*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

RIN2070-AK02_EO12866_Lead_MinorAmendment s_NPRM_EA_Redline_Revisions_2014- 1 12-10.docx 2

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## Economic Analysis for the Lead-Based Paint Program 6 

## Minor Amendments Proposed Rule 7

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## RIN 2070-AK02 10 11 12 13 

# EO 12866 REVIEW DRAFT 14

15 16 17 18 July 23 December 10 , 2014 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Economic and Policy Analysis Branch 34 Economics, Exposure and Technology Division 35 Office of Pollution, Prevention, and Toxics 36 U.S. Environmental Protection Agency 37 1200 Pennsylvania Avenue 38 Washington, DC 20460 39i This Page Intentionally Left Blank*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

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### Acknowledgement
Analytical and draft preparation support was provided by Abt Associates Inc. under EPA Contract No. EP-W-08-0100.*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

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### Table of Contents

Executive Summary ............................................................................................................. .................... ES-1 1. Introduction .................................................................................................................. .................... 1-1 1.1 Regulatory and Programma tic Background ............................................................................. 1-1 1.2 Summary of Analytic Approach .............................................................................................. 1-2 1.3 Organization of This Report.................................................................................................... . 1-2 2. Affected Entities ............................................................................................................. ................... 2-1 2.1 Regulated Community ........................................................................................................... .. 2-1 3. Industry Cost Savings ......................................................................................................... ............. 3-1 3.1 Introduction .................................................................................................................. ............ 3-1 3.2 Abatement Multi-jurisdiction Registration Fee Amendment ................................................... 3-1 3.3 Renovator Refresher Training Course Amendment ................................................................. 3-2 3.4 Total Industry Cost Savings ................................................................................................... .. 3-9 3.5 Other Industry Costs .......................................................................................................... ...... 3-9 4. Agency Costs .................................................................................................................. ................... 4-1 5. Social Cost Savings ........................................................................................................... ................ 5-1 6. Small Entity Impact Analysis .................................................................................................. ........ 6-1 7. Other Impact Analyses ......................................................................................................... ............ 7-1 7.1 Paperwork Reduction Act ....................................................................................................... . 7-1 7.2 Unfunded Mandates Reform Act ............................................................................................. 7-3 7.3 Executive Order 13132 – Federalism ....................................................................................... 7-4 7.4 Executive Order 13175 – Consultation and Coordina tion with Indian Tribal Governments ... 7-4 7.5 Executive Order 13045 - Children’s Health ............................................................................. 7-4 7.6 Executive Order 13211 – Energy Supply, Distribution, or Use ............................................... 7-4 7.7 National Technology Transfer and Advancement Act ............................................................. 7-4 7.8 Executive Order 12898 – Environmental Justice ..................................................................... 7-5 8. References .................................................................................................................... ..................... 8-1 Appendix A. Training Courses Tuition Data ..................................................................................... ..... A-1*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

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### List of Exhibits

Exhibit ES-1: Total and Annualized Social Cost Savi ngs of the Proposed Amendments Over 50 Years (millions 2014$) .............................................................................................................. ........................... ES-2
Exhibit 2-1: Lead-based Paint Activities Individuals a nd Firms Applying for (Re)certification and Training Providers Applying for (R e)accreditation from 2011-2013 ....................................................................... ... 2-1 Exhibit 2-2: Renovator Initial Certifications under the Renovation, Repair, and Painting Program Rule from 2010 through 2013. ............................................................................................................ ........................... 2-1 Exhibit 3-1: Annual Multi-jurisdiction Registrati on Fees for Individuals and Firms Applying for (Re)certification, and Training Providers Applying for (Re)accreditation ................................................... 3- 1 Exhibit 3-2: Fifty Year Net Present Value and Annualized Cost Savings for Individuals and Firms Applying for (Re)certification, and Training Providers Applying for (Re)accreditation (2014$) ................................ 3-2 Exhibit 3-3: Procedure to estimate in-person classroom refresher training course tuition ........................... 3-4 Exhibit 3-4: Estimated refresher training tuition summary ..................................................................... ...... 3-4 Exhibit 3-5: Total Renovator Travel Cost ...................................................................................... ............... 3-5 Exhibit 3-6: Incremental Renovator Training Co st Savings under the Proposed Rule ................................. 3-5 Exhibit 3-7: Expected Number of Renovators Seeking Training ................................................................. 3 -7 Exhibit 3-8: Expected Number of Renovators Seeking In-person and E-learning Refresher Training Options ....................................................................................................................... ................................... 3-7 Exhibit 3-9: Fifty Year Net Present Value and Annuali zed Cost Savings for Renovators Seeking In-person Classroom Training Under the Proposed Rule (2014$) ............................................................................ .... 3-8 Exhibit 3-10: Fifty Year Net Present Value and A nnualized Cost Savings for Renovators Seeking E-learning Classroom Training Under the Proposed Rule (2014$) .............................................................. 3- 8 Exhibit 3-11: Combined Fifty Year Net Present Value and Annualized Renovator Recertification Cost Savings Under the Proposed Rule (thousands 2014$) ............................................................................. ..... 3-9 Exhibit 3-12: Total and Annualized Industry Cost Savings of the Proposed Amendments Over 50 Years (thousands 2014$) ............................................................................................................. ............................ 3-9 Exhibit 4-1: EPA Wage Rate .................................................................................................... .................... 4-1 Exhibit 4-2: Fifty Year Net Present Value and Annualized Cost to EPA Under the Proposed Rule (2014$) 4- 1
Exhibit 5-1: Total and Annualized Social Cost Savi ngs of the Proposed Amendments Over 50 Years (thousands 2014$) ............................................................................................................. ............................ 5-1 Exhibit 7-1: Incremental RRP Training Provider Hour Burden ................................................................... 7-2 Exhibit 7-2: Loaded RRP Training Provider Wage Rates .......................................................................... .. 7-3 Exhibit 7-3: RPP Incremental Training Provider Cost (2014$) ................................................................... . 7-3 Exhibit A-1: Sample of Renovation (Re)certification Training Courses ..................................................... A-1*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

ES-1 

## Executive Summary

The United States Environmental Protection Agency (EPA ) is considering two cost saving amendments to the regulations for Lead-based Paint Poisoning Prevention in Certain Residential Structures, codified at 40 CFR part 745 and promulgated under TSCA §402(a) a nd §402(c). This report estimates the cost savings from the proposed rule that includ es these amendments to the Lead-based Paint (LBP) Activities rule for lead abatement and the Residential Property Renova tion rule for renovation, repair and painting (RRP).

The first amendment removes the multi-jurisdiction registration fee that individuals and firms pay for (re)certification and that training programs pay for (r e)accreditation in the lead abatement program. Under the existing regulations, there is a $35 fee for each additional EPA-administered jurisdiction for which organizations apply to perform LBP abatement activities or to provide lead abatement training. In a typical year, individuals, firms, and training providers appl y to perform lead-based paint activities or provide training in a total of 431 additi onal EPA-administered jurisdictions. Removing the $35 fee will result in total estimated cost savings of approxima tely $15,000 per year to these entities.

The second amendment removes the hands-on training requirement from the lead renovation refresher training course. Under the existing rule, both the initial and refresher renovator training courses must include a classroom component (which may be take n in person or online) and a hands-on component (which must be taken in person). Removing the hands- on training requirement is estimated to reduce the tuition for refresher training courses by an average of $37. Removing the hands-on requirement is also expected to make online renovator refresher training more attractive to training providers and renovators. If renovators become recertified solely by taking an e- learning course (i.e., without an in-person component) they are estimated to save an additional $165 by avoi ding the time and associated expenses needed to travel to a training site.

