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January 14, 2016

Cost Impact Analysis for the EPA’s Draft 2016 Pesticide General Permit (PGP)

I. OVERVIEW 

As a result of the U.S. Sixth Circuit Court of Appeals decision in National Cotton Council, et al. 

v. EPA, as of October 31, 2011, point source discharges of biological pesticides, and chemical 

pesticides that leave a residue, into waters of the United States are required to comply with 

National Pollutant Discharge Elimination System (NPDES) requirements. In 2011, EPA issued a 

Pesticide General Permit (PGP) to offer coverage for pesticide operators in geographic areas 

where EPA is the NPDES permitting authority. EPA’s 2011 PGP, became effective on October 

31, 2011 (see 76 FR 68750), and expires on October 31, 2016. EPA is proposing a draft 2016 

PGP. When finalized the draft 2016 PGP will replace the EPA’s 2011 PGP.

EPA provides this cost impact analysis as part of the administrative record in support of the 

draft 2016 PGP. Because the draft 2016 PGP contains the same requirements as the 2011 PGP 

there are no significant changes to analyze in this cost analysis. However, some minor 

differences such as a decrease in number of entities covered under the draft 2016 PGP and 

inflation impacts are analyzed herein. Thus, each change is examined in light of the previous 

permit’s (the “2011 PGP”) requirements. The objective of this examination is to show where 

or to what extent the draft 2016 PGP includes requirements that impose an incremental 

increase in costs, if any, on permittees above and beyond costs that are already accounted for 

in the 2011 PGP, which defines the costs to which these permittees are currently subject.

A. The 2011 PGP and the draft 2016 PGP 

In order to gain an understanding of the incremental differences between the 2011 PGP and 

the proposed draft 2016 PGP, it is first necessary to provide a summary of changes from the 

2011 PGP. The draft 2016 PGP is similar to EPA’s 2011 PGP and regulates discharges to waters 

of the United States from the application of (1) biological pesticides, and (2) chemical 

pesticides that leave a residue for the following pesticide use patterns: 

 Mosquito and Other Flying Insect Pest Control - to control public health/nuisance 

and other flying insect pests that develop or are present during a portion of their life 

cycle in or above standing or flowing water. Public health/nuisance and other flying 

insect pests in this use category include mosquitoes and black flies. 

 Weed and Algae Pest Control - to control weeds, algae, and pathogens that are pests 

in water and at water’s edge, including ditches and/or canals.

 Animal Pest Control - to control animal pests in water and at water’s edge. Animal 

pests in this use category include fish, lampreys, insects, mollusks, and pathogens.

 Forest Canopy Pest Control –application of a pesticide to a forest canopy to control 

the population of a pest species (e.g., insect or pathogen) where, to target the pests 

effectively a portion of the pesticide unavoidably will be applied over and deposited 

to water.

The scope of activities encompassed by these pesticide use patterns is described in greater 

detail in Part III.1.1 of the fact sheet for the draft 2016 PGP.
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January 14, 2016

The draft 2016 PGP is similar to the existing permit, and is structured in nine parts: (1) 

coverage under this permit, (2) technology-based effluent limitations, (3) water quality-based 

effluent limitations, (4) monitoring, (5) pesticide discharge management plan, (6) corrective 

action, (7) recordkeeping and annual reporting, (8) EPA contact information and mailing 

addresses, and (9) permit conditions applicable to specific states, Indian Country lands or 

territories. Additionally, the permit includes nine appendices with additional conditions and 

guidance for permittees: (A) definitions, abbreviations, and acronyms, (B) standard permit 

conditions, (C) areas covered, (D) Notice of Intent Form, (E) Notice of Termination Form, (F) 

Pesticide Discharge Evaluation Worksheet, (G) Annual Reporting Template, (H) Adverse 

Incident template, and (I) Endangered species procedures. 

