporting and Recordkeeping Requirements 1446.07 2005

* This table lists all the ICRs to be automated by the CDX as identified by the EPA programs. Note that certain programs listed an ICR more than once if it contained multiple collections that will be automated through the CDX. For example, UIC ICR #370.18 is listed multiple times for each collection in the ICR that will be automated. On the other hand, other EPA programs listed an IC R once regardless of the number of collections it contained.

### 51 

### Appendix II. Information Collections Under Which Direct Reporting Will Occur As described in Section 1, this CBA estimates costs to (1) EPA for developing and implementing electronic reporting under its programs (e.g., building portals, publishing rules, implementing identity proofing); (2) State/Locals for upgrading their receiving systems, applying for EPA program modification approval, and implementing identity proofing; (3) direct reporters for registering with the CDX and complying with identity-proofing requirements, as applicable, and reporting by paper or electronically under information collections to be automated by EPA (direct reporting); and (4) indirect reporters for complying with identity-proofing requirements under information collections automated by State/Locals. The EPA programs identified 137 information collections to be automated by EPA during the modeling period. These information collections are currently contained in 73 ICRs, which estimate the hour and cost burden to respondents and the Agency. In reviewing the 137 information collections, EPA noted two types of information collections that required particular consideration in estimating costs to direct reporters. One type included collections that would not be implemented by EPA under the CROMERR/CDX (the hazardous waste manifest system will be automated independently of CROMERR and the CDX). Any information collection that would not be implemented under CROMERR/CDX was excluded from analysis in this CBA. The other type included collections that are fully administered by State/Locals in lieu of EPA. For purposes of this analysis, EPA assumed that collections under the Clean Air Act (CAA) and the Safe Drinking Water Act (SDWA) are fully administered by the states; and hence, only indirect reporters would have an opportunity to report electronically under them. 1 

### For this reason, the CBA does not estimate any costs to direct reporters under them. The CBA does, however, estimate costs to State/Locals in upgrading their receiving systems, applying for EPA program modification approval, and implementing identity proofing under them, as applicable. The CBA also estimates costs to indirect reporters for complying with identity-proofing requirements under them, as applicable. Based on the above assumptions, the CBA estimates the costs of direct reporting under 68 information collections. These collections are listed in Table II-1, along with their automation start dates under “Baseline” and “To Be”. Table II-1 lists all the ICRs to be automated by the CDX as identified by the EPA programs. Note that certain programs listed an ICR more than once if it contained multiple collections that will be automated through the CDX. For example, UIC ICR #370.18 is listed multiple times for each collection in the ICR that will be automated. On the other hand, other EPA programs listed an ICR once regardless of the number of collections it contained.

1 The only CAA information collection in the model is the radionuclide emissions reports under NESH APS (ICR #1100.11). This collection is administered primarily by EPA, not the states. EPA intends to use this collection as a model for incorporating ad ditional NESHAPS collections into the CDX over the coming years. At present, however, the inclusion of these additional collections into the CDX is in a state of flux, and therefore, they have not been examined in the model.

### 52 

### Table II-1. Information Collections Under Which Direct Reporting Will Occur*

Office Name ICR Title ICR Number Automation Date “Baseline” Automation Date “To Be” OEI Toxic Chemical Release Reporting, Recordkeeping, Supplier Notification and Petitions 1363.11 9/1/2000 9/1/2000

OW Clean Water Needs Survey 318.09 12/31/2000 12/31/2000 OPPTS TSCA Section 12(b) Notification of Chemical Exports 795.1 9/30/2001 9/30/2001

OPPTS Partial Updating of TSCA Inventory Data Base; Production and Site Reports 1011.05 9/30/2001 9/30/2001

OA Amendment to Regulatory Reinvention Pilot Projects (Project XL) ICR; New York State 1755.06 10/30/2001 10/30/2001

OGC National Roster of Environmental Dispute Resolution and Consensus Building 1888.01 10/30/2001 10/30/2001

OPPTS Voluntary Cover Sheet for TSCA Submissions 1780.02 9/1/2002 9/1/2002

OW Questionnaire for Operations and Maintenance, Biosolids Use, Combined Sewer Over 1287.06 9/30/2002 9/30/2002

OW CWA State Revolving Fund Program 1391.06 9/30/2002 9/30/2002

OW National Water Quality Inventory Reports (TMDL Final Rule: Clean Water Act Section 1560.06 9/30/2002 9/30/2002

OW Drinking Water State Revolving Fund Program (DWSRF) 1803.03 9/30/2002 9/30/2002

OAR NESHAPS: Radionucli des 1100.11 12/31/2002 12/31/2002 OW Water Alliances for Voluntary Efficiency (WAVE) Program 1654.03 9/30/2005 9/30/2003

OAR IAQ Practices in Large Buildings Survey 1917.01 9/30/2005 37893

OW National Program to Regulate Nondomestic Discharges to Municipal Sanitary Sewer 2.09 10/31/2005 10/31/2003

OW Modification of Secondary Treatment Requirements for Discharges into Marine Water 138.06 10/31/2005 10/31/2003

OW Applications for NPDES Discharge Permits and the Sewage Sludge 226.15 10/31/2005 10/31/2003

### 53 Office Name ICR Title ICR Number Automation Date “Baseline” Automation Date “To Be” Management Permit OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 10/31/2005 10/31/2003

OW Applications for NPDES Discharge Permits and the Sewage Sludge 226.15 10/31/2005 10/31/2003

OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 10/31/2005 10/31/2003

OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 10/31/2005 10/31/2003

OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 10/31/2005 10/31/2003

OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 10/31/2005 10/31/2003

OW Application for NPDES Discharge Permits and the Sewage Sludge Management Permits 226.15 10/31/2005 10/31/2003

OW Application for NPDES Discharge Permits and the Sewage Sludge Management Permits 226.15 10/31/2005 10/31/2003

OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 10/31/2005 10/31/2003

OW NPDES DMR ICR 229.15 10/31/2005 10/31/2003 OSWER Notification of Regulated Waste Activity 261.13 10/31/2005 10/31/2003

OSWER RCRA Hazardous Waste Permit Application and Modification, Part A 262.09 10/31/2005 10/31/2003

OW UIC Program 370.18 10/31/2005 10/31/2003 OW UIC Program 370.18 10/31/2005 10/31/2003 OW UIC Program 370.18 10/31/2005 10/31/2003 OW UIC Program 370.18 10/31/2005 10/31/2003 OW UIC Program 370.18 10/31/2005 10/31/2003 OW UIC Program 370.18 10/31/2005 10/31/2003 OW UIC Program 370.18 10/31/2005 10/31/2003

### 54 Office Name ICR Title ICR Number Automation Date “Baseline” Automation Date “To Be” OW UIC Program 370.18 10/31/2005 10/31/2003 OW UIC Program 370.18 10/31/2005 10/31/2003 OW UIC Program 370.18 10/31/2005 10/31/2003 OW UIC Program 370.18 10/31/2005 10/31/2003 OW UIC Program 370.18 10/31/2005 10/31/2003 OW UIC Program 370.18 10/31/2005 10/31/2003 OW UIC Program 370.18 10/31/2005 10/31/2003 OW UIC Program 370.18 10/31/2005 10/31/2003 OW UIC Program 370.18 10/31/2005 10/31/2003 OW UIC Program 370.18 10/31/2005 10/31/2003 OW UIC Program 370.18 10/31/2005 10/31/2003 OW UIC Program 370.18 10/31/2005 10/31/2003 OW UIC Program 370.18 10/31/2005 10/31/2003 OW UIC Program 370.18 10/31/2005 10/31/2003 OW UIC Program 370.18 10/31/2005 10/31/2003 OW UIC Program 370.18 10/31/2005 10/31/2003 OW UIC Program 370.18 10/31/2005 10/31/2003 OW UIC Program 370.18 10/31/2005 10/31/2003 OW Construction Grants Program 827.05 10/31/2005 10/31/2003 OW Water Quality Standards Regulation 988.08 10/31/2005 10/31/2003 OSWER Application for Reimbursement to Local Governments for Emergency Response to Hazardous Substance Releases 1425.05 10/31/2005 10/31/2003