Renovator training and certification became mandatory in 2010 and a large number of renovators were trained that year, with smaller numbers becomi ng trained in each subsequent year. Training and certification are valid for five years, and many renova tors will need to be recertified over the next few years. The largest number of recertifications is expect ed in 2015, when 168,000 renovators are expected to seek refresher training. Over time, the number of re novators seeking refresher training is predicted to equilibrate to approximately 48,000 per year. Nearly all of these renovators are assumed to choose to receive their refresher training online if the hands-on requirement is removed, thus reducing travel costs. Removing the hands-on requirement fo r renovator refresher training is estimated to save over $9 million per
year.
If the hands-on requirement is rem oved, training providers currently accredited for the renovator refresher training course are expected to apply for an e-l earning refresher training accreditation to accommodate the high demand for the course. EPA will incur additional costs because the Agency must review and process applications submitted by training providers to become accredited for an e-learning course. An estimated 275 training providers would apply for an e-learni ng refresher course accreditation if the rule is promulgated. Reviewing and processing the additional accr editation applications is estimated to cost the EPA over $80,000.

The rule includes a correction to the training notifica tion requirements to add back regulatory text on posttraining notifications that was inadvertently overw ritten in a 2011 rulemaking (although most training providers are continuing to provide post-training no tifications to EPA in a timely manner). EPA has*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

ES-2 already accounted for the burden and cost of requi ring accredited providers of renovation training to provide notification to EPA after each training course the provider delivers. Fo r example, the currently approved Information Collection Request for the RRP program 1 estimates that 600 renovation training providers will submit an average of 14 post-training notifi cations per year. This yields a total of 8,400 posttraining notifications per year at an average burden of 1.6 hours per response, resulting in a total burden for this activity of 13,440 hours at a cost of $339,578. In order to avoid double-counting cost that has already been accounted for, the current analysis does not include the burden and cost of reinstating the post-training notification requirements.
The rule also adds clarifying language explaining that training providers must follow the regulations. This does not affect the cost of compliance because it does not change any requirements for accredited training providers, and the analysis assumes that training pr oviders already comply with the regulations.
Exhibit ES-1 presents estimates for the total and an nualized industry cost savings and Agency costs associated with the enactment of the proposed amendm ents, as well as the total and annualized social cost savings. Estimates are discounted at 3 and 7 percent. The cost savings to society is estimated to be between $9.6 and $9.8 million per year with the passage of the proposed amendments to the LBP activities and renovation regulations (see Exhibit ES-1).

Exhibit ES-1: Total and Annualized Social Co st Savings of the Proposed Amendments Over 50 Years (millions 2014$) 1

Category Net Present Value Annualized Cost Savings
3% 7% 3% 7% Total Industry Cost Savings $246.551 $134.938 $9.583 $9.777 Multi-jurisdiction Amendment $0.388 $0.208 $0.015 $0.015 Refresher Training Amendment $246.163 $134.730 $9.568 $9.762

Total Agency Costs $0.083 $0.080 $0.003 $0.006 E-learning Application Processing $0.083 $0.080 $0.003 $0.006
Social Cost Savings $246.468 $134.858 $9.580 $9.771

1 A fifty year analytical period is selected to be cons istent with economic analyses of prior Lead-based Paint Activities program rules and RRP program rules.

1 Information Collection Request for the TSCA Sections 402 and Section 404 Training, Certification, Accreditation and Standards for Lead-Based Paint Activities and Renovation, Repair, and Painting (EPA ICR No. 1715.13, OMB Control No. 2070-0155).*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

1-1 

## 1. Introduction

This report assesses the cost savings expected to resu lt from amendments to EPA’s Lead-based Paint (LBP) Activities rule and to the Residential Property Ren ovation rule. These amendments would eliminate EPA’s multi-jurisdiction registration fee in the abatement pr ogram and remove the hands-on requirement from the renovator refresher training course curriculum. This chapter provides background information on EPA’s lead-based paint (LBP) regulations, a brief summary of the methodology used in the analysis, and a description of the organization of the remainder of this report.


### 1.1 Regulatory and Programmatic Background

1.1.1 Abatement Multi-jurisdiction Registration Fee In 1996 EPA promulgated final regulations for Lead-based Paint Activities under TSCA §402(a) that govern LBP inspections, lead hazard scr eens, risk assessments, and lead ab atements in target housing and child-occupied facilities (61 FR 45778, codified at 40 CFR part 745). On June 9t h, 1999, EPA amended the regulations (64 FR 31092) to include a fee schedule for individuals and firms seeking EPA (re)certification and for training programs seeking EPA (re)accreditation. The fee schedule created a multi-jurisdiction registration fee of $35 per discipline for each additiona l EPA-administered jurisdiction (e.g., a state) in which an individual, firm, or tr aining program applies for (re)certification or (re)accreditation (40 CFR §745.238 (c)(3)). For purposes of this multi-jurisdiction registration fee, an EPA-administered jurisdiction is an individual state without an authorized program or all tribes without authorized programs in a given EPA Region. The EPA-administered jurisdictions for the lead abatement program are:

 States – Alaska, Arizona, Florida, Idaho, Montana, Nevada, New Mexico, New York, South Carolina, South Dakota, and Wyoming;

 U.S. territories – American Samoa, Guam, and the Northern Marianas; and

 Tribal lands – tribal lands except the Cherok ee Nation, Lower Sioux Nation, and Upper Sioux Community. All other states, U.S. territories, as well as the Cherokee Nation, Lower Sioux Nation, and Upper Sioux Community, have EPA-authorized LBP abatement programs (U.S. EPA 2014b).

1.1.2 Hands-on Refresher Training for Renovators In 2008, EPA issued a final rule for Residential Pr operty Renovations under the authority of §402(c)(3) of TSCA to address LBP hazards created by Renovation, Re pair, and Painting (RRP) activities that disturb LBP in target housing and child-occupied facilities ( 73 FR 21692). To become a certified renovator, an individual must successfully complete an appropria te training course accredited by EPA (40 CFR §745.90). Individuals who have not previously been trained must complete an initial training course lasting a minimum of eight hours, including a minimum of tw o hours of hands-on training. To maintain renovator certification, an individual must complete a refresh er course from an accredited training provider within five years of completing the initial course. The rule requires renovator refresher training courses to last a minimum of four hours (40 CFR §745.225 (e)(2)) and include a hands-on component (40 CFR §745.225 (e)(3)). EPA manages the RRP program in most areas of the country. However, the states of Alabama, Delaware, Georgia, Iowa, Kansas, Massachusetts, Mi ssissippi, North Carolina, Oklahoma, Oregon, Rhode Island, Utah, Washington, and Wisconsin are authorized to administer their own programs in lieu of the federal program. The proposed rule, and this analysis, apply only in states that do not have authorized
programs.*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

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### 1.2 Summary of Analytic Approach
This analysis seeks to quantify, to the extent possible, the cost savings to society of the two amendments. The costs to industry associated with the multi-juri sdiction registration fee include a $35 fee for each additional EPA-administered jurisdiction for which organizations apply to perform lead-based paint abatement activities or to provide lead abatement training. The cost savings to industry for eliminating the fee is the amount in fees that they would no longer be required to pay.

Costs to renovators associated with the refresher trai ning course currently include course tuition and travel cost to a training site to receive hands-on training. Tuition costs are estimated to decrease if the hands-on requirement is removed. For those renovators choosi ng to take the refresher course online, there is an additional cost savings because there is no travel co st. The cost savings from eliminating the hands-on requirement for renovator refresher training includes reductions in both average tuition cost and average travel cost.