The draft 2016 PGP has the same conditions and requirements as the 2011 PGP. The following 

is a summary of the PGP’s requirements: 

 The PGP defines Operator (i.e., the entity required to obtain NPDES permit coverage 

for discharges) to include any (a) Applicator who performs the application of pesticides 

or has day-today control of the application of pesticides that results in a discharge to 

waters of the United States, or (b) Decision-maker who controls any decision to apply 

pesticides that results in a discharge to waters of the United States. There may be 

instances when a single entity acts as both an Applicator and a Decision-maker. 

 All Applicators are required to minimize pesticide discharges by using only the amount 

of pesticide and frequency of pesticide application necessary to control the target pest, 

maintain pesticide application equipment in proper operating condition, control 

discharges as necessary to meet applicable water quality standards, and monitor for 

and report any adverse incidents.

 All Decision-makers are required, to the extent not determined by the Applicator, to 

minimize pesticide discharges by using only the amount of pesticide and frequency of 

pesticide application necessary to control the target pest. All Decision-makers are also 

required to control discharges as necessary to meet applicable water quality standards 

and monitor for and report any adverse incidents.

 Certain Decision-makers (i.e., any agency for which pest management for land 

resource stewardship is an integral part of the organization’s operations, entities with 

a specific responsibility to control pests (e.g., mosquito and weed control districts), 

local governments or other entities that apply pesticides in excess of specified annual 

treatment area thresholds, and entities that discharge pesticides to Tier 3 waters or to 

waters of the United States containing National Marine Fisheries Service (NMFS) Listed 

Resources of Concern) are required to also submit a Notice of Intent (NOI) to obtain 

authorization to discharge and implement pest management options to reduce the 

discharge of pesticides to waters of the United States. Certain large Decision-makers 

must also develop a Pesticide Discharge Management Plan (PDMP), submit annual 

reports, and maintain detailed records. Certain small Decision-makers are required to 

complete a pesticide discharge evaluation worksheet for each pesticide application (in 

lieu of the more comprehensive PDMP), an annual report (only for entities in NMFS 

area of concerns), and detailed recordkeeping.
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January 14, 2016

One change between the 2011 PGP and the 2016 draft PGP requirements is that the draft 

2016 PGP includes an electronic reporting requirement in Part 7.8, mandating the use of the 

internet for submitting permit information (NOIs, Notices of Termination, and Annual 

Reports). Decision-makers must send this information to the eNOI (Electronic Notice of Intent) 

Center. The 2011 PGP had the option for Decision-makers to submit such information either 

electronically or by paper copy. 

In addition, there is a reduction in geographic areas covered in the draft 2016 PGP as 

compared to the 2011 PGP. The draft 2016 PGP is only available for geographic areas where 

EPA is the permitting authority (unauthorized NPDES areas). At present, EPA is the permitting 

authority for pesticide discharges in four states (Idaho, Massachusetts, New Hampshire, and 

New Mexico), the District of Columbia, all U.S. Territories with the exception of the Virgin 

Islands, federal facilities in four states (Colorado, Delaware, Vermont, and Washington), all 

Indian Country lands except in Maine and for activities associated with oil, gas and geothermal 

resources in Texas. The 2011 PGP was also available for Alaska and Oklahoma which now have 

NPDES authority for discharges to waters of the United States resulting from the application of 

pesticides.

B. Facilities Subject to the draft 2016 PGP 

The 2011 PGP was the first time that EPA issued an NPDES permit for discharges to waters of 

the United States resulting from the application of pesticides. EPA is relying on the analysis 

done for the 2011 PGP to estimate the potentially affected entities for the draft 2016 PGP. 

EPA will incorporate, as appropriate, any data received during the public comment period in 

the analysis for the final 2016 PGP. See the 2011 PGP’s economic analysis titled, “Economic 

Analysis of the Pesticide General Permit (PGP) for Point Source Discharges from the 

Application of Pesticides” in the Docket for further discussion on information available for the 

analysis.