OSWER Reporting and Recording Requirements under EPA's Wastewise Program 1698.04 10/31/2005 10/31/2003

OW National Health Protection Survey of Beaches 1814.02 10/31/2005 10/31/2003

OW Phase II of the NPDES Stormwater Program (Final Rule ICR) 1820.02 10/31/2005 10/31/2003

OW Notice of Intent for Storm Water discharges Associated with Construction Activity 1842.02 10/31/2005 10/31/2003

OAR Motor Vehicle Emission and Fuel 783.42 2006 2004

### 55 Office Name ICR Title ICR Number Automation Date “Baseline” Automation Date “To Be” Economy Compliance; Light Duty Vehicles; Light Duty Trucks and Motorcycles OPPTS TSCA Section 402/404 Training, Certification, Accreditation and Standards for Lead-Based Paint Activities 1715.03 2006 2004

OPPTS Request for Contractor Access to TSCA Confidential Business Information 1250.06 2007 2005

OPPTS Correction of Misreported Chemical Substances on the Toxic Substances Control Act 1741.03 2007 2005

OPPTS Pre-Manufacture Review Reporting and Exemption Requirements for New Chemical 574.11 2007 2005

OPPTS PCBs: Consolidated Reporting and Recordkeeping Requirements 1446.07 2007 2005

OPPTS PCBs: Consolidated Reporting and Recordkeeping Requirements 1446.07 2007 2005

* In developing automation start dates for “Baseline”, EPA assumed that an information collection would be delayed by 2 years i n relation to “To Be”. Hence, each information collection under “Baseline” begins 2 years after its automation start date under “ To Be ”.

### 56 

### Appendix III. Summary of the Model Data and Assumptions Table III-1 summarizes the primary model data and assumptions used in estimating costs to EPA, State/Locals, and facilities. Table III-1 summarizes the primary data and assumptions for all activities taken by these entities under “Baseline” and “To Be”. 

### Table III-1. Summary of the Model Data and Assumptions*

Estimate of Parameter Parameters “Baseline” Scenario “To Be” Scenario Scope of the Rule
The model estimates the annual cost impact to EPA, State/Locals, and facilities under two scenarios:

An “Baseline” scenario, in which EPA would enable electronic reporting through an approach other than CROMERR and CDX; and A “To Be” scenario, in which EPA enables electronic reporting under CROMERR and CDX. In both scenarios, the model includes activities and costs most likely to be incurred by these entities in complying with EPA’ s rules and receiving systems. In developing the model, EPA surveyed all of its programs and identified all information collections that they expect to automate over the coming years, as well as the expected date of automation (i.e., "automation start date").** EPA reviewed their feedback and determined that a number of collections were outside the scope of the model’s analysis. Hence they are not included in the model: Information collections being implemented, or planned to be implemented, under a separate, non-CDX receiving system. These include information collections under the Reformulated Gas, RCRA Manifest System, and Acid Rain Programs. Information collections implemented under non- EPA programs, e. g., the Federal Acquisition Regulations (i.e., 48 CFR).

Number of Information Collections Included in the Model 68
Environmental Protection Agency Activities and Burdens
Portal and Rule Development
Under the “Baseline” scenario, EPA estimates that nine program areas would develop a portal and rulemaking for receiving electronic submissions: OAR-OMS, OAR-OAQPS, OPPTS-TSCA,OPPTS-FIFRA, OSWER-OSW, OSWER-CEPPO, OSWER-CERCLA, OW-NPDES, and OWSDW. Under the “To Be” scenario, EPA assumes that CDX and CROMERR would be developed.
Total Number of Portals Developed 9 1 Total Development Cost per Portal $6.2 million $95.6 million
Annual Maintenance Cost per Portal $2.1 million $0.4 million to $3.9 million
Total Number of Rulemakings 9 

### 1
Development of Automated Collections
Under both the “Baseline” and “To Be” scenarios, the model assumes that EPA would incur costs for converting each collection to an electronic format. Under the “To Be” scenario, EPA would also issue a Federal Register notice announcing the availability of electronic reporting of each

### 57 Estimate of Parameter Parameters “Baseline” Scenario “To Be” Scenario

collection. Total Cost for Converting Each Collection to Electronic Format $0.2 million

Total Number of Federal Register Notices Prepared NA 68
Total Development Cost per Federal Register Notice NA $0.03 million
Help Desk
Under the “Baseline” scenario, the model assumes that each employee registrant to a program’s portal would need to contact the program for assistance. Furt her, EPA has determined that EPAregulated facilities are subject to 1.3 EPA programs on average. Therefore, the model assumes that each employee r egistrant would make 1.3 calls to EPA’s Help De sk on average. Under the “To Be” scenario, the model assumes that each employee registrant to the CDX would make one call to EPA’s Help Desk.
Total Number of Calls per Registrant 1.3 1
Time per Call 6 minutes 8 minutes
Implementation
Wet-Ink-on-Paper Signature Agreements
Receive, process, review, approve, and file new wet-ink-on-paper signature agreements 

### 0.17

Receive, process, review, approve, and file new wet-ink-on-paper signature agreements (employee turnover) 0.17

Receive, process, review, approve, and file wet-ink-on-paper signature agreements renewals 0.17

LRA Certification and Notification of Registered Users
Receive application to designate first-time local authority 0.5
Receive, store, process and review notification of registered users 0.17
Receive application to designate local authority (local authority turnover) 0.5

Receive, process, review, and approve updated notification of certificate (employee turnover) 0.17

Receive notification of breach of storage security and take appropriate follow-up action 1

Receive, process, review, and approve updated notification of certificate (breach of security) 0.17

Receive, process, review, approve, and file application renewals 0.5

### 58 Estimate of Parameter Parameters “Baseline” Scenario “To Be” Scenario Ongoing Management
Identify and resolve problems 1
Respond to information requests 1.5
Review of State/Locals Program Modification Applications
The model estimates costs to EPA for reviewing program modification applications from State/Locals. Under the “Baseline” scenario, the model assumes that each authorized state environmental protection agency would submit three program modification applications to EPA on average. Under the “To Be” scenario, the model assumes that each authorized state environmental protection agency would submit one consolidated program modification application to EPA. In additi on, the model assumes that under both the “Baseline” and “To Be” scenarios, “other authorized State/Locals jurisdictions” (e.g., county governments) would each submit one application to EPA on average. 3 1

Total Number of Applications submitted by eac h State EPA 80 160
Total EPA Hours for Review/Approval of a State EPA Application 1
Total Number of Applications submitted by each “Other State/Locals Jurisdiction” 80

Total EPA Hours for Review/Approval of an “Other State/Locals Jurisdiction” Application
Wet-ink-on-paper signature agreements 20
Develop a process for collecting, processing, and storing wet-inkon-paper signature agreements 8

Local Registration Authority (LRA) Certification and Notification of Registered Users
Develop a process for collecting, processing, and storing applications and other submittals 20

Develop Web certification guidance 8
Processing of Paper/Electronic Submittals

The model assumes EPA would incur annual cost s for processing paper and electroni c submittalsfrom direct reporters under all of the collections under “Baseline” and “To Be”. Refer to Figure VII1 of Appendix VII for the equation used in the model to estimate EPA costs in processing paper and electronic submittals under each of the collections. (Although the equation, as written, is directed at facility burden in submitting information, the model uses the same equation to estimate EPA burden in processi ng submittals.)

