### SUPPORTING STATEMENT FOR

EPA INFORMATION COLLECTION REQUEST NUMBER 2002.06

“CROSS-MEDIA ELECTRONIC REPORTING RULE”

February 26, 2015

Office of Environmental Information U.S. Environmental Protection Agency Washington, D.C. 20460

### TABLE OF CONTENTS

1. IDENTIFICATION OF THE INFORMATION COLLECTION ....................................................... 3 1(a) TITLE AND NUMBER OF THE INFORMATION COLLECTION ...................................... 3 1(b) CHARACTERIZATION OF THE INFORMATION COLLECTION ..................................... 3

2. NEED FOR AND USE OF THE COLLECTION .............................................................................. 5 2(a) NEED AND AUTHORITY FOR THE COLLECTION ........................................................... 5 2(b) PRACTICAL UTILITY AND USERS OF THE DATA .......................................................... 6

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA ................ 8 3(a) NONDUPLICATION ........................................................................................................... .... 8 3(b) PUBLIC NOTICE ............................................................................................................ ......... 8 3(c) CONSUL TATIONS ............................................................................................................ ...... 8 3(d) EFFECTS OF LESS FREQUENT COLLECTION ................................................................ 15 3(e) GENERAL GUIDELINES ...................................................................................................... 15 3(f) CONFIDENTIALITY .......................................................................................................... ... 16 3(g) SENSITIVE QUESTIONS ...................................................................................................... 16

4. THE RESPONDENTS AND THE INFORMATION REQUESTED .............................................. 17 4(a) RESPONDENTS AND NAICS CODES ................................................................................ 17 4(b) INFORMATION REQUESTED ............................................................................................. 17

5. THE INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT ...................................................... 24 5(a) AGENCY ACTIVITIES ........................................................................................................ . 24 5(b) COLLECTION METHODOLOGY AND MANAGEMENT ................................................ 25 5(c) SMALL ENTITY FLEXIBILITY ........................................................................................... 25 5(d) COLLECTION SCHEDULE .................................................................................................. 25

6. ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION .............................. 27 6(a) ESTIMATING RESPONDENT BURDEN HOURS .............................................................. 27 6(c) ESTIMATING AGENCY HOUR AND COST BURDEN .................................................... 30 6(d) ESTIMATING RESPONDENT UNIVERSE AND TOTAL HOUR AND

COST BURDEN ................................................................................................................... .. 30 6(e) BOTTOM LINE HOUR AND COST BURDEN ................................................................... 40 6(f) REASONS FOR CHANG E IN BURDEN .............................................................................. 41 6(g) PUBLIC BURDEN STATEMENT ......................................................................................... 413

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) TITLE AND NUMBER OF TH E INFORMATION COLLECTION

This Information Collection Request (ICR) is entitled “Cross-Media Electronic Reporting Rule (Renewal)” EPA ICR Numb er 2002.06, OMB Control Number 2025-0003.

1(b) CHARACTERIZATION OF THE INFORMATION COLLECTION

The U.S. Environmental Protection Agency (E PA) allows regulated entities to report electronically to EPA by allowing the use of el ectronic document receiving systems to receive

electronic documents in satisfaction of certain document submission requirements in EPA’s regulations. 1 The Cross-Media Electronic Reporting Rule (CROMERR) also allo ws state, tribal, and local governments to seek EPA approval, as provided under 40 Code of Federal Regulations (CFR) 3.1000, to accept electronic documents to satis fy reporting requirements under authorized or delegated environmental programs that they admi nister. In seeking EPA approval, these state, tribal, and local governments mu st upgrade existing electronic doc ument receiving systems or develop new electronic document receiving systems to satisfy the criteria laid out at 40 CFR 3.2000. Regulated entities that use an electr onic signature device in submitting electronic documents to the EPA or a state, tribal, or local government receiving system must comply with identity proofing requirements, as applicable. In the remainder of this document, we refer to state, tribal, and local governments as “States/ Locals” because, at the current time, EPA is not aware of any tribal governments that have electr onic document receiving systems or are planning to develop such systems duri ng the next three years.

CROMERR does not require any regulated entity to report electronically to EPA or States/Locals. CROMERR establishes requireme nts for utilizing electro nic reporting as an alternative to paper-based repor ting. It does not require States /Locals to implement electronic reporting; rather, it establishes the framewor k for implementing the electronic reporting alternative for Federal laws that they administer. In this regard, regulat ed entities are affected only as follows:

 Entities that report electronically to EPA have to register with EPA’s electronic document receiving system (e.g., log on to the EPA Web site and enter requested information), comply with the identity proofing provisions, and then commence electronic reporting. In this document, we re fer to these entities as “direct reporters.”

 States/Locals must upgrade existing elect ronic document receiving systems or develop new electronic document r eceiving systems to meet 40 CFR 3.2000 requirements. These States/Locals mu st apply for EPA program modification approval under 40 CFR 3.1000. They also mu st implement the identity proofing requirements at 40 CFR 3.2000(b)(5).

1 In this document, EPA is using the term “electronic reporting” in a sense that excludes submission of a report via magnetic media, (i.e., via diskette, compact disc, or tape). EPA is also excluding transmission via hard copy facsimile. Likewise, EPA’s use of the term “electronic document” throughou t this document refers exclusively to documents that are transmitted via a telecommunications network, excluding hard copy facsimile.4

 Entities that report electronically to States /Locals must comply with the identity proofing requirements at 40 CFR 3.2000(b)(5). In this document, we refer to these entities as “indirect reporters.”

 Entities that opt to implement the local re gistration authority (LRA) alternative for identity proofing must identify an individua l who will collect subscriber agreements

from each individual that intends to use an electronic signature device in reporting electronically to a State/Local electroni c document receiving system. In this document, we refer to these entiti es as “indirect reporting firms.”

 The LRA must collect and store subscriber agreements from indi viduals in his/her indirect reporting firm. The LRA also must prepare an agreement collection

certification and submit a certification of receipt and secure storage to the corresponding State/Local agency.

Sections 1 through 5 of this document descri be the information collection requirements covered in this ICR (e.g., in regard to need a nd use of the information collected). Section 6 estimates the annual burden to respondents. This ICR does not address the burden savings to respondents in reporting electroni cally under EPA programs. EPA’s programs will amend their program-specific ICRs to address these impacts.

CROMERR establishes requirements applicable to electronic re porting and receiving systems, as specified. Many of the activitie s to be conducted by direct reporters will be determined by the instructions associated with EPA’s electronic document receiving system. Specifically, EPA has developed an Agency-wide receiving system, the Central Data Exchange (CDX), which guides direct reporters through th e registration and reporting procedures. In developing this ICR, EPA referred to the regulato ry text, as well as CDX, in describing direct reporters’ activities a nd associated burden.5

2. NEED FOR AND USE OF THE COLLECTION

2(a) NEED AND AUTHORIT Y FOR THE COLLECTION

EPA established the CROMERR requirements to ensure compliance with the Government Paperwork Elimination Act (GPEA). 2 GPEA requires that Federal agencies be prepared, by October 21, 2003, to allow persons who are required to maintain, submit, or disclose information, the option of doing so electr onically, when practicable, as a substitute for paper; and to use electronic auth entication (electronic signature) met hods to verify the identity of the sender and the integrity of electronic content. GPEA specifically provides that electronic records, and their relate d electronic signatures, are not to be denied legal effect, validity, or enforceability merely because th ey are in electronic form.

(1) Registering with EPA Electro nic Document Receiving System

Regulated entities must initially register with the EPA electronic document receiving system to establish a user account. EPA needs the registration information to identify the registrant, contact information, a nd registrant’s organization. Re gistrants also select a password and user name during registration. This information is needed to en sure that only the registrant

has access to his/her account.

(2) Compliance with Identity Proofing Requirements

The identity proofing provisions in 40 CF R 3.2000(b)(5) are needed to strengthen the non-repudiation provisions of CROMERR. The elec tronic signature agr eement, required in Section 3.2000(b)(5)(v), esta blishes that the signatory was info rmed of their obligation to keep the signature device from compromi se, by ensuring that it is not ma de available to anyone else. These provisions are intended to ensure that th e Federal laws regarding the falsification of information submitted to the government still apply to any and all electronic transactions, and that fraudulent electronic submissions will be prosecuted to the fullest extent of the law. In establishing clear requirements for electronic re porting systems, CROMERR helps to minimize fraud by assuring that the responsible individuals can be readily identified.

(3) Approval of State/Local Electronic Do cument Receiving Sy stem Applications

EPA needs information submitted by States/Locals in their program modification applications to evaluate the States/Locals’ upgraded or new electronic document receiving systems to ensure they satisfy the criteria at 40 CFR 3.2000.

EPA also needs the information to evaluate whether the State/Local’s modified program has been satisfactorily revised or modified in regard to their electronic document receiving system. In particular, the application must include a certification th at the State/Local has sufficient legal authority provided by lawfully enact ed or promulgated statut es or regulations to implement the electronic reporting component of its authorized pr ogram covered by the

2 Title XVII of Pub. L. 105 277.6

application; and to enforce the affected pr ograms using electronic documents collected under these programs. The cer tification must be signed by the gov ernmental official who is legally competent to certify with respect to legal author ity on behalf of their government. In the case of a state, this official must be the Attorney Genera l or designee. In the ca se of a tribe or local government, this official must be the chief administrative official or officer or designee. As a legal matter, EPA’s position is that Attorneys Ge neral or their designees are the only officials capable of certifying with respect to their stat es’ legal authority. Where there are substantial administrative obstacles involving the Attorney General in such certifications, EPA urges the State Attorney General to provide for a lega lly competent designee who is available to participate in the submission of the state’s application.

2(b) PRACTICAL UTILITY AND USERS OF THE DATA

(1) Registering with EPA Electro nic Document Receiving System

Regulated entities must initially register with the EPA electronic document receiving system to establish a user account and create a password. EPA uses the information to identify the registrant (e.g., by name and/or organization), establish the account, and contact the registrant if needed. Regulated entities use the password to access their account and to protect it from

unauthorized use.

(2) Compliance with Identity Proofing Requirements

EPA, States/Locals, and LRAs use the ident ity proofing information from registrants to determine each registrant’s identity and relatio nship to their regulated entity. The information may be used in an EPA or State/Local enfor cement action to rebut a signatory’s attempt to repudiate their electronic signature and/or other elements of the document that was signed.

When EPA or State/Local agency receives a su bscriber agreement, cer tification of receipt and secure storage, or other identity-proofing in formation, the agency will review, process, and file the submittal. EPA or State/Local agency w ould then provide the registrant with access to the electronic document receiving system (e.g., ope n its account) so that it may begin using the electronic signature device in reporting electronically.

(3) Approval of State/Local Electronic Do cument Receiving Sy stem Applications

EPA uses the information submitted by Stat es/Locals in their program modification applications to evaluate the States/Locals’ upgraded or new electronic document receiving systems against the criteria at 40 CFR 3.2000(b )(1)-(5). For example, EPA will review the application to determine if the systems are able to generate data as needed, and in a timely manner, including copy of record for each electroni c document received, sufficient to prove that

the electronic document was not altered without detection during transmission or at any time after receipt.7

EPA also reviews the applicati on to ensure that the State/ Local has taken all necessary steps to modify its regulations and statutes, as needed, so that it has authority to implement electronic reporting and enforce the affected programs using electronic documents collected under its programs. This includes, among other th ings, an evaluation of the Attorney General’s certification under 40 CFR 3.1000(b)(1)(i).8

3. NONDUPLICATION, CONSULTATION S, AND OTHER COLLECTION

CRITERIA

3(a) NONDUPLICATION

CROMERR establishes uniform, Agency-wide criteria for electronic document receiving systems, thereby minimizing the potential for duplication or redundancy across EPA or State/Local programs. In addi tion, electronic reporting is volunt ary, and will likely be used by facilities only if cost-effectiv e and non-duplicative w ith their other compliance activities. CROMERR does not alter the repor ting requirements under existing regulations and statutes, and

does not affect whether a document must be cr eated, submitted, or reta ined under the existing provisions 40 CFR.

3(b) PUBLIC NOTICE

In compliance with the Paperwork Reducti on Act of 1995 (PRA), EPA issued a public

notice in the Federal Register on November 4, 2014 (79 FR 65391). The notice indicated that EPA was planning to submit an ICR, “Cross-Me dia Electronic Reporting Rule” (EPA ICR No. 2002.06, OMB Control No. 2025–0003), to the O ffice of Management and Budget (OMB) for review and approval in accordance with th e PRA. The notice also requested comments on

the information collection and burden estimates c overed in the ICR. The public comment period extended through January 5, 2015. EPA did not r eceive any written comments on the ICR in response to the Federal Register notice.

3(c) CONSULTATIONS

Most of the underlying assumptions in this ICR (e.g., hour and cost burden estimates) are based on EPA consultations with industry a nd States/Locals during the development of CROMERR and renewal of previ ous CROMERR ICRs. In devel oping this current ICR, EPA carefully reviewed all of the I CR’s data and assumptions and determined that a few should be strengthened based on additional consultations.

Table 1 identifies the or ganizations contacted.

Table 1 Organizations EPA Contacted during the De velopment of this ICR (February 2015)

Organization Contact Name Phone Number

Industry (i.e., Direct/Indirect Reporters)

3M Linda Murray (651) 733-3461

Maersk Line, Limited Larry Bowling (757) 531-7799

OVS Ken Wessels (503) 437-1414

Shields Bag and Printing Company Derek LaFramboise (509) 248-75009

Organization Contact Name Phone Number

State/Local Agencies

Arkansas Department of Environmental Quality Letty Hardee (501) 682-0672

New York Department of Environmental C onservation Robert Wither (518) 402-8154

Ohio Environmental Protection Agency Adele Vogelgesang (614) 728-1747

The following paragraphs summarize the f eedback obtained on the burden associated

with various information collection activities.

(1) Direct/Indirect Reporters

(a) Identity Proofing Activities

 Prepare and submit a non-electronic (paper) subscriber agreement. EPA received mixed feedback about the ICR’s original burden for preparing and submitting a non-electronic (paper) subscriber agreement (i.e., 15 minutes or 0.25 hour per subscriber agreement) from the employee registrants contacte d. One registrant indicated th at the ICR’s original burden estimate was a realistic industry average, while two registrant s disagreed with the burden estimate. (One registrant did not provide feed back on this information collection activity.) The registrants contacted suggest ed a revised burden estimate of 30 minutes or 0.50 hour. Based on the consultation information, the average burden for preparing and submitting a non-electronic (paper) subscriber agreement was estimated to be 25 minutes or 0.42 hour per subscriber agreement.

 Prepare and submit an electronic, reuse (c onsolidated), or third-party subscriber

agreement. EPA received mixed feedback about the ICR’s original burden for preparing and submitting an electronic, reuse (consolidated), or third-party subscriber agreement (i.e., 10 minutes or 0.17 hour per subscriber agreement) from the employee registrants contacted. One registrant indicat ed that the ICR’s original burden estimate was a realistic industry average, while two regist rants disagreed with the burden estimate. (One registrant did not provide feedback on this information collection activity.) The registrants contacted suggested a revised burden estimate of 20 mi nutes or 0.33 hour. Based on the consultation information, the average burden for preparing and submitting an electronic, reuse (consolidated), or third-part y subscriber agreement was estimated to be 17 minutes or 0.28 hour per subscriber agreement.

 File subscriber agreement. EPA was informed that, genera lly, the ICR’s original burden for filing a subscriber agreement (i.e., 5 minutes or 0.08 hour per subscriber agreement) was a realistic industry average. However, one of th e four registrants contact ed suggested a revised

burden estimate of 15 minutes or 0.25 hour. Based on the consultation information, the average burden for filing a subscriber agreement was estimated to be 7 minutes or 0.12 hour per subscriber agreement.10

 Report compromised or surrendered electronic signature device and prepare/submit new subscriber agreement. EPA was informed that, generall y, the ICR’s original burden for reporting a compromised or surrendered electronic signature device and preparing/submitting a new subscriber agreement (i .e., 5 minutes or 0.08 hour per subscriber agreement) was a realistic industry average. However, one of th e four registrants contact ed suggested a revised burden estimate of 20 minutes or 0.33 hour. (One registrant did not provide feedback on this information collection activity.) Based on the consultation informati on, the average burden for reporting a compromised or surre ndered electronic signature device and preparing/submitting a new subscriber agreement was estimated to be 10 minutes or 0.17 hour per subscriber agreement.

 Contact the Help Desk for technical support. EPA received mixed feedback about the ICR’s original burden for contacting the Help Desk for technical support (i.e., 3.6 minutes or 0.06 hour per subscriber agreement) from the em ployee registrants contacted. One registrant indicated that the ICR’s origin al burden estimate was a realis tic industry average, while two registrants disagreed with the burden estimate. (One registrant did not provide feedback on this information collection activity.) The regi strants contacted suggested a revised burden estimate that ranged from 7.5 minutes to 10 mi nutes, or 0.13 hour to 0.17 hour. Based on the consultation information, the average burden fo r contacting the Help Desk for technical support was estimated to be 7 minutes or 0.12 hour per subscriber agreement.

 Prepare subscriber agreement and send to LRA. EPA received mixed feedback about the ICR’s original burden for preparing a subscr iber agreement and sending it to the LRA (i.e., 20 minutes or 0.33 hour per subscriber agreement) from the employee registrants contacted. One registrant indicat ed that the ICR’s original burden estimate was a realistic industry average, while one regist rant disagreed with the burden estimate. (Two registrants did not provide feedback on this information collection activity.) The registrants contacted suggested a revised burden estimate of 30 mi nutes or 0.50 hour. Based on the consultation information, the average burden for preparing a subscriber agreement and sending it to the LRA was estimated to be 25 minutes or 0.42 hour per subscriber agreement.

 Report breach of security or compromised/surrendered electronic signature device to LRA.

EPA received mixed feedback about the ICR’ s original burden for reporting a breach of security or a compromised/surrendered electr onic signature device (i.e., 5 minutes or 0.08 hour per report) from the employee registrants co ntacted. One registrant indicated that the ICR’s original burden estimate was a realisti c industry average, while one registrant disagreed with the burden estimate. (Two registrants did not provi de feedback on this information collection activity.) The regist rants contacted suggested a revised burden

estimate of 15 minutes or 0.25 hour. Based on the consultation information, the average burden for reporting a breach of security or a compromised/surrendere d electronic signature

device was estimated to be 10 minutes or 0.17 hour per report.11

(b) Local Registration Authority Activities

 Develop a process or plan to implement the requirement, designate the LRA, and submit LRA application to agency. EPA was informed by the employee registrants contacted that the ICR’s original burden for developing a pro cess or plan to implement the requirement, designate the LRA, and submit an LRA applica tion to an agency (i.e., 13 hours per reporting firm) was a realistic industry average. (Two registrants did not pr ovide feedback on this information collection activity.) Based on the consultation informati on, the average burden for developing a process or plan to impleme nt the requirement, designate the LRA, and submit an LRA application to an agency was not revised and thus, remained at 13 hours per reporting firm.