EPA estimated 35,376 potential affected entities for the 2011 PGP which included the states of 

Alaska and Oklahoma. However, as of 2012, Alaska and Oklahoma administer permits for 

pesticide discharges in all areas except Indian Country lands, for which EPA remains the 

permitting authority. As a result of this shift in permitting responsibility, the total estimated 

number of potentially affected entities decreased relative to the 2011 PGP from 

approximately 35,376 to 30,869 entities with the following reduction in entities by use 

pattern: 3 for Mosquito and Other Flying Insect Pest Control; 4,238 for Weed and Algae Pest 

Control; 89 for Animal Pest Control and 177 for Forest Canopy Pest Control. Table 1 presents 

the numbers of potentially affected entities to be covered under the draft 2016 PGP that are 

in areas not authorized to administer the NPDES program and according to pesticide use 

pattern. Nearly 97% of these entities are in the weed and algae pest control use pattern. 

However, based on the best available information, EPA does not expect that most of the weed 

and algae pest control entities will exceed the annual treatment area threshold established in 

the PGP for the pesticide use pattern and thus will not be required to submit NOIs.
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January 14, 2016

Table 1: Summary of Estimate of Potentially Affected Entities Covered Under the Draft 

2016 PGP

Unauthorized 

Area

Mosquito and 

Other Flying 

Insect Pest 

Control

Weed and 

Algae Pest 

Control

Animal Pest 

Control

Forest 

Canopy 

Pest Control

Total

Idaho 23 16,489 12 48 16,572

Massachusetts 9 2,153 26 214 2,402

New Hampshire 44 642 10 85 781

New Mexico 13 10,285 8 26 10,332

District of Columbia 1 8 2 0 11

Territories 1 314 38 4 357

Tribes 17 93 25 34 169

Federal Facilities 65 65 65 50 245

Total 173 30,049 186 461 30,869

EPA estimated 714 potentially affected entities which overlap with NMFS Listed Resources of 

Concern for the 2011 PGP. As in the 2011 PGP, these are potentially affected entities who may 

(in addition to other costs as a result of the permit) incur costs solely because of discharges to 

waters of the United States containing NMFS Listed Resources of Concern. Since there were 

no overlap areas identified in Alaska and Oklahoma, this value remains unchanged for the 

draft 2016 PGP.

II. COSTS 

This section provides an analysis of the potential incremental costs that may be associated 

with the draft 2016 PGP. The costs are divided into technology-based effluent limitation 

control costs and administrative and monitoring costs. EPA is relying on the assumptions used 

in the 2011 PGP’s economic analysis to estimate the cost for the draft 2016 PGP as explained 

below. EPA will incorporate, as appropriate, any data received during the public comment 

period in the analysis for the final 2016 PGP. See the 2011 PGP’s economic analysis titled, 

“Economic Analysis of the Pesticide General Permit (PGP) for Point Source Discharges from the 

Application of Pesticides” in the Docket for further discussion on assumptions used for the 

analysis.

A. Total Cost to Comply with the Draft 2016 PGP 

Because the same requirements are required in the 2011 and 2016 PGPs, the difference in 

costs from 2011 to 2016 is due only to two factors: 1) a reduction in coverage due to the 

removal of Alaska and Oklahoma, 2) an increase due to inflation. Using the assumptions in the 

2011 PGP’s economic analysis, the total annual cost across all unauthorized NPDES areas and 

pesticide use patterns (including both technology-based effluent limitations and 
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administrative costs) for the draft 2016 PGP is from a range of $10,383,871 to $11,078,8711

with a potential additional cost of $9,980 per year associated with corrective actions. Using an 

alternate method which incorporates the 2011 PGP’s NOIs and Annual Reports data, the total 

annual cost is from a range of $9,587,617 to $10,282,617 with a potential additional cost of 

$9,980 per year associated with corrective actions. Both methods show the total annual cost 

for the 2016 PGP decreased from the 2011 PGP. A summary of the total costs is presented in 

Tables 2A and 2B. 

Though the total annual cost for the draft 2016 PGP decreased from the 2011 PGP, the cost 

each entity incurs will remain the same beyond accounting for increases in inflation and wage 

rates. The total annual cost for the 2011 PGP was estimated to be within the range of 

$10,180,962 to $11,224,962 [$11,300,022 to $12,454,345 in 2015 dollars]2 with a potential 

additional cost of $11,320 [$12,524 in 2015 dollars] per year associated with corrective 

actions. The decrease is a result of removing Alaska and Oklahoma from coverage under the 

draft 2016 PGP. See below for discussion of the technology-based effluent limitation costs and 

administrative and monitoring costs.

