Supporting Statement for Renewal of OECA Tips & Complaints 

Regarding Environmental Violations 

Part A

1. Identification of the Information Collection –

1(a) Title of the Information Collection

Tips and Complaints Regarding Environmental Violations (Renewal)

EPA ICR Number 2219.05, OMB Control Number 2020-0032

1(b) Short Characterization/Abstract

The Office of Enforcement and Compliance Assurance (OECA) is the 

component of the Environmental Protection Agency responsible for 

administrative, civil and criminal enforcement of the environmental laws that 

EPA administers. EPA's criminal enforcement program, and, to a lesser extent, 

its civil enforcement program are, like other federal law enforcement programs, 

dependent on tips and complaints from concerned citizens and members of the 

regulated community. The OECA Tips & Complaints web page provides a 

convenient means by which these individuals can voluntarily submit tips and 

complaints regarding suspected violations of environmental law. OECA is 

considering the use of a mobile-friendly version of the Tips and Complaints 

web pages that will complement the existing process. Tips or complaints 

received are used by civil and/or criminal enforcement personnel at EPA to 

determine whether an investigation is warranted into the suspected or alleged 

misconduct. In some cases, EPA may decide to refer tips or complaints for 

investigation to other federal agencies or to State or local authorities within 

whose jurisdiction the matter may appropriately fall. The OECA Tips and 

Complaints web page or mobile-friendly versions does not replace or otherwise 

supplant other means of providing tips or complaints to EPA; it merely provides 

a convenient means by which to supply these tips or complaints. 

As with complaints provided by phone, fax, or electronic mail, we expect that 

tippers or complainants are already in the possession of information that leads 

them to suspect a violation of environmental law when they contact EPA to 

report the matter. Accordingly, EPA believes that the burden associated with 

the reporting is merely that arising from the need to read the instructions and 

type or select information into the appropriate fields. 

2. Need For and Use of the Collection

2(a) Need/Authority for the Collection
Under the statutes that EPA is charged to administer, apprehending violators 

and responding to ongoing environmental violations is central to the Agency's 

mission. See, e.g., 33 U.S.C. § 1319 (Clean Water Act), 42 U.S.C. § 7413 

(Clean Air Act). EPA's criminal enforcement program, and, to a lesser extent, 

its civil enforcement program are, like other federal law enforcement programs, 

dependent on tips and complaints from concerned citizens and members of the 

regulated community. In fact, in some cases, the statute expressly contemplates 

that EPA will take action on citizen complaints. See, e.g., 15 U.S.C. § 2647(d) 

(citizen complaints regarding asbestos hazards). These tips and complaints help 

EPA focus its investigative resources on violations of environmental law that 

could otherwise escape detection.

2(b) Practical Utility/Users of the Data

Tips and complaints regarding environmental violations are used principally by

civil and criminal law enforcement personnel at EPA to investigate reported 

accidental violations and intentional misconduct. When appropriate, the

collected information may be shared with other law enforcement agencies that 

may have jurisdiction over the matter reported.

3. Non-duplication, Consultations, and Other Collection Criteria

3(a) Non-duplication

OECA’s tips and complaints webpage or mobile friendly version does not 

duplicate other EPA web-based information collections. OECA’s Senior 

Information Resources Management Office (SIRMO) has previously confirmed 

that the tips and complaints webpage does not duplicate other web-based 

information collections.

As noted in Section 1, above, the OECA tips and complaints webform does not

replace or otherwise supplant other means of providing tips or complaints to 

EPA; it merely provides a convenient means by which to supply these tips or

complaints online. Accordingly, tippers or complainants remain free to submit 

their tips or complaints in person or by telephone, fax, or e-mail.

3(b) Public Notice Required Prior to ICR Submission to OMB.

EPA has published notice of its intent to renew the ICR for the OECA tips and

complaints regarding environmental violations. The Federal Register Notice 

was published at 80 FR 67400 on November 2, 2015. There were no comments 

received.

3(c) Consultations
In order to confirm its burden estimates, EPA previously timed the entries of 

actual tippers or complainants who have used the OECA tips and complaints 

webpage. In order to preserve the confidentiality of these tippers or 

complainants, EPA did not record the names of these tippers or complainants or 

otherwise record any identifying information.

3(d) Effects of Less Frequent Collection

Tips and Complaints are provided to EPA on an entirely voluntary basis; 

accordingly, there is no specified frequency with which tips or complaints 

should or must be provided. There is, therefore, no basis to assess the effects of 

less frequent collection.

3(e) General Guidelines

The information collection requirements covered by this ICR adhere to the 

guidelines specified by OMB. 