 Register LRA with the electroni c document receiving system. EPA was informed by the employee registrants contacted that the ICR’s or iginal burden for regi stering the LRA with

the electronic document receivi ng system (i.e., 10 minutes or 0.17 hour per reporting firm) was a realistic industry average. (Two re gistrants did not provide feedback on this information collection activity.) Based on the consultation informati on, the average burden for registering the LRA with the electronic document receiving system was not revised and thus, remained at 10 minutes or 0.17 hour per reporting firm.

 Re-designate LRA, due to turnover, and send application materials. EPA was informed by the employee registrants contacte d that the ICR’s orig inal burden for re-designating an LRA, due to turnover, and sending application ma terials (i.e., 1 hour per reporting firm) was a realistic industry average. (Two registrant s did not provide feedback on this information collection activity.) Based on the consulta tion information, the average burden for re-designating an LRA, due to turnover, and sending applica tion materials was not revised and thus, remained at 1 hour per reporting firm.

 Collect and securely store subscriber agreements. EPA was informed by the employee registrants contacted that the I CR’s original burden for an LRA to collect and securely store subscriber agreements (i.e., 10 minutes or 0.17 h our per subscriber agreement) was a realistic industry average. (Two regist rants did not provide feedback on this information collection activity.) Based on the consultation inform ation, the average burden for collecting and securely storing subscriber agreements was not revised and thus, remained at 10 minutes or 0.17 hour per subscriber agreement.

 Prepare agreement collection certification afte r securely storing subscriber agreements, and submit certification of receipt and secure storage. EPA was informed by the employee registrants contacted that the ICR’s original burden for prep aring an agreement collection certification after securely storing subscriber agreements, and submitting the certification of receipt and secure storage (i.e., 10 minutes or 0.17 hour per certificat ion) was a realistic industry average. (Two regist rants did not provide feedback on this information collection activity.) Based on the consultation inform ation, the average burden for preparing an agreement collection certification after securely storing subscriber agreements, and submitting the certification of receipt and secure storage was not revised and thus, remained at 10 minutes or 0.17 hour per certification.12

(c) On-Going Management Activities

 Identify and resolve problems. EPA was informed that, gene rally, the ICR’s original burden for identifying and resolving problems (i.e., 1 hour per employee registrant) was a realistic industry average. However, one of the four re gistrants contacted suggested a revised burden estimate of 3 hours. (One registrant did not provide feedback on this information collection activity.) Based on the consultation inform ation, the average burden for identifying and resolving problems was estimated to be 1.67 hour s per employee registrant.

(2) State/Local Agencies

(a) Identity Proofing Activities

 Receive, process, review, approve an d file a subscriber agreement. EPA was informed by two of the three state agenci es contacted that the ICR’s original burden for receiving, processing, reviewing, approving and filing a s ubscriber agreement (i.e., 10 minutes or 0.17 hour per subscriber agreement) was a realistic national average. (One state agency did not provide feedback on this information colle ction activity.) Based on the consultation information, the average burden for receiving, processing, reviewing, approving and filing a subscriber agreement was not revised and t hus, remained at 10 minutes or 0.17 hour per subscriber agreement.

(b) Local Registration Authority Activities

 Receive, process, review, and approve certification of receipt and secure storage. EPA was informed by one of the three state agencies contacted that the ICR’s original burden for receiving, processing, reviewing, and approving a certification of receipt and secure storage (i.e., 10 minutes or 0.17 hour per certification) was a realistic nati onal average. (The remaining two state agencies did not provide feedback on this information collection activity.) Based on the consultation information, the average burden for receiving, processing, reviewing, and approving a certificatio n of receipt and secure storage was not revised and thus, remained at 10 minutes or 0.17 hour per certification.

 Receive notification of breach of security or compromised/surrendered electronic signature device, and take action. EPA was informed by one of the three state agencies contacted that the ICR’s original burden for receiving a notificati on of breach of security or compromised/surrendered elec tronic signature device, and taking action (i.e., 1 hour per notification) was a realistic national average. (The remaining two state agencies did not provide feedback on this information colle ction activity.) Based on the consultation information, the average burden for receiving a notification of breach of security or compromised/surrendered electr onic signature device, and taki ng action was not revised and thus, remained at 1 hour per notification.13

 Receive application to designate LRA. EPA was informed by one of the three state agencies contacted that the ICR’s origin al burden for receiving an application to designate an LRA (i.e., 30 minutes or 0.50 hour per reporting firm ) was a realistic national average. (The remaining two state agencies did not provide feedback on this information collection activity.) Based on the consultation information, the average burden for receiving an application to designate an LRA was not re vised and thus, remained at 30 minutes or 0.50 hour per reporting firm.

(c) On-Going Management Activities

 Identify and resolve problems. EPA was informed by two of the three state agencies contacted that the ICR’s origin al burden for identifying and resolving problems (i.e., 1 hour per employee registrant) was a realistic national average. (One state agency did not provide feedback on this information collection activity.) Based on the consultation information, the average burden for identifying and resolving pr oblems was not revised and thus, remained at 1 hour per employee registrant.

 Respond to information requests. EPA was informed by two of the three state agencies

contacted that the ICR’s original burden for respondi ng to information requests (i.e., 1.5 hours per employee registrant) was a rea listic national average. (One state agency did not provide feedback on this information collection activity.) Based on the consultation information, the average burden for responding to information requests was not revised and thus, remained at 1.5 hours per employee registrant.

(d) State/Local Electronic Document Rece iving System Application Activities

 Read the regulations. EPA received mixed feedback a bout the ICR’s original burden for reading the regulations (i.e., 1.5 hours per Stat e/Local agency) from the state agencies contacted. One state agency indi cated that the ICR’s original burden estimate was a realistic industry average, while one state agency disa greed with the burden estimate. (One state agency’s feedback on the burden estimate incl uded other activities and thus, was excluded from the analysis for consistency purposes.) The state agencies contacted suggested a

revised burden estimate of 1.5 hours. Base d on the consultation information, the average burden for reading the regulations was estimated to be 2.26 hours per State/Local agency.

 Upgrade existing electronic document rece iving system or develop new electronic document receiving system to meet 40 CFR 3.2000 and apply for EPA program modification approval under 40 CFR 3.1000 (state agency). EPA was informed by two of the three state agencies contact ed that the ICR’s original burden for upgrading an existing electronic document receiving system or de veloping a new electronic document receiving system to meet 40 CFR 3.2000 and applying for EPA program m odification approval (i.e., 331 hours per state agency ) was a realistic national aver age. (One state agency’s

feedback on the burden estimate seemed to in clude other activities and thus, was excluded from the analysis for consistency purposes.) Based on the consultation information, the average burden for upgrading an existing el ectronic document receiving system or14

developing a new electronic doc ument receiving system to meet 40 CFR 3.2000 and applying for EPA program modification approval was estim ated to be 331 hours per state agency.

 Submit amendment to original application for EPA program modification approval under

40 CFR 3.1000. EPA was informed by one of the thre e state agencies contacted that the ICR’s original burden for submitting an amendment to the original application for EPA program modification approval under 40 CFR 3.1 000 (i.e., 24 hours per State/Local agency) was a realistic national average. (The remaini ng two state agencies did not provide feedback on this information collection activity.) Base d on the consultation information, the average burden for submitting an amendment to the original application for EPA program modification approval under 40 CFR 3.1000 was not revised and thus, remained at 24 hours per State/Local agency.

 Submit notification to EPA about changes to laws, policies, or electronic document receiving systems that have the potential to affect progr am conformance with 40 CFR

3.2000. EPA received mixed feedback about th e ICR’s original burden for submitting a notification to EPA about changes to laws, policies, or electronic document receiving systems that have the potential to a ffect program conformance with 40 CFR 3.2000 (i.e., 45 minutes or 0.75 hour per State/Local agen cy) from the state agencies contacted. One state agency indicated that the ICR’s original burden esti mate was a realistic industry average, while one state agency disagreed with the burden estimate. (One state agency did not provide feedback on this information collect ion activity.) The state agencies contacted suggested a revised burden estimate of 22 hours. Based on the consultation information, the average burden for submitting a notification to EPA about changes to laws, policies, or electronic document receiving systems that have the potential to affect program conformance with 40 CFR 3.2000 was estimated to be 11.39 hours per State/Local agency.

 Cost for upgrading or developing electronic document receiving sy stem (state agency). EPA was informed by one of the three state agen cies contacted that the ICR’s original cost estimate for upgrading or developing an elec tronic document receiving system (i.e., $152,701 per state agency) was a realistic national averag e. However, the remaining two state agencies disagreed with the cost estimate. The stat e agencies contacted suggested revised cost estimates that ranged from $300,000 to $479,364.06. Based on the consultation information, the average cost for upgrading or developing an electronic document receiving system was estimated to be $310,688 per state agency.

The above feedback is reflected in the burden assumptions of this ICR, as appropriate. Detailed information on EPA’s assumptions re garding these and other activities are fully

discussed in Section 6 of this document.15

3(d) EFFECTS OF LESS FREQUENT COLLECTION

(1) Registering with EPA Electro nic Document Receiving System

Facilities must initially regi ster with the EPA electronic document receiving system to establish a user account. Registration informati on is collected at the tim e of registration (i.e., a one-time event) and updated if needed. Becau se it is a one-time activity, the information cannot be collected less frequently. If this info rmation were not collected, EPA would not have a way to learn the identity of the re gistrant and establish its account.

(2) Compliance with Identity Proofing Requirements

Facilities must comply with the iden tity proofing provisions of CDX and 40 CFR 3.2000(b)(5), as applicable. These provisions prov ide that, in the case of priority reports for which an electronic signature devi ce was used to create an electr onic signature, a determination of identity must be made before the electronic docume nt is received. It is critical that registrants submit the identity proofing paperwork in advance of their priority reports so that the Agency can establish a link between each registrant and its electronic signature device to hold them

accountable for their submittals. Fa cilities also must report any compromise or surrender of its electronic signature device to EPA or State/Local.

LRAs must report any breach of storage of its subscriber agreements. These are asneeded submittals. If these reports were not co llected, EPA and States/Locals would not have a way to learn about the signature compromise/surrender or storage breaches. Hence, they would not be in a position to take follow up action as needed (e.g., to temporaril y prevent access to an account whose signature device has been compromise d). This could result in the unauthorized use an electronic signature device.

(3) Approval of State/Local Electronic Do cument Receiving Sy stem Applications

CROMERR sets forth timeframes for EPA r eceipt, review, and approval of State/Local program modification applications to implem ent electronic document receiving systems. States/Locals that did not have an electronic document receiving system in use or substantially developed on or before Oct ober 13, 2005 must apply to EPA fo r program modification approval before receiving electronic documents (40 CF R 3.10000(a)(2)). If this frequency were not specified, EPA would not have assurance that St ates/Locals are developi ng and using electronic document receiving systems that comply w ith CROMERR’s provisions at 40 CFR 3.2000.

3(e) GENERAL GUIDELINES

This ICR adheres to the guidelines stated in the PRA, OMB’s implementing regulations, applicable OMB guidance, and EPA’s ICR Handbook.

EPA notes that subscriber agreements must be kept on file until five years after

deactivation of the associated el ectronic signature device. A five-year retention period is necessary to ensure that such r ecords are available in case of an EPA or State/Local enforcement16

action. EPA recognizes that a registrant may us e an electronic signatu re device in signing a range of enforcement-sensitive reports. Certain reports may have relevance to an enforcement action long after it is submitted to EPA or State/Lo cal. Because of this, EPA needed to establish a sufficiently long retention period for the subscriber agreements so that they would available for

such enforcement actions.

3(f) CONFIDENTIALITY

If a confidentiality claim were asserted, EP A would treat the information in accordance with the confidentiality regulations at 40 CFR Part 2, Subpart B. EPA also would ensure that the information collection procedures comply with the Privacy Act of 1974 and the OMB Circular

108.

3(g) SENSITIVE QUESTIONS

Persons registering with CDX are asked to provide knowledge-based information (e.g., date of birth) to ensure the security of their password, user name, and other information supplied. If the person loses his/her password or user name, or otherwise needs to confirm his/her identity to EPA, EPA could use the knowledge-based information to confirm his/her identity.17

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) RESPONDENTS AND NAICS CODES

The information collection requirements cove red in this ICR will likely have broad applicability across indu stries. Refer to Appendix A for a list of the North American Industry Classification System (NAICS) codes associated with industries most likely affected by these requirements.

4(b) INFORMATION REQUESTED

Following is a description of the data items and activities associated with the information collection requirements covered in this ICR. Re fer to Section 1(b) for the types of respondents

examined in this subsection.

(1) Registering with EPA Electro nic Document Receiving System

Facilities must register their employees with CDX before reporting electronically to EPA. The employees must update their regi stration information if it changes.

(i) Data Items:

 An on-line registration application:

 Registrant name.

 Organization name.

 Address.

 Knowledge-based information (e.g., us er-supplied secret question-andanswer pair).

(ii) Respondent Activities:

Facility employees must perf orm the following activities:

 Log on to receiving system site and enter requested information.

 Update the information, as needed.

(2) Compliance with Identity Proofing Requirements

Direct reporters, indirect repor ters, indirect reporting firms, and LRAs must comply with the identity proofing provisions of CDX a nd CROMERR, as applicable. In addition, States/Locals that accept electroni c documents to satisfy reporting requirements under authorized or delegated environmental programs that they ad minister must process, review, and approve the identity proofing information s ubmitted by indirect reporters.18

CDX and 40 CFR 3.2000(a)(2) requ ire that any electronic document must bear the valid electronic signature of a signato ry if that signatory would be required under the authorized program to sign the paper document for which the electronic document substitutes, except as otherwise specified. In the case of an electronic document that mu st bear electronic signatures of individuals as provided by CDX and 40 CFR 3.2000(a)(2), each si gnatory must sign either an electronic signature agreement, or a subscriber agreement with re spect to the elect ronic signature

device used to create their electronic signature on the electronic document.

CDX and 40 CFR 3.2000(b)(5)(vii) require that the identity of the individual uniquely

entitled to use the device and their relation to an y entity for which he or she will sign electronic documents must be determined with legal certainty by EPA or State/Local, as applicable. In the case of priority reports, this determination mu st be made before the electronic document is received, by means of:

 Identifiers or attributes that are verified by attestation of disint erested individuals to be uniquely true of the individual in whos e name the application is submitted, based on information or objects of independent or igin, at least one item of which is not subject to change without govern mental action or authorization.

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

 Collection of either a subscriber agreement or a certification from a LRA that such an agreement has been received and securely stored.

The term “subscriber agreement” means an electronic signature agreement signed by an

individual with a handwritten si gnature. The agreemen t must be signed by an individual with respect to an electronic signature device that the individual will us e to create his/her electronic signature requiring such individu al 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 co mpromised; and to be held as legally bound, obligated, or responsible by the el ectronic signatures created as by a handwritten signature. This agreement must be stored until five years afte r the associated electr onic signature device has

been deactivated.

The term “Local Registration Authority” mean s an individual who is authorized by a State/Local to issue an agreement collection cert ification, whose identity has been established by notarized affidavit, and who is authorized in writing by a regulated entity to issue agreement

collection certifications on its behalf. Once approved by EPA or State/Local, the LRA would collect subscriber agreements from each individual in the regulated entity that intends to use an electronic signature device in re porting electronically to EPA or State/Local electronic document receiving system. The LRA would collect and stor e the subscriber agreements in a manner that prevents authorized or unauthorized access to th ese agreements by anyone other than the LRA. The LRA would prepare an agreement collectio n certification and submit a certification of receipt and secure storage to the EPA or State/Local.19

(i) Data Items:

 Compliance with identity proofing requirements by means of identifiers, attributes, or alternative method:

 Identifiers or attributes that are ve rified by attestation of disinterested individuals to be unique ly true, as specified.

 Other information necessary to determine identity.

 Compliance with subscriber agreement provisions:

 Subscriber agreement.

 Report of compromised or surr endered electronic signature.

 Submission of subscriber agreement to LRA:

 Subscriber agreement.

 Report of breach of security.

 Report of compromised or surr endered electronic signature.

 Designation of LRA:

 Application to designate a LRA, including notarized affidavit and a written authorization from the regul ated entity to issue collection agreement certifications on its behalf.

 Collection of subscriber agreements by LRA:

 Agreement collection certif ication. This is a signed statement by which a LRA certifies that a subscriber agre ement has been received from a registrant; the agreement has been stored in a manner that prevents

authorized or unauthorized access to these agreements by anyone other than the LRA; and the LRA has no ba sis to believe that any of the collected agreements have been tamper ed with or prematurely destroyed.

 Certification of receipt and secure storage.

(ii) Respondent Activities:

Direct and indirect reporters must perform the following activities, as applicable:

 Comply with requirements for identifier , attribute, or alternative method:

 Prepare and submit information on identif iers, attributes, or other identityproofing information.

 Comply with subscriber agreement provisions:

 Prepare and submit a subscriber agreement.

 File subscriber agreement.

 Prepare and submit new subscriber agreement, for employee turnover.

 File new subscriber agreement, for employee turnover.20

 Contact the Help Desk for technical support.

 Report compromised or surrendered electronic signature device and prepare/submit new subscriber agreement if necessary.

 Submit subscriber agreement to LRA:

 Prepare subscriber agreement and send to LRA.

 Prepare and submit new subscriber agreement to LRA, for employee

turnover.

 Report breach of security or compromi se/surrender of electronic signature

device.

 Prepare and submit new subscriber agreement to LRA subsequent to breach of security or compromise of electronic signature device, if

necessary.

 Conduct ongoing management:

 Identify and resolve problems.

Indirect reporting firms and LRAs must perform the following activities, as applicable:

 Designating a LRA:

 Develop a process or plan to implement the requirement, designate the LRA, and submit LRA application to agency.

 Register the LRA with the elec tronic document receiving system.

 Redesignate LRA, due to turnover, and send application materials.

 Register new LRA with electr onic document receiving system.

 Collect subscriber agreements from reporters:

 Collect and securely store subscriber agreements

 Prepare agreement collecti on certification after secu rely storing subscriber agreements, and submit certification of receipt and secure storage.

 Collect and securely store subscriber agreements, for employee turnover.

 Prepare agreement collecti on certification after secu rely storing subscriber agreements, and submit certification of receipt and secure storage, for employee turnover.

 Collect and securely store subscr iber agreements, for breach of security/compromise of el ectronic signature device.

 Prepare agreement collecti on certification after secu rely storing subscriber agreements, and submit certification of receipt and secure storage, for breach of security/compromise of electronic signature device.21

State/Local agencies acting as regulators must perform the following activities:

 Collect identifiers, attributes, or alternative information:

 Receive, process, review, and approve id entifier, attribute, or alternative

information.