 

1 Estimated costs are presented in ranges for some states throughout this analysis as the available net 

incremental costs used to estimate potential technology-based effluent limitation costs (specifically for pest 

management options in the weed and algae control use pattern) were in low and high ranges. This incremental 

cost range was only applied to affected entities not already in compliance with certain permit requirements. See 

the “Economic Analysis of the Pesticide General Permit (PGP) for Point Source Discharges from the Application of 

Pesticides”.

2 As discussed under Section B. Cost Impact Analysis of Technology-Based Effluent Limitations, Total annual costs 

were inflated to 2015 dollars using Bureau of Labor Statistics’ Consumer Price Index (CPI). See Section B for 

further discussion.
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January 14, 2016

Table 2A: Summary of Total Estimated Costs, Based on Assumptions in the 2011 PGP’s

Economic Analysis ($/yr)

Unauthorized 

Area

Mosquito 

and Other 

Flying Insect 

Pest Control

Weed and Algae Pest 

Control

Animal 

Pest 

Control

Forest 

Canopy 

Pest 

Control

Total

Idaho $4,488,672 $445,891 $1,961 $2,325 $4,938,850

Massachusetts $16,651 $224,366 - $482,366 $2,103 $4,002 $247,122 - $505,122

New Hampshire $84,785 $91,007 - $349,007 $1,941 $2,699 $180,432 - $438,432

New Mexico $2,835,091 $168,060 $1,921 $2,103 $3,007,175

District of Columbia $217,850 $1,921 $1,860 $0 $221,631

Territories $1,850 $22,353 $11,424 $7,400 $43,027

Tribes $404,572 $199,600 - $378,600 $31,533 $59,224 $694,928 - $873,928

Federal Facilities $120,257 $120,257 $120,257 $92,505 $453,276

NMFS Listed 

Resources $5,070 $462,340 $20,260 $109,760 $597,430

Total $8,174,798 $1,735,795 - $2,430,795 $193,260 $280,018 $10,383,871 - $11,078,871

Note: Detail may not add to total due to rounding.

Estimated costs are presented in ranges for some states throughout this analysis as the available net incremental costs used to estimate potential 

technology-based effluent limitation costs (specifically for pest management options in the weed and algae control use pattern) were in low and high 

ranges. This incremental cost range was only applied to affected entities not already in compliance with certain permit requirements. See the “Economic 

Analysis of the Pesticide General Permit (PGP) for Point Source Discharges from the Application of Pesticides”.
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January 14, 2016

Table 2B: Summary of Total Estimated Costs Using the 2011 PGP’s NOI and Annual 

Report Data ($/yr)

Unauthorized 

Area

Mosquito and 

Other Flying 

Insect Pest 

Control

Weed and Algae Pest 

Control

Animal

Pest 

Control

Forest 

Canopy 

Pest 

Control

Total

Idaho $4,490,932 $252,424 $3,811 $475 $4,747,642

Massachusetts $22,561 $240,918 - $498,918 $253 $2,152 $265,884 - $523,884

New Hampshire $42,791 $63,405 - $321,405 $91 $849 $107,135 - $365,135

New Mexico $2,838,071 $140,768 $1,921 $253 $2,981,012

District of Columbia $216,000 $3,771 $10 $0 $219,781

Territories $1,850 $8,471 $323 $0 $10,644

Tribes $399,841 $210,241 - $389,241 $81 $20 $610,183 - $789,183

Federal Facilities $14,801 $53,653 $14,801 $1,850 $85,105

NMFS Listed 

Resources $240 $434,560 $18,730 $106,700 $560,230

Total $8,027,087 $1,408,209 - 

$2,103,209 $40,021 $112,299 $9,587,617 - $10,282,617

Note: Detail may not add to total due to rounding.