### 59 Estimate of Parameter Parameters “Baseline” Scenario “To Be” Scenario State and Local Environmental Programs Activities and Burdens
Number of State/Locals Jurisdictions Expected to Have Electronic Receiving Systems During Modeling Period
EPA believes that many State/Locals jurisdictions are implementing or are planning to implement electronic receiving systems. The model assumes that a percentage of State/Locals will upgrade their systems and apply for EPA program modification approval throughout the modeling period. Refer to Section 2.3.2 of this document for the percentage of State/Locals expected to upgrade and apply for modification approval each year. 56

Number of State EPAs Examined During the Modeling Period 20
Number of Tribes Examined During the Modeling Period 40
Number of County Air Programs Examined During the Modeling Period 412***

Number of POTWs Examined During the Modeling Period 22
Number of State Health Departments Examined During the Modeling Period 19

Number of Oil and Gas Agencies Examined During the Modeling Period
Upgrade Costs
Under the “To Be” scenario, EPA be lieves that a percentage of State/Locals would need to upgrade their receiving systems to make them CROMERR-compliant. EPA believes that the standards established under EPA’s rules under the “Baseline” scenario would be comparable in scope and stringency to CROMERR and the CDX and hence would require the same level of upgrades. Following is information on the features expected to be upgraded and the percentage of State/Locals performing the upgrades under “Baseline” and “To Be”. Upfront Start-up: $50,000 - $208,333 Annual Maintenance: $10,000 -$28,333

Copy of Record (COR) Upgrade Costs 58%
Percent of State/Locals Receiving Systems that Would Need COR Upgrade Upfront Start-up: $25,000 Annual Maintenance: $600
Secure Socket Layer (SSL) Upgrade Costs 27%
Percent of State/Locals Receiving Systems that Would Need SSL Upgrade Upfront Start-up: $56,000 Annual Maintenance: NA
Email Notification Upgrade Costs 7%

### 60 Estimate of Parameter Parameters “Baseline” Scenario “To Be” ScenarioPercent of State/Locals Receiving Systems that Would Need Email Notification Upgrade Upfront Start-up: $15,270 Annual Maintenance: NA
Electronic Signature Upgrade Costs 100%
Percent of State/Locals Receiving Systems that Would Need Electronic Signature Upgrade
Program Modification Application 3 1
Total Number of Applications Submitted per State EPA 1
Total Number of Applications Submitted per “Other State/Locals Jurisdiction” 180 225 to 425

Total Hours per State EPA for Application Development/Submittal 180 225
Total Hours per “Other State/Locals Jurisdiction” for Application Development/Submittal
Wet-Ink-On-Paper Signature Agreements 20

Develop a process for collecting, processing, and storing wet-inkon-paper signature agreements 8

Develop Web guidance
Facility Activities and Burdens
Direct Reporters 9 minutes 11 minutes
Time for Registration and Help Desk per Employee Registrant 30 minutes
Time for Digital Signature Certification and Re-Certification per Employee Registrant 20%

Percent of Employee Registrants that will Require Digital Signature Refer to Appendix VII

Costs for reporting to EPA by paper and electronic methods
Indirect Reporters under Electronic Signature Agreement for “Baseline” Scenario 10 minutes See “Electronic Signature Agreement” below
Time per employee registrant to prepare, sign, and keep records of electronic signature agreement

### 61 Estimate of Parameter Parameters “Baseline” Scenario “To Be” Scenario Direct and Indirect Reporters under Electronic Signature Agreement for “To Be”
Implementation
Small facilities/wet-ink-on-paper signature agreements
Prepare, submit, and file wet-ink-on-paper signature agreements 0.25
Prepare, submit, and file new wet-ink-on-paper signature agreements (employee turnover) 0.25

Help Desk/technical support 0.033
Renew wet-ink-on-paper signature agreements 0.25
Medium-Size and Large Facilities/Local Registration Authority
Develop a plan/process to collect and wet-ink-on-paper signature agreements, designate local authority, and submit application material 12

Obtain legal counsel 1
Register local authority with CDX or State/Locals system 0.183
Prepare/send wet-ink-on-paper signature agreements to local authority 0.25

Prepare local authority certification and submit notification of certificate 1

Prepare/send new wet-ink-on-paper signature agreements to local authority (employee turnover) 0.25

Submit updated notification of certificate (employee turnover) 0.08
Re-designate local authority and send application material (local authority turnover) 1

Register new local authority 0.183
Report breach of storage security 0.5
Prepare/send wet-ink-on-paper signature agreements to local authority (breach of security) 0.25

Prepare and submit notification of certificate (breach of security) 0.08
Renew local authority designation 1
Ongoing Management
Identify and resolve problems 1

### 62 Estimate of Parameter Parameters “Baseline” Scenario “To Be” Scenario Other Model Operating Parameters
Annual implementation Rates for Electronic Reporting
The annual implementation rate is the rate at which direct reporters would adopt electronic reporting each year under each information collection. The costs in this chapter reflect a 30- percent first-year implementation rate and a 10-percent rate per annum thereafter. The model applies this rate to derive the total annual costs associated with both paper and electronic submittals, as well as the number of registrants each year. The implementation rate was applied on a collection-by-collection basis, based on the collection’s automation start date under “Baseline” or “To Be”. An information collection’s automation start date determines the percentage of facilities and submittals that will be automated by the end of the modeling period. As an example, information collections with an automation start date of 2003 would see 73 percent automation by the end of 2012. The majority of collections would be automated in the 2003 to 2005 timeframe under “Baseline” and “To Be”. The results presented in Section 3 and the appendices of this CBA are based on the central rates shown below. In Section 4 of this document, EPA conducted sensitivity runs using the low and high rates, referred to as Scenario 1 and Scenario 2, respectively, in Section 4. First Year: 25% Annually thereafter: 8.5%

Low Implementation Rate First Year: 30% Annually thereafter: 10%
Central Implementation Rate First Year: 45% Annually thereafter: 15%
High Implementation Rate N/A
Electronic Reporting Savings Rate
The model assumes that facilities that report electronically would save time and costs per document preparation and submittal in comparison with paper submittals. 10%

Percent of Time Saved Per Document Submittal (Web Form) 25%
Percent of Time Saved Per Document Submittal (XML/Flat File) N/A

### 63 Estimate of Parameter Parameters “Baseline” Scenario “To Be” Scenario Usage Rate of Web Forms and XML/Flat File

The model assumes t hat EPA woul d make both Web forms and XML/flat file available to reporters under all 68 collections. The model assumes that most small and medium-size reporters, as well as some large reporters, will opt for Web forms. The model assumes that a subpopulation of medium-size and large reporters will opt for XML/flat file for all of their electronic reporting. Refer to Appendix X for more information on XML and flat file assumptions. 94%

Annual Percent of Electronic Reporters Using Web Forms 6%
Annual Percent of Electronic Reporters Using XML or Flat File N/A
*This table presents the basic data and assumptions used in the model. Refer to Section 2 for additional discussion on how the data and assumptions were incorporated into the model. **The automation start dates under “To Be” reflect EPA program feedback. In developing automation start dates for “Baseline”, E PA assumed that an information collection would be delayed by 2 years in relation to its start date under “To Be”. ***The model assumes that 10% of POTWs would implement electronic receiving systems in the first 2 years of EPA rule promulgation and 5% annually thereafter. Because the modeling period for State/Locals receiving system implementation spans roughly 7 years, the model does not assume that all 412 POTWs would implement electronic systems during that timeframe.