### 1.3 Organization of This Report Regulated entities are characterized in Chapter 2. Chapter 3 includes the economic analysis of cost savings to regulated entities. The small entity impacts are di scussed in Chapter 4. Several additional impacts are described in Chapter 7. Cited references are listed in Chapter 8. The Appendix contains the tuition data for renovator initial and refresher training courses that were u sed in the analysis. Note that all dollar values in this analysis are reported in 2014 dollars.*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

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## 2. Affected Entities
2.1 Regulated Community
The multi-jurisdiction registration fee amendment may a ffect individuals, firms, and training providers regulated by the Lead-based Paint Activities rule, with the exception of non-profit training providers (which are exempt from the fee). The renovator refresher training course amendment directly affects individuals who must take a training course to comp ly with the Residential Property Renovation rule. The number of entities affected under both amendments is estimated from data in EPA’s Federal Leadbased Paint Program (FLPP) database (U.S. EPA 2014a).

Exhibit 2-1 presents the number of all applications submitted by individuals and firms engaging in leadbased paint activities, and all training providers o ffering lead-based paint activities training courses, from 2011 through 2013 (not just those applying to work in additional jurisdictions). Exhibit 2-1 also presents the number of additional jurisdictions in which i ndividuals and firms are sought (re)certification and training providers are sought (re)accreditation.

Exhibit 2-1: Lead-based Paint Activities Indivi duals and Firms Applying for (Re)certification and Training Providers Applying fo r (Re)accreditation from 2011-2013
Applicant Total Number of Applications Additional Jurisdictions Sought
Individuals 5,127 864
Firms 1,780 403 Training Providers (for-profit) 23 27

The RRP rule required that, starting in 2010, all regul ated renovations disturbing lead-based paint must be performed by renovators who have taken an 8 hour training course (including 2 hours of hands-on training). Renovators must take a 4 hour refresher training class (which currently includes a required hands-on component) every five years. Exhibit 2-2 presents the number of renovator certifications from 2010 through 2013. Column 1 of Exhibit 2-2 lists the year the certification was issued, and Column 2 lists the year the certification expires. The number of cer tifications was highest in 2010 because that was the year that the renovator training requirement became effective. Consequently, the number of refresher trainings is expected to be highest five years la ter (in 2015), and decline for several years at a rate analogous to the rate of decline observed in certifications from 2011 to 2013.

Exhibit 2-2: Renovator Initial Cert ifications under the Renovation, Repair, and Painting Program Rule from 2010 through 2013.

Year Certified Expiration Year Number of Initial Certifications
2010 2015 357,500
2011 2016 52,800
2012 2017 38,800
2013 2018 29,300*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-1 

## 3. Industry Cost Savings

3.1 Introduction This chapter presents estimates of the cost savings associated with the amendments. Section 3.2 presents estimates for the multi-jurisdiction registration fee am endment and Section 3.3 presents estimates for the renovator refresher training course amendment. Total co st savings of both amendments are summarized in Section 3.4. A fifty year analytical period is used in this to be consistent with prior economic analyses of abatement and RRP program rules. Net present value and annualized savings are presented for this time period using 3 and 7 percent discount rates.


### 3.2 Abatement Multi-jurisdicti on Registration Fee Amendment If jurisdictions are eliminated, regulated entities will no longer have to send an application and fees to EPA for the purpose of adding additional EPA-administe red state jurisdictions to their certification or accreditation. Once a regulated entity applies and is approved in the Lead-based Paint Activities program, it will be able to work in any EPA-administered stat e. EPA’s multi-jurisdiction registration fee data for 2011 through 2013 are presented in Ex hibit 3-1. Column 2 and Column 3 of Exhibit 3-1 present the total and annual average number of add itional EPA-administered jurisdictions for which organizations applied to perform lead-based paint activities or provide trai ning from 2011 through 2013, respectively. Note thatnon-profit training programs are excluded from the analysis because they are exempt from the multijurisdiction registration fee. The average annual cost s borne by regulated entities are summarized in the last column of Exhibit 3-1 and are calculated by applying the $35 multi-jurisdiction registration fee to Column 3. Removing the multi-jurisdiction fee would save individuals, firms, and training providers a combined $15,085 per year.

Exhibit 3-1: Annual Multi-jurisdiction Re gistration Fees for Individuals and Firms Applying for (Re)certification, and Training Providers Applying for (Re)accreditation

Applicant Additional Jurisdictions Total Annual Fees 2011 - 2013 Average Annual
Individuals 864 288 $10,080
Firms 403 134 $4,690 Training Providers (for-profit) 27 9 $315
Total 431 $15,085

Exhibit 3-2 presents the fifty year net present value and annualized cost savings under the proposed rule for individuals and firms applying for (re)certif ication, and training providers applying for (re)accreditation (2014$). The cost savings are discounted using rates of 3 and 7 percent.*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-2 Exhibit 3-2: Fifty Year Net Present Value and Annualized Cost Savings for Individuals and Firms Applying for (Re)certification, and Training Pr oviders Applying for (R e)accreditation (2014$)

Period Additional Jurisdictions Unit Incremental Cost Savings Incremental Cost Savings Discounted Incremental Cost Savings
3% 7%
2015 431 $35 $15,085 $14,646 $14,098
2016 431 $35 $15,085 $14,219 $13,176
2017 431 $35 $15,085 $13,805 $12,314
2018 431 $35 $15,085 $13,403 $11,508
2019 431 $35 $15,085 $13,012 $10,755
2020 431 $35 $15,085 $12,633 $10,052



# ⁞

2064 (year 50) 431 $35 $15,085 $3,441 $512

Net Present Value $388,133 $208,184 Annualized Cost Savings $15,085 $15,085


### 3.3 Renovator Refresher Training Course Amendment
Incremental training cost savings associated with the proposed amendment include tuition and travel cost. The cost of the time spent on training activities is not affected because the proposed rule does not change the duration of the refresher training course.

3.3.1 Tuition Under the existing rule, both the initial and refr esher renovator training courses consist of both a classroom and a hands-on component. The classroom co mponent can be taken in-person or online, whereas the hands-on component must be taken in -person. Under the proposed rule, the hands-on requirement would be rescinded from the refresher training course, allowing renovators to become recertified remotely solely by taking an e-learning course. Traveling to a training provider’s facility, or contracting a traveling training provider, would no longer be obligatory. The refresher training course tuition is estimated under both the existing rule (with a hands-on training requirement) and the proposed rule (no hands-on training requirement). Estimates are based on tuition data collected from the websites of a sample of training providers offering refresher a nd/or initial renovator trai ning. The tuition data and summary statistics can be found in Appendix A.

A renovator is currently able to enroll in an in-p erson classroom and hands-on refresher training course. (The current rule would allow a renovator to take an e-learning classroom and hands-on refresher training course, but no training providers currently offer re fresher training courses with an e-learning classroom component. 2 ) The mean tuition for an in-person classroom and hands-on refresher training course is

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

renovators will not need to be recertif ied until 2015. The refresh er course has so far only been offered to renovators with prior lead-safety traini ng in order to receive certification un der the RRP rule. In 2015, when the refresher training course is in its highest demand, traini ng providers will offer the course more frequently and may offer an e-learning option as well.*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-3 $134.65 (see Appendix A). Based on data from initial renovator training courses 3 , it appears that training providers tend to charge the same tuition whether th e classroom component is taught in-person or online. From the sample of training provider course tuiti ons, four training providers listed tuitions for both options on their websites. Three of the four training providers offered both options for the same tuition. Accordingly, it is assumed that if a refresher training course with an e-learning classroom component and a hands-on component were offered, the mean tuition would also be $134.65 (identical to the tuition for a course with an in-person classroom component). As shown in Appendix A, the mean tuition for the 8 hour initial renovator training course (which includes 2 ho urs of hands-on training) is $214.86. The mean tuition for the 2 hour hands-on training component by itself is estimated to be $150.02.