3(f) Confidentiality

Tippers or complainants are not required to provide contact information in order 

to submit a tip or complaint. However, if contact information is provided, EPA 

may use this information to initiate follow-up communications with the tipper or 

complainant and may be shared by EPA with appropriate administrative, law 

enforcement, and judicial entities engaged in investigating or adjudicating the 

tip or complaint. The information is otherwise protected from disclosure to 

third parties to the extent permitted by law.

Access to the database in which tips and complaints are stored is limited by 

system administrator to a small, known universe of users. Before this access is 

granted, these users are informed that any misuse of the information stored in 

the database will cause them to lose access to the database and subject them to 

disciplinary action. Contractors do not have access to the database. 

EPA does not maintain hardcopies of the information supplied through the 

webform. Tips or complaints not acted upon within 30 days are automatically

purged from the database. Tips or complaints upon which some action is taken 

are preserved for a period of five years, pursuant to the record schedule for 

criminal investigations.

3(g) Sensitive Questions

The tips and complaints regarding environmental violations does not pose any

sensitive questions.

4. The Respondents and the Information Requested
4(a) Respondents/SIC Codes

Respondents are expected to be members of the general public as well as 

employees of any company subject to federal environmental regulation. There 

is no specific industry or group of industries about which EPA expects tips or 

complaints. For the foregoing reasons, it is not possible to classify the expected 

universe of respondents by SIC code.

4(b) Information Requested

(i) Data items, including recordkeeping requirements

The information requested on the tips and complaints regarding environmental 

violations is listed below. Items of information that are required in order to 

submit a tip or complaint are shown in italics.

 If known, the suspected violator’s name

 If known, the suspected violator’s street address

 If known, the suspected violator’s city

 If known, the suspected violator’s zip code

 Tipper’s name

 Tipper’s email address

 Tipper’s phone number

 Tipper’s street address

 Tippers city

 Tipper’s zip code

 Is the violation is ongoing?

 Has the tipper has already contacted other authorities?

 If another authority already contacted, the name of the department

contacted, if known.

 If known, is the violation accidental or intentional?

 What type of act constitutes the violation? (Release, dumping, spill,

spraying, etc.)

 Does the violation affect land, water, air, workers, or documents?

 If known, is the violator an individual, company, or government/military

agency or department?

 A description of the incident or hazard.

 Directions to the site of the violation.

 Checkbox attestation of awareness and understanding of the meaning and 

significance of submitting a tips or complaint.

 Optional photo upload tool. (To be added within the approval period).

Generally speaking, the items of information requested are not dictated by

environmental statute or regulation; instead, the information is intended to make 
it possible to route the tip or complaint within EPA (or to another, appropriate 

law enforcement agency) and to provide inspectors and/or investigators the 

information that they need to follow-up on the tip or complaint. The sole 

exception is the checkbox attestation at the end of the web form. The items of 

knowledge to which a tipper or complainant attests by checking this box are 

dictated by the general false statements provision of the U.S. Criminal Code, 18 

U.S.C. § 1001. In the event that EPA prosecutes a tipper of complainant for 

deliberately supplying false information on this web form, this attestation is 

intended to frustrate a mistake-of-fact defense that the tipper or complainant did 

not understand the nature and/or significance of submitting a tip or complaint 

using this web form.

(ii) Respondent Activities

Tippers or complainants are generally expected to review the form and complete 

the form by answering the questions posed. Those who choose to do so may

also review a general information link on reporting an environmental violation 

and/or a link that describes the EPA web privacy policy. 

Generally speaking, EPA expects tippers to be either a general member of the 

public or an employee who believes that their employer has violated an 

environmental law. In either case, EPA expects that tippers or complainants 

will come to the form already in possession of all of the information needed to 

submit a tip or complaint. Even where the form calls for information that a 

general member of the public may not have (say, for example, the address of the 

suspected violator), the instructions on the form explain that the tipper or 

complainant may simply enter/select “unknown” in the field provided for their 

response.

EPA expects that tippers or complainants who are an employee of the company

about which they are filing a tip or complaint will maintain, as a matter of 

customary business practice, the name and address of the suspected violator. In 

all other cases, EPA has no basis to presume that data items would be 

maintained as a matter of customary business practice.

5. The Information Collected – Agency Activities, Collection Methodology, and Information

Management

5(a) Agency Activities

Many of the activities associated with this form are either one-time events that 

have already occurred or are ongoing agency activities that are fully automated 

(such that they do not constitute an ongoing burden or expense). The only 

activities that are ongoing but not automated are as follows:

 Answer respondent questions
 Review and distribute tips or complaints

5(b) Collection Methodology and Management

Previously the EPA tips and complaints web form was tested as a “pilot” at a 

less prominent location on EPA’s website for a period of months. Only after 

this evaluation period did EPA provide a link to the web form on its internet 

home page.

EPA does not check the quality of data entry by tippers or complainants. Of 

course, where a tip or complaints appears to warrant further investigation, EPA 

conducts an investigation into the tip or complaint. Only in this respect does 

EPA check data quality.