### 64 

### Appendix IV. Labor Rates Used in the Analysis As described in Section 2, EPA accessed two data sources for the model’s hourly labor costs. For facility reporting costs under specific collections, EPA referred to the average hourly labor costs in the corresponding ICR. For all other labor activities, EPA developed its own costs. In doing so, EPA developed weighted-average labor cost for EPA, State/Locals, and facilities. The weighted average costs reflect an assumed “weight” for each labor category, i.e., the percent of time that the labor category is assumed to be involved in the activities being modeled. EPA developed the weights using its best judgment. EPA multiplied each weight by the corresponding average loaded hourly rate (i.e., loaded with fringe and overhead) and summed these products in order to derive a single loaded hourly rate for each labor category for EPA, State/Locals, and facilities, respectively.



### ■ For EPA employees, EPA referred to the 2002 General Services Pay Schedule to ascertain the annual average salary of legal, managerial, technical, and administrative staff. EPA divided total annual salaries by 2080, the total hours in the work-year, to derive annual hours. EPA then applied a 1.6 loading factor to account for overhead and fringe.



### ■ For State/Locals employees, EPA referred to Table 3, Employer costs per hour worked for employee compensation and costs as a percent of total compensation: State and Local government, by selected characteristics, June 2002, U.S. Department of Labor, Bureau of Labor Statistics, Employer Costs for Employee Compensation-June 2002

.



### ■ For facility employees, EPA referred to Table 5, Employer costs per hour worked for employee compensation and costs as a percent of total compensation: Private industry workers, by major industry group, June 2002, U.S. Department of Labor, Bureau of Labor Statistics, Employer Costs for Employee Compensation–June 2002. Updated hourly wage rates were inflated to 2003 dollars. The Bureau of Labor Statistics (BLS) employment cost index (available at http://www.bls.gov/news.release/eci.t02.htm) was used to inflate the wage rates. The tables below present these loaded rates and corresponding weights. Refer to Exhibit 2-3 for the weighted-average rates used in the model. 

### Table IV-1. Labor Rates and Weight for EPA Employees

Labor Category Wage Weight

Lawyers $65.59 10%

Managers $55.94 20%

Technical Staff $40.40 50%

Administrative Staff $18.65 20%

### 65 

### Table IV-2. Labor Rates and Weight for State/Locals Employees

Labor Category Wage Weight

Lawyers $43.28 10%

Managers $40.58 20%

Technical Staff $27.53 50%

Administrative Staff $21.07 20%


### Table IV-3. Labor Rates and Weight for Facility Employees

Labor Category Wage Weight

Lawyers $69.34 10%

Managers $51.47 20%

Technical Staff $34.69 50%

Administrative Staff $23.25 20%

Contractors $93.51

### 66 

### Appendix V. State Survey Data During the Summer of 2002, EPA consulted with regulators in 15 states to learn about their automation activities and receiving systems. EPA believes the states contacted are sufficiently representative of all states in the U.S. to enable an extrapolation of the summary data to all State/Locals. Tables V-1 through V-3 present the raw data used in estimating cost impacts to State/Locals and facilities under the “Baseline” and “To Be” scenarios.
EPA reviewed the data in the tables to:



### ■ Estimate the average number of receiving systems per state environmental protection agency and other State/Locals jurisdictions. EPA’s review of the state data suggests that the state environmental protection agencies are implementing, or plan to implement, three receiving systems on average. Therefore, the model assumes that each state environmental protection agency would implement three receiving systems, on average, during the duration of the modeling period. Based on the table, the model also assumes that other State/Locals jurisdictions (e.g., county agencies, etc.) would implement one receiving system, on average.



### ■ Estimate the percentage of receiving systems that would need to upgrade to meet CROMERR’s standards at 40 CFR 3.2000. EPA’s review of the state survey data, in relation to the 3.2000 standards, suggests the following upgrades would be needed: – Copy of Record with Context (40 CFR 3.2000(b)). EPA identified eight or nine of the 15 state receiving systems that potentially would not satisfy the 3.2000(b) standard for copy of record with context. Therefore, the model extrapolates to the universe State/Locals to assume that 58 percent of their receiving systems would need to be upgraded for copy of record with context. – EPA used its best judgment to estimate the costs associated with each of the upgrade options below. EPA was unable to collect sufficient information to enable it to precisely predict the level of upgrades needed for the state environmental protection agencies’ receiving systems. Therefore, the model derived the average startup and maintenance cost across all three options (i.e., $208,000 in startup and $28,333 in annual maintenance costs), and assumed the state environmental protection agencies would incur these average costs for each receiving system. Copy of Record Upgrade Costs
Upgrade Options Initial/Startup Cost Annual Maintenance Cost Print out and file hardcopy of each submittal and keep transaction log $50,000 $10,000

Use Web upload approach that captures transaction history and copy of record $20,000 $25,000

Reconfigure backend of receiving system to enable electronic archiving of records $375,000 $50,000



### – The model assumes that the other State/Locals jurisdictions would generally be collecting less enforcement-sensitive information from facilities and face greater resource limitations than the state environmental protection agencies. Therefore, the model assumes that, on average, these other State/Locals jurisdictions would opt for the least-cost option of maintaining a paper-based copy of record system (i.e., $50,000 in start up and $10,000 ongoing maintenance).

### 67 – Secure Sockets Layer. EPA expects that all State/Locals receiving system would need to have SSL to provide for data encryption, server authentication, and message integrity among other things. The state survey table suggests that four states’ receiving systems do not have SSL technology. Therefore, the model assumes that 27 percent of State/Locals receiving systems would need to be upgraded for SSL. EPA used its best judgment to estimate one-time SSL costs of $25,000 for network administration and $600/yr for maintaining the vendor certificate. – E-mail Notification. EPA expects that all State/Locals receiving systems would need to have a process to confirm receipt of the facilities’ electronic submittals. The model assumes notification would be accomplished by sending an e-mail confirmation to the facility’s e-mail inbox. EPA’s review of the state summary table suggests that one state has a receiving system that would need to be upgraded for e-mail notification. Therefore, the model assumes that 7 percent of State/Locals systems would need to be upgraded for e-mail notification. EPA used its best judgment to estimate one-time upgrade costs of $56,000 per system. This includes $12,000 to $20,000 for an e-mail server and $40,000 to bring the e-mail server online. – Electronic Signature (40 CFR 3.2000(a) (2)). EPA’s review of the state summary table suggests that 50 percent of receiving systems do not have electronic signature features in satisfaction of CROMERR. However, EPA does not expect that all receiving systems would need to be upgraded. Rather, only those systems that receive information of a sufficiently enforcement-sensitive nature would need to meet the signature standards. EPA used its best judgment to assume that 20 percent of these receiving systems would receive sensitive information and need to upgrade (i.e., 50% x 20% = 10% of receiving systems). The model assumes these state systems would need to implement a process for maintaining a database of registrants’ signature information. The model assumes this would require about 0.25 of a full-time equivalent, at about $15,270/system/year. Refer to Table V-4 for EPA’s upgrade cost estimates and the percentage of State/Locals performing the upgrades annually. – Estimate the average hour burden to State/Locals in applying to EPA for program modification approval. EPA’s review of the state summary table suggests that, on average, a State/Local would take about 180 hours/program to apply to EPA for program modification approval. EPA believes this per-program estimate is relevant to state environmental protection agencies under the “Baseline” scenario, since they would be submitting program-specific applications to EPA. The estimate is also appropriate for other State/Locals jurisdictions under both “Baseline” and “To Be”, because it is assumed they generally administer one program. For state EPAs under “To Be”, EPA believes the burden for preparing the consolidated program modification application would be greater, because it would encompass all of the Agency’s receiving systems across its programs. The State Overview Table suggests that it would take a state environmental protection agency about 245 hours under “To Be” for preparing/submitting the consolidated application. – Estimate the number of facilities reporting to State/Locals receiving systems (i.e., indirect reporters). EPA ta llied up the total number of electronic reporters to the 15 states’ receiving systems and extrapolated to the U.S., to estimate the total number of indirect reporters that would report electronically. In total, EPA estimates that 490,218 indirect facilities would be reporting electronically. Refer to Tables V-5 and V-6 for EPA’s estimated number of indirect employee registrants.