Removing the hands-on requirement is expected to make online renovator refresher training more attractive to training providers and renovators. 4 Under the proposed rule, a renovator can enroll in an in-person or an e-learning classroom refresher training course. While the tuition for an e-learning classroom refresher training course is assumed to be th e same as for an in-person class, it is worth noting that the e-learning classroom refresher training course tuition could be less expensive than the in-person option. For example, lower overhead costs may allo w training providers to offer the course at a lower price, or new firms that have a competitive advant age in providing e-learning courses may begin offering the renovator refresher training course. 5

The procedure to estimate the tuition for the classroo m portion of a refresher course relies on the mean tuition for an initial and refresher training course, a nd the mean tuition for the hands-on component of an initial training course. The estimated tuition for an in-person classroom refresher training course is $97.68. The steps taken to produce this estimate are detailed in Exhibit 3-3.

The difference between the tuition of $134.65 (for an in-person refresher course with a hands-on component) and $97.68 (for an in-person refresher co urse without a hands-on component) is $36.97. This $36.97 in savings results from decreases in the co st of supplies and instruction if the hands-on requirement is removed. 6

3 Unlike for refresher training, there are training provide rs currently offering the classroom portion of the initial renovator course online.

4 There may be less incentive for training providers to o ffer an e-learning option – or for renovators to take advantage of it – if there is a hands-on training requirement. If the renovator and/or the in structor are traveling to the training site, they are incurring the trav el costs whether or not the classroom portion is taken in-person or online. If the hands-on requirement is removed the renovator can ta ke the entire refresher course online, eliminating these travel costs. This makes e-learning more attractiv e to both the renovator and the training provider.

5 Currently, many e-learning courses for initial training are developed by third party firms and are offered by

training providers who package the course with their hands-on training course.

6 The cost of providing instruction decreases if the hands-on component is removed because the recommended student teacher ratio is 6-to-1 for the hands-on component of the course, compar ed to 25-to-1 for the rest of the inperson classroom course. The tuition for the hands-on component also covers the cost of various supplies (such as EPA-recognized test kits, disposable plastic drop cloths, tape, electrostatically charged cleaning cloths, disposable wet cleaning wipes, garbage bags, and so on) for each student.*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-4 Exhibit 3-3: Procedure to estimate in-p erson classroom refresher training course tuition
Estimation Steps Value Formula Tuition data (mean) (A) Initial Course $214.86 (B) Refresher Course $134.65 (C) Hands-on Training (2 hours) $150.02
Derived estimates (D) Cost of 3 classroom hours and 1 hands-on training hour $80.21 (A) - (B) (E) Fixed cost of Initial Course $54.44 (B) - (D) (F) Incremental costs of 2 hours of hands-on training $95.58 (C) - (E) (G) Hands-on training cost per hour $47.79 (F) ÷ 2 (H) Cost of 3 classroom hours $32.42 (D) - (G) (I) Classroom cost per hour $10.81 (H) ÷ 3 In-person classroom refresher training course, 4 hours $97.68 (E) + [4 * (I)]
Note: Unlike the initial training course, there is no ma ndatory duration for the hands-on component of the refresher course. The ha nds-on portion of the initial course must be at least 2 hours, which is 25% of the total 8 hours of training. So for the refresher course, the hands-on component is assumed to be 1 hour, which is 25% of the 4 hour duration of the refresher course.

Exhibit 3-4 presents a summary of the estimated re fresher training course tuitions under the existing and proposed rule.

Exhibit 3-4: Estimated refresher training tuition summary
Existing Rule

In-person classroom and in-person hands-on $134.65 E-learning classroom and in-person hands-on $134.65 Proposed Rule removing hands-on requirement

In-person classroom (no hands-on) $97.68 E-learning classroom (no hands-on) $97.68

3.3.2 Travel Cost
Travel cost consists of the cost for a renovator to tr avel to the training site, incidental expenses, and the value of the time spent traveling to and from the trai ning site. The estimated cost of travel relies on the Standard Mileage Rates published by the Internal Revenue Service (IRS). The IRS published a rate of $0.56 per mile, effective January 1 st , 2014 (IRS 2013). The travel distance is assumed to be 100 miles (50 miles each way), as in the 2008 economic analysis of the RRP program rule (U.S. EPA 2008). The total cost of travel is estimated to be $56. Expenses co mprise the cost of lunch and are estimated using the Meals and Incidental Expenses Breakdown published by the General Services Administration. These expenses are estimated to be $14.17 and are calculated by averaging the six tiers of lunch reimbursement rates representing the lower 48 states (GSA 2014).

The travel duration and the average renovator wage rate are used to estimate the cost of renovators’ time to travel to a training site. Travel duration is assume d to be two hours, as in the 2008 economic analysis of the RRP program rule (U.S. EPA 2008). The wage ra te assigned to renovators is derived with methods*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-5 and from sources identical to or similar to those used in previous Information Collection Request renewals and economic analyses for EPA’s RRP pr ogram. A renovator’s fully loaded wage rate incorporates wages and salaries, benefits, and overh ead. A renovator’s wages and salaries are represented by the mean hourly wage rate of First-Line Superv isors of Construction Trades and Extraction Workers, published by the Bureau of Labor Statistics (BLS) - Occupational Employment Statistics (OES). The mean hourly wage rate inflated to 2014 dollars is $31.12 for First Line Supervisors of Construction Trades and Extraction Workers (BLS 2012; BLS 2014). The base wage rate is inflated to 2014 dollars by applying the Consumer Price Index (CPI) for All Urban Consumers published by the Bureau of Labor Statistics (BLS 2014). The September 2013 release of the BLS Employer Costs for Employee Compensation (ECEC) data indicates that wages a nd salaries constitute 69.1% of total employee compensations for civilian workers, implying a wa ge multiplier of 1.45 to account for benefits (BLS 2013). An overhead of 8.3% is derived from the 2012 publication of the Cost of Doing Business (NAHB Business Management & Information Technology 2012) . By combining 1.45 and 8.3%, a multiplier of 1.53 is used to estimate a fully loaded hourly wage rate of $47.61 for renovators. Taking into account the total travel duration of two hours, the cost of travel time for a renovator attending training is estimated to be $95.22.

Exhibit 3-5 summarizes the components of the travel cost to attend in-person training.

Exhibit 3-5: Total Renovator Travel Cost
Category Cost Mileage Cost $56.00 Expenses (lunch) $14.17
Cost of Travel Time $95.22
Travel Cost $165.39

3.3.3 Incremental Training Cost Savings per Renovator Exhibit 3-6 presents the incremental training cost savings per renovator seeking recertification under the proposed rule. The cost savings includes reduced tu ition and avoided travel co sts. Renovators switching to the e-learning course realize the greatest cost sav ings because they avoid the costs associated with traveling to a training provider’s facility.

Exhibit 3-6: Incremental Renovator Tr aining Cost Savings under the Proposed Rule

Training Course Existing Rule Costs Proposed Rule Costs Cost Savings
In-person classroom
Tuition $134.65 $97.68 $36.97
Travel Cost $165.39 $165.39 0
Total $300.04 $263.07 $36.97 E-learning classroom
Tuition $134.65 $97.68 $36.97
Travel Cost $165.39 0 $165.39
Total $300.04 $97.68 $202.36*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-6 3.3.4 Number of Individuals Seeking Renovator Recertification Renovator training and certification for persons conducting covered renova tion activities became mandatory in 2010, and a large number of renovators were trained that year. There was a decrease in the number of individuals trained in 2011, and a furt her decrease in 2012 and 2013. The total number of renovators expected to seek refresher training in 2015 through 2018 is estimated using certification expiration data for the current stock of trained a nd certified renovators (see Exhibit 3-7) and an assumed turnover rate for renovators exiting the industry. The total number of renovators expected to seek training in 2019 is assumed to equal the total in 2018 because e xpiration data is not yet available for that year. Beyond 2019, it is assumed that the total number of renovators expected to seek training each year will stabilize. Exhibit 3-7 presents the total number of re novators expected to seek training from 2015 through 2064, as well as the subset expected to seek refresher training.

