Supporting Statement for Renewal of OECA Tips & Complaints Webpage

Part A

1. Identification of the Information Collection –

1(a) Title of the Information Collection

Office of Enforcement and Compliance Assurance Tips and Complaints 

Webpage

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 webpage provides a 

convenient means by which these individuals can voluntarily submit tips and 

complaints regarding suspected violations of environmental law.

Tips or complaints received through the webpage 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 webpage does not replace or otherwise 

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

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

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 then contact EPA to 

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

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

type information into the appropriate fields on the webpage. In our estimate, 

this amounts to approximately 1⁄2 hour per tip or complaint, for total annualized 

burden for all tippers and complainants of 3,780 hours. While we do not expect 

actual labor costs associated with these burden hours, the opportunity cost of 

3,780 burden hours would be approximately $75,146.

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 received through the EPA tips and complaints web form 

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 does not duplicate other EPA web-based

information collections. OECA’s Senior Information Resources Management 

Office (SIRMO) has 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 new and 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 webpage. This notice is attached as part of the renewal package of 

which this supporting statement is a part.

EPA received one comment regarding the notice of intent to renew this ICR. 

This commenter complained of governmental inaction on a matter reported by

phone to various agencies, including EPA. As the comment did not pertain in 

any way to the tips and complaints webpage, no response is warranted in 

renewing this ICR.
3(c) Consultations

In order to confirm its burden estimates, EPA 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(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 web page 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 web page 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 web form and 

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

so may also review a general information web page on reporting an 

environmental violation and/or a web page that describes the EPA web privacy

policy – the form provides links to these documents.

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 web 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 web form explain that the 

tipper or complainant may simply enter “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 web 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

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 web 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 web 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 630 tips or complaints per month through the 

existing webpage, for a total of approximately 7,560 responses per year. 

Reading instructions and completing the webform takes approximately a half 

hour per response; accordingly, respondents collectively spend approximately 

3,780 hours per year providing tips or complaints through the tips and 

complaints webform. Assuming an average annual wage of $19.88, the 

opportunity cost of these burden hours is approximately $75,146 per year. This 

information is summarized in the table shown below.

Annual Respondent Burden & Cost

Information 

collection activity

Respondent 

hours per year

Labor 

opportunity

cost per year

Capital/startup 

costs per year

O&M 

costs 

Number of 

respondents

Total hours 

per year

Total cost per 

year

Reading 

instructions 2,520 50,098 0 0 7,560 2,520 75,146

Completing form 1,260 25,049 0 0 7,560 1,260

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

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. 

In 2010, EPA expects to add the option to upload photos to the webpage and to 

design and deploy a mobile phone application that permits the same information 

collected on the webpage to be submitted through a web-enabled mobile phone. 

These system enhancements, taken together, are expected to cost $19,700 in 

2010, or $6,567 per year when averaged over the 3-year approval period. No 

recurrent costs are expected thereafter. 

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

officers spend barely a quarter of an hour answering respondent questions per 

year. They spend approximately 24 hours per month reviewing tips and 

complaints received through the system. At an hourly wage of $39, these 

functions collectively cost EPA approximately $11,232 per year. The total cost 

to the agency of operating the tips and complaints webpage is approximately, 

$23,410. This information is summarized in the table shown below.
Annual Agency Burden & Cost

Information 

collection activity

Agent hours 

($39/hour)

Technical 

hours

($24/hour)

Annual labor 

cost

Capital/start

up costs per 

year

Total cost per 

year

System 

maintenance 0 120 $2,880 $0 $2,880

System 

enhancements $6,567 $6,567

Answer 

respondent 

questions

.25 0 $9.75 $0 $10

Review and 

distribute tips and 

complaints

288 0 $11,232 $0

$11,232

TOTAL $20,689

6(e) Bottom Line Burden & Cost Tables

The tables set forth above reflect bottom line estimates. 

6(f) Reasons for Burden Change

There is an increase of 1980 hours in the total estimated respondent burden 

compared with that identified in 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.

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.