 Collect subscriber agreements:

 Receive, process, review, approve, and file new subscriber agreements.

 Receive, process, review, approve, and file new subscriber agreements, for employee turnover.

 Receive, process, review, and approve report of compromise or surrender of electronic signature device.

 Collect submittals from LRAs:

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

storage.

 Receive, process, review and approve updated certification of receipt and secure storage, for employee turnover.

 Receive notification of breach of security or compromise/surrender of electronic signature and take action.

 Receive, process, review, and approve certification of receipt and secure storage, for breach of security or compromise/surrender of electronic signature device.

 Collect applications fo r designation of LRAs:

 Receive application to de signate first-time LRA.

 Receive application to designa te LRA, for LRA turnover.

 Conduct ongoing management:

 Identify and resolve problems.

 Respond to information requests.

(3) Approval of State/Local Electronic Do cument Receiving Sy stem Applications

To obtain EPA approval of authorized program revision or modificat ion using procedures provided under 40 CFR 3.1000, a State /Local must submit an application for program revision to EPA that includes the elements specifi ed in Sections 3.1000( b)(1)(i) th rough(iv).

A State/Local that revises or modifies more than one (1) authorized program for receipt of electronic documents, in lieu of paper doc uments, may submit a consolidated application covering more than one authorized program, provi ded the consolidated application complies with applicable requirements for each authorized program.22

If the State/Local receives a notice from EPA that its application is incomplete or does not satisfy the requirements at 40 CFR 3.2000, the State/Local must submit an amendment to the original application that incl udes the missing information.

A State/Local that accepts electronic docum ents in lieu of paper documents under an authorized program for which EPA has approved program revisions or modifications under the procedures provided in 40 CFR 3.2 000(a)(1) must keep EPA apprised of those changes to laws, policies, or the electronic docum ent receiving systems that have the potential to affect program

conformance with Section 3.2000.

The State/Local program must satisfy the requirements at 40 CFR 3.2000. Pursuant to Section 3.2000, authorized program s that receive electronic do cuments, in lieu of paper documents, to satisfy requirements under such programs must use an acceptable electronic document receiving system as specified and require that any electronic document must bear valid electronic signatures to the same extent that th e paper submission for which it substitutes would bear handwritten signatures unde r the authorized program, unle ss otherwise specified. An electronic document receiving system that receives electronic documents, submitted in lieu of paper documents, to satisfy requirements under an au thorized program must be able to generate data with respect to any such electronic documen t, as needed and in a timely manner, including a copy of record for the electronic document, that meets the criteria specified at Sections 3.2000(b )(1) through (5).

(i) Data Items:

 An application (or application amendmen t) for program revision that includes the following elements:

 A certification that the St ate/Local has sufficient legal authority provided by lawfully enacted or promulgated stat utes or regulations that are in full

force and effect on the date of certi fication to implement the electronic reporting component of its authorized programs covered by the application

in conformance with Section 3.2000 and to enforce the affected programs using electronic documents collected unde r these programs, together with copies of the relevant statutes and regulations, signed by the State Attorney General or designee, or in the case of an authorized tribal or local government program, by the Chief Admi nistrative Official or Officer of the governmental entity or designee.

 A listing of all State/Local electronic document receiving systems to accept the electronic documents be ing addressed by the program

modification or revisions that are cove red by the application, together with a description for each such system that specifies how the system meets the applicable criteria in Section 3.2000(b) with respect to those electronic

documents.23

 A schedule of upgrades for electroni c document receiving systems that have the potential to affect the pr ogram’s continued conformance with Section 3.2000, if appropriate.

 Other such information as the Administ rator may request to fully evaluate the application.

 Appraisals to EPA of changes to la ws, policies, or electronic document receiving systems.

(ii) Respondent Activities:

State/Local agencies that are regulated entities must perform the following

activities:

 Upgrade existing electronic document receiving system or develop new electronic document receiving system to meet 40 CFR 3.2000 requirements and apply for EPA program modi fication approval under 40 CFR 3.1000.

 Submit amendment to original applic ation for EPA program modification approval under 40 CFR 3.1000.

 Submit notification to EPA about change s to laws, policies, or electronic document receiving systems that have the potential to affect program

conformance with 40 CFR 3.2000.24

5. THE INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) AGENCY ACTIVITIES

(1) Registering with EPA Electro nic Document Receiving System

EPA activities associated with facility re porting to EPA’s electronic document receiving system (i.e., CDX) include:

 Develop, operate, and maintain CDX.

(2) Compliance with Identity Proofing Requirements

EPA activities associated with the identity proofing requirements covered in this ICR

include:

 Collect identifiers or attributes or other information:

 Receive, process, review, and approve id entifier, attribute, or alternative

information.

 Collect subscriber agreements:

 Receive, process, review, approve, and file new subscriber agreements.

 Receive, process, review, approve, and file new subscriber agreements, for employee turnover.

 Receive, process, review, and approve re port of compromise or surrender of electronic signature device.

 Conduct ongoing management:

 Identify and resolve problems.

 Respond to information requests.

(3) Approval of State/Local Electronic Do cument Receiving Sy stem Applications

EPA activities associated with the approval of State/Local electro nic document receiving systems include:

 Process and file applications submitted by States/Locals seeking to modify their programs, as required by 40 CFR 3.1000.

 Process and file amendments to program modification applications submitted by

States/Locals.

 Process and file appraisals of changes to laws, policies, or electronic document receiving systems.25

5(b) COLLECTION METHODOLOGY AND MANAGEMENT

CDX serves as EPA’s primary gateway for electronic documents re ceived by EPA. CDX

functions include:

 Access management allowing or de nying an entity access to CDX.

 Data interchange accepting and returning data via various file transfer mechanisms.

 Signature/certification management providi ng devices and required scenarios for individuals to sign and certify what they submit.

 Submitter and data authentication assuring that electronic signatures are valid and data is uncorrupted.

 Transaction logging providing date, time, and source information for data received to establish “chain of custody.”

 Acknowledgment and provision of copy of record providing the submitter with

confirmations of the data received.

 Archiving placing files received and transmissi on logs into secure, long term storage.

 Error checking flagging obvious errors in documents and document transactions, including duplicate documents and unauthorized submissions.

 Translating, forwarding, and converting subm itted documents into formats that will load to EPA databases, and forwarding them to the appropriate systems.

 Outreach providing education and other cust omer services to CDX users (e.g., user manuals, Help Desk).

5(c) SMALL ENTITY FLEXIBILITY

CROMERR allows electronic reporting by permitting the use of electronic document receiving systems to receive electronic documents in satisfaction of certain document submission requirements in EPA’s regulati ons. Electronic reporting under CROMERR is voluntary. These changes will reduce the burden on al l affected entities, including small businesses. In addition,

facilities will find that the initia l set up process requires little e xpenditure of time and resources, and in the long run, this process will redu ce the time spent on submissions each year.

5(d) COLLECTION SCHEDULE

The collection frequencies associated with CDX include the following:

 Registrants must initially re gister with the electronic document receiving system and obtain electronic signature ce rtification, if applicable.

 Facilities must comply with requirements for determining the iden tity of individuals who use electronic signature devices (e.g., prepare/submit subscriber agreements or certification of receipt and secure storage) , before submitting electronic reports using

the associated device.

 Registrants must submit a notice of compromi se or surrender of electronic signature device promptly, should this occur.26

States/Locals that did not have an electronic document receiving system in use or substantially developed on or before October 13, 2005 must, usi ng specified procedures, apply for and receive EPA approval of revisions or modi fications to the authorized program before the program may receive electronic doc uments in lieu of paper documents to satisfy requirements of such program.

Within 75 calendar days of receiving an appl ication for program revision or modification, the Administrator will respond with a letter th at either notifies the State/Local that the application is complete or identifies deficiencies in the application that render the application incomplete. The State/Local receiving a notice of deficiencies may amend the application and resubmit it. Within 30 calendar days of receivi ng the amended application, the Administrator will respond with a letter that either notifies the applicant th at the amended application is complete or identifies remaining deficiencies that render the application incomplete.

Except where an opportunity for public hearing is required, if the Administrator does not take any action on a specific request for revi sion or modification of a specific authorized program addressed by an application submitte d within 180 calendar days of notifying the State/Local that the application is complete , the specific request for program revision or modification for the specific authorized program is considered automatically approved by EPA at the end of the 180 calendar days unless the revi ew period is extended at the request of the State/Local submitting the application.

If a State/Local submits material to amend its application after the date that the Administrator sends notification that the appl ication is complete, this new submission will

constitute withdrawal of the pending application and submission of a new, amended application for program revision or modification, and the 18 0-day time period will begin again only when

the Administrator makes a new determination and notifies the State/ Local under that the amended application is complete.27

6. ESTIMATING THE HO UR AND COST BURDEN OF THE COLLECTION

6(a) ESTIMATING RESPONDENT BURDEN HOURS

Exhibit 1 provides estimates of the responde nt hourly burden associated with the information collection requirements covered in this ICR. The exhibit includes burden hours (total and by labor type) per res pondent, as well as the overall burden hours for all respondents. The majority of the hour estimates in Exhibit 1 are based on the Agen cy’s technical background document, Cross Media Electronic Reporting Rule Cost Benefit Analysis, and consultations with industry and states.

6(b) ESTIMATING RESPONDENT COSTS

Exhibit 1 provides estimates of the annual respondent costs associated with the information collection requirements covered in this ICR. These costs are based on the cost of labor, capital, and operation and maintenance (O&M).

(1) Labor Costs

Using the total burden hours discussed in Section 6(a) and the hourly respondent labor costs outlined in this section, E xhibit 1 illustrates the labor costs associated with the information collection requirements covered in this ICR.

(a) Direct Reporters, Indirect Reporters, Indirect Reporting Firms, and Local Registration Authorities

EPA estimates an average hourly respondent labor cost (including fringe and overhead) of $61.63 for legal staff, $39.50 for managerial staff, $39.17 for technica l staff, and $17.23 for clerical staff. These respondent labor costs were obtained from the previously approved CROMERR ICR (i.e., EPA I CR Number 2002.05, dated June 22, 2011), and updated to 2014 levels using Employment Cost Indexes deve loped by the Bureau of Labor Statistics. 3

(b) State/Local Agencies

EPA estimates an average hourly respondent labor cost (including fringe and overhead) of $41.13 for legal staff, $41.13 for managerial staff, $31.15 for technica l staff, and $14.78 for clerical staff. These respondent labor costs were obtained from the previously approved CROMERR ICR (i.e., EPA I CR Number 2002.05, dated June 22, 2011), and updated to 2014 levels using Employment Cost Indexes deve loped by the Bureau of Labor Statistics. 4

3 Bureau of Labor Statistics; “Table 4. Employment Cost Index for total compensation, for civilian workers, by occupational and industry;” Employment Cost Index, Historical Listing – Volume V, Continuous Occupational and Industry Series, September 1975 –June 2014 ;July 2014. Available online at: http://www.bls.gov/web/eci/ecico is.pdf, last accessed on October 8, 2014. Civilian Workers, All Workers, March

2011=114.0 and June 2014= 121.4.

4 Bureau of Labor Statistics, “Table 7. Employment Cost Index for total compensation, for State and local government workers, by occupational and industry,” Employment Cost Index, Historical Listing – Volume V,28

(2) Capital Costs

Capital costs usually include any produced physical good needed to provide the needed information, such as machinery, computers, and other equipment.

(a) Direct Reporters, Indirect Reporters, Indirect Reporting Firms, and Local Registration Authorities

EPA does not anticipate that direct reporters, indirect reporters, i ndirect reporting firms, and LRAs will incur capital costs in carryi ng out the information collection requirements

covered in this ICR.

(b) State/Local Agencies

EPA anticipates that State/Local agencies will incur capital costs in upgrading their existing electronic document receiving systems or developing new electronic document receiving systems to satisfy CROMERR standards at 40 CF R 3.2000 (e.g., copy of record, Secure Sockets Layer (SSL), e-mail notification, electronic sign ature, electronic signat ure agreement). In particular, EPA estimates that each state agency will incur a cost of $310,688 and that each local agency will incur a cost of $57,996. The capital costs for state agencies were obtained from consultations (refer to Section 3(c) of this docum ent). The capital costs for local agencies were obtained from the previously approved CROMERR ICR (i.e., EPA ICR Number 2002.05, dated June 22, 2011), and updated to 2014 levels using Consumer Price Indexes developed by the

Bureau of Labor Statistics. 5 The above capital costs are show n in Exhibit 1 for all applicable respondent activities.

EPA notes that capital costs for local agencies are estimated to be lower than the capital costs for state agencies because local agencies are expected to have simpler electronic document receiving systems that cover fewer programs and fe wer electronic reports than state systems. For example, EPA has received only one applicati on from a local agency under CROMERR, and that system only accepts reports under one authorized program.

(3) Operation and Maintenance Costs

O&M costs are those costs associated with an information collection requirement incurred continually over the life of the ICR.

Continuous Occupational and Industry Series, September 1975 –June 2014 ;July 2014. Available online at: http://www.bls.gov/web/eci/ecico is.pdf, last accessed on October 8, 2014. State and Local Government Workers, All Workers, March 2011=116.6 and June 2014= 123.1.

5 Bureau of Labor Statistics, “Table 24. Historical Consumer Price Index for All Urban Consumers (CPIU): U. S. city average, all items,” CPI Detailed Report for August 2014 ; August 2014. Available online at: http://www.bls.gov/cpi/cpid1408.pdf, last accessed on Oc tober 8, 2014. April 2011=224.906 and August

2014=237.852.29

(a) Direct Reporters, Indirect Reporters, Indirect Reporting Firms, and Local Registration Authorities

O&M costs include:

 EPA estimates that employee registrants that submit subscriber agreements to EPA or States/Locals will incur a cost of $3.82 to mail a one-ounce letter by certified mail (i.e., $0.49 for first-class letter postage, $3.30 for the certified-mail fee, and $0.03 for standard business envelope). 6, 7, 8

 EPA estimates that employee registrants that submit subscriber agreements to their LRA will incur a cost of $0.52 to mail a one-ounce letter using first-class mail (i.e., $0.49 for first-class letter postage and $0.03 for standard business envelope). 9, 10

 EPA estimates that indirect reporting firms will incur a cost of $2.78 for obtaining a notarized affidavit to establish the identity of a LRA. This O&M cost was obtained from the previously approved CRO MERR ICR (i.e., EPA ICR Number 2002.05, dated June 22, 2011), and updated to 2014 le vels using Consumer Price Indexes developed by the Bureau of Labor Statistics. 11

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

(b) State/Local Agencies

For State/Local agencies, O&M costs include ma iling costs. In particular, EPA estimates that State/Local agencies submitting documentation to EPA (e.g., applications for program modification approval under 40 CFR 3.1000) will incur a cost of $6.09 to mail a nine-ounce large envelope by certified mail ($2.66 for firs t-class large envelope postage, $3.30 for the certified-mail fee, and $0.13 for catalog envelope). 12, 13, 14 These O&M costs are shown in Exhibit 1 for all applicab le respondent activities.

6 U.S. Postal Service; “First-Class Mail Prices.” Available online at: https://www.usps.com/201 4/mailing/m-fcm-retail.xls, last accessed on October 8, 2014.

7 U.S. Postal Service; “Extra Serv ices Prices.” Available online at: https://www.usps.com/2014/mailing/ m-dom-extra-services.xls, last accessed on October 8, 2014.

8 Standard business envelope cost based on current market price, as of October 8, 2014 (i.e., box of 500 standard business envelopes with gummed closure at $15.59).

9 U.S. Postal Service; “First-Cla ss Mail Prices.” Available online at: https://www.usps.com/201 4/mailing/m-fcm-retail.xls, last accessed on October 8, 2014.

10 Standard business envelope cost based on current market price, as of October 8, 2014 (i.e., box of 500 standard business envelopes with gummed closure at $15.59).

11 Bureau of Labor Statistics, “Table 24. Historical Consumer Price Index for All Urban Consumers (CPIU): U. S. city average, all items,” CPI Detailed Report for August 2014 ; August 2014. Available online at: http://www.bls.gov/cpi/cpid1408.pdf, last accessed on Oc tober 8, 2014. April 2011=224.906 and August

2014=237.852.

12 U.S. Postal Service; “First-Cla ss Mail Prices.” Available online at:30

6(c) ESTIMATING AGEN CY HOUR AND COST BURDEN

EPA estimates the Agency hour and cost burden associated with the information collection requirements covered in this ICR in Exhibit 2. As shown in the exhibit, EPA estimates an average hourly labor cost of $65.58 for legal staff (GS-14, Step 5), $55.50 for managerial staff (GS-13, Step 1), $46.67 for t echnical staff (GS-12, Step 1), and $23.68 for clerical staff (GS-06, Step 1). To derive these hourly estimat es, EPA referred to the General Schedule (GS) Salary Table 2014. 15 This publication summarizes the unloaded (base) hourly rate for various labor categories in the Federa l government. EPA then applied the standard government overhead factor of 1.6 to the unloade d rate to derive loaded hourly rates.

EPA estimates that, each year, the Agency will incur a capital cost of $173,600 in CDX development, operation, and maintenance activities. 16 This capital cost is shown in Exhibit 2.

O&M costs include electronic transaction f ees associated with the processing of electronic subscriber agreements (ESA) by a thir d party vendor. In particular, EPA estimates that the Agency will incur an electronic transaction cost of $0.61 per subscriber agreement. 17
This O&M cost is shown in Exhibit 2 for all applicable activities.

6(d) ESTIMATING RESPONDENT UNIVERSE AND TOTAL HOUR AND

COST BURDEN

In this section, EPA first describes the estimated respondent universe. EPA then estimates the annual burden to respondents under the information co llection requirements

covered in this ICR.

EPA notes that, as used in this do cument, the term “respondent” includes:

 Direct reporters, indirect reporters, indire ct reporting firms, and LRAs complying with the registration and identity proofi ng requirements covered in this ICR, as applicable. This includes:

https://www.usps.com/201 4/mailing/m-fcm-retail.xls, last accessed on October 8, 2014.

13 U.S. Postal Service; “Extra Serv ices Prices.” Available online at: https://www.usps.com/2014/mailing/ m-dom-extra-services.xls, last accessed on October 8, 2014.

14 Catalog envelope cost based on current market price, as of October 8, 2014 (i.e., box of 100 6” x 9” brown kraft catalog envelopes with gummed closure at $13.29).

15 US Office of Personnel Management, “Base Hourly Rate,” 2014 General Schedule (Base) , January 2014. Available online at: http://www.opm.gov/polic y-data-oversight/pay-leave/salaries-wages/salarytables/pdf/2014/GS_h.pdf, last accessed on October 8, 2014.