The number of expired certifications presented in Colu mn 2 of Exhibit 3-7 is equal to the number of initial certifications attained five years earlier. Each year, some certified individuals exit the industry and are replaced by new entrants who seek initial training and certification. Due to this turnover, the number of individuals seeking renovator refresher training an d recertification will be less than the numbers of individuals with expiring certifica tions (which represents the total number of individuals assumed to be trained each year).

It is assumed that 53 percent of the stock of renova tors seeking training exits the industry during the five year certification period. This turnover rate is b ased on the average percent of Abatement Supervisor applications that are for initial certification, reco rded in the FLPP database between 2007 and 2009 (U.S. EPA 2010). Therefore, the number of renovators seeking re fresher training in a given year is equal to the number of renovators that remained active throughout the certification period, which is 47 percent of the number of renovators trained five years earlier (see Column 2 of Exhibit 3-7). The other 53 percent are assumed to exit the industry and be replaced by new entrants who take the initial training course.

Because renovators were required to be trained and certified starting in 2010 and because renovator training and certification is valid for five years, a large number of renovators are expected to seek refresher training in 2015, with a decrease in 2016, 2017, and 2018. Beginning in 2020, the number of renovators seeking training each year is assumed to equ ilibrate to 101,540, one fifth of the total stock of certified renovators. The total stock of certified renovators is equal to the sum of expiring certifications from 2015 through 2019 (507,700 renovators).

The number of renovators receiving initial training decreased each year from 2010 through 2013. One might expect a spike in refresher training starting in 2015 followed by a decrease for the next four years, followed by another spike in 2020, with a repeating patte rn every five years. That is, one might expect a cyclical pattern of retraining to emerge. However, ove r time the original cohort of trained individuals will retire or leave the market and be replaced by new renova tors whose training cycle is not tied to the start of the RRP program in 2010. So the cycle will be damp ened and eventually disappear. Trying to model such a trend in the declining cycli cality would add litt le to the analysis while significantly increasing the complexity of the calculations. Instead, the analysis uses a declining level for the first cycle of refresher training (because this mirrors the histori cal data on initial training shown in Exhibit 3-7 ). Then, in order to simplify the calculations, the analysis assumes a consta nt average number of individuals receive refresher training each year starting in 2020.*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-7 Exhibit 3-7: Expected Number of Renovators Seeking Training

Year 1 Number of Renovators Seeking Initial or Refresher Training 1 Renovators Seeking Refresher Training 2

2015 357,500 168,025
2016 52,800 24,816
2017 38,800 18,236
2018 29,300 13,771
2019 29,300 13,771 Average for 2015-2019 101,540 47,723
2020 101,540 47,723



# ⁞

2064 (year 50) 101,540 47,723

1 The number of renovators seeking training in 2019 is assumed to equal the number in 2018.

2 Each year 47 percent of renovators with expiring certifications are expected to seek refresher training. The other

53 percent are assumed to exit the industry, and be replaced by new entrants who take the initial training course.

If the refresher hands-on training requirement is re moved, renovators seeking refresher training would have the option to become recertified by enrolling in an in-person course or an e-learning course. Ninety-eight percent of renovators seeking training are assumed to enroll in an e-learning course due to the convenience of taking the course online and the savings in travel costs. 7 The remaining 2 percent of renovators are assumed to continue taking in-person tr aining after the amendment because they prefer to take their training in class rather than online. Enro llment expectations are summarized in Exhibit 3-8.

Exhibit 3-8: Expected Number of Renovators Seeking In-person and E-learning Refresher Training Options

Year 1 In-person E-learning
2015 3,361 164,665
2016 496 24,320
2017 365 17,871
2018 275 13,496
2019 275 13,496 Average for 2015-2019 954 46,769
2020 954 46,769



# ⁞

2064 (year 50) 954 46,769

1 The number of renovators seeking training in 2019 is assumed to equal the number in 2018.

7 The 98% value is a demonstrative assu mption for analytical purposes. It is not based on experience with any other training programs, such as the initial renovator training. (Because the initial renovator training requires hands-on training, as well as travel expenses, th at online training does not result in comparable cost savings or adoption rates.)*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-8 3.3.5 Total Renovator Training Costs Savings Exhibit 3-9 and Exhibit 3-10 present the net present valu e and annualized cost savings under the proposed rule, over a fifty year period from 2015 through 2064, for the in-person and e-learning classroom refresher training courses, respectively. The cost savi ngs are discounted using rates of 3 and 7 percent.

Exhibit 3-9: Fifty Year Net Present Value and Annua lized Cost Savings for Renovators Seeking In-person Classroom Training Under th e Proposed Rule (2014$)

In-person classroom training Recertifications Unit Incremental Cost Savings Incremental Cost Savings

(1,000$) Discounted Incremental Cost Savings (1,000$)
3% 7%
2015 3,361 $36.97 $124 $121 $116
2016 496 $36.97 $18 $17 $16
2017 365 $36.97 $13 $12 $11
2018 275 $36.97 $10 $9 $8
2019 275 $36.97 $10 $9 $7
2020 954 $36.97 $35 $30 $24 

# ⁞

2064 (year 50) 954 $36.97 $35 $8 $1

Net Present Value $914 $500 Annualized Cost Savings $36 $36

Exhibit 3-10: Fifty Year Net Present Value and An nualized Cost Savings for Renovators Seeking E-learning Classroom Training Under the Proposed Rule (2014$)

E-learning classroom training Recertifications Unit Incremental Cost Savings Incremental Cost Savings

(1,000$) Discounted Incremental Cost Savings (1,000$)
3% 7%
2015 164,665 $202.36 $33,322 $32,351 $31,142
2016 24,320 $202.36 $4,921 $4,639 $4,298
2017 17,871 $202.36 $3,616 $3,310 $2,952
2018 13,496 $202.36 $2,731 $2,426 $2,083
2019 13,496 $202.36 $2,731 $2,356 $1,947
2020 46,769 $202.36 $9,464 $7,926 $6,306 

# ⁞

2064 (year 50) 46,769 $202.36 $9,464 $2,159 $321

Net Present Value $245,249 $134,230 Annualized Cost Savings $9,532 $9,726

Exhibit 3-11 presents the combined net present value and annualized incremental cost savings accrued by renovators over a fifty year period from 2015 through 2064, under the proposed rule. Costs are discounted using rates of 3 and 7 percent.*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-9 Exhibit 3-11: Combined Fifty Year Net Present Value and Annualized Renovator Recertification Cost Savings Under th e Proposed Rule (thousands 2014$)

Category Net Present Value Annualized Costs
3% 7% 3% 7% Proposed Rule Cost Savings $246,163 $134,730 $9,568 $9,762



### 3.4 Total Industry Cost Savings
The net present value and annualized industry co st savings for both proposed amendments are summarized in Exhibit 3-12. These savings reflect a 50 year period from 2015 through 2064, and are discounted using rates of 3 and 7 percent. The net present value of the industry cost savings ranges from $134,938 thousand to $246,551 thousand, in 2014$. Annualized industry cost savings are expected to range from $9,583 thousand to $9,777 thousand per year, in 2014$.