Estimated costs are presented in ranges for some states throughout this analysis as the available net incremental costs used to estimate 

potential technology-based effluent limitation costs (specifically for pest management options in the weed and algae control use pattern) were in 

low and high ranges. This incremental cost range was only applied to affected entities not already in compliance with certain permit 

requirements. See the “Economic Analysis of the Pesticide General Permit (PGP) for Point Source Discharges from the Application of 

Pesticides”.

B. Cost Impact Analysis of Technology-Based Effluent Limitations 

The method for estimating the potential incremental costs associated with the technologybased effluent limitation provisions in the PGP involves identifying entities that may be 

affected by the particular provision, determining incremental control activities (i.e., activities 

above and beyond those necessary under existing regulations) needed for compliance with 

the PGP, and estimating unit costs of those activities. Unit costs for the incremental activities 

multiplied by the number of affected entities performing the respective incremental activities 

provide an estimate of the incremental cost. Because the 2016 PGP has the same 

requirements as the 2011 PGP, EPA is relying on the assumptions and unit costs estimated for 

the technology-based effluent limitation provisions for 2011 PGP in this analysis inflated to 

2015 dollars. EPA will incorporate, as appropriate, any data received during the public 

comment period in the analysis for the final 2016 PGP.

Note that the costs presented in this section represent estimates; actual incremental costs 

may differ depending on the number of entities affected, current compliance costs, and 

existing level of controls. Using the Bureau of Labor Statistics’ Consumer Price Index (CPI), EPA 

updated the technology-based effluent limitation unit costs used in the 2011 PGP from 2009 
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January 14, 2016

to 2015 dollars.3 The costs presented in Table 3 also account for the reduction in the number

of affected entities (i.e. removing Alaska and Oklahoma). The estimated annual technology 

based effluent limitation costs for the draft 2016 PGP is from a range of $8,467,400 to 

$9,162,400 compared to a range of $8,101,300 to $9,145,300 [$8,995,970 to $10,150,293 in 

2015 dollars] for the 2011 PGP. See the 2011 PGP’s economic analysis titled, “Economic 

Analysis of the Pesticide General Permit (PGP) for Point Source Discharges from the 

Application of Pesticides” in the Docket for further discussion.

Table 3: Summary of Estimated Annual Technology-Based Effluent Limitation Costs 

($/yr)

Unauthorized 

Area

Mosquito 

and Other 

Flying Insect 

Pest Control

Weed and Algae 

Control

Animal 

Pest 

Control

Forest 

Canopy 

Pest 

Control

Total

Idaho $4,464,000 $0 $0 $0 $4,464,000

Massachusetts $0 $144,000 - $402,000 $0 $0 $144,000 - $402,000

New Hampshire $38,000 $55,000 - $313,000 $0 $0 $93,000 - $351,000

New Mexico $2,817,000 $0 $0 $0 $2,817,000

District of Columbia $216,000 $0 $0 $0 $216,000

Territories $0 $0 $0 $0 $0

Tribes $391,000 $180,000 - $359,000 $0 $0 $571,000 - $750,000

Federal Facilities $0 $0 $0 $0 $0

NMFS Listed 

Resources $0 $67,000 $14,900 $80,500 $162,400

Total $7,926,000 $446,000 - $1,141,000 $14,900 $80,500 $8,467,400 - $9,162,400

Estimated costs are presented in ranges for some states throughout this analysis as the available net incremental costs used to estimate 

potential technology-based effluent limitation costs (specifically for pest management options in the weed and algae control use pattern) 

were in low and high ranges. This incremental cost range was only applied to affected entities not already in compliance with certain 

permit requirements. See the “Economic Analysis of the Pesticide General Permit (PGP) for Point Source Discharges from the Application 

of Pesticides”.

 

C. Cost Impact Analysis of Administrative and Monitoring Costs

This section provides estimates of the potential costs that may be associated with the 

administrative and monitoring provisions of the draft 2016 PGP. Administrative requirements 

include activities such as maintaining documentation, preparing annual reports, developing

the pesticide discharge management plan, completing pesticide discharge evaluation 

worksheets, and submitting a notice of intent.