16 Based on data current as of October 13, 2014.

17 Based on data current as of September 10, 2014.31

 Private sector entities; and

 State/Local agencies that are regulated entities 18

.

 State/local agencies admini stering electronic document r eceiving systems subject to

CROMERR 19 . In this document, we refer to these respondents as “State/Local agencies acting as regulators.”

 State/local agencies seeking EPA appr oval to allow electr onic reporting under

CROMERR 20 . In this document, we refer to these respondents as “State/Local agencies that are re gulated entities.”

(1) Respondent Universe

EPA estimates that, in total, 102,387 responde nts will be subject to the information collection requirements covered in this ICR. This includes 77,482 direct reporters, 24,834 indirect reporters, 48 State/Local agencies acting as regulators, and 23 State/Local agencies that are regulated entities. The following paragra phs provide additional information on how these respondent universe estim ates were derived.

(a) Direct Reporter Employees

EPA estimates that, each year, 77,482 direct repo rters will be subject to the information collection requirements covered in this ICR. This includes 55,483 direct reporter employees expected to register with C DX and 21,999 direct re porters expected to submit subscriber

agreements.

Table 2 presents information on the annual num ber of employee registrants expected to register with CDX during the thr ee-year period covered by the ICR. As shown in the table, EPA estimates that, on average, 55,483 employees will register with CDX each year.

Appendix B provides detailed information on the methodology used to estimate the average annual number of direct reporters expect ed to register with the CDX during the threeyear period covered by this ICR.

18 Addressing State/Local agencies as “respondents” is consistent with EPA’s interpretation of the definition of respondent in the PRA.

19 Ibid.

20 Ibid.32

Table 2 Annual Number of Direct Reporter Empl oyees Expected to Register with EPA’s CDX during the Three-Year Period Covered by the ICR

Respondent Universe Average Annual Number of New Employee Registrants a

Private Sector Entities 47,772 State/Local Agencies that are Regulated Entities 7,711
Total 55,483

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

Table 3 presents information on the estimated annual number of subscriber agreements to be submitted to EPA during the three-year period covered by the ICR. As shown in the table, direct reporters have various op tions for complying with the s ubscriber agreement requirements

covered in this ICR:

 Paper subscriber agreement. Direct reporters have the option of preparing and mailing a paper subscriber agreement (i.e., a non-ESA).

 Electronic subscriber agreement (ESA). Direct reporters have the option of completing and submitting an ESA directly to CDX (i.e., without using a third party vendor). This eliminates the requirement to prepare and mail new paper subscriber

agreements.

 Reuse (Consolidated) ESA. Direct reporters now have the option of “reusing” an ESA. CDX has the ability to recognize when a regist rant has already provided sufficient forensic evidence through wet-ink signature, organiza tion information, and audit information tying forensic evidence to CDX credentials in order to allow reuse of the forensic evidence and accept a digitally signed (electronic) signature using the registrant’s existing CDX credential. This eliminates the requirement to prepare and mail new paper subscriber agreements.

 Third Party ESA. Direct reporters now have the option of completing and submitting an ESA through a third party vendor. CDX provides a voluntary method for real-time identity proofing using a third party vendor to validate government identification (ID) and additional personal information in compliance with OMB Memorandum M-04-04, while retaining repeatable di gital evidence of validation using cryptographic hash technology and not retaining the highly sensitive personally identifying information. The third party pr ocess validates both identity and business affiliation. This eliminates the requiremen t to prepare and mail new paper subscriber

agreements.

Appendix B provides detailed information on the methodology used to estimate the average annual number of subscriber agreements to be submitted to EPA during the three-year period covered by this ICR.33

Table 3 Annual Number of Subscriber Agreements to Be Submitted to EPA during the Three-Year Period Covered by the ICR a

Type of Subscriber Agreement Annual Number of Subscriber Agreements b, c Average

2015 2016 2017

Private Sector Entities Non-ESA Registrants 1,696 1,867 1,856 1,806 ESA Registrants 8,701 9,693 9,792 9,395 Reuse (Consolidated) ESA Registrants 1,040 506 68 538 Third Party ESA Registrants 6,476 6,872 8,256 7,201
Subtotal 17,913 18,938 19,972 18,941 State/Local Agencies that Are Regulated Entities Non-ESA Registrants 274 301 300 292 ESA Registrants 1,404 1,565 1,581 1,517 Reuse (Consolidated) ESA Registrants 168 82 11 87 Third Party ESA Registrants 1,045 1,109 1,333 1,162
Subtotal 2,891 3,057 3,225 3,058

Total Non-ESA Registrants 1,970 2,168 2,156 2,098 ESA Registrants 10,105 11,258 11,373 10,912 Reuse (Consolidated) ESA Registrants 1,208 588 79 625 Third Party ESA Registrants 7,521 7,981 9,589 8,364
Total 20,804 21,995 23,197 21,999

a Table includes rounding error.

a Table contains data provided by EPA’s Office of Information Collection (OIC), and are current as of August 8, 2014.

c Federal government employees are not reflected in the table because they are exem pt from ICR requirements.

(b) Indirect Reporter Employees

Table 4 presents information on the annual num ber of employee registrants expected to register and comply with identify proofing requirements of State/Local electronic document receiving systems during the three- year period covered by the ICR. As shown in the table, EPA estimates that, on average, 24,834 employees from i ndirect reporting faciliti es will register and comply with identify proofing requirements of State/Local electronic document receiving systems each year.

For indirect reporters, EPA assumes that on ly a portion of employee registrants from medium-size and large firms will use the LRA alte rnative. The remaining facility employees will comply with the subscriber agreement provisi ons. Thus, in order to perform the analysis, EPA categorized employee registrants based on th e size of their firms (i.e., small firm or medium-size and large firm). Table 4 presents information on the annual number of employee registrants by type of firm.34

As shown in Table 4, EPA estimates that, on average, 13,372 employees from small firms and 11,462 employees from medium-size and large fi rms will register and comply with identify proofing requirements of State/Local electr onic document receiving systems each year.

Appendix C provides detailed information on the methodology used to estimate the average annual number of indirect reporters fo r the three-year period covered by this ICR.

Table 4 Annual Number of Indirect Reporter Employees Expected to Register and Comply with Identify Proofing Requirements during the Three-Year Period Covered by the ICR

Type of Firm Average Annual Number of Employee Registrants a

Private Sector Entities
Small Firms 11,514 Medium-Size and Large Firms 9,869
Subtotal 21,383 State/Local Agencies that are Regulated Entities
Small Firms 1,858 Medium-Size and Large Firms 1,593
Subtotal 3,451

Total
Small Firms 13,372 Medium-Size and Large Firms 11,462
Total 24,834

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

(c) Indirect Reporting Firms

As shown in Table 4, EPA estimates that, on average, 13,372 employees from small indirect reporting firms will register and co mply with identify proofing requirements of

State/Local electronic document receiving systems each year. Each small firm is expected to have an average of three employees 21 , for a total of 4,457 small firms (i.e., 13,372 employees ÷ 3 employees/firm).

EPA also estimates that, on average, 11,462 employees from medium-size and large indirect reporting firms will register with St ate/Local electronic document receiving systems each year. Each medium-size and large firm is expected to have an average of 18 employees 22

, for a total of 637 medium-size and large firms (i.e., 11,462 employees ÷ 18 employees/firm).

(d) State/Local Agencies Acting as Regulators

21 This assumption was taken from Cross-Media Electronic Reporting and Records Rule (CROMERRR) Cost Benefit Analysis, Final , dated November 17, 2004.

22 This assumption was taken from Cross-Media Electronic Reporting and Records Rule (CROMERRR) Cost Benefit Analysis, Final , dated November 17, 2004.35

Based on data from EPA’s CROMERR Program and Stakeholder Management (PSM) System, EPA estimates that, currently, 48 State/ Local agencies administer electronic document receiving systems subject to CROMERR. 23

(e) States/Locals Agencies That Are Regulated Entities

Based on information currently available to EPA on the submission and approval of program modification applica tions under 40 CFR 3.1000 (i.e., CROMERR applications), EPA estimates that, on average, four States/Locals (i.e., 3 state agencies and 1 local agency) will upgrade their existing electroni c document receiving systems or develop new electronic document receiving systems and submit CR OMERR applications each year.

EPA also estimates that, on average, 15 States /Locals (i.e., 15 state agencies and 0 local agencies) will submit amendments to their or iginal CROMERR applications each year.

In addition, EPA estimates that, on average, 4 States/Locals (i.e., 4 state agencies and 0 local agencies) wi ll submit notifications to EPA about changes to laws, policies, or electronic document receiving systems each year.

Based on the above information, EPA estimates that, each year, 23 State/Local agencies will be regulated entities during the th ree-year period covered by this ICR.

(2) Annual Respondent Burden (Exhibit 1)

(a) Registering with EPA Electronic Do cument Receiving System – Direct Reporters

EPA estimates that, on average, 55,483 empl oyees of direct reporting facilities will register with EPA’s electronic document receiving system each year. EPA also estimates that, of the 55,483 employee registrants, approximately 10 percent (or5,548) will need to update their registration information each year.

(b) Compliance with Identity Proof ing Requirements – Direct Reporters

The following paragraphs discuss the assumpti ons associated with compliance with the identity proofing requireme nts by direct reporters.

Comply with Requirements for Identifier, Attribute, or Alternative Method

EPA does not anticipate that direct repor ters will prepare and submit information on identifiers or attributes, or ot her identity-proofing information.

23 PSM is a custom implementation of a Salesforce.com platform that integrates database records, online file storage, multiple distinct spreadsheets, and email l ogs, to support the reduction of Technical Review Committee (TRC) and EPA’s Office of Environmental Information (OEI) levels of effort in managing the application approval process. Data current as of October 9, 2014.36

Comply with Subscriber Agreement Provisions

EPA assumes that all direct reporters will comply with the subscriber agreement requirements.

Non-ESA Registrants. EPA estimates that, on average, employee registrants from direct reporting facilities will prepare, submit, and file a total of 2,097 paper subscriber agreements each year. EPA also estimates that, of the 2,097 paper subscriber agreements prepared each year, 89 percent (1,867) will be from new and existing employee registrants (e.g., employees registering for the first time with a data flow); 10 percent (209) will be associated with employee turnover, which requires the submittal of a new subscriber agreement by the employee replacement; and one percent (21) will be associ ated with a compromised electronic signature, which requires the submittal of a new subscriber agreement. EPA anticipates that all employee registrants preparing a paper subscriber agreement will contact the Help Desk for technical

support.

ESA Registrants. EPA estimates that, on average, employee registrants from direct reporting facilities will prepare, submit, and file a total of 10,912 ESAs each year. EPA also estimates that, of the 10,912 ESAs prepared each year, 89 percent (9,712) will be from new and existing employee registrants (e.g., employees register ing for the first time w ith a data flow); 10 percent (1,091) will be associated with employee turnover, which requires the submittal of a new subscriber agreement by the employee replacement; and one percent (109) will be associated with a compromised electronic signature, which requires the submittal of a new subscriber agreement. EPA anticipates that all employee re gistrants preparing an ESA will contact the Help Desk for technical support.

Reuse (Consolidated) ESA Registrants. EPA estimates that, on average, 625 employee registrants from direct re porting facilities will reuse their ESA each year. EPA also estimates that, of the 625 reuse (consolidated) ESAs, 89 percent (556) will be from existing employee registrants (e.g., existing employee registrants regist ering for the first time with a data flow); 10 percent (63) will be associated with employee turnover, which requires the submittal of a new subscriber agreement by the employee replacement; a nd one percent (6) will be associated with a compromised electronic signature, wh ich requires the submittal of a new subscriber agreement. EPA anticipates that all employee registrants re using an ESA will contact the Help Desk for technical support.

Third Party ESA Registrants. EPA estimates that, on average, employee registrants from direct reporting facilities will prepare, submit, and file a to tal of 8,364 third party ESAs each year. EPA also estimates that, of the 8,364 th ird party ESAs prepared each year, 89 percent (7,444) will be from new and existing employee re gistrants (e.g., employees registering for the first time with a data flow); 10 percent (836) wi ll be associated with employee turnover, which requires the submittal of a new subscriber agreement by the employee replacement; and one percent (84) will be associated with a compro mised electronic signature, which requires the submittal of a new subscriber agreement. EPA an ticipates that all employee registrants preparing a third party ESA will contact the He lp Desk for technical support.37

Conduct On-Going Management

EPA assumes that, of the 21,999 employee regist rants from direct reporting facilities, three percent (660) will have to work with EP A to resolve problems i nvolving their agreements or certifications each year.

(c) Compliance with Identity Proofin g Requirements – Indirect Reporters

The following paragraphs discuss the assumpti ons associated with compliance with the identity proofing requirements by indirect reporters.

Comply with Requirements for Identifier, Attribute, or Alternative Method

EPA does not anticipate that indirect repor ters will prepare and submit information on identifiers or attributes, or ot her identity-proofing information.

Comply with Subscriber Agreement Provisions

For indirect reporters, EPA assumes that all employee registrants from small firms (13,372) and 98 percent of employee registrants from medium-size and large firms (11,462 x 0.98 =11,233) will comply with the subscriber agreement requirements. In addition, EPA estimates that indirect reporters submit info rmation to 1.3 State/Local electronic document receiving systems, on average; hence, their empl oyees must submit subscriber agreements for 1.3 receiving systems, on average. 24 EPA assumes that all employ ee registrants from indirect reporting facilities will submit paper subscriber agreements.

Based on the above assumptions, EPA estimates that, on average, employee registrants from indirect reporting facilities will prepare, submit, and file a total of 31,986 subscriber agreements each year (i.e., [13,372 small firm employees + 11,233 medium-size and large firm employees] x 1.3 subscriber agreements/employee).

EPA also estimates that, of the 31,986 subscr iber agreements prepared each year, 89 percent ( 28,468) will be from new and ex isting employee registrants (e.g., employees registering for the first time w ith a data flow); 10 percent 25 ( 3,199) will be associated with employee turnover, which requires the submittal of a new subscriber agreement by the employee replacement; and one percent (320) will be associated with a co mpromised electronic signature, which requires the submittal of a new subscriber agreement

EPA anticipates that all employee registra nts preparing a subscriber agreement will contact the Help Desk for technical support.

24 Ibid.

25 This assumption was taken from Section 2.3.4.2 (page 29) of Cross-Media Electronic Reporting and Records Rule (CROMERRR) Cost Benefit Analysis, Final , dated November 17, 2004.38

Submit Subscriber Agreements to Local Registration Authority

EPA assumes that two percent of medium -size and large firms will use the LRA

alternative. EPA also assumes that indirect re porting firms submit information to 1.3 State/Local electronic document receiving systems, on aver age; hence, their employees must submit subscriber agreements for 1.3 receiving systems, on average. 26 Based on these assumptions, EPA estimates that, on average, employees from indirect reporting firms will prepare and send to their LRA a total of 298 subscriber agreements each year (i.e., [11,462 medium-size and large firm employees x 0.02] x 1.3 subscriber agreements/employee).

EPA estimates that, of the 298 subscriber agreements prepared each year, 89 percent (265) will be from new employee registrants; 10 percent (30) will be a ssociated with employee turnover, which requires the submittal of a new subscriber agreement by the employee replacement; and one percent (3) will be associ ated with a compromised electronic signature, which requires the submittal of a new subscriber agreement.

Conduct On-Going Management

EPA assumes that, of the 24,605 employee registra nts from indirect reporting facilities (13,372 + 11,233 = 24,605), three percent (738) will have to work with States/Locals to resolve problems involving their agreements each year.

(c) Implementation of Local Registra tion Authority Alternative – Indirect Reporting Firms and Local Registration Authorities

The following paragraphs discuss the assumpti ons associated with implementation of the LRA alternative by indirect reporting firms and LRAs.

Designating a Local Registration Authority

As stated above, EPA assumes that two pe rcent of medium-size and large indirect reporting firms (637 x 0.02 =13) will use the LRA alternative. These firms will develop a process or plan to implement the LRA alte rnative, designate the LRA, submit the LRA application to the agency, and register the LR A with the electronic document receiving system.

Of the 13 medium-size and large indirect reporting firms that will use the LRA alternative, two percent (1) w ill need to redesignate the LRA annually due to turnover, which requires registration of the new LRA with the electronic document receiving system.

Collect Subscriber Agreements from Reporters

EPA estimates that, on average, LRAs will co llect a total of 298 subscriber agreements each year. Of these 298 subscriber agreements , 265 will be from new employee registrants, 30 will be associated with empl oyee turnover, and 3 will be associated with a compromised

26 Ibid.39

electronic signature. For each of these subscrib er agreements, LRAs will need to prepare an agreement collection certification after securely storing the subscriber agreements, and submit a certification of receipt and secure storage.

(d) Compliance with Identity Proofing Requirements – State/Local Agencies Acting as Regulators

Collect Identifier, Attribute, or Alternative Information

EPA does not anticipate that indirect repor ters will prepare and submit information on identifiers or attributes, or ot her identity-proofing information.

Collect Subscriber Agreements

EPA estimates that, on average, employee regist rants from indirect reporting facilities will prepare, submit, and file a total of 31,987subscriber agreements each year. This includes 28,468 subscriber agreements from new employ ee registrants, 3,199 subscriber agreements associated with employee turnover, and 320 s ubscriber agreements associated with a compromised electronic signature. State/Local agencies will receive, process, review, approve, and file all these subscriber agreements.

Collect Submittals from Local Registration Authority

EPA estimates that, each year, employee registra nts from indirect reporting facilities will submit 298 subscriber agreements to their LRAs. This includes 265 subscriber agreements from new employee registrants, 30 subscriber agreemen ts associated with employee turnover, and 3 subscriber agreements associated with a compromi sed electronic signature. State/Local agencies will need to receive, process, review, and approv e the certification of receipt and secure storage submitted by the LRAs.

Collect Applications for Designati on of Local Regist ration Authority

EPA estimates that, each year, 13 indirect reporting firms will use the LRA alternative. EPA also estimates that, each year, one of these firms will need to redesignate the LRA due to turnover. State/Local agencies will need to receive and approve these LRA applications.

Conduct On-Going Management

EPA estimates that, each year, State/Local agen cies will have to work with 738 employee registrants to resolve problems involving their agreements or certific ations, and respond to information requests.40

(e) Approval of State/Local Electro nic Document Receiving System Applications – State/Local Agenci es that Are Regulated Entities

Read the Regulations

EPA estimates that, on average, 23 States/Locals will submit documentation to EPA associated with the approval of State/Local electronic document receiving systems each year. These States/Locals are expected to r ead the regulations at 40 CFR Part 3.

Submit Electronic Document R eceiving System Application

EPA estimates that, on average, 4 States/L ocals will upgrade thei r existing electronic document receiving systems or develop new elect ronic document receiving systems and submit a CROMERR application each year . This includes 3 state agencies and 1 local agency.