Exhibit 3-12: Total and Annualiz ed Industry Cost Savings of the Proposed Amendments Over 50 Years (thousands 2014$)

Category Net Present Value Annualized Cost Savings
3% 7% 3% 7% Multi-jurisdiction Amendment $388 $208 $15 $15 Refresher Training Amendment $246,163 $134,730 $9,568 $9,762 Total Industry Cost Savings $246,551 $134,938 $9,583 $9,777



### 3.5 Other Industry Costs

3.5.1 Abatement Multi-jurisdiction Registration Fee Amendment EPA does not anticipate other direct or indirect im pacts resulting from the proposed rule that would cause entities regulated under the abatement program to ex perience increases or reductions in their costs.

3.5.2 Renovator Refresher Training Course Amendment Individual training providers offering RRP training c ourses could be negatively impacted by the proposed rule if (1) their profit margins are lower for the e-l earning course, or (2) they lose market share with the introduction of the e-learning course.

Under the proposed rule, a much larger portion of re novators are expected to enroll in the e-learning refresher training course than the e-learning componen t of the initial training course. This is because renovators would not have to travel to a training f acility in the absence of a hands-on refresher training requirement. (By contrast, renovators taking the initial tr aining course will still have to travel to take the hands-on portion.) If training providers do not develop their own e-learning course, they must contract a third-party firm to offer the course online. In this scen ario, training providers will incur costs in the form of fees paid to the third-party firms to develop and administer the e-learning courses. At the same time other training provider costs, such as classroom space and faculty costs, will decrease. In addition, tuition is expected to be lower if the hands-on requirement is removed. Thus, tuition is expected to decrease*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-10 while some costs are expected to increase and others are expected to decrease. Many uncertainties and data gaps exist about the extent to which individua l training provider profit margins might change. Some training providers may exit the market, others may a dd market share, and new entrants might also seek training provider accreditation. Alternatively, if many renovators choose to take refresher training from the provider of their initial training, there may be little change in market shares.

Third-party firms developing renovator e-learning re fresher training courses could decide to become accredited RRP training providers. In this scenario, th ird-party firms could gain a large portion of the market share due to their competitive advantage gain ed by experience and economies of scale. Assuming there are relatively few third-party firms developing e-learning courses, the proposed rule could result in the consolidation of the market of training prov iders offering refresher training courses. While there would not be a net loss to the economy, training provide rs unable to compete with third-party firms that might attain accreditation would likely experience redu ced profits or exit the refresher training market (although they might continue to offer initial certification training).*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

4-1 

## 4. Agency Costs

EPA will incur costs resulting from the new rule asso ciated with reviewing the expedited e-learning applications submitted by training provi ders to attain accreditation. It is estimated to take an average of 4 hours apiece for an Agency employee to review each of the 275 applications. The base wage rate of the federal government employee review ing applications is taken from the 2014 General Schedule (GS) Locality Pay Table for Washington-Baltimore-Northern Virginia, published by the Office of Personnel Management (OPM). A loaded wage rate of $78.13 is then derived by applying a 1.6 fringe benefits and overhead multiplier to the base wage rate of a GS- 13 Step 5 government employee (see Exhibit 4-1) (OPM 2014). The 1.6 fringe benefits a nd overhead multiplier is taken from the ICR Handbook- EPA’s Guide to Writing Information Collection Requests , published in 2009 (U.S. EPA 2009).

Exhibit 4-1: EPA Wage Rate

Labor Category Date Base Wage 1 Fringe Benefits and Overhead Multiplier 2 Loaded Wages (a) (b) (c)=(a)*(b) GS-13 Step 5 1/14 $48.83 1.6 $78.13

1 Office of Personal Management (2014). 2014 General Schedule (GS) Locality PayTables: WASHINGTON-BALTIMORE-NORTHERN VIRGINIA, DC-MD-VAWV-PA. SALARY TABLE 2014-DCB .

2 U.S. EPA (2009). "ICR Handbook- EPA’s Guide to Writing Information Collection

Requests."
Exhibit 4-2 presents net present value and annualized cost accrued by EPA over a fifty year period from 2015 through 2064, under the proposed rule. Costs are di scounted using rates of 3 and 7 percent. It is not known how many training providers will only offer refr esher training online and how many will maintain dual accreditations (one for in-person training and one for online training). Therefore, it is unknown whether there will be a change in the number of r eaccreditation applications af ter 2015. If most training providers begin offering refresher training only on line, EPA’s work load for reviewing accreditation applications would not change much in future year s since the training providers would be substituting an online accreditation for one that is in-person. As a result, the analysis only considers EPA’s costs for reviewing additional accreditati on applications in 2015.

Exhibit 4-2: Fifty Year Net Present Value and Annualized Cost to EPA Under the Proposed Rule (2014$)

Application Review Costs Hours per Application Cost per Application ($78.13/hour) Applications Reviewed Total Cost Discounted Total Cost

3% 7%

2015 4.00 $312.52 275 $85,943 $83,440 $80,321

Net Present Value $83,440 $80,321
Annualized Cost $3,243 $5,820*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

5-1 

## 5. Social Cost Savings

The estimated total social cost savings of the proposed rule is equal to the sum of industry cost savings less Agency costs. Exhibit 5-1 presents the net present value and annualized equiva lent value of expected cost savings to society over a fifty year period ranging from 2015 to 2064. Estimates are discounted using rates of 3 and 7 percent.

Exhibit 5-1: Total and Annualized Social Cost Savings of the Proposed Amendments Over 50 Years (thousands 2014$)

Category Net Present Value Annualized Cost Savings
3% 7% 3% 7% Industry Cost Savings $246,551 $134,938 $9,583 $9,777

Multi-jurisdiction Amendment $388 $208 $15 $15 Refresher Training Amendment $246,163 $134,730 $9,568 $9,762

Total Agency Costs $83 $80 $3 $6

E-learning Application Processing $83 $80 $3 $6
Social Cost Savings $246,468 $134,858 $9,580 $9,771*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

6-1 

## 6. Small Entity Impact Analysis

The Regulatory Flexibility Act (RFA) of 1980, amen ded by the Small Business Regulatory Enforcement Fairness Act (SBREFA) of 1996, requires regulators to assess the effects of regulations on small entities including businesses, nonprofit organizations, and govern ments. In some instan ces, agencies are also required to examine regulatory alternatives that may reduce adverse economic effects on significantly impacted small entities. The RFA requires agencies to prepare an initial and final regulatory flexibility analysis for each rule unless the Agen cy certifies that the rule will not have a significant economic impact on a substantial number of small entities.

The proposed rule would eliminate multi-jurisdiction registration fees and eliminate the hands-on training requirement from the lead renovation refresher training course, resulting in cost savings for entities that no longer would pay the multi-jurisdiction registra tion fees and renovators that would have a less expensive refresher training option available to th em. Training providers might incur costs associated with accrediting e-learning courses. However, it is exp ected that only training providers that anticipate recovering accreditation costs through tuition charges would opt to apply for the additional accreditation because there is no requirement mandating these firms to offer an e-learning refresher training option under the proposed rule. Therefore, there would be no direct negative cost impacts on small entities as a result of the proposed rule.*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

7-1 

## 7. Other Impact Analyses

Several statutes and executive orders (EOs) pertain to the proposed rule. This chapter presents statements discussing unfunded mandates, envi ronmental justice, children’s health, and paperwork burden, among others.


