1

January 14 , 2016 

### Cost Impact Analysis for the EPA’s Draft 2016 Pesticide General Permit (P GP)

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 U nited States are required t o 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 wher e 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 pr ovides this