Submit Amendment to Or iginal Application

EPA estimates that, on average, 15 states will submit amendments to their original CROMERR application each year. EPA does not anticipate that Locals will submit amendments to their original CROMERR applications during the three-year period covered by this ICR.

Submit Notification on Changes to Laws, Polic ies, or Electronic Document Receiving System

EPA estimates that, on average, 4 state agen cies will submit a notification about changes to laws, policies, or electronic document receiving systems that have the potential to affect program conformance with 40 CFR 3.2000. EPA doe s not anticipate that local agencies will submit this notification during the thr ee-year period cove red by this ICR.

6(e) BOTTOM LINE HOUR AND COST BURDEN

(1) Respondent Tally

Exhibits 3 and 4 summarize th e total annual respondent hour and cost burden associated with all the requirements covered in this ICR. Exhibit 3 presents information on the total estimated respondent hour and cost burden for a ll respondents. Exhibit 4 presents information on the total estimated respondent ho ur and cost burden, by type of respondent. As used in this document, the term “respondent” includes pr ivate sector and State/Local entities. 27 As shown in the exhibits, EPA estimates the annual respondent burden to be 49,604 hours and $2,995,642. The bottom line burden to respondents over th ree years is estimated to be 148,812 hours and $8,986,926.

27 Refer to Section 6(d) for additi onal clarification on the types of respondents examined in this ICR.41

(2) Agency Tally

Exhibit 5 summarizes the total annual EPA hour and cost burden associated with all the requirements covered in this ICR. As shown in the exhibit, EPA estimates the annual agency burden to be 22,393 hours and $1,226,664. The bottom line burden to the agency over three years is estimated to be 67,179 hours and $3,679,992.

6(f) REASONS FOR CHANGE IN BURDEN

The annual respondent burden estimate in the previously approved CROMERR ICR (EPA ICR Number 2002.05) was 39,763 hours. The a nnual respondent burden estimate for this ICR (EPA ICR Number 2002.06) is 49,604 hours. This represents an increase of 9,841 hours.

This increase in burden occurred primarily because, in developing this ICR, EPA carefully reviewed the respondent activities. Based on consulta tions with industry and state agencies, EPA increased some of the hourly burde n estimates. EPA believes that the revised burden estimates included in this ICR reflect a realistic average.

Note, however, that the increase in burden associated with the revised hourly burden estimates was offset by a decrease in the to tal annual number of employees complying with CROMERR’s identity proofing requirement s, from 58,996 employees (i.e., 33,072 direct reporters + 25,924 indirect re porters) in the previously approved ICR to 46,833 employees (i.e., 21,999 direct reporters + 24,834 indirect reporters) in this ICR. In estimating the annual number of employees complying with the CROMERR’s identity proofing requirements for this ICR, EPA was able to take advantage of im provements in data software and hardware capabilities and thus, develop estim ates based on actual data instead of the complex calculations used in the previously approved ICR. In partic ular, EPA was able to obtain actual numbers and growth rates for the annual number of subscriber agreements submitted to CDX over the past several years. These data were used to improve the estimate for the annu al number of subscriber agreements submitted by direct reporters. EPA believes that the respondent estimates included in this ICR are a reasonable approxima tion of the actual re spondent universe.

All changes in burden are considered “adjustme nts,” since they resulted from changes in the size of the respondent universe and refinement s to the assumptions us ed in the development

of the ICR.

6(g) PUBLIC BURDEN STATEMENT

(1) Registering with EPA Electronic Docume nt Receiving System – Direct Reporters

The reporting burden is estimated to be 10 mi nutes for a facility employee to register with CDX. This includes time for preparing th e on-line application and calling the CDX Help Desk. There are no recordkeep ing requirements associated w ith registering with the CDX application.

(2) Compliance with Identity Proofing Requi rements – Direct and Indirect Reporters42

The reporting burden is estimated to be a bout 80 minutes for a facility employee to prepare and submit identifier, attr ibute, or alternative informa tion. There are no recordkeeping requirements associated with this requirement, and as such, there is no recordkeeping burden.

The reporting burden is estimated to range fr om 17 minutes to 25 minutes for a facility employee to prepare and submit a subscriber agreement. The recordkeeping burden for the facility employee is estimated to be about 7 minutes to file an agreement on site.

(3) Implementation of Local Registration Au thority Alternative – Indirect Reporting Firms and Local Regist ration Authorities

The reporting burden is estimated to be 13 hours for a firm to develop a process or plan to use the LRA alternative, designate the LRA, submit the LRA application to the agency, and register the LRA with the electronic documen t receiving system. There are no recordkeeping requirements associated with this requirement, and as such, there is no recordkeeping burden.

The reporting burden is estimated to be 1 hour for a firm to redesignate the LRA, due to turnover; send the LRA application to the agency ; and register the new LRA with the electronic document receiving system. There are no recordk eeping requirements associated with this requirement, and as such, ther e is no recordk eeping burden.

The reporting burden is estimated to be 10 minutes for a LRA to prepare and submit a certification of receipt and secure storage af ter receiving a subscriber agreement. The recordkeeping burden is estimated to be 10 minutes for a LRA to compile subscriber agreements from employee registrants within the LRA’s fi rm and place them in secure storage.

(4) Compliance with Identity Proofing Requiremen ts – State/Local Agencies Acting as Regulators

The reporting burden is estimated to be 30 mi nutes for a State/Local agency to receive, process, review, and approve id entifier, attribute, or alternative information. There are no recordkeeping requirements associated with this requirement, and as such, there is no recordkeeping burden.

The reporting burden is estimated to be 10 mi nutes for a State/Local agency to receive, process, review, and approve subscriber agreem ents. There are no recordkeeping requirements associated with this requirement, and as such, there is no recordkeeping burden.

The reporting burden is estimated to be 30 mi nutes for a State/Local agency to receive, process, review, and approve an LRA applica tion. There are no recordkeeping requirements associated with this requirement, and as such, there is no recordkeeping burden.43

The reporting burden is estimated to be 2.5 hours for a State/Local agency to resolve problems involving subscriber agreements or certif ications, and respond to information requests. There are no recordkeeping requirements associated with this requirement, and as such, there is no recordkeeping burden.

(5) Approval of State/Local Electro nic Document Receiving System Applications – State/Local Agenci es that Are Regulated Entities

The reporting burden is estimated to range from 210 hours to 331 hours for a State/Local agency to prepare and submit the CROMERR applic ation to EPA. The r ecordkeeping burden is estimated to be 90 minutes to read the regulations.

The reporting burden is estimated to be 24 hour s for a State/Local agency to prepare and submit an amendment to its original CROMERR a pplication to EPA. Th e recordkeeping burden

is estimated to be 90 minutes to read the regulations.

The reporting burden is estimated to be about 11 hours for a State/Local agency to notify EPA about changes to laws, policies, or electr onic document receiving systems that have the potential to affect program conformance with 40 CFR 3.2000. The recordkeeping burden is estimated to be 90 minutes to read the regulations.

Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disc lose or provide information to or for a Federal agency. This

includes the time needed to revi ew instructions; develop, acquire , install, and utilize technology and systems for the purposes of collecting, valid ating, and verifying information, processing and maintaining information, and disclosing and providi ng information; adjust the existing ways to comply with any previously applicable instructio ns and requirements; train personnel to be able to respond to a collection of info rmation; search data sources; co mplete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to re spond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA’s regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA–HQ–OEI–2011–0096, which is available for online viewing at www.regulations.gov, or in person viewing at the Office of Environmental Information (OEI) Docket in the EPA Docket Center (EPA /DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, ex cluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and th e telephone number for the OEI Docket is (202) 566-1752. An electronic version of the pub lic docket is available at www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documen ts in the public docket that are available electronically. When in the sy stem, select “search,” then ke y in the Docket ID Number44