There are several levels of administrative costs that could be incurred as a result of the PGP 

requirements. To estimate potential administrative and monitoring costs, EPA identified the 

 

3 Unit costs were inflated using U.S. city average and regional index values for all items, not seasonally adjusted. 

Comparing index values from June 2009 to June 2015, the CPI estimates an inflation rate of approximately 

1.106% for the U.S. city average, 1.103% for the Northeast region, 1.108% for the South region, and 1.111% for 

the West region. (CPI, 2015)
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January 14, 2016

likely level of effort (e.g., number of hours) associated with performing each activity and the 

potential cost of that effort (e.g., average wage rate) based on best professional judgment. 

Labor categories likely to be involved in administrative and monitoring tasks include 

managerial, technical, and clerical. The Bureau of Labor Statistics (BLS) publishes base mean 

annual wage rates in its Occupational Employment Statistics (OES, 2014), and an Employment 

Cost Index (ECI, 2015) to update the wage rates to 2015 values to account for inflation. 

Entities may use their own employees for pesticide applications or contract out the services. 

EPA used average government and commercial wage rates to estimate administrative and 

monitoring costs assuming that each entity is equally likely to use either government or 

commercial labor.

For state and local governments, EPA included employee benefits in the wage rate, and for 

commercial applicators, included benefits, overhead, and profit in estimating total labor rates. 

The BLS Employer Costs for Employee Compensation (ECEC, 2015) provides estimates for 

benefit markups for governments (benefits account for approximately 25% of the total labor 

rate), and PSMJ Resources (2009) indicates that the wage rate multiplier is 3.05 for 

commercial/engineering firms. Labor rates for managers reflect OES category 11-9121, Natural 

Sciences Managers; technical staff reflect OES category 19-4091, Environmental Science and 

Protection Technicians, Including Health; and clerical staff reflect OES category 43-0000, Office 

and Administrative Support Occupations. Under each applicable OES category, state 

government labor categories use NAICS code 9992000 (State Government, excluding schools 

and hospitals), local government labor categories use NAICS code 999300 (Local Government, 

excluding schools and hospitals), and commercial labor categories use 541600 (Management, 

Scientific, and Technical Consulting Services). Table 4 presents the estimated labor cost by 

labor category in 2009 dollars used in the 2011 PGP and their updated values in 2015 dollars 

used to estimate administrative and monitoring costs for the draft 2016 PGP. 
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January 14, 2016

Table 4: Estimated Labor Cost ($/hour)

Labor Category State 

Government

Local 

Government Commercial Average

2009 dollars

Managers $51 $64 $167 $113

Technical $38 $38 $63 $51

Clerical $29 $28 $53 $41

2015 dollars

Managers $57 $72 $218 $142 

Technical $37 $41 $65 $52 

Clerical $33 $31 $59 $46 

Note: Detail may not add to total due to independent rounding.

Sources: BLS OES, 2014; BLS ECI, 2015; BLS ECEC, 2015.

1. Mean annual 2014 wages, updated to 2015 dollars; includes cost of employee benefits.

2. Mean annual 2014 wages, updated to 2015 dollars; includes cost of employee benefits, overhead cost, and profit 

(estimated based on a total wage rate multiplier of 3.05).

3. Represents average of government rates (state and local government average) and commercial rate.

The administrative requirements in the draft 2016 PGP remain unchanged from the EPA’s 

2011 PGP except for the addition of the electronic reporting requirement in Part 7.8 of the 

draft 2016 PGP. This part mandates the use of the internet for submitting the kind of 

information operators must send to the eNOI Center (NOIs, Notices of Termination, and 

Annual Reports). The 2011 PGP had the option for Decision-makers to submit such 

information either electronically or by paper copy. EPA assumes no additional cost for the 

electronic reporting requirement, as the ability to do electronic information submittals 

represents a reduction of burden from producing hard copies and having them delivered.

EPA is relying on two sources to estimate the potential costs that may be associated with the 

administrative and monitoring provisions of the draft 2016 PGP: 1) the level of effort 

assumptions used for the 2011 PGP’s cost analysis, and 2) the NOI and annual report data 

collected under the 2011 PGP. This is done to illustrate that using two different methods the 

same conclusion is obtained and that is though the overall cost has decreased (due to a 

reduction in the covered universe) the unit cost remains the same (with the exception of 

inflation from 2009 to 2015). EPA will incorporate, as appropriate, any data received during 

the public comment period in the analysis for the final 2016 PGP.