### 7.1 Paperwork Reduction Act The Paperwork Reduction Act of 1995 (PRA) (supers eding the PRA of 1980), as implemented by the Office of Management and Budget (OMB), requires that agencies submit a supporting statement to OMB for any information collection th at solicits the same data from more than nine parties. The PRA seeks to ensure that Federal ag encies balance their need to collect information with the paperwork burden imposed on the pub lic by the collection. The definition of “information collection” includes activities require d by regulations such as permit development, monitoring, recordkeeping, and reporting. The term “burden” refers to the “time, effort, or financial resources” the public expends to provide in formation to or for a Federal agency, or to otherwise fulfill statutory or regulatory require ments. PRA paperwork burden is measured in terms of annual time and financial resources th e public devotes to meet one-time and recurring information requests (44 U.S.C. 3502(2); 5 C.F.R. 1320.3(b)). Information collection activities may include:

 reviewing rule requirements;

 using technology to collect, process, and disclose information;

 adjusting existing practices to comply with requirements;

 searching data sources;

 completing and reviewing the response; and

 transmitting or disclosing information. Agencies must provide information to OMB on th e parties affected, the annual reporting burden, and the annual cost of responding to the information collection.

7.1.1 Industry Burden RPP Training Provider Burden Currently accredited training providers that wish to add an already reviewed and accepted RRP e-learning course from another training provider to their training curriculum are eligible for an expedited e-learning course approval. All requ ests to add an already-reviewed e-learning curriculum to an already-accredited training provi ders' record must include a cover letter; a training provider application to amend their accred itation; and an e-learning quality control (QC) plan. The e-learning QC plan must address is sues such as how the trainer will ensure that students successfully complete the e-learning modules and the e-learning module final assessment. Training providers that are already accredited are not charged a fee when adding an already-reviewed e-learning curriculum.

Training providers currently accredited for the renova tor refresher training course are expected to apply for an e-learning refresher training accredita tion if the hands-on requi rement is removed. Therefore they would incur an incremental pape rwork burden. Training providers applying for accreditation incur a one-time burden associated w ith becoming familiar with the new rule’s requirements, as well as the burden of completing the accreditation application. Recordkeeping burdens and reporting burdens associated with notification are not incorporated into the incremental burden because they are incurre d with or without this proposed rule.*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

7-2 There are 275 training providers with accredited renovator refresher training programs. It is estimated that renovation training providers will spend half as long on becoming accredited for an e-learning refresher training course as on initial accr editation for an initial training course. (Less information needs to be provided for an expedite d e-learning application, given that the training provider has already been accredite d for an in-person course.) Bu rden for the initial accreditation of an initial renovation training course is take n from the previously approved ICR (EPA No. 1715.13). Burden hour estimates were rounded to one decimal place for this ICR. The resulting burden is estimated to be 4 hours for training provi ders to familiarize themselves with the rule requirements; 4.8 hours to complete the accredita tion statement; and 5 hours to complete the Quality Control Plan (see Exhibit 7-1).

Wage rates for each category of personnel are derived with methods and from sources either identical or very similar to those used in prev ious ICRs and economic analyses. Loaded wage rates of $53.66 and $26.79 represent training provider wages for professional and clerical workers, respectively. Wage and fringe benefits data are taken from the Employer Cost for Employee Compensation data series published by the Bureau of Labor Statistics (BLS 2013). Both the professional and clerical base wage rates are inflated to 2014 dollars by applying the CPI for All Urban Consumers published by the Bureau of Labor Statistics (BLS 2014). The overhead data is taken from Wage Rates for Economic Analyses of The Toxics Release Inventory Program (U.S. EPA 2002). The overhead loading factor is added to the benefits loading factor, and the total is then applied to the base wage to deri ve the fully loaded wage. See Exhibit 7-2 for a detailed derivation of the training provider loaded wage rates.

Exhibit 7-1: Incremental RRP Trai ning Provider Hour Burden

Activity Professional Hours 1 Clerical Hours 1 Burden Hours Per Activity 1 Number of Training Providers Number of Events Per Provider 2 Total Burden Hours E-learning Accreditation

Rule Familiarization 4.00 0.00 4.00 275 1 1,100
Accreditation Statement 3.80 1.00 4.80 275 1 1,320 Quality Control Plan 4.00 1.00 5.00 275 1 1,375 Total Reporting 11.80 2.00 13.80 275 1 3,795

1 Burden hour estimates per activit y for an expedited e-learning application are assu med to be half the burden in the previously

approved ICR EPA No. 1715.13. The hour estimates we re rounded to one decimal place for this ICR.

2 Number of events are from the previously approved ICR EPA No. 1715.13.*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

7-3 Exhibit 7-2: Loaded RRP Training Provider Wage Rates

Labor Category Occupation Category (BLS) 1 Date Base Wage 1 Fringe Benefits Benefits (% of Wage) 1 Overhead (% of Wage) 2 Wage Multiplier Loaded Wages 3

(a) (b) (c) =(b)/(a) (d) (e) =1+(c)+(d) (f) =(a)*(e)

Professional Professional and related 9/12 $33.96 $13.92 41% 17% 1.58 $53.66

Clerical Office and administrative support 9/12 $16.64 $7.32 44% 17% 1.61 $26.79

1 Bureau of Labor Statistics (BLS). (2013, Dec. 11). "Employe r Costs for Employee Compensa tion - September 2013." Private

industry workers, goods-producing and service-producing.

2 U.S. EPA (2002). Wage Rates for Economic Analyses of The Toxi cs Release Inventory Program, U.S. Environmental Protection

Agency, Office of Environmental Information, Environm ental Analysis Division, Analytical Support Branch.

3 Wage rates are rounded to the closest penny.

As shown in Exhibit 7-1, training providers woul d incur an incremental burden of 3,795 hours. Exhibit 7-3 presents the incremental costs to training providers associated with new training program accreditation, which are estimated to be $188,861. 8 Wage rates of $53.66 and $26.79 are applied to the professional and clerical hour burdens, respectively, to calculate costs.

Exhibit 7-3: RPP Incremental Tr aining Provider Cost (2014$)

Cost Element Professional Costs ($53.66/hour) Clerical Costs ($26.79/hour) Costs per Activity Number of Training Providers Events per Training Provider Total Cost 1

E-learning Accreditation

Rule Familiarization $214.64 $0.00 $214.64 275 1 $59,026
Accreditation Statement $203.91 $26.79 $230.70 275 1 $63,442 Quality Control Plan $214.64 $26.79 $241.43 275 1 $66,393 Total Reporting $633.19 $53.58 $686.77 275 1 $188,861

1 Wage rates of $53.66 and $26.79 are applied to the pr ofessional and clerical hour burdens, respectively.



### 7.2 Unfunded Mandates Reform Act

Title II of the Unfunded Mandates Reform Ac t of 1995 (UMRA), 2 U.S.C. 1531-1538, directs agencies to assess the effects of significant regulatory actions that impose Federal mandates on State, local, and tribal governments, and the pr ivate sector. This proposed rule would not impose an enforceable duty on any State, local or tr ibal governments or the private sector, nor does it contain any regulatory requirements that might significantly or uniquely affect small governments. Training providers (both those in the private sector as well as local or tribal

8 The cost of training providers becoming accredited is incorporated in to the tuition they charge their students, so the labor cost of the accreditation is not listed separately in the social cost estimate for the rule. But since the activity involves disclosing informati on, it is accounted for separately as part of the paperwork burden analysis.*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

7-4 governments) that choose to offer e-learning refr esher renovator training would incur a cost to apply for accreditation of their e-learning cour ses. However, only trai ning providers that anticipate recovering accreditation costs through tuition charges would opt to apply for the additional accreditation because there is no requirement mandating these firms to offer an e-learning refresher training option under the proposed rule.