identified above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503,

Attention: Desk Officer for EPA. Please in clude the EPA Docket ID Number EPA–HQ–OEI– 2011–0096 and OMB Control Number 2025–0003 in any correspondence.45EXHIBIT 1CROSS-MEDIA ELECTRONIC REPORTING RULELeg. Mgr. Tech. Cler. Respon. Labor Capital/ Number of Total Total$61.63/ $39.50/ $39.17/ $17.23/ Hours/ Cost/ Startup O&M Respon. Hours/ Cost/INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Activity Activity Cost Cost Activities Year YearLog on to the receiving system site and enter requested information 0.00 0.00 0.15 0.00 0.15 $5.88 $0.00 $0.00 55,483 8,322.45 $326,240.04Update the information as needed 0.00 0.00 0.02 0.00 0.02 $0.78 $0.00 $0.00 5,548 110.96 $4,327.44Subtotal Varies Varies Varies Varies Varies Varies Varies Varies Varies 8,433.41 $330,567.48Comply with Requirements for Identifier, Attribute, or Alternative MethodPrepare and submit requested information 0.00 0.25 1.00 0.10 1.35 $50.77 $0.00 $0.00 0 0.00 $0.00Comply with Subscriber Agreement Provisions - Non-ESA RegistrantsPrepare and submit a subscriber agreement 0.00 0.00 0.42 0.00 0.42 $16.45 $0.00 $3.82 1,867 784.14 $37,844.09File subscriber agreement 0.00 0.00 0.12 0.00 0.12 $4.70 $0.00 $0.00 1,867 224.04 $8,774.90Prepare and submit a new subscriber agreement, for employee turnover 0.00 0.00 0.42 0.00 0.42 $16.45 $0.00 $3.82 209 87.78 $4,236.43File new subscriber agreement, for employee turnover 0.00 0.00 0.12 0.00 0.12 $4.70 $0.00 $0.00 209 25.08 $982.30Report compromised or surrendered electronic signature device and prepare/submitnew subscriber agreement if necessary0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $3.82 21 3.57 $220.08Contact the Help Desk for technical support 0.00 0.00 0.06 0.00 0.06 $2.35 $0.00 $0.00 2,097 125.82 $4,927.95Comply with Subscriber Agreement Provisions - ESA RegistrantsPrepare and submit a subscriber agreement 0.00 0.00 0.28 0.00 0.28 $10.97 $0.00 $0.00 9,712 2,719.36 $106,540.64File subscriber agreement 0.00 0.00 0.12 0.00 0.12 $4.70 $0.00 $0.00 9,712 1,165.44 $45,646.40Prepare and submit a new subscriber agreement, for employee turnover 0.00 0.00 0.28 0.00 0.28 $10.97 $0.00 $0.00 1,091 305.48 $11,968.27File new subscriber agreement, for employee turnover 0.00 0.00 0.12 0.00 0.12 $4.70 $0.00 $0.00 1,091 130.92 $5,127.70Report compromised or surrendered electronic signature device and prepare/submitnew subscriber agreement if necessary0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $0.00 109 18.53 $725.94Contact the Help Desk for technical support 0.00 0.00 0.06 0.00 0.06 $2.35 $0.00 $0.00 10,912 654.72 $25,643.20Prepare and submit a subscriber agreement 0.00 0.00 0.28 0.00 0.28 $10.97 $0.00 $0.00 556 155.68 $6,099.32File subscriber agreement 0.00 0.00 0.12 0.00 0.12 $4.70 $0.00 $0.00 556 66.72 $2,613.20Prepare and submit a new subscriber agreement, for employee turnover 0.00 0.00 0.28 0.00 0.28 $10.97 $0.00 $0.00 63 17.64 $691.11File new subscriber agreement, for employee turnover 0.00 0.00 0.12 0.00 0.12 $4.70 $0.00 $0.00 63 7.56 $296.10Report compromised or surrendered electronic signature device and prepare/submitnew subscriber agreement if necessary0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $0.00 6 1.02 $39.96Contact the Help Desk for technical support 0.00 0.00 0.06 0.00 0.06 $2.35 $0.00 $0.00 625 37.50 $1,468.75Prepare and submit a subscriber agreement 0.00 0.00 0.28 0.00 0.28 $10.97 $0.00 $0.00 7,444 2,084.32 $81,660.68File subscriber agreement 0.00 0.00 0.12 0.00 0.12 $4.70 $0.00 $0.00 7,444 893.28 $34,986.80Prepare and submit a new subscriber agreement, for employee turnover 0.00 0.00 0.28 0.00 0.28 $10.97 $0.00 $0.00 836 234.08 $9,170.92File new subscriber agreement, for employee turnover 0.00 0.00 0.12 0.00 0.12 $4.70 $0.00 $0.00 836 100.32 $3,929.20Report compromised or surrendered electronic signature device and prepare/submitnew subscriber agreement if necessary0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $0.00 84 14.28 $559.44Contact the Help Desk for technical support 0.00 0.00 0.06 0.00 0.06 $2.35 $0.00 $0.00 8,364 501.84 $19,655.40Conduct On-Going ManagementIdentify and resolve problems 0.00 0.00 1.67 0.00 1.67 $65.41 $0.00 $0.00 660 1,102.20 $43,170.60Subtotal Varies Varies Varies Varies Varies Varies Varies Varies Varies 11,461.32 $456,979.38aExhibit includes rounding error.Comply with Subscriber Agreement Provisions - Reuse (Consolidated) ESA RegistrantsComply with Subscriber Agreement Provisions - Third Party ESA RegistrantsESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDENaHours and Costs Per Respondent Per ActivityRegistering with EPA Electronic Document Receiving System - Direct ReportersCompliance with Identity Proofing Requirements - Direct ReportersTotal Hours and Costs46EXHIBIT 1 (CONTINUED)CROSS-MEDIA ELECTRONIC REPORTING RULELeg. Mgr. Tech. Cler. Respon. Labor Capital/ Number of Total Total$61.63/ $39.50/ $39.17/ $17.23/ Hours/ Cost/ Startup O&M Respon. Hours/ Cost/INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Activity Activity Cost Cost Activities Year YearComply with Requirements for Identifier, Attribute, or Alternative MethodPrepare and submit requested information 0.00 0.25 1.00 0.10 1.35 $50.77 $0.00 $0.00 0 0.00 $0.00Comply with Subscriber Agreement Provisions - Non-ESA RegistrantsPrepare and submit a subscriber agreement 0.00 0.00 0.42 0.00 0.42 $16.45 $0.00 $3.82 28,468 11,956.56 $577,046.36File subscriber agreement 0.00 0.00 0.12 0.00 0.12 $4.70 $0.00 $0.00 28,468 3,416.16 $133,799.60Prepare and submit a new subscriber agreement, for employee turnover 0.00 0.00 0.42 0.00 0.42 $16.45 $0.00 $3.82 3,199 1,343.58 $64,843.73File new subscriber agreement, for employee turnover 0.00 0.00 0.12 0.00 0.12 $4.70 $0.00 $0.00 3,199 383.88 $15,035.30Report compromised or surrendered electronic signature device and prepare/submitnew subscriber agreement if necessary0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $3.82 320 54.40 $3,353.60Contact the Help Desk for technical support 0.00 0.00 0.06 0.00 0.06 $2.35 $0.00 $0.00 31,987 1,919.22 $75,169.45Prepare subscriber agreement and send to LRA (non-ESA registrant) 0.00 0.00 0.42 0.00 0.42 $16.45 $0.00 $0.52 265 111.30 $4,497.05Prepare new subscriber agreement and send to LRA, for employee turnover (nonESA registrant)0.00 0.00 0.42 0.00 0.42 $16.45 $0.00 $0.52 30 12.60 $509.10Report breach of security or comprimise/surrender of electronic signature device 0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $0.00 3 0.51 $19.98Prepare new subscriber agreement and send to LRA subsequent to breach ofsecurity/compromise of electronic signature device (non-ESA registrant)0.00 0.00 0.42 0.00 0.42 $16.45 $0.00 $0.52 3 1.26 $50.91Conduct On-Going ManagementIdentify and resolve problems 0.00 0.00 1.67 0.00 1.67 $65.41 $0.00 $0.00 738 1,232.46 $48,272.58Develop a process or plan to implement the requirement, designate the LRA, andsubmit LRA application to agency1.00 0.00 12.00 0.00 13.00 $531.67 $0.00 $6.60 13 169.00 $6,997.51Register LRA with the electronic document receiving system 0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $0.00 13 2.21 $86.58Redesignate LRA, due to turnover, and send application materials 0.00 0.00 1.00 0.00 1.00 $39.17 $0.00 $6.60 1 1.00 $45.77Register new LRA with electronic document receiving system 0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $0.00 1 0.17 $6.66Collect and securely store subscriber agreements 0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $0.00 265 45.05 $1,764.90Prepare agreement collection certification after securely storing subscriber agreements,and submit certification of receipt and secure storage0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $2.79 265 45.05 $2,504.25Collect and securely store subscriber agreements, for employee turnover 0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $0.00 30 5.10 $199.80Prepare agreement collection certification after securely storing subscriber agreements,and submit certification of receipt and secure storage, for employee turnover0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $2.79 30 5.10 $283.50Collect and securely store subscriber agreements, for breach of security/compromiseof electronic signature device0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $0.00 3 0.51 $19.98Prepare agreement collection certification after securely storing subscriber agreements,and submit certification of receipt and secure storage, for breach ofsecurity/compromise of electronic signature device0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $2.79 3 0.51 $28.35Subtotal Varies Varies Varies Varies Varies Varies Varies Varies Varies 20,705.63 $934,534.96aExhibit includes rounding error.ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDENHours and Costs Per Respondent Per Activity Total Hours and CostsCompliance with Identity Proofing Requirements - Indirect ReportersDesignating a Local Registration AuthoritySubmit Subscriber Agreement to Local Registration AuthorityImplementation of Local Registration Authority Alternative - Indirect Reporting Firms and Local Registration AuthoritiesCollect Subscriber Agreements from Reporters47EXHIBIT 1 (CONTINUED)ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDENLeg. Mgr. Tech. Cler. Respon. Labor Capital/ Number of Total Total$41.13/ $41.13/ $31.15/ $14.78/ Hours/ Cost/ Startup O&M Respon. Hours/ Cost/INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Activity Activity Cost Cost Activities Year YearReceive, process, review and approve identifier, attribute, or alternativeinformation0.00 0.00 0.50 0.00 0.50 $15.58 $0.00 $0.00 0 0.00 $0.00Receive, process, review, approve and file new subscriber agreements 0.00 0.00 0.17 0.00 0.17 $5.30 $0.00 $0.00 28,468 4,839.56 $150,880.40Receive, process, review, approve and file new subscriber agreements, foremployee turnover0.00 0.00 0.17 0.00 0.17 $5.30 $0.00 $0.00 3,199 543.83 $16,954.70Receive, process, review, approve report compromise/surrender electronicsignature device0.00 0.00 0.17 0.00 0.17 $5.30 $0.00 $0.00 320 54.40 $1,696.00Receive, process, review, and approve certification of receipt and securestorage0.00 0.00 0.17 0.00 0.17 $5.30 $0.00 $0.00 265 45.05 $1,404.50Receive, process, review and approve updated certification of receipt andsecure storage, for employee turnover0.00 0.00 0.17 0.00 0.17 $5.30 $0.00 $0.00 30 5.10 $159.00Receive notification of breach of security or compromise/surrender ofelectronic signature device and take action0.00 0.00 1.00 0.00 1.00 $31.15 $0.00 $0.00 3 3.00 $93.45Receive, process, review and approve certification of receipt and securestorage, for breach of security0.00 0.00 0.17 0.00 0.17 $5.30 $0.00 $0.00 3 0.51 $15.90Receive application to designate first-time LRA 0.00 0.00 0.50 0.00 0.50 $15.58 $0.00 $0.00 13 6.50 $202.54Receive application to designate LRA, for LRA turnover 0.00 0.00 0.50 0.00 0.50 $15.58 $0.00 $0.00 1 0.50 $15.58Identify and resolve problems 0.00 0.00 1.00 0.00 1.00 $31.15 $0.00 $0.00 738 738.00 $22,988.70Respond to information requests 0.00 0.00 1.50 0.00 1.50 $46.73 $0.00 $0.00 738 1,107.00 $34,486.74Subtotal Varies Varies Varies Varies Varies Varies Varies Varies Varies 7,343.45 $228,897.51aExhibit includes rounding error.CROSS-MEDIA ELECTRONIC REPORTING RULEHours and Costs Per Respondent Per Activity Total Hours and CostsCollect Identifer, Attribute, or Alternative InformationConduct On-Going ManagementCollect Subscriber AgreementsCollect Applications for Designation of Local Registration AuthorityCompliance with Identity Proofing Requirements - State/Local Agencies Acting as RegulatorsCollect Submittals from Local Registration Authority48EXHIBIT 1 (CONTINUED)CROSS-MEDIA ELECTRONIC REPORTING RULEESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDENLeg. Mgr. Tech. Cler. Respon. Labor Capital/ Number of Total Total$41.13/ $41.13/ $31.15/ $14.78/ Hours/ Cost/ Startup O&M Respon. Hours/ Cost/INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Activity Activity Cost Cost Activities Year YearRead the regulations 0.00 1.13 1.13 0.00 2.26 $81.68 $0.00 $0.00 23 51.98 $1,878.64Upgrade existing electronic document receiving system or develop newelectronic document receiving system to meet 40 CFR 3.2000 and applyfor EPA program modification approval under 40 CFR 3.1000 (stateagencies)0.00 31.00 300.00 0.00 331.00 $10,620.03 $310,688.35 $6.09 3 993.00 $963,943.41Upgrade existing electronic document receiving system or develop newelectronic document receiving system to meet 40 CFR 3.2000 and applyfor EPA program modification approval under 40 CFR 3.1000 (localagencies)0.00 20.00 190.00 0.00 210.00 $6,741.10 $57,996.00 $6.09 1 210.00 $64,743.19Submit amendment to original application for EPA program modificationapproval under 40 CFR 3.1000 (States/Locals)0.00 8.00 16.00 0.00 24.00 $827.44 $0.00 $6.09 15 360.00 $12,502.95Submit notification to EPA about changes to laws, policies, or electronicdocument receiving systems that have the potential to affect programconformance with 40 CFR 3.2000 (States/Locals with approvedapplications)0.00 3.77 7.62 0.00 11.39 $392.42 $0.00 $6.09 4 45.56 $1,594.04Subtotal Varies Varies Varies Varies Varies Varies Varies Varies Varies 1,660.54 $1,044,662.23TOTAL Varies Varies Varies Varies Varies Varies Varies Varies Varies 49,604.35 $2,995,641.56aExhibit includes rounding error.Submit Amendment to Original ApplicationRead the RegulationsHours and Costs Per Respondent Per Activity Total Hours and CostsApproval of State/Local Electronic Document Receiving System Application - State/Local Agencies that Are Regulated EntitiesSubmit Electronic Document Receiving System ApplicationSubmit Notification on Changes to Laws, Policies, or Electronic Document Receiving System49EXHIBIT 2ESTIMATED ANNUAL EPA HOUR AND COST BURDENaLeg. Mgr. Tech. Cler. Respon. Labor Capital/ Number of Total Total$65.58/ $55.50/ $46.67/ $23.68/ Hours/ Cost/ Startup O&M Respon. Hours/ Cost/INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Activity Activity Cost Cost Activities Year YearDevelop, operate, and maintain CDX 0.00 330.00 13,790.00 0.00 14,120.00 $661,894.30 $173,600.00 $0.00 1 14,120.00 $835,494.30Subtotal 0.00 330.00 13,790.00 0.00 14,120.00 $661,894.30 $173,600.00 $0.00 1 14,120.00 $835,494.30Receive, process, review and approve identifier, attribute, or alternativeinformation0.00 0.00 0.50 0.00 0.50 $23.34 $0.00 $0.00 0 0.00 $0.00Receive, process, review, approve and file new subscriber agreementsb0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $0.00 1,867 0.00 $0.00Receive, process, review, approve and file new subscriber agreements, foremployee turnoverb0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $0.00 209 0.00 $0.00Receive, process, review, approve report compromise/surrender electronicsignature device0.00 0.00 0.17 0.00 0.17 $7.93 $0.00 $0.00 21 3.57 $166.53Receive, process, review, approve and file new subscriber agreements 0.00 0.00 0.52 0.00 0.52$24.27 $0.00 $0.00 9,712 5,050.24 $235,710.24Receive, process, review, approve and file new subscriber agreements, foremployee turnover0.00 0.00 0.52 0.00 0.52 $24.27 $0.00 $0.00 1,091 567.32 $26,478.57Receive, process, review, approve report compromise/surrender electronicsignature device0.00 0.00 0.17 0.00 0.17 $7.93 $0.00 $0.00 109 18.53 $864.37Receive, process, review, approve and file new subscriber agreementsc0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $0.00 556 0.00 $0.00Receive, process, review, approve and file new subscriber agreements, foremployee turnoverc0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $0.00 63 0.00 $0.00Receive, process, review, approve report compromise/surrender electronicsignature device0.00 0.00 0.17 0.00 0.17 $7.93 $0.00 $0.00 6 1.02 $47.58Receive, process, review, approve and file new subscriber agreementsd0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $0.61 7,444 0.00 $4,540.84Receive, process, review, approve and file new subscriber agreements, foremployee turnoverd0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $0.61 836 0.00 $509.96Receive, process, review, approve report compromise/surrender electronicsignature device0.00 0.00 0.17 0.00 0.17 $7.93 $0.00 $0.00 84 14.28 $666.12Identify and resolve problems 0.00 0.00 1.00 0.00 1.00 $46.67 $0.00 $0.00 660 660.00 $30,802.20Respond to information requests 0.00 0.00 1.50 0.00 1.50 $70.01 $0.00 $0.00 660 990.00 $46,206.60Subtotal Varies Varies Varies Varies Varies Varies Varies Varies Varies 7,304.96 $345,993.01aExhibit includes rounding error.cLabor cost associated with the collection of subscriber agreements from reuse (consolidated) ESA registrants is equal to $0.00 because, under this option, registrants can use their existing CDX credential. As a result, EPA does not need toreceive, process, review, approve, and file new paper subscriber agreements from these registrants.dLabor cost associated with the collection of subscriber agreements from third party ESA registrants is equal to $0.00 because, under this option, a third party vendor processes the subscriber agreements for an electronic transaction fee of$0.61 per subscriber agreement.Collect Subscriber Agreements - Third Party ESA RegistrantsConduct On-Going ManagementCollect Subscriber Agreements - ESA RegistrantsCollect Subscriber Agreements - Non-ESA RegistrantsCollect Identifer, Attribute, or Alternative InformationCollect Subscriber Agreements - Reuse (Consolidated) ESA RegistrantsbLabor cost associated with the collection of subscriber agreements from non-ESA registrants is equal to $0.00 because it is included in the registration costs covered under "Reporting to EPA Electronic Document Receiving System."Registering with EPA Electronic Document Receiving SystemCompliance with Identity Proofing RequirementsCROSS-MEDIA ELECTRONIC REPORTING RULEHours and Labor Costs Per Respondent Per Activity Total Hours and Costs50EXHIBIT 2 (CONTINUED)ESTIMATED ANNUAL EPA HOUR AND COST BURDENaLeg. Mgr. Tech. Cler. Respon. Labor Capital/ Number of Total Total$65.58/ $55.50/ $46.67/ $23.68/ Hours/ Cost/ Startup O&M Respon. Hours/ Cost/INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Activity Activity Cost Cost Activities Year YearProcess and file receiving system documentation submitted by State/Localseeking to modify their programs, as required by 40 CFR 3.1000 (stateagencies)0.00 0.00 160.00 0.00 160.00 $7,467.20 $0.00 $0.00 3 480.00 $22,401.60Process and file receiving system documentation submitted by State/Localseeking to modify their programs, as required by 40 CFR 3.1000 (localagencies)0.00 0.00 80.00 0.00 80.00 $3,733.60 $0.00 $0.00 1 80.00 $3,733.60Process and file amendment to original application for EPA programmodification approval under 40 CFR 3.1000 (States/Locals)0.00 0.00 24.00 0.00 24.00 $1,120.08 $0.00 $0.00 15 360.00 $16,801.20Process and file notifications about changes to laws, policies, or electronicdocument receiving systems that have the potential to affect programconformance with 40 CFR 3.2000 (States/Locals with approvedapplications)0.00 0.00 12.00 0.00 12.00 $560.04 $0.00 $0.00 4 48.00 $2,240.16Subtotal Varies Varies Varies Varies Varies Varies Varies Varies Varies 968.00 $45,176.56TOTAL 0.00 Varies Varies Varies Varies Varies Varies Varies Varies 22,392.96 $1,226,663.87aExhibit includes rounding error.CROSS-MEDIA ELECTRONIC REPORTING RULEHours and Labor Costs Per Respondent Per Activity Total Hours and CostsApproval of State/Local Electronic Document Receiving System Applications51EXHIBIT 3CROSS-MEDIA ELECTRONIC REPORTINGTOTAL ESTIMATED RESPONDENT HOUR AND COST BURDEN SUMMARYaAnnual BurdenHoursAnnual LaborCostAnnual Capital/Startup CostAnnual O&MCostTotal AnnualCostRegistering with EPA Electronic Document Receiving System - Direct Reporters 8,433.41 $330,567.48 $0.00 $0.00 $330,567.48Compliance with Identity Proofing Requirements - Direct Reporters 11,461.32 $448,968.84 $0.00 $8,010.54 $456,979.38Compliance with Identity Proofing Requirements - Indirect Reporters 20,705.63 $811,265.84 $0.00 $123,269.12 $934,534.96Compliance with Identity Proofing Requirements - State/Local Agencies Acting as Regulators 7,343.45 $228,897.51 $0.00 $0.00 $228,897.51Approval of State/Local Electronic Document Receiving System Application - State/Local Agencies that Are Regulated Entities 1,660.54 $54,461.11 $990,061.05 $140.07 $1,044,662.23Total 49,604 $1,874,161 $990,061 $131,420 $2,995,6423-year Total 148,812 $5,622,483 $2,970,183 $394,260 $8,986,926aExhibit includes rounding error.EXHIBIT 4CROSS-MEDIA ELECTRONIC REPORTINGTOTAL ESTIMATED RESPONDENT HOUR AND COST BURDEN SUMMARY, BY TYPE OF RESPONDENTaAnnual BurdenHoursAnnual LaborCostAnnual Capital/Startup CostAnnual O&MCostTotal AnnualCostRegistering with EPA Electronic Document Receiving System - Direct Reporters 7,261.34 $284,625.42 $0.00 $0.00 $284,625.42Compliance with Identity Proofing Requirements - Direct Reporters 9,870.63 $386,657.49 $0.00 $6,898.92 $393,556.41Compliance with Identity Proofing Requirements - Indirect Reporters 17,827.07 $698,476.85 $0.00 $106,140.31 $804,617.16Subtotal for Private Sector Respondents 34,959.04 $1,369,759.76 $0.00 $113,039.23 $1,482,798.99Reporting to EPA Electronic Document Receiving System - Direct Reporters 1,172.07 $45,942.06 $0.00 $0.00 $45,942.06Compliance with Identity Proofing Requirements - Direct Reporters 1,590.69 $62,311.35 $0.00 $1,111.62 $63,422.97Compliance with Identity Proofing Requirements - Indirect Reporters 2,878.56 $112,788.99 $0.00 $17,128.81 $129,917.80Compliance with Identity Proofing Requirements - State/Local Agencies Acting as Regulators 7,343.45 $228,897.51 $0.00 $0.00 $228,897.51Approval of State/Local Electronic Document Receiving System Application - State/Local Agencies that Are Regulated Entities 1,660.54 $54,461.11 $990,061.05 $140.07 $1,044,662.23Subtotal for State/Local Respondents 14,645.31 $504,401.02 $990,061.05 $18,380.50 $1,512,842.57Total for All Respondents (i.e., Private Sector and State/Local) 49,604 $1,874,161 $990,061 $131,420 $2,995,642aExhibit includes rounding error.Private Sector RespondentsState/Local Respondents52EXHIBIT 5CROSS-MEDIA ELECTRONIC REPORTINGTOTAL ESTIMATED EPA HOUR AND COST BURDEN SUMMARYaAnnual BurdenHoursAnnual LaborCostAnnual Capital/Startup CostAnnual O&MCostTotal AnnualCostRegistering with EPA Electronic Document Receiving System14,120.00 $661,894.30 $173,600.00 $0.00 $835,494.30Compliance with Identity Proofing Requirements7,304.96 $340,942.21 $0.00 $5,050.80 $345,993.01Approval of State/Local Electronic Document Receiving System Applications968.00 $45,176.56 $0.00 $0.00 $45,176.56Total 22,393 $1,048,013 $173,600 $5,051 $1,226,6643-year Total 67,179 $3,144,039 $520,800 $15,153 $3,679,992aExhibit includes rounding error.A-1

Appendix A List of North American Industry Classification System (NAICS)

Codes Associated with Industries Most Likely Affected by the

Information Collection Requirements Covered in this ICR

11 Agriculture, Forestry, Fishing and Hunting 111 Crop Production

112 Animal Production 113 Forestry and Logging 114 Fishing, Hunting and Trapping 115 Support Activities for Agriculture and Forestry

21 Mining

211 Oil and Gas Extraction 212 Mining (except Oil and Gas) 213 Support Activities for Mining

22 Utilities

221 Utilities

23 Construction 233 Building, Developing, and General Contracting 234 Heavy Construction 235 Special Trade Contractors

31 Manufacturing 311 Food Manufacturing 312 Beverage and Tobacco Product Manufacturing

313 Textile Mills

314 Textile Product Mills 315 Apparel Manufacturing 316 Leather and Allied Product Manufacturing

321 Wood Product Manufacturing 322 Paper Manufacturing 323 Printing and Related Support Activities 324 Petroleum and Coal Products Manufacturing 325 Chemical Manufacturing 326 Plastics and Rubber Products Manufacturing 327 Nonmetallic Mineral Product Manufacturing

331 Primary Metal Manufacturing 332 Fabricated Metal Product Manufacturing 333 Machinery Ma nufacturing 334 Computer and Electronic Product Manufacturing 335 Electrical Equipment, Appliance, and Component Manufacturing 336 Transportation Equipment Manufacturing

337 Furniture and Related Product Manufacturing 339 Miscellaneous Manufacturing 42 Wholesale Trade 421 Wholesale Trade, Durable Goods 422 Wholesale Trade, Nondurable Goods

44-45 Retail Trade

441 Motor Vehicle and Parts Dealers 442 Furniture and Home Furnishings Stores 443 Electronics and Appliance Stores 444 Building Material and Garden Equipment and Supplies Dealers 445 Food and Beverage Stores

446 Health and Personal Care Stores

447 Gasoline Stations 448 Clothing and Clothing Accessories Stores

451 Sporting Goods, Hobby, Book, and Music

Stores

452 General Merchandise Stores

453 Miscellaneous Store Retailers

454 Nonstore Retailers

48-49 Transportation and Warehousing 481 Air Transportation 482 Rail Transportation 483 Water Transportation 484 Truck Transportation 485 Transit and Ground Passenger Transportation 486 Pipeline Transportation 487 Scenic and Sightseeing Transportation 488 Support Activities for Transportation

491 Postal Service 492 Couriers and Messengers 493 Warehousing and Storage

51 Information 511 Publishing Industries 512 Motion Picture and Sound Recording

Industries 513 Broadcasting and Telecommunications 514 Information Services and Data Processing

Services

52 Finance and Insurance 521 Monetary Authorities Central Bank

522 Credit Intermediation and Related Activities 523 Securities, Commodity Contracts, and Other

Financial Investments and Related Activities

524 Insurance Carriers and Related Activities 525 Funds, Trusts, and Other Financial VehiclesA-2

53 Real Estate and Rental and Leasing

531 Real Estate 532 Rental and Leasing Services 533 Lessors of Nonfinancial Intangible Assets (except Copyrighted Works)

54 Professional, Scientific, and Technical

Services 541 Professional, Scientific, and Technical

Services

55 Management of Companies and Enterprises 551 Management of Companies and Enterprises

56 Administrative and Support and Waste Management and Remediation Services

561 Administrative and Support Services 562 Waste Management and Remediation

Services

61 Educational Services

611 Educational Services

62 Health Care and Social Assistance 621 Ambulatory Health Care Services 622 Hospitals 623 Nursing and Residential Care Facilities

624 Social Assistance

71 Arts, Entertainment, and Recreation 711 Performing Arts, Spectator Sports, and

Related Industries 712 Museums, Historical Sites, and Similar

Institutions 713 Amusement, Gambling, and Recreation

Industries

72 Accommodation and Food Services

721 Accommodation

722 Food Services an d Drinking Places

81 Other Services (except Public Administration) 811 Repair and Maintenance 812 Personal and Laundry Services 813 Religious, Grantmaking, Civic, Professional,

and Similar

814 Private Households

92 Public Administration 921 Executive, Legisla tive, and Other General Government Support 922 Justice, Public Order, and Safety Activities

923 Administration of Human Resource Programs 924 Administration of Environmental Quality Programs 925 Administration of Housing Programs, Urban Planning, and C 926 Administration of Economic Programs 927 Space Research and Technology 928 National Security and International AffairB-1

Appendix B Methodology for Estimating the Annual Number of Facility Employees Expected to Register and Comply with the Identity Proofing Requirements of EPA’s Electronic Document Receiving System during the Three-Year Period Covered by the ICR

This appendix describes the methodology for estimating the annual number of facility employees expected to register and comply with the identity proofing requirements of EPA’s electronic document receiving system (i.e., CDX) during the three-year period covered by the

ICR.