Using the same level of effort under the 2011 PGP’s cost analysis, but incorporating updated 

2015 wage rates and changes to the number of affected entities (i.e. removing Alaska and 

Oklahoma), the potential annual administrative and monitoring costs are presented in Table 

5A for a total cost of $1,926,451. The total potential annual administrative and monitoring 

cost under the 2011 PGP was $2,090,982 [$2,316,576 in 2015 dollars].4

 

4 As discussed under Section B. Cost Impact Analysis of Technology-Based Effluent Limitations, Total potential 

annual administrative and monitoring costs were inflated to 2015 dollars using Bureau of Labor Statistics’ 

Consumer Price Index (CPI). See Section B for further discussion.
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January 14, 2016

Table 5A: Summary of Potential Annual Administrative and Monitoring Costs Based on 

Assumptions in the 2011 PGP’s Economic Analysis ($/yr)

Unauthorized Area

Mosquito and 

Other Flying 

Insect Pest 

Control

Weed and 

Algae Control

Animal Pest 

Control

Forest 

Canopy Pest 

Control

Total

Idaho $24,672 $445,891 $1,961 $2,325 $474,850

Massachusetts $16,651 $80,366 $2,103 $4,002 $103,122

New Hampshire $46,785 $36,007 $1,941 $2,699 $87,432

New Mexico $18,091 $168,060 $1,921 $2,103 $190,175

District of Columbia $1,850 $1,921 $1,860 $0 $5,631

Territories $1,850 $22,353 $11,424 $7,400 $43,027

Tribes $13,572 $19,600 $31,533 $59,224 $123,928

Federal Facilities $120,257 $120,257 $120,257 $92,505 $453,276

NMFS Listed 

Resources $5,070 $395,340 $5,360 $29,260 $435,030

Corrective Action $0 $9,980 $0 $0 $9,980

Total $248,798 $1,299,775 $178,360 $199,518 $1,926,451

Note: Detail may not add to total due to rounding.

In an alternate method, EPA uses the NOI and annual report data collected by EPA under the 

2011 PGP as the baseline for calculating the potential annual administrative and monitoring 

costs for the draft 2016 PGP. Data collected under the 2011 PGP are available in the docket 

EPA-HQ-OW-2015-0499 at www.regulations.gov. (See spreadsheet titled 2012-2014 PGP 

Annual Report Data.) EPA analyzed the NOI data to determine the number of active or 

submitted NOIs under the 2011 PGP. EPA received 346 applicable NOIs after excluding those 

for Alaska and Oklahoma5. Based on the annual report data, EPA received 366 annual reports 

in 2012, 2013 and 2014 from 169 unique permittees, excluding Alaska and Oklahoma6, 7. Since 

 

5 There were 213 potential NOIs estimated for AK and OK in the 2011 PGP economic analysis. Excluding those two 

states, EPA estimates 2,623 potential NOIs to calculate the administrative and monitoring costs in Table 5A.

6 There were 82 potential annual reports estimated for AK and OK in the 2011 PGP economic analysis. Excluding 

those two states, EPA estimates 2,378 potential annual reports to calculate the administrative and monitoring 

costs in Table 5A.

7

Entities who are required to submit NOIs have different reporting requirements (e.g., PDMP vs PDEW, etc) 

depending on the type of entity (e.g., federal or state, entities exceeding a threshold, etc) and the size of the 

entity (large or small). Although there is a substantial difference in the number of entities submitting NOIs and 

annual reports (from about 3,000 using the 2011 PGP cost analysis to about 400 using the data collected under 

the 2011 PGP), the mix of entities required to submit NOIs (type and size) used to calculate the cost in Table 5A is 

different from the mix of entities in Table 5B. Therefore, the difference in total administrative and monitoring 

costs between Tables 5A and 5B does not reflect a proportional change (i.e., the change in the cost is not 

proportional to the change in the number of NOIs and Annual Reports received). In addition, the total costs in 