### 68 

### Table V-1. State Overview

System Credential Signature Scenario Archive System Security E-mail notification

(Y = yes, N = no, U = under consideration) Transmission Protocol (E = Email, HS = HTTPS,

H = HTTP)

States P = Planned or E = Existing System(s) Staff Mgmt PS = Shared PIN; PA =PIN SelfAssigned; DS = Digital Signature Warnings A = Affix Signature to Document;

S = pr Associated;

NA = No Signature Human readable COR COR w. context
or audit trail Hash/ Sign General

Arizona P 320 20 PS 1 S Y Y N Y Y HS

Florida E 240 20 PA, PS 1 A Y N Y Y Y N Georgia P NONE 0 NA Y N N N Y N
Illinois P DS 1 A Y N Y Y Y Y HS, Kentucky P PS, Encryption Mississippi E PS, Encryption Nebraska (oil and gas) E 320 20 PS 1 S Y N N N Y Y H, HS

North Dakota (OIL and GAS) E 120 20 PS 1 S Y N N N Y N E, H

New Mexico E 200 20 PS, Encryption 1 A Y N Y Y Y U E

P PS 1 S Y N N N Y U HS New Jersey P 120 15 PS 1 A Y N N N Y Y HS E PS, Encryption 1 S Y N Y Y Y N

Ohio E 320 20 PS 1 S y N N N Y E, Pennsylvania P 320 40 PS 1 A Y Y N N Y Y HS E PS 1 S Y Y N N Y E

Tennessee P PS, Encryption Virginia P DS 1 A Y N Y Y Y HS, H

Wisconsin E PS, HASH 1 A Y N Y N Y Y



### Table V-2. Existing State Receiving Systems
State Existing Systems Start Date Program Number of Entities

Arizona
Florida 2000 EDMR 3 Georgia
Illinois Kentucky Michigan

### 69 State Existing Systems Start Date Program Number of Entities Mississippi Nebraska (oil and gas) North Dakota (oil and gas) 2000 UIC 250

New Mexico 1999 Air (NEI) 200
New Jersey 2000 Air (CEM) 12
2000 EPCRA(Tier II) 28000

2002 UST 1000
2002 P2 250

2002 Air Permits 1500

Ohio 2001 HW annual report 480
2000 Drinking/Ground Water 5700

1999 Wastewater 1550

1999 Air title V emissions 780
1999 Air Permits (PTIs) 200

1999 Risk Management 500
1999 PTO applications 780

1999 Emission Reports (non-title V) 2400
Pennsylvania Air Facility Trust 4000 Air Quality 125

Asbestos Notification 6000

Texas
Tennessee Virginia
Wisconsin 2002 Consolidated (air, haz waste) 5800

2002 EDMR 22



### Table V-3. Planned State Receiving Systems

State Planned Systems

Start Date Implementation Date Program Number of Entities

Arizona 37621 37986 Drinking Water 1800

37986 38352 NPDES (NOI) 60000

### 70 State Planned Systems

Start Date Implementation Date Program Number of Entities

Florida 37621 37986 NPDES (DMR) 900

37543 37986 Drinking Water 7000

Georgia 37680 37986 EPCRA (Tier II) 5000

Illinois 37621 37986 DMR 800

Indiana

Kentucky
Michigan

Mississippi
Nebraska (oil and gas) 37621 37986 UIC 177

North Dakota (oil and gas) 37621 UIC 250

New Mexico 37621 37986 Air Excess Emissions 1000

37621 1/2 /04 NEI 1000

37621 37988 Title V 200

37986 37989 Air Emissions Scan

New Jersey 37590 Water (DMR) 2000

Ohio 37621 37986 HW Annual report 1200

37621 37986 Drinking Water Ground Water 5700

37621 37986 Wastewater

37621 37986 Air title V emissions 780

37621 37986 Air Permits 200

37621 37986 Risk Management 500

37621 37986 PTO applications 780

### 71 State Planned Systems

Start Date Implementation Date Program Number of Entities

37621 37986 Emission Reports (non-title V) 2400

Pennsylvania 37772 38138 DMR 6000

Texas

Tennessee
Virginia 37346 37955 DMRs 3000

Wisconsin 37955 38321 DMRs 1800

Compliance NESHAPS



### Table V-4. Summary of State/Locals System Upgrade Costs Per Receiving System

Copy of Record SSL Email Notification E-Signature

Cost Per System Upgrade Cost Per System Upgrade

Startup Cost Annual Maintenance % of Systems Needing Upgrade Startup Cost Annual Maintenance % of Systems Needing Upgrade Cost Per System Upgrade % of Systems Needing Upgrade Cost Per System Upgrade % of Systems Needing Upgrade

State EPAs $208,333 $28,333 58% $25,000 $600 27% $56,000 7% $15,270 10%

All Other State and Local Agencies $50,000 $10,000 58% $25,000 $600 27% $56,000 7% $15,270 10%



### Table V-5. Annual Number of State/Locals Receiving System Employee Registratants Under “Baseline”

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

Total - - - - 489,726 114,270 102,840 95,562 83,301 74,973

### 72 

### Table V-6. Annual Number of State/Locals Receiving System Employee Registrants under “To Be”*

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

Total - - 489,726 114,270 102,840 92,562 83,301 74,973 67,476 60,729

* Table includes rounding error.



### Table V-7. Upgrade Costs Per State/Locals Receiving System under Electronic Signature Agreement Provisions
Activities for Upgrade Receiving Systems Burden Hours Cost per Hour Total Cost

Requirements analysis 49 $93.51 $4,581.99

System design analysis 73 $93.51 $6,826.23

Database changes and testing 35 $93.51 $3,272,85

Application changes and testing 73 $93.51 $6,826.23

QA testing and rework 35 $93.51 $3,272.85

Deployments 22 $93.51 $2,057.22

Project management 47 $93.51 $4,394.97

Totals: Hours, Rate, Cost 334 $93.51 $31,232.34

### 73 

### Appendix VI. State Contacts The information pertinent to State/Locals Agency’s existing and planned receiving systems have been obtained from the following individuals via a phone interview. 