EPA does not employ special machines or processing technology in evaluating 

tips or complaints. The information supplied by the tipper or complainant 

automatically populates a database that is regularly reviewed by EPA personnel 

for matters that warrant investigation. The information stored in this database 

cannot be accessed by the public and, within EPA, access to the database is 

limited by system administrator to a small universe of people who are 

responsible for reviewing the tips and complaints.

EPA has not eliminated more traditional means of collecting tips and 

complaints; the tips and complaints form simply adds an additional, convenient 

method of providing a tip or complaint for those with internet access. EPA 

expects that this method of accepting tips or complaints will reduce burden for 

many individuals. As expected, the prominence of the tips and complaint web 

form on our site, the ease with which the form may be completed, and the 

relative anonymity that the internet affords tippers or complainants has resulted 

in a significant increase in the number of tips or complaints received. The web 

form also elicits specific items of information that allow EPA to efficiently 

route tips or complaints within EPA to the appropriate office. The standardized 

format of the form also represents an advantage over tips or complaints received 

by phone, where items of information needed to evaluate a tip or complaints are 

more likely to be accidentally omitted.

5(c) Small Entity Flexibility

The tips and complaints form is an addition to, not a substitution for, other 

methods of supplying tips or complaints to EPA; accordingly, the form, itself, 

constitutes an increase in agency flexibility with respect to small entities as well 

as anyone else who may wish to supply a tip or complaint.

5(d) Collection Schedule
Individuals may submit a tip or complaint at any time. There is no schedule 

associated with this collection.

6. Estimation of the Burden and Cost of the Collection

6(a),(b) Annual Respondent Burden & Cost

EPA receives approximately 857 tips or complaints per month through the 

existing webpage, for a total of approximately 10,286 responses per year. 

Reading instructions and completing the form takes approximately a half hour 

per response; accordingly, respondents collectively spend approximately 5,143 

hours per year providing tips or complaints through the tips and complaints 

form. Assuming an average annual wage of $19.88, the opportunity cost of 

these burden hours is approximately $102,242 per year. 

6(c),(d) Annual Agency Burden & Cost

1. EPA technical staff spends approximately 10 hours per month on system 

maintenance and upkeep, for a total of 120 hours of technical work on the 

system per year. At an hourly wage of $24, system maintenance costs EPA 

approximately $2,880 per year. 

2. EPA receives very few queries from respondents; accordingly, EPA desk 

officers little time answering respondent questions per year. At an hourly 

wage of $39, these functions collectively cost EPA approximately $11,232 

per year. 

Total agency cost: $2,880 + $11,232 = $14,112

6(e) Bottom Line Burden & Cost 

The bottom line estimates to respondents are 5,143 annual burden hours, 10,286 

responses per year, and $102,242 labor cost per year. 

6(f) Reasons for Burden Change

There is an increase of 542 hours in the total estimated respondent burden 

compared with the ICR currently approved by OMB. This increase reflects the 

fact that tips and complaints are being filed at a higher rate than originally 

anticipated, a strong indication of the success of this program. There has been 

no change in the information being reported or the estimated burden per 

respondent. 

6(g) Burden Statement
ICR: Tips and Complaints Webpage Regarding Environmental Violations

OMB Control Number: 2020-0032

Providing a tip or complaint to EPA is entirely voluntary and use of the tips and complaints 

webpage to provide a tip or complaint is also entirely a matter of tipper or complainant choice. EPA 

estimates that it will take tippers or complainants approximately 1⁄2 hour to provide a tip or complaint 

using the tips and complaints webpage. This estimate includes time for reading the instructions, gathering 

required information, and completing the webform. There are no associated record-keeping requirements 

and, accordingly, no associated record-keeping burden.

The annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 1⁄2 hour per response. Burden means the total 

time, effort, or financial resources expended by persons to generate, maintain, 

retain, or disclose or provide information to or for a Federal agency. This 

includes the time needed to review instructions; develop, acquire, install, and 

utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing 

and providing information; adjust the existing ways to comply with any 

previously applicable instructions and requirements; train personnel to be able 

to respond to a collection of information; search data sources; complete 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 respond 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-HQOECA-2009-0494, which is available for online viewing at 

www.regulations.gov, or in person viewing at the Enforcement and Compliance 

Docket and Information Center 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, excluding legal holidays. The telephone number for 

the Reading Room is (202) 566-1744, and the telephone number for the 

Enforcement and Compliance Docket and Information Center is 202-566-1744. 

An electronic version of the public 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 documents in the 

public docket that are available electronically. When in the system, select 

“search,” then key in the Docket ID Number 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 include the EPA Docket ID Number 
EPA-HQ-OECA-2009-0494 and OMB Control Number 2020-0032 in any 

correspondence.