### 7.3 Executive Order 13132 – Federalism Executive Order 13132 (64 FR 43255, August 10, 1999) applies to policies that have substantial direct effects on the States, on the relationship be tween the national government and the States, or on the distribution of power and responsibilities am ong the various levels of government. This proposed rule would not have substantial direct effects on the States, on the relationship between the national government and the States, or on the distribution of power and responsibilities among the various levels of government. Local govern ments can serve as training providers, and thus might incur costs associated with accrediting their e-learning courses as a result of this action. However, only training providers that anticip ate recovering accreditation costs through tuition charges would opt to apply for the additiona l accreditation because there is no requirement mandating these firms to offer an e-learning refresher training option under the proposed rule.



### 7.4 Executive Order 13175 – Consultati on and Coordination with Indian Tribal Governments Executive Order 13175 (65 FR 67249, November 9, 2000) directs agencies to consult and collaborate with tribal officials in Federal policy decisions that have tribal implications. This proposed rule would not have tribal implicati ons. Tribal governments can serve as training providers, and thus might incur costs associa ted with accrediting their e-learning courses. However, only training providers that anticip ate recovering accreditation costs through tuition charges would opt to apply for the additiona l accreditation because there is no requirement mandating these firms to offer an e-learning refresher training option under the proposed rule.



### 7.5 Executive Order 13045 - Children’s Health
Executive Order 13045 (62 FR 19885, April 23, 1997) applies to rules that are economically significant and that concern health or safet y risks that EPA has reason to believe may disproportionately affect children. This action is not an economically significant regulatory action as defined by Executive Order 12866 because it is not likely to result in a rule that may have an annual effect on the economy of $10 0 million or more, or adversely affect in a material way the economy, a sector of the economy, productivity, competition, jobs, the environment, public health or safety, or State, local or tribal governments or communities.


### 7.6 Executive Order 13211 – Energy Supply, Distribution, or Use Executive Order 13211 (66 FR 28355, May 22, 2001 ) addresses actions that effect the supply, distribution, or use of energy. This proposed rule is not likely to have any adverse effect on the supply, distribution, or use of energy.


### 7.7 National Technology Transfer and Advancement Act
Section 12(d) of NTTAA, 15 U.S.C. 272 note, directs agencies to use voluntary consensus standards in their regulatory activities unless to do so would be inconsistent with applicable law*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

7-5 or otherwise impractical. Voluntary consen sus standards are technical standards ( e.g. , materials specifications, test methods, sampling procedures, and business practices) that are developed or adopted by voluntary consensus standards bodies. This proposed rule does not involve technical standards.



### 7.8 Executive Order 12898 – Environmental Justice Executive Order 12898 (59 FR 7629, February 16, 1994) establishes federal executive policy on environmental justice. Its main provision di rects federal agencies, to the greatest extent practicable and permitted by law, to make envi ronmental justice part of their mission by identifying and addressing, as appropriate, dispropor tionately high and adverse human health or environmental effects of their programs, polici es, and activities on minority populations and lowincome populations in the United States.
This proposed rule does not directly affect the le vel of protection provided to human health or the environment. This is a rule amendment that removes multi-jurisdiction fees for lead-based paint activities and removes the hands-on requirement fo r refresher renovator training. However, it does not change the work practice requirement s for lead-based paint activities or renovation, repair or painting activities disturbing lead-based paint.*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

8-1 

## 8. References

Bureau of Labor Statistics (BLS). (2012, Mar. 29, 2013). "Occupational Employment Statistics - Occupational Employment and Wages, May 2 012, 47-1011 First-Line Supervisors of Construction Trades and Extraction Worker s." Retrieved Jan. 30, 2014, from http://www.bls.gov/oes/current/oes471011.htm#(2)

. Bureau of Labor Statistics (BLS). (2013, Dec. 11). "Employer Costs for Employee Compensation - September 2013." Retrieved Jan. 30, 2014, from http://www.bls.gov/news.release/archives/ecec_12112013.pdf

. Bureau of Labor Statistics (BLS). (2014). "Consum er Price Index - All Urban Consumers, U.S. City Average (2004 to 2014)." CUSR0000SA0 Retrieved Mar. 21, 2014.

Internal Revenue Service (IRS). (2013, Dec. 6). " 2014 Standard Mileage Rates." Retrieved Mar. 19, 2014, from http://www.irs.gov/2014-Standard-Mil eage-Rates-for-Business,-Medicaland-Moving-Announced

. NAHB Business Management & Information Technol ogy (2012). Cost of Doing Business Study, 2012 Edition, NAHB BuilderBooks.com®.
Office of Personal Management (OPM) (2014) . 2014 General Schedule (GS) Locality PayTables: WASHINGTON-BALTIMORE-NORTHERN VIRGINIA, DC-MD-VA-WVPA. SALARY TABLE 2014-DCB
U.S. EPA (2002). Wage Rates for Economic Analyses of The Toxics Release Inventory Program, U.S. Environmental Protection Agency, Office of Environmental Information, Environmental Analysis Division, Analytical Support Branch.
U.S. EPA (2008). Economic Analysis for th e TSCA Lead Renovation, Repair, and Painting Program Final Rule for Target Housing and Child-Occupied Facilities.

U.S. EPA (2009). "ICR Handbook- EPA’s Guide to Writing Information Collection Requests."

U.S. EPA (2010). "Federal Lead-Based Paint Program (FLPP) Database 2007-2009."

U.S. EPA (2014a). "Federal Lead-Based Paint Program (FLPP) Database 2010-2013."

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. U.S. General Services Administration (GSA). (2014, Jan. 14). "Meals and Incidental Expenses (M&IE) Breakdown." Retrieved Jan. 30, 2014, from www.gsa.gov/mie

.*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

A-1 

### Appendix A. Training Courses Tuition Data

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

Company Initial Refresher Complete Hands-on Complete Access Training $195.00 $150.00 AEHS, Inc. $200.00 $140.00 Analytical Testing and C onsulting Services, Inc. $150.00 Benchmark Envir onmental Training $165.00 Benchmark Envir onmental Training $200.00 Cardno ATC $225.00 $135.00 CEI CNY Environmental Institute $150.00 $135.00 CEI CNY Environmental Institute $175.00 Chem Scope $180.00 $125.00 Contractor Training 1 $160.04 Environmental Education $145.00 Environmental Management Institute $280.00 $180.00 GEBCO Associates, LP $220.00 $200.00 Greenville Technical College $215.00 $150.00 LEW Corporation $200.00 $120.00 Lianna Development Corporation Training Program $190.00 $100.00 Midwest Environmental Consulting, LLC $195.00 $95.00 Midwest Training Institute $175.00 $100.00 National Econ Corporation $185.00 $135.00 Northwest Independent C ontractors Association $250.00 $200.00 Northwest Independent C ontractors Association $295.00 Northwest Independent C ontractors Association $300.00 Public Health and Safety Inc. $260.00 Resolution, Inc. $225.00 $95.00 The Environmental Institute $250.00 $125.00 The Western Regional Lead Training Center $217.00 The Westside Environmental Pl an of Action Committee, LLC $225.00 TORF Environmental Management $250.00 Weecycle Environm ental Consulting $200.00 Weecycle Environm ental Consulting $250.00 Wunderlin Environmental Training Services LLC $209.00 $99.00
Number of Courses 29 2 17 Mean $214.86 $150.02 $134.65 Median $209.00 $150.02 $135.00 Minimum $150.00 $140.00 $95.00 Maximum $300.00 $160.04 $200.00 Standard Deviation $39.52 $14.17 $33.91

1 Initial hands-on training course tuition is derived by taking the tuition for the initial e-learning cl assroom and hands-on training course and subtracting the e-learning classr oom component ($160.04 = $199.99 - $39.95). The e-learning component was developed by a thir d-party firm, Contractor Harbor.