### Table VI-1. State Survey Contacts

Name Entity

Tom Aten Wisconsin Department of Environmental Quality

Russ Brodie Arizona Department of Environmental Quality

John Coates Florida

Mike Garretson Illinois EPA

Allison Kittle Virginia

Renee Martinez New Mexico

Greg Nudd Texas
Pete Tenebruso New Jersey

Stan Belieu NB Oil and Gas

### 74 

### Appendix VII. Burden Hours and Costs to Direct Reporters EPA reviewed the ICRs in Appendix II to estimate the hours and cost burden to direct reporters and the Agency under each collection. In doing so, EPA “scaled” the hour and cost burden in each ICR to determine the burden associated only with these direct reporters. To do so, the Agency developed a scaling factor for each EPA program. The scaling factor reflects the percentage of burden in each of the program’s ICRs that is associated with only direct reporting. Specifically, a program’s scaling factor is derived by the following equation: Number of Regulated Entities in Nonauthorized States in Program = Program Scaling Factor Total number of Regulated Entities in all States The equation reflects the general assumption that facilities located in nonauthorized states submit information to EPA for any given program. That is, EPA generally administers information collections in nonauthorized states, whereas authorized states generally collect the information themselves. For example, OSWER/Office of Solid Waste (OSW) oversees the Resource Conservation and Recovery Act (RCRA) hazardous waste program and has authorized 48 of the 50 states to administer state RCRA programs in lieu of EPA. In these 48 states, facilities generally submit reports to the state, not EPA. In only the two nonauthorized states (i.e., Alaska and Iowa) are information collections administered by EPA. Because 1 percent of the regulated universe is located in these states, the model multiplies the hour and cost burden in OSWER/OSW’s ICRs by 1 percent, in order to derive the burden associated with direct reports. The model performed a similar computation for each of the collections in Appendix II. Table VII-1 shows the scaling factors for each program. 

### Table VII-1. Scaling Factors

Program Scaling Factor Source

CWA 0.09 http://www.epa.gov/npdes/pubs/npdes-modules.pdf http://oaspub.epa.gov/enviro/ef_home2.water

OSW 0.01145 National Biennial RCRA Hazardous Waste Report (1999 data)

SDWADrinking Water Systems 0 http://www.epa.gov/safewater/dwinfo.htm. http://www.epa.gov/safewater/dwa/electronic/intropwss/pwss.pdf epa.gov/safewater/data/00factoid.pdf

TRI 1 EPA's bes t judgment

CERCLA 1 EPA's best judgment 

### Based on this analysis, EPA reduced the hours in each ICR, as appropriate, by applying the scaling factors. These hours are shown in Table VII-2. 

### Table VII-2. Annual Burden Hours to Direct Reporters*

Office Name ICR Title ICR Number Scaling Factor Annual Scaled Burden Hours

### 75 Office Name ICR Title ICR Number Scaling Factor Annual Scaled Burden Hours

OEI Toxic Chemical Release Reporting, Recordkeeping, Supplier Notification and Petitions 1363.11 1.00 6,870,800

OW Clean Water Needs Survey 318.09 1.00 7,700

OPPTS TSCA Section 12(b) Notification of Chemical Exports 795.10 1.00 10,400

OPPTS Toxic Substances Partial Updating of TSCA Inventory Data Base; Production and Site Reports 1011.05 1.00 53,600

OA Amendment to Regulatory Reinvention Pilot Projects (Project XL) ICR; New York State 1755.06 1.00 58,300

OGC National Roster of Environmental Dispute Resolution and Consensus Building Profe 1888.01 1.00 500

OPPTS Voluntary Cover Sheet for TSCA Submissions 1780.02 1.00 900

OW Questionnaire for Operations and Maintenance, Biosolids Use, Combined Sewer Over 1287.06 0.09 300

OW CWA State Revolving Fund Program 1391.06 1.00 34,400

OW National Water Quality Inventory Reports (TMDL) Final Rule: Clean Water Act 1560.06 1.00 4,243,500

OW Drinking Water State Revolving Fund (DWSRF) Program 1803.03 1.00 29,800

### 76 Office Name ICR Title ICR Number Scaling Factor Annual Scaled Burden Hours

OAR NESHAP: Radionuclides 1100.11 1.00 5,400

OW Water Alliances for Voluntary Efficiency (WAVE) Program 1654.03 1.00 2,600

OAR IAQ Practices in Large Buildings Survey 1917.01 1.00 1,100

OW National Program to regulate nondomestic discharges to municipal sanitary sewer 2.09 0.09 85,000

OW Modification of Secondary Treatment Requirements for Discharges into Marine Water 138.06 0.09 5,900

OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 0.09 3,100

OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 0.09 120,300

OW Applications for NPDES Discharge Permits and the Sewage Sludge 226.15 0.09 1,400

OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 0.09 1,300

OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 0.09 1,100

OW Applications for NPDES Discharge Permits and the Sewage Sludge 226.15 0.09 5,800

### 77 Office Name ICR Title ICR Number Scaling Factor Annual Scaled Burden Hours
Management Permit
OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 0.09 3,600

OW Application for NPDES Discharge Permits and the Sewage Sludge Management Permits 226.15 0.09 100

OW Application for NPDES Discharge Permits and the Sewage Sludge Management Permits 226.15 0.09 24,300

OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 0.09 12,400

OW NPDES DMR ICR 229.15 0.09 199,500

OSWER Notification of Regulated Waste Activity 261.13 0.01 1,100

OSWER RCRA Hazardous Waste Permit Application and Modification, Part A 262.09 0.01 10

OW UIC Program 370.18 0.04 27,300
OW UIC Program 370.18 0.04 -
OW UIC Program 370.18 0.04 -
OW UIC Program 370.18 0.04 -
OW UIC Program 370.18 0.04 - OW UIC Program 370.18 0.04 -
OW UIC Program 370.18 0.04 -
OW UIC Program 370.18 0.04 -
OW UIC Program 370.18 0.04 -
OW UIC Program 370.18 0.04 -
OW UIC Program 370.18 0.04 -

### 78 Office Name ICR Title ICR Number Scaling Factor Annual Scaled Burden Hours
OW UIC Program 370.18 0.04 - OW UIC Program 370.18 0.04 -
OW UIC Program 370.18 0.04 -
OW UIC Program 370.18 0.04 -
OW UIC Program 370.18 0.04 -
OW UIC Program 370.18 0.04 -
OW UIC Program 370.18 0.04 - OW UIC Program 370.18 0.04 -
OW UIC Program 370.18 0.04 -
OW UIC Program 370.18 0.04 -
OW UIC Program 370.18 0.04 -
OW UIC Program 370.18 0.04 -
OW UIC Program 370.18 0.04 - OW UIC Program 370.18 0.04 -

OW Construction Grants Program 827.05 0.09 118.10

OW Water Quality Standards Regulation 988.08 1.00 238,800

OSWER Application for Reimbursement to Local Governments for Emergency Response to Hazardous Substance Releases 1425.05 1.00 1,600.00

OSWER Reporting and Recording Requirements under EPA's Wastewise Program 1698.04 1.00 57,600

OW National Health Protection Survey of Beaches 1814.02 1.00 1,300

OW Phase II of the NPDES Stormwater Program (Final Rule ICR) 1820.02 0.09 74,200

OW Notice of Intent for 1842.02 0.09 671,600

### 79 Office Name ICR Title ICR Number Scaling Factor Annual Scaled Burden Hours

Storm Water Discharges Associated with Construction Activity

OAR Motor Vehicle Emission and Fuel Economy Compliance; Light Duty Vehicles; Light Duty Trucks and Motorcycles 783.42 1.00 489,000

OPPTS TSCA Section 402/404 Training, Certification, Accreditation andStandards for LeadBased Paint Activities 1715.03 1.00 93,200

OPPTS Request for Contractor Access to TSCA Confidential Business Information 1250.06 1.00 300

OPPTS Correction of Misreported Chemical Substances on the Toxic Substances Control Act 1741.03 1.00 200

OPPTS Pre-Manufacture Review Reporting and Exemption Requirements for New Chemical 574.11 1.00 178,700

OPPTS PCBs: Consolidated Reporting and Recordkeeping Requirements 1446.07 1.00 800

OPPTS PCBs: Consolidated Reporting and Recordkeeping Requirements 1446.07 1.00 62,900

* This table lists all the ICRs to be automated by the CDX as identified by the EPA programs. Note that certain programs listed an ICR more than once if it contained multiple collections that will be automated through the CDX. For example, UIC ICR #370.18 is listed multiple times for each collection in the ICR that will be automated. On the other hand, other EPA programs listed an IC R once regardless of the number of collections it contained. 