1. Annual Number of New Employee Registrants

This section describes the methodology for estimating the annual number of facility employees expected to register with CDX dur ing the three-year period covered by the ICR (i.e., new employee registrants). Section 1.1 provides an overview of the methodology, Section 1.2 provides a detailed discussion of the methodology, and Section 1.3 presents the

results.

1.1. Overview

In estimating the annual number of facility employees expected to register with CDX, EPA first compiled historical information on the number of new employee registrants for years 2011 through 2013. We then estimat ed the annual number of new employee registrants for the three-year period covered by the ICR (i.e., years 2015 through 2017).

1.2. Detailed Discussion

EPA took the following steps to carry out the methodology.

A. Compile historical information on number of new employee registrants. EPA referred to CDX in order to compile historical inform ation on the number of new registrants for years 2011 through 2013.

Year Number of New Employee Registrants

2011 45,755

2012 83,701

2013 40,511

B. Estimate annual number of new employee regist rants over the three-year period covered

in the ICR. We estimated the annual number of ne w employee registrants over the threeyear period covered by the ICR (i.e., y ears 2015 through 2017) by averaging the number of new employee registrants for years 2011 through 2013. That is, we assumed that 56,656 new registrants (i.e., (45,755 + 83,701 + 40,511) ÷ 3) will register with CDX each

year.B-2

C. Estimate annual number of new registrants by ty pe of ownership (i.e., private sector vs. State/Local) and remove Federal government employee registrants from this analysis. We referred to data published by the Bureau of Labor Statistics on the number of employees in the U.S. These data indicate th at 84.32 percent of U.S. employees work for the private sector, 13.61 percent of employees work for States/Locals, and 2.07 percent of employees work for the Federal government. We applied these percentages to the annual number of new employee registrants in Step B. We then excluded Federal Government employees from the analysis because they are exempt from ICR requirements.

1.3. Results

Exhibit B-1 presents information on the av erage annual number of facility employees expected to register with CDX.

Exhibit B-1 Annual Number of Facility Employ ees Expected to Register with EPA’s CDX during the Three-Year Period Covered by the ICR

Respondent Universe Average Annual Number of New Employee Registrants a

Private Sector 47,772

States/Locals 7,711

Total 55,483

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

2. Annual Number of Subscriber Agreements

This section describes the methodology for es timating the annual number of subscriber agreements submitted to EPA to comply with th e identity proofing requirements of CDX during the three-year period covered by the ICR. S ection 2.1 provides an overview of the methodology, Section 2.2 provides a detailed discussion of the methodology, and Section 2.3 presents the

results.

2.1. Overview

In estimating the annual number of subscrib er agreements submitted to CDX, EPA first compiled information on the number of ESAs for years 2012 through 2014. We then estimated the annual number of subscriber agreements (i .e., paper subscriber agreements, electronic subscriber agreements (ESAs), reuse (consolidat ed) ESAs, and third party ESAs) for the threeyear period covered by the ICR (i .e., years 2015 through 2017) based on analysis of growth rates and implementation rates.B-3

2.2. Detailed Discussion

EPA took the following steps to carry out the methodology.

Non-Electronic Subscriber Agreements

A. Compile historical information on numbe r of non-ESAs (i.e., paper subscriber agreements), by CROMERR data flow. Some of the CROMERR data flows do not support ESAs. For purposes of this analysis, the subscriber agreements associated with these data flows are categori zed as “non-ESAs” or paper subscriber agreements.

To estimate the number of non-ESAs or pa per subscriber agreements for years 2015 through 2017, we referred to CDX in order to compile historical information on the number of non-ESAs, by CROMERR data flow, for years 2012 through 2014.

CROMERR

Data Flow Number of Non-ESAs or Paper Subscriber Agreements

2012 2013 2014 a

ARCS 3 26 9

CEDRI 23 314

CEDRI1 5 45

CSPP 10 46 36

eSIPS 11

LEAD 36 500 349

MYRCRAID 17 11

ODS 1 2 1

OTAQDCFUEL 46 176 58

SSTS 6 39

TRIMEweb 1 1,317 1,719

Total 102 2,158 2,547

a Number of paper subscriber agreements were avai lable through July 2014. EPA projected the number of paper subscriber agreemen ts for the entire year, based on available 2014 data.

B. Estimate total number of non-ESAs or paper subscriber agreements, by CROMERR data flow, for the three-year period covered in the ICR. We estimated the total number of non-ESAs or paper subscriber agreemen ts, by CROMERR data flow, for years 2015 through 2017 by using the following equations:

Number of

Non-ESAs for Year Y = ([3 x Registrants Y-1 ] + [2 x Registrants Y-2 ] + [Registrants Y-3 ]) / 6B-4

The table below shows the estimated numb er of non-ESAs or paper subscriber agreements, by CROMERR data flow, for years 2015 through 2017.

CROMERR

Data Flow Number of Paper Subscriber Agreements a

2015 2016 2017

ARCS 14 14 13

CEDRI 165 191 203

CEDRI1 16 16 13

CSPP 35 37 36

eSIPS 6 7 7

LEAD 347 373 360

MYRCRAID 11 12 12

ODS 1 1 1

OTAQDCFUEL 95 96 89

SSTS 22 25 26

TRIMEweb 1,299 1,442 1,441

Total 2,011 2,214 2,201

a Table includes rounding error.

Electronic Subscriber Agreements

C. Compile historical information on number of ESAs, by CROMERR data flow. EPA referred to CDX in order to compile histor ical information on the number of ESAs, by CROMERR data flow, for years 2012 through 2014.

CROMERR Data Flow Number of ESAs

2012 2013 2014 a

ARCS 2 1 0

CEDRI 32 1,731

CEDRI1 5 66 0

CSPP 30 66 35

eSIPS 21

LEAD 377 4,971 5,954

MYRCRAID 11 3

ODS 4 12
OTAQDCFUEL 3 2 110

SSTS 19 109

TRIMEweb 5 3,758 6,567
Total 422 8,930 14,542

a Number of paper subscriber agreements were available through July 2014. EPA projected the number of paper subscriber agr eements for the entire year, based on available 2014 data.B-5

D. Estimate number of ESAs, by CROMERR data fl ow, for the three-year period covered in

the ICR. We estimated the number of ESAs, by CROMERR data flow, for years 2015 through 2017 by using the following equation:

Number of

ESAs for Year Y = ([3 x Registrants Y-1 ] + [2 x Registrants Y-2 ] + [Registrants Y-3 ]) / 6

The table below shows the estimated numb er of ESAs, by CROMERR data flow, for years 2015 through 2017.

CROMERR Data Flow Number of ESAs a

2015 2016 2017

ARCS 1 1 1

CEDRI 876 1,020 1,091

CEDRI1 23 23 19

CSPP 45 45 43

eSIPS 11 13 14

LEAD 4,697 5,162 5,139

MYRCRAID 5 5 5

ODS 7 8 8

OTAQDCFUEL 56 65 70

SSTS 61 70 74

TRIMEweb 4,537 5,084 5,149
Total 10,319 11,496 11,613

a Table includes rounding error.

E. Estimate number of reuse (consolidated) ESAs, by CROMERR data flow, for the threeyear period covered in the ICR. We estimated the number of reuse (consolidated) ESAs, for participating data flows, by applying impl ementation rates derived from data provided by CDX to the number of ESAs obtained in Step D. The implementation rates are presented in the table below:

CROMERR Data Flow Implementation Rates for Reuse (Consolidated) ESAs

2012 2013 2014

ARCS 4%

CEDRI 49% 1%

CSPP 97% 18% 29%

LEAD 2% 0.3% 0.02%

MYRCRAID 6%

ODS 67% 50% 67%
OTAQDCFUEL 2% 2% 7%

SSTS 11% 2%

TRIMEweb 24% 1% 1%B-6

The table below shows the estimated nu mber of reuse (consolidated) ESAs, by CROMERR data flow, for years 2015 through 2017.

CROMERR Data

Flow Number of Reuse (Consolidated) ESAs a

2015 2016 2017

ARCS 0

CEDRI 499 16

CSPP 44 8 13

LEAD 94 14 1

MYRCRAID 0

ODS 5 4 5

OTAQDCFUEL 1 1 5

SSTS 8 1

TRIMEweb 1,089 66 40

Total 1,233 600 81

a Table includes rounding error.

F. Estimate number of third party ESAs, by CROMERR data flow, for the three-year period

covered in the ICR. We estimated the number of third party ESAs for participating data flows by applying implementation rates derived from data provided by CDX to the number of ESAs obtained in Step D. The im plementation rates are provided in the table

below:

CROMERR Data Flow Implementation Rates for Third Party ESAs

2012 2013 2014

CEDRI 81%

CEDRI1 50% 37%

CSPP 2% 46% 47%

eSIPS 56%

LEAD 90% 86% 93%
OTAQDCFUEL 2% 6% 50%

SSTS 56% 67%

TRIMEweb 76% 71% 78%

The table below shows the estimated number of third party ESAs, by CROMERR data flow, for years 2015 through 2017.

CROMERR Data Flow Implementation Rates for Third Party ESAs a

2012 2013 2014

CEDRI 882

CEDRI1 12 8

CSPP 1 21 20

eSIPS 8

LEAD 4,227 4,456 4,801
OTAQDCFUEL 1 4 35B-7

CROMERR Data Flow Implementation Rates for Third Party ESAs a

2012 2013 2014

SSTS 39 50

TRIMEweb 3,439 3,622 3,995
Total 7,680 8,150 9,791

a Table includes rounding error.

All Subscriber Agreements

G. Estimate annual number of subscriber agreemen ts for the three-yea r period covered by

the ICR. Using the number of subscriber agreements obtained in Steps B, D, E, and F,

we estimated the annual number of subscrib er agreements for the three-year period covered by the ICR. To do this, we averaged the number of subscriber agreements for years 2015 through 2017. The results are presented in the table below.

Type of Subscriber Agreement Number of Subscriber Agreements a

Year 2015 Year 2016 Year 2017 Average

Non-ESAs (Paper Subscriber Agreements) 2,011 2,214 2,201 2,142
ESAs 10,319 11,496 11,613 11,143
Reuse (Consolidated) ESAs 1,233 600 81 638 Third Party ESAs 7,680 8,150 9,791 8,540

a Table includes rounding error.

H. Estimate number of subscriber agreements by type of ownersh ip (i.e., private sector vs. State/Local) and remove subscriber agreem ents from Federal government employee registrants from this analysis. We referred to data published by the Bureau of Labor Statistics on the number of employees in the U.S. These data indi cate that 84.32 percent of U.S. employees work for the private se ctor, 13.61 percent of employees work for States/Locals, and 2.07 percen t of employees work for the Federal government. We applied these percentages to th e number of ESAs obtained in Step G. We then excluded the subscriber agreements from Federal Government employees from the analysis because Federal government employees are exempt from ICR requirements.

2.3. Results

Exhibit B-2 presents information on the aver age annual number of s ubscriber agreements to be submitted to CDX during the three-year period covered by this ICR.B-8

Exhibit B-2 Annual Number Subscriber Agreements to be Submitted to EPA’s CDX during the Three-Year Period Covered by the ICR a

Type of Subscriber Agreement Average Annual Number of Subscriber Agreements b

Private Sector Non-ESAs (Paper Subscriber Agreements) 1,806
ESAs 9,395
Reuse (Consolidated) ESAs 538 Third Party ESAs 7,201
Subtotal 18,941

States/Locals Non-ESAs (Paper Subscr iber Agreements) 292
ESAs 1,517
Reuse (Consolidated) ESAs 87 Third Party ESAs 1,162

Subtotal 3,058
All (Private Sector and States/Locals) Non-ESAs (Paper Subscriber Agreements) 2,098
ESAs 10,912
Reuse (Consolidated) ESAs 625 Third Party ESAs 8,364
Total 21,999

a Exhibit includes rounding error.

b Federal government employees are exempt from I CR requirements. As a result, their subscriber agreements are not included in the exhibit.C-1

Appendix C Methodology for Estimating the Annual Number of Facility Employees Expected to Register and Comply with Identity Proofin g Requirements of State/Local Electronic

Document Receiving Systems during the Three-Year Period Covered by the ICR

This appendix describes the methodology for estimating the annual number of facility employees expected to register and comply with identity proofing requi rements of State/Local electronic document receiving systems during the three-year period covered by the Information Collection Request (ICR). S ection 1 provides an overview of the methodology, Section 2 provides a detailed discussion of the met hodology, and Section 3 presents the results.

1. Overview

EPA estimated the number of facilities re porting to State/Local electronic document receiving systems by first identif ying states with existing and new systems and compiling them into a table (referred to as the “Master Table” in this analysis). 28, 29 We then referred to survey data compiled by EPA in 2002 from states that estimat ed the number of facili ties subject to their respective receiving systems by e nvironmental program. We updated these state estimates to current (2014) levels based on analysis of re spondent universe growth rates in EPA program ICRs. We then extrapolated the updated survey da ta to the states in the Master Table to estimate their number of facilities. The extrapolation was performed by first finding the total number of

commercial establishments in each state based on U.S. Census data, comparing the number of establishments in the survey states to the states in the Master Table, and using a scaling factor to extrapolate the number of facilities in the survey st ates to the states in the Master Table based on their respective number of commercial establis hments. We performed this extrapolation by environmental program for all states in the Master Table. Finally, we estimated the number of employees based on the nu mber of facilities.

28 “Existing electronic document r eceiving system” means an electronic document receiving system that is being used to receive electr onic documents in lieu of paper to satisfy re quirements under an authorized program on October 13, 2005 or the system, if not in use, has been substantially developed on or before that date as evidenced by the establishment of system services or specifications by contract or other binding agreement (40 CFR 3.3). Pursuant to 40 CFR 3.1000(a)(3), States/Locals with an existing electronic document receiving system for an authorized program must submit an application to revise or modify such authorized program in compliance with 40 CFR 3.1000(a)(1) no later than January 13, 2010.

29 “New electronic document receiving system” refers to an electronic do cument receiving system that was not being used to receive electronic doc uments in lieu of paper to satisfy re quirements under an authorized program on October 13, 2005 or the system, if not in use, that had not been substantially developed on or before that date. Pursuant to 40 CFR 3.1000(a)(2), St ates/Locals with new electronic docume nt receiving systems must receive EPA approval of revisions or modifications to the authorized program before the program may receive electronic documents in lieu of paper documents to satisfy program requirements.C-2

2. Detailed Discussion

EPA took the following steps to carry out the methodology.

Find the Number of States with Receivi ng Systems, by State Environmental Program

A. Identify states with existing and new electronic document receiving systems. To identify states with existing and ne w electronic document receivi ng systems, we referred to EPA’s CROMERR Program and Stakeholder Ma nagement (PSM) System. PSM is a custom implementation of a Salesforce.com plat form that integrates database records, online file storage, multiple distinct spreadsh eets, and email logs, to support the reduction of Technical Review Committee (TRC) and EP A’s Office of Environmental Information (OEI) levels of effort in managing the application approval process.

For purposes of this analysis, EPA categori zed systems based on the following criteria:

Existing Electronic Document Receiving Systems New Electronic Document Receiving Systems

System Type System Stage System Type System Stage

 Existing

 New  Approval Review

 Completeness Review

 Draft Received

 EPA Approved

 Incomplete

 TRC Approved  New

 Pending Receipt

 Scoping

EPA used data current as of October 9, 2014.

B. Estimate the number of exis ting and new state receiving sy stems, by environmental

program. Existing and new receiving systems were categorized into state environmental programs based on the statute associated with the authorized progr am (e.g., Clean Air Act (CAA), Clean Water Act (CWA)). Attachment C-1 presents a table of the states with existing and new receiving systems, by state envi ronmental program. This table is called

the “Master Table” in this appendix.

Estimate the Number of Facilities , by State Environmental Program

C. Estimate number of facilities by state environmental program, based on CROMERR costbenefit analysis (CBA) survey data. To obtain information on the number of facilities by state environmental program, we referred to “Table V-2. Existing State Receiving Systems” of Cross-Media Electronic Reporting a nd Records Rule (CROMERRR) Cost Benefit Analysis - Final ; dated November 17, 2004. This table contains information on

the number of facilities associated with st ate receiving systems reported in a survey conducted by EPA during the summer of 2002. Attachment C-2 shows the number of facilities by state environmental pr ogram based on CBA survey data.C-3

D. Update CBA’s facility estimate for each state environmental program, based on ICR respondent data. The data on number of facilities developed under Step C are based on 2002 data. In order to bring these numbers to the present (2014), we took the following

steps:

 Obtained data on annual number of respondents in the ICRs listed in Attachment C-3. For each ICR, we obtained respondent univers e estimates for at least two different years (e.g., 2003 and 2012) to enable us to es timate the annual per cent change in the

universe.

 Estimated the annual percent change in number of respondents for each ICR.

 Multiplied the annual percent change by 12 to estimate percent change over the 2002-2014 period.

 Applied the 2002-2014 percent change to faci lity estimates in order to update the number of facilities for each environmental program.

Attachment C-4 shows the ICR data used to update the CBA’s facility estimates, by state environmental program.

Extrapolate Updated State Survey Data on Number of Facilities to All States in Master Table

E. Develop a scaling factor for use in extrapolation. We referred to U.S. Census Bureau data on number of establishments by employment size for states. 30 Based on these data, which are presented in Attachment C-5, we obtained the following information for each environmental program:

 Number of commercial establishments in th e survey states for which respondent data were available; and

 Number of commercial establishments in states in the Master Table with existing and/or planned receiving systems. We then used these data to derive a scaling fa ctor to be used in Step F. This scaling factor was derived using the following equation:

Scaling Factor = Number of establishments in states in Master Table Number of establishments in survey states

F. Extrapolate the CBA’s updated facility estimates to states with existing and new receiving

systems. In deriving the total number of facilities in all states in the Master Table, we

first estimated the total number of facilities associated with each environmental program. To do this, we multiplied the updated survey data (Step D) by the corresponding scaling factor derived in Step E. This gave us th e total number of facilities reporting to the receiving systems of states in the Master Table, by environmental program. We then added up the total number of facilities in states in the Master Table across all environmental programs.

30 U.S. Census Bureau, “Number of Firms, Number of Establishments, Employment, and Annual Payroll by Enterprise Employment Size for the Un ited States and States, Totals: 20 11,” December 2013. Available online

at: http://www.census.gov/econ/susb/ , last accessed on October 12, 2014. These are the latest Statistics of U.S. Businesses (SUSB) annual data.C-4

G. Estimate annual number of facilities subject to the ICR requirements . In estimating the annual number of facilities subject to th e ICR requirements, we made the following assumptions:

 Existing receiving systems: For purposes of this analysis, we assume that existing systems have been in operation since 2005. EPA estimates that 30 percent of facilities began to use the receiving system in the first year (i.e., 2005) and 10 percent in each subsequent year.