Tables 5A and 5B include the cost (about $0.7M) assigned to entities below the threshold (entities not required
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a portion of the NOIs received were submitted to cover more than one use pattern, EPA

assigned each received NOI to the first use pattern declared in the dataset to avoid double 

counting. EPA then separated these NOIs by use pattern, geographic area and type 

(Federal/State, Large Mosquito Control Districts (MCDs), Large Entities Exceeding Thresholds 

or Small MCDs and Small Entities Exceeding Thresholds), and permittees with pesticide 

discharges in NMFS Areas of Concern based on the information provided. Permittees with 

pesticide discharges in NMFS Areas of Concern were classified according to their submission 

under criteria A-F (see Part 1.1.2.4 of the PGP) with applicable costs applied. 

Entities below the threshold were not captured in this dataset as they are not required to 

submit NOIs and thus incur minimal costs. Therefore, EPA maintained the existing 

assumptions of the number of entities below the threshold for each use pattern from the 2011 

PGP’s economic analysis. EPA calculated costs using the new baseline of affected entities and 

the same level of effort assumed under the 2011 PGP (with updated 2015 wage rates). 

Assumptions regarding PGP administrative requirements by entity type remain unchanged 

(i.e. only large entities or permittees with pesticide discharges in NMFS Areas of Concern will 

submit annual reports, etc.). The potential annual administrative and monitoring costs using 

NOI and annual report data from the 2011 PGP are presented in Table 5B with a total cost of 

$1,130,197.

 

to submit NOIs and annual reports). The total administrative and monitoring costs for entities submitting NOIs 

and annual reports are then about $1.2M (Table 5A) and about $0.4M (Table 5B).
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January 14, 2016

Table 5B: Summary of Potential Annual Administrative and Monitoring Costs Using the 

2011 PGP’s NOI and Annual Report Data ($/yr)

Unauthorized Area

Mosquito and 

Other Flying 

Insect Pest 

Control

Weed and 

Algae Control

Animal Pest 

Control

Forest 

Canopy Pest 

Control

Total

Idaho $26,932 $252,424 $3,811 $475 $283,642

Massachusetts $22,561 $96,918 $253 $2,152 $121,884

New Hampshire $4,791 $8,405 $91 $849 $14,135

New Mexico $21,071 $140,768 $1,921 $253 $164,012

District of Columbia $0 $3,771 $10 $0 $3,781

Territories $1,850 $8,471 $323 $0 $10,644

Tribes $8,841 $30,241 $81 $20 $39,183

Federal Facilities $14,801 $53,653 $14,801 $1,850 $85,105

NMFS Listed 

Resources $240 $367,560 $3,830 $26,200 $397,830

Corrective Action $0 $9,980 $0 $0 $9,980

Total $101,087 $972,189 $25,121 $31,799 $1,130,197

Note: Detail may not add to total due to rounding.

Both methods show the total administrative and monitoring cost for the draft 2016 PGP 

decreased from the 2011 PGP. Though the total cost for the draft 2016 PGP decreased from 

the 2011 PGP, the cost each entity incurs will remain the same beyond accounting for 

increases in inflation and wage rates.

 
14

January 14, 2016

References 

 

Bureau of Labor Statistics. 2015. Consumer Price Index. Available electronically at: 

http://www.bls.gov/cpi/data.htm

Bureau of Labor Statistics. 2015. Employer Costs for Employee Compensation (ECEC). March 

2015 Release. Available electronically at: 

http://www.bls.gov/news.release/archives/ecec_06102015.pdf

Bureau of Labor Statistics. 2015. Employment Cost Index (ECI). June 2015 Release. Available 

electronically at: http://www.bls.gov/news.release/archives/eci_07312015.pdf

Bureau of Labor Statistics. 2014. Occupational Employment Statistics (OES). May 2014

Release. Available electronically at: http://www.bls.gov/oes/tables.htm

PSMJ Resources, Inc. 2009. 2009 PSMJ A/E Financial Performance Survey, 29th Edition: CEO 

Snapshot.