### Based on the hours in Table VII-2, the model uses the equation in Figure VII-1 to estimate the total costs to direct reporters in preparing and submitting information under EPA’s information collections. The model uses the equation for both “Baseline” and “To Be”. Specifically, the model applies the equation to each of the collection’s scaled hours, as described above. Through the equation, the model applies the annual automation implementation rate described

### 80 in Exhibit 2-5. The model then applies the Web form and XML form usage and savings rates described in Exhibit 2-5 to reduce the electronic hours by the savings rate.

Following this, the model sums up both the paper and electronic hours and applies the ICR’s average hour labor rate to derive total costs. Through this process, the model estimates the total annual cost to direct reporters under the collection. Finally, the model sums up the total annual costs for each of the 68 collections to derive total annual aggregate costs for all collections per year. From this, the model estimates total aggregate annual costs to direct reporters under “Baseline” and “To Be” across all collections for each year during the modeling period. Note that the model performs the same process for estimating costs to EPA in receiving and processing paper and electronic submittals.



### Figure VII-1. Model Equation for Estimating Costs under EPA Collections Total ICR Hours for Reporting Hours for Paper Submittals

Implementation Rate Hours for Electronic Submittals Web Form Usage Rate Hours for Web Submittals

Hours for XML Submittals (1

- Savings Rate) Total Hours Average ICR Hourly Labor Rate X =
i = 1 Total Annual Cost For ICR

X

X (1

- Savings Rate) k Total Annual Cost i

* k = number of ICRs used in the analysis (1

-

Implementation Rate)

where i = 1...k*

XML Form Usage Rate

### 81 

### Appendix VIII. Multi-Media Reporting Scaling Factor In several places in the analysis, the model examines the universe of “unique” facilities subject to EPA’s collections. EPA notes, however, that the number of facilities in the ICRs in Appendix II is potentially overlapping across programs. That is, a facility in an OSWER ICR might also be examined in an OW ICR. Given this, EPA derived a multi-media scaling factor (i.e., 1.3), which reflects the average number of EPA programs to which the average facility is subject. The scaling factor was derived by the equation shown in Table VIII-1: 

### Table VIII-1. Facility Count

Multi-Media Frequency Count
Single 873,253

Double 83,847

Triple 30,600

Four 13,881

Five 7,489

Six 4,474

Seven 2,564

Eight 1,265

Nine 589

Ten 234

Eleven 41

Twelve 2

Thirteen 0

Source: FRS Statistics as of October 16, 2002.

### 82 

### Appendix IX. Number of Direct Reporters To derive the number of facilities reporting to the CDX, EPA obtained the number of respondents associated with each of the information collections in Appendix II. Note that each collection is examined in an ICR that estimates the total annual number of respondents to that collection. EPA then “scaled” the number respondents in each ICR to determine the number of facilities reporting directly to the Agency. To estimate the number facilities reporting to EPA, the Agency developed a scaling factor for each of EPA’s environmental programs. The scaling factor reflects the percentage of respondents in each program that is located in a nonauthorized state. Specifically, a program’s scaling factor is derived by the following equation: No. of Regulated Entities in Nonauthorized States in Program = Program Scaling Factor Total No. of Regulated Entities in all States The equation reflects the general assumption that facilities located in nonauthorized states submit information directly to EPA, not the state. That is, EPA generally administers information collections in nonauthorized states until the state receives authorization. For example, OSWER/OSW oversees the RCRA hazardous waste program and has authorized 48 of the 50 states to administer state RCRA programs in lieu of EPA. In these 48 states, facilities generally submit reports to the state, not EPA. In only the two nonauthorized states (i.e., Alaska and Iowa) are information collections administered by EPA. Because 1 percent of the regulated universe is located in these states, the model multiplies the total number of respondents in OSWER/OSW’s ICRs by 1 percent, in order to derive the number that reports directly to EPA. Scaling factors are presented in Table IX-1. 

### Table IX-1. Scaling Factors

Program Scaling Factor Source

CWA 0.09 \d 4http://www.epa.gov/npdes/pubs/npdes-modules.pdf \d 4http://oaspub.epa.gov/enviro/ef_home2.water

OSW 0.01145 National Biennial RCRA Hazardous Waste Report (1999 data)
SDWA-Drinking Water Systems 0 \d 4http://www.epa.gov/safewater/dwinfo.htm. \d 4http://www.epa.gov/safewater/dwa/electronic/intropwss/ pwss.pdf epa.gov/safewater/data/00factoid.pdf
TRI 1 EPA best judgment
CERCLA 1 EPA best judgment

SDWA-UIC 0.04 http://www.epa.gov/safewater/uic.tml
OAR 0 EPA best judgment 

### Through the calculations above, EPA estimated the number of respondents who report directly to EPA. Note, however, that EPA needed to further refine these estimates to determine the number of unique respondents to EPA. That is, regulated entities may be subject to more than one information collection in Appendix II. This could include, for example, more than one information collection within any program or more than one information collection across

### 83 programs (e.g., information collections under the hazardous waste and water programs). To eliminate this potential duplication, EPA took the following two steps:



### ■ Reviewed all ICRs within each program to determine if the ICRs contained overlapping respondent universes. EPA used its best judgment in determining if two or more ICRs within the same program applied to the same population of respondents, using information such as the Standard Industrial Classification codes and respondent universe descriptions in the ICR supporting statement. In doing so, EPA eliminated potential duplication within programs.



### ■ Once EPA had eliminated potential duplication within each program, the Agency summed up to the total number of respondents that remained and divided this sum by the multimedia scaling factor described in Appendix VIII to eliminate duplication across programs. From these calculations, EPA estimated the total number of unique respondents to EPA under each of the information collections. EPA then further refined these estimates by distinguishing the size of facilities in terms of number of employees. Understanding the breakdown in number of small vs. medium/large facilities assisted the Agency in configuring the model to account for differences in number of employees who would register with EPA’s receiving systems. It also informed the Agency of appropriate implementation rate assumptions, in that smaller facilities might not have the same level of capabilities in reporting electronically. For purposes of this analysis, EPA has defined a “small” facility as one with 20 employees or fewer. EPA believes this is a reasonable threshold, as it focuses in on the smallest and most vulnerable of facilities and those most likely to face resource constraints in reporting electronically. The U.S. Census data indicate that 89 percent of all businesses employ 20 or fewer persons, and the remaining 11 percent employ 21 or more. 2 

### EPA used these percentages to estimate the number of small and large facilities reporting to EPA. These estimates are shown in Table IX-2. In addition, EPA estimated the average number of employees per facility that would register with EPA’s receiving systems. Based on public comments on the proposed CROMERR, EPA estimates that the typical small facility will designate three employee registrants and the typical large facility will designate six employee registrants, on average. Table IX-2 presents the total number of employee registrants per facility and for all facilities. 