 New receiving systems: We assume that one third of facilities will begin reporting in each year of the three-year period covered by the ICR. In each year of the ICR, EPA estimates that 30 percent of facilities will begin to use the receiving system in the first year and 10 percent in ea ch subsequent year. The above implementation rates for use of an electronic receiving system were taken from the CBA (Exhibit 2-5).

H. Estimate average annual number of facilities subject to the ICR requirements, by employment size . In estimating the average annual number of facilities by employment size, we referred to the U.S. Census Bureau data presented in Attachment C-5. Based on these data, in the U.S., 70 percent of estab lishments have less than 20 employees and 30 percent of establishments have 20 or mo re employees. We applied these percentages

to the annual number of facili ties in Step G. Once we estimated the annual number of facilities for each year from 2015 through 2017 (i .e., the three-year period covered by the ICR), we obtained the av erage over three years.

I. Estimate average annual number of facility employees subjec t to the ICR requirements

. In estimating the average annual number of facility employees, we assumed that small firm facilities have three employees and th at medium/large firm facilities have six employees. These estimates were taken from the CBA (Section 2.3.3, “Facilities;” page 26).

J. Estimate average annual number of facility employees subject to the ICR requirements by type of ownership (i.e., private sector vs . State/Local) and remove Federal government facilities from this analysis. In estimating the average annual number of facility employees by type of ownership, we referred to data published by the Bureau of Labor Statistics on the number of employees in the U.S. 31 These data indicate that 84.32 percent of U.S. employees work for the private sector, 13.61 percent of employees work for States/Locals, and 2.07 percent of employees work for the Federal government. We applied these percentages to the annual numbe r of facility employees in Step I. We then excluded Federal government employees fr om the analysis because they are exempt from ICR requirements.

31 Bureau of Labor Statistics; Quarterly Census of Employment and Wages; Number of Employees (US Total, All Industries, A ll Establishment Sizes, All Employees); 2013 (Annual). Available online at: http://data.bls.gov/pdq/querytool.jsp?survey=en , last accessed on October 12, 2014.C-5

Attachments C-6 and C-7 present details on the application of the above methodology to existing and new receiving systems, respectively.

3. Results

Exhibit C-1 presents information on the av erage annual number of facility employees expected to register with existing an d new State/Local receiving systems.

Exhibit C-1 Average Annual Number of Facility Employees Expected to Register with Existing and New State/Local Receiving Systems during the Three-Year Period Covered by the ICR a

Type of Firm Average Annual Number of Facility Employees b

Existing Receiving Systems New Receiving System All Receiving Systems (i.e., Existing and New)

Private Sector

Small Firms 6,769 4,988 11,757

Medium-Size and Large Firms 5,803 4,275 10,078

Subtotal 12,572 9,263 21,835

States/Locals

Small Firms 1,093 805 1,898

Medium-Size and Large Firms 937 690 1,627

Subtotal 2,030 1,495 3,525

All (Private Sector and States/Locals)

Small Firms 7,862 5,793 13,655

Medium-Size and Large Firms 6,740 4,965 11,705

Total 14,602 10,758 25,360

a Exhibit includes rounding error.

b Federal government employees are not reflected in th e table because they are ex empt from ICR requirements.C-6

Attachment C-1 Number of Existing and New State/Local Electronic Document Receiving Systems, by State Environmental Program (also referred to as the “Master Table”)

State Existing Systems New Systems

Air Water Waste Air Water Waste

Alabama X

Alaska X X

American Samoa

Arizona X X

Arkansas X X X

California X X X

Colorado X

Connecticut X X

Delaware X X X

District of Columbia X X X X

Florida X X X

Georgia X X

Guam

Hawaii X X

Idaho X

Illinois X X

Indiana X X X

Iowa X X

Kansas X X X

Kentucky X X X

Louisiana X

Maine X

Maryland X

Massachusetts X X X X

Michigan X X X

Minnesota X X X

Mississippi X X X

Missouri b X X X X

Montana X

Nebraska X X

Nevada X X

New Hampshire X

New Jersey X X XC-7

Attachment C-1 (continued) Number of Existing and New State/Local Electronic Document Receiving Systems, by State Environmental Program (also referred to as the “Master Table”)

State Existing Systems New Systems

Air Water Waste Air Water Waste

New Mexico X

New York X X X

North Carolina X X X X

North Dakota X

Northern Mariana Islands

Ohio X X X

Oklahoma X X X

Oregon X

Pennsylvania

Puerto Rico

Rhode Island X

South Carolina X

South Dakota X X X

Tennessee X X

Texas X X X

U.S. Virgin Islands

Utah X

Vermont X X X

Virginia X X X

Washington X X X

West Virginia X

Wisconsin X X X

Wyoming X X X

Source: U.S. Environmental Protection Ag ency (USEPA), CROMERR Program and Stakeholder Manageme nt (PSM) System, data current as of October 9, 2014.C-8Attachment C-2Number of Facilities Associated with ExistingState Electronic Document Receiving Systemsin the CROMERR Cost-Benefit AnalysisSurvey, by State Environmental Program(Data Current as of Summer 2002)StateAirWaterWaste, USTs, Emergency PlanningAir(CEM)AirPermitsAir(NEI)AirTitle VEmissionsEmissionReports(Non-Title V)AirQualityPTOApplicationsAsbestosNotificationEDMRDrinking/GroundWaterWastewaterUICHWAnnualReportUSTRiskManagementFlorida3New Jersey 12 1,5001,000New Mexico200North Dakota250Ohio200780 2,400 7805,700 1,550 480 500Pennsylvania125 6,000Wisconsin 5,200 22 600aFor purposes of this analysis, data for Wisconsin’s “Consolidated (air, haz waste)” program was divided among the “Air” and “HW Annual Report” categories.Specifically, 90 percent ofthe facilities were allocated tothe “Air” category and the remaining 10 percentwere allocated to the “HW Annual Report” category. This allocation was basedon Ohio’s data and availableinformation on the number of hazardous waste handlers that reported to the 2007 Hazardous Waste Report.Source: U.S. Environmental Protection Agency(USEPA), “Table V-2. Existing State Receiving Systems” of Cross-Media Electronic Reporting and Records Rule (CROMERRR) CostBenefit Analysis, Final; November 17, 2004.AcronymsCEM Continuous Emissions MonitoringEDMR Electronic Discharge Monitoring ReportHW Hazardous WasteNEI National Emission InventoryPTO Permit to OperateUIC Underground Injection ControlUST Underground Storage TankC-9

Attachment C-3 List of ICRs Used in Analys is, by Environmental Program

ICR Numbers ICR Name

Air

1587.06

1587.12 State Operating Permit Regulations

111.10

111.13 NESHAP for Asbestos

1088.10

1088.13 NSPS for Industrial-Commercial-Institutional Steam Generating Units

Water

2.11

2.15 National Pretreatment Program

270.42

270.45 Public Water System Supervision Program

Waste, USTs, Emergency Planning

261.14 Notification of Regulated Waste Activity

976.11 2007 Hazardous Waste Report

976.16 2013 Hazardous Waste Report , Notification of Regulated Waste Activity, and Part A Hazardous Waste Permit App lication and Modification

1380.07

1380.12 Underground Storage Tanks: Technical and Financial Requ irements, and State Program Approval Procedures

Source: U.S. Environmental Protectio n Agency (USEPA), Information Collectio n Request, Review, and Approval System (ICRAS). Data obtained on August 13, 2014.C-10Attachment C-4aICR Data Used to Update Number ofFacilities Obtained from CROMERR CBAAir ProgramsStateOperatingPermitRegulationsEPAICRNumber1587.06EPAICRNumber1587.122004 2011PermittingAuthoritiesandSourcesSubjecttoPermittingunder40CFRPart70 17,738 16,052‐9.5% 7‐1.4% 0.59‐0.8%‐0.6%NESHAPforAsbestosEPAICRNumber111.10EPAICRNumber111.132003 2011Respondents 9,848 9,517‐3.4% 8‐0.4% 0.35‐0.1%NSPSforIndustrial‐Commercial‐InstitutionalSteamGeneratingUnitsEPAICRNumber1088.10EPAICRNumber1088.132003 2012Respondents 1,230 1,727 40.4% 9 4.5% 0.06 0.3%TotalNumberRespondentsforAllICRs 27,296WeightWeightWeightAverageAnnualPercentChangeforEnvironmentalProgramWeightedAnnualPercentChangeinNumberofRespondentsWeightedAnnualPercentChangeinNumberofRespondentsWeightedAnnualPercentChangeinNumberofRespondentsRespondentUniverseRespondentUniverseRespondentUniverseAnnualNumberofRespondentsAnnualNumberofRespondentsNumberofYearsPercentChangeinNumberofRespondentsAnnualPercentChangeinNumberofRespondentsNumberofYearsNumberofYearsAnnualNumberofRespondentsPercentChangeinNumberofRespondentsAnnualPercentChangeinNumberofRespondentsPercentChangeinNumberofRespondentsAnnualPercentChangeinNumberofRespondentsC-11Attachment C-4bICR Data Used to Update Number ofFacilities Obtained from CROMERR CBAWater ProgramsNationalPretreatmentProgramEPAICRNumber2.11EPAICRNumber2.152004 2011Industrialusers(IUs),POTWs,andStates 28,285 24,411‐13.7% 7‐2.0% 0.14‐0.3%‐0.8%PublicWaterSystemSupervisionProgramEPAICRNumber270.42EPAICRNumber270.452004 2011ExistingPWSs,PrimaryAgencies,andLaboratories 161,682 154,938‐4.2% 7‐0.6% 0.86‐0.5%TotalNumberRespondentsforAllICRs 179,349AverageAnnualPercentChangeforEnvironmentalProgramPercentChangeinNumberofRespondentsAnnualPercentChangeinNumberofRespondentsWeightWeightedAnnualPercentChangeinNumberofRespondentsRespondentUniverseAnnualNumberofRespondentsRespondentUniverseAnnualNumberofRespondentsWeightedAnnualPercentChangeinNumberofRespondentsPercentChangeinNumberofRespondentsNumberofYearsNumberofYearsWeightAnnualPercentChangeinNumberofRespondentsC-12Attachment C-4cICR Data Used to Update Number ofFacilities Obtained from CROMERR CBAWaste, USTs, Emergency Planning ProgramsNotificationofRegulatedWasteActivityEPAICRNumber261.14EPAICRNumber976.162003 2012InitialandSubsequentNotificationsunderRCRASection3010;40CFRPart273,SubpartC;and40CFRPart279 31,125 46,035 47.9% 9 5.3% 0.17 0.9%‐1.0%HazardousWasteReportEPAICRNumber976.11EPAICRNumber976.162003 2012RespondentstotheHazardousWasteReport10,178 10,533 3.5% 9 0.4% 0.04 0.0%UndergroundStorageTanks:TechnicalandFinancialRequirements,andStateProgramApprovalProceduresEPAICRNumber1360.07EPAICRNumber1360.122004 2011PrivateandGovernments254,705 211,040‐17.1% 7‐2.4% 0.79‐1.9%TotalNumberRespondentsforAllICRs 267,608WeightWeightedAnnualPercentChangeinNumberofRespondentsNumberofYearsAnnualPercentChangeinNumberofRespondentsWeightWeightedAnnualPercentChangeinNumberofRespondentsAnnualPercentChangeinNumberofRespondentsRespondentUniverseAnnualNumberofRespondentsRespondentUniverseAnnualNumberofRespondentsRespondentUniverseAnnualNumberofRespondentsNote:The"NotificationofRegulatedWasteActivity,""HazardousWasteReport,"and"PartAHazardousWastePermitApplicationandModification,”ICRswereconsolidatedintoasingleICR.Forpurposesofthisanalysis,EPAreviewedtheconsolidatedICRandextractedinformationontheannualnumberofrespondentsassociatedwiththenotificationandHazardousWasteReportinformationcollectionrequirements.PercentChangeinNumberofRespondentsAverageAnnualPercentChangeforEnvironmentalProgramPercentChangeinNumberofRespondentsPercentChangeinNumberofRespondentsNumberofYearsAnnualPercentChangeinNumberofRespondentsWeightWeightedAnnualPercentChangeinNumberofRespondentsNumberofYearsC-13

Attachment C-5 Number of Establishments (Facilities) by Employment Size, 2011

STATE Less than 20 Employees 20 or More Employees Total

United States 5,160,237 2,193,806 7,354,043

Alabama 63,531 34,212 97,743

Alaska 14,672 5,447 20,119

Arizona 87,427 42,878 130,305

Arkansas 43,523 20,948 64,471

California 620,726 228,590 849,316

Colorado 110,895 39,994 150,889

Connecticut 61,646 26,394 88,040

Delaware 15,928 8,204 24,132

District of Columbia 12,569 8,976 21,545

Florida 367,662 123,189 490,851

Georgia 146,828 67,807 214,635

Hawaii 21,295 10,177 31,472

Idaho 31,493 10,906 42,399

Illinois 221,285 91,152 312,437

Indiana 93,609 49,870 143,479

Iowa 54,344 25,769 80,113

Kansas 49,554 24,044 73,598

Kentucky 58,367 31,403 89,770

Louisiana 68,736 34,480 103,216

Maine 29,446 10,666 40,112

Maryland 91,698 41,550 133,248

Massachusetts 118,936 50,210 169,146

Michigan 151,473 65,871 217,344

Minnesota 101,406 43,200 144,606

Mississippi 38,705 19,887 58,592

Missouri 99,894 47,380 147,274

Montana 27,970 7,717 35,687

Nebraska 35,862 15,691 51,553

Nevada 39,689 19,088 58,777

New Hampshire 26,003 11,028 37,031

New Jersey 170,203 56,675 226,878

New Mexico 29,748 14,112 43,860

New York 404,335 117,202 521,537

North Carolina 145,815 69,298 215,113

North Dakota 15,765 6,605 22,370

Ohio 161,735 88,741 250,476

Oklahoma 62,095 27,654 89,749C-14

Attachment C-5 (continued) Number of Establishments (Facilities) by Employment Size, 2011

STATE Less than 20 Employees 20 or More Employees Total

Oregon 76,997 29,343 106,340

Pennsylvania 199,334 96,386 295,720

Rhode Island 20,622 7,559 28,181

South Carolina 66,893 33,588 100,481

South Dakota 18,501 6,993 25,494

Tennessee 81,870 47,619 129,489

Texas 346,994 178,426 525,420

Utah 50,110 18,637 68,747

Vermont 15,984 5,206 21,190

Virginia 127,999 63,064 191,063

Washington 126,548 46,963 173,511

West Virginia 24,565 13,585 38,150

Wisconsin 93,519 44,526 138,045

Wyoming 15,433 4,896 20,329

Source: U.S. Census Bureau, “Num ber of Firms, Number of Estab lishments, Employment, and Annual Payroll by Enterprise Employment Size for the United States and States, Totals: 2011,”

December 2013. Available online at: http://www.census.gov/econ/susb/ , last accessed on October 12, 2014. These are the latest Statis tics of U.S. Businesse s (SUSB) annual data.C-15Attachment C-6Application of Methodology to Existing Receiving SystemsEnvironmentalProgramStateswithFacilityDatainCBATotalNumberofFacilitiesinCBAAverageAnnualPercentChangeforEnvironmentalProgram2002‐2014PercentChangeforEnvironmentalProgramUpdatedTotalNumberofFacilitiesinCBAAir NJ,NM,OH,PA,WI 17,197‐0.6%‐7.2% 15,959Water FL,ND,OH,WI 7,525‐0.8%‐9.6% 6,803Waste,USTs,EmergencyPlanning NJ,OH,WI 2,580‐1.0%‐12.0% 2,270EnvironmentalProgramNumberofEstablishmentsforStateswithFacilityDatainCBANumberofEstablishmentsforStateswithExistingReceivingSystemsScalingFactorAir 954,979 5,415,429 5.67Water 901,742 6,883,480 7.63Waste,USTs,EmergencyPlanning 615,399 3,696,214 6.01EnvironmentalProgramUpdatedTotalNumberofFaciltiesinCBAScalingFactorTotalNumberofFacilitiesforStateswithExistingReceivingSystemsAir 15,959 5.67 90,488Water 6,803 7.63 51,907Waste,USTs,EmergencyPlanning 2,270 6.01 13,643156,038TotalNumberofFacilitiesforAllEnvironmentalProgramsC-16Attachment C-6 (continued)Application of Methodology to Existing Receiving SystemsYear NumberofFacilities2005 46,8112006 10,9232007 9,8302008 8,8472009 7,963Legend:2010 7,1662011 6,4502012 5,8052013 5,2242014 4,7022015 4,2322016 3,8092017 3,4282018 3,0852019 2,7762020 2,499Year1 Year2 Year3SmallFirms 2,962 2,666 2,400 2,676 8,028Medium‐SizeandLargeFirms 1,270 1,143 1,028 1,147 6,882Total 4,232 3,809 3,428 3,823 14,910TypeofFirmNumberofFacilitiesperYearAverageAnnualNumberofFacilitiesAverageAnnualNumberofFacilityEmployeesYearsCoveredintheICRC-17Attachment C-7Application of Methodologyto New Receiving SystemsEnvironmentalProgramStateswithFacilityDatainCBATotalNumberofFacilitiesinCBAAverageAnnualPercentChangeforEnvironmentalProgram2002‐2014PercentChangeforEnvironmentalProgramUpdatedTotalNumberofFacilitiesinCBAAir NJ,NM,OH,PA,WI 17,197‐0.6%‐7.2% 15,959Water FL,ND,OH,WI 7,525‐0.8%‐9.6% 6,803Waste,USTs,EmergencyPlanning NJ,OH,WI 2,580‐1.0%‐12.0% 2,270EnvironmentalProgramNumberofEstablishmentsforStateswithFacilityDatainCBANumberofEstablishmentsforStateswithNewReceivingSystemsScalingFactorAir 954,979 585,036 0.61Water 901,742 1,573,831 1.75Waste,USTs,EmergencyPlanning 615,399 360,209 0.59EnvironmentalProgramUpdatedTotalNumberofFaciltiesinCBAScalingFactorTotalNumberofFacilitiesforStateswithNewReceivingSystemsAir 15,959 0.61 9,735Water 6,803 1.75 11,905Waste,USTs,EmergencyPlanning 2,270 0.59 1,33922,9797,660Year1 Year2 Year3Year1 2,298 536 483Year2 0 2,298 536Year3 0 0 2,298Total 2,298 2,834 3,317Year1 Year2 Year3SmallFirms 1,609 1,984 2,322 1,972 5,916Medium‐SizeandLargeFirms 689 850 995 845 5,070Total 2,298 2,834 3,317 2,817 10,986AnnualNumberofFacilitiesthatWillComeOnlineTotalNumberofFacilitiesforAllEnvironmentalProgramsTypeofFirmNumberofFacilitiesperYearYearSystemWillComeOnlineNumberofFacilitiesperYearAverageAnnualNumberofFacilitiesAverageAnnualNumberofFacilityEmployees