### Table IX-2. Direct Reporters and Registrants*

Unique Facilities No. of Registrants per Facility Total No. of Registrants

Small Facilities 67263 3 201,790
Large Facilities 8313 6 49,881

TOTAL 75577 - 251671
*Table includes rounding error.

2 U.S. Bureau of Census. Statistics of U.S. Businesses: 1999: All industries in the United States. http://www.census.gov/epcd/susb/1999/us/US--.HTM84Appendix X. XML and Flat File UsageTo derive the number of XML/flat file users, EPA’s first assumption was that XML or flat file would be used only by medium andlargefacilities, because of the upfront costs and technical expertise required. Given this assumption,EPA reviewed all of the ICRs inAppendix II to estimate the total number of respondents under each information collection. EPA then assumed that 11 percent ofthem are medium or large.12In total, EPA estimates 8,313 medium and large facilities are subject to the information collections.EPA further assumed that approximately 50 percent of these facilities would opt for XML or flat file, while the rest would optfor Webform, for each collection.13EPA also assumed that each facility is part of a business that consists of, on average, three facilities each,and that XML or flat file mapping (or purchase of off-the-shelf software) would be done centrally at one facility location (e.g.,headquarters location) and then distributed to the other two facilities.14EPA consulted with several of the respondents in Appendix XI,who agreed with this assumption. Tables X-1 and X-2 present the total number of facilities that are expected to conduct XML orflatfile mapping across all of the ICRs in Appendix II.Table X-1. Number of Companies Implementing XML/Flat File under “Baseline”2000200120022003200420052006200720082009201020112012No. of CompaniesImplementing XML108 39 34 25 23 377 113 115 92 82 74 66 59Table X-2. Number of Companies Implementing XML/Flat File under “To Be”2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012No. of CompaniesImplementing XML10839 34 382 118 119 95 85 77 69 61 55 49In addition, EPA estimated the total XML or flat file mapping cost to facilities. EPA recognizes that, in actuality, mapping costs willvary greatly during the modeling period. They will be higher during the earlier years as facilities begin to use XML or flat files andthen decline over time because of greater user sophistication. In addition, EPA anticipates the emergence of customizable off-theshelf software that can work within a user’s environment, eliminating the need for significant mapping.12U.S. Bureau of Census. Statistics of U.S. Businesses: 1999: All industries in the United States.13“eMarketplaces Spur XML Adoption,”Business Technographics of North America, May 11, 2001. The article estimates that more than 50 percent of Global 3,500 companies areimplementing, rolling out, or piloting XML.14U.S. Bureau of Census. Statistics of U.S. Businesses: 1999: All industries in the United States. The Census estimates that firms with 20 or more employees consist of threeestablishments, on average.85EPA estimates that current XML and flat file mapping costs are roughly $25,000 for a facility per collection, on average. This estimateis based on EPA’s best judgment and consultations with industry representatives listed in Appendix XI. EPA estimates that the costto a facility to purchase and install the off-the-shelf software would be approximately $1,000 for a facility per collection.EPA further expects that the vast majority of userswill opt for the off-the-shelf software, on average, over the modeling period. This isdue to its lower cost and greater convenience. For purposes of this analysis, the model assumes that 5 percent of users would opt toperform their own mapping and that the remaining 95 percent would purchase/install the software, on average, over the modelingperiod. Note that EPA fully expects that, during the early years, the majority of facilities will map on their own. However, astheAgency implements greater electronic reporting across its programs, commercial vendors will increasingly supply software applicableto EPA’s collections. As such, facilities will transition from mapping on their own to purchasing the software.86Appendix XI. Industry ConsultationsEPA contacted industry stakeholders on November 6 and 7, 2002, to collect information used in this cost analysis. The industrycontacts are as follows:■Salman Shaikh - Suffolk County Water Authority, New York (UCMR: Lab and PWS)■Steve McSherry - Decatur Utilities, Alabama (UCMR: PWS)■Brad Bollen - New Jersey Bureau of Air Quality Evaluation - (AEI: State)■Angelique Luedeker - Institute for Tribal Professionals, Arizona - (AEI: Tribe)■Ruth Curfman - Dow Corning Corporation, Michigan - (TSCA-HASD)■Jack Halstuch - JH Consulting Group, New York - (UCMR: PWS Consultant)87Appendix XIV. Background Tables on Sensitivity RunsTable XIV-1. EPA Costs under Baseline”, “To Be”, and Difference(in millions of dollars)** Costs presented for Scenario 1.** Cost savings shown in parentheses.Table XIV-2. State/Locals Costs under “Baseline”, “To Be”, and Difference(in millions of dollars)** Costs presented for Scenario 1.** Cost savings shown in parentheses.88Table XIV-3. Facility Costs under “Baseline”, “To Be”, and Difference(in millions of dollars)** Costs presented for Scenario 1.** Cost savings shown in parentheses.89Table XIV-4. EPA Costs under “Baseline”, “To Be”, and Difference(in millions of dollars)** Costs presented for Scenario 2.** Cost savings shown in parentheses.Table XIV-5. State/Locals Costs under “Baseline”, “To Be”, and Difference(in millions of dollars)** Costs presented for Scenario 2.** Cost savings shown in parentheses.90Table XIV-6. Facility Costs under “Baseline”, “To Be”, and Difference(in millions of dollars)** Costs presented for Scenario 2.** Cost savings shown in parentheses.91Appendix XV. Acronyms and TermsBLS Bureau of Labor StatisticsCAA Clean Air ActCBA Cost Benefit AnalysisCDX Central Data ExchangeCEPPO Chemical Emergency Preparedness and Prevention OfficeCERCLA Comprehensive Environmental Response, Compensation, and Liability ActCFR Code of Federal RegulationsCOR copy of recordCROMERR Cross-Media Electronic Reporting RuleCWA Clean Water ActDMR Discharge Monitoring ReportDWSRF Drinking Water State Revolving FundEDMR Electronic Discharge Monitoring ReportEPA Environmental Protection AgencyEPCRA Emergency Planning and Community Right-to-Know ActFBCA Federal Bridge Certificate AuthorityFIFRA Federal Insecticide, Fungicide, and Rodenticide ActFOIA Freedom of Information ActGPEA Government Paperwork Elimination Act92HW hazardous wasteIAQ indoor air qualityIFB Invitation for BidICR Information Collection RequestLRA local registration authorityNEIN National Environmental Integrated NetworkNESHAPS National Emissions Standards for Hazardous Air PollutantsNPDES National Pollutant Discharge Elimination SystemOA Office of AdministratorOAQPS Office of Air Quality Planning and StandardsOAR Office of Air and RadiationOARM Office of Administration and Resource ManagementOEI Office of Environmental InformationOGC Office of General CounselOMB Office of Management and BudgetOMS Office of Mobile SourcesOPPTS Office of Prevention, Pesticides and Toxic SubstancesOSW Office of Solid WasteOSWER Office of Solid Waste and Emergency ResponseOW Office of Water93PIN personal identification numberPOTW publicly owned treatment worksPRA Paperwork Reduction ActRCRA Resource Conservation and Recovery ActRFP Request for ProposalsSDW safe drinking waterSDWA Safe Drinking Water ActSSL secure socket layerTRI Toxics Release InventoryTSCA Toxic Substances Control ActUIC Underground Injection CodeUST Underground Storage TankSML Extensive Markup LanguageWAVE Water Alliances for Voluntary EfficiencyWWW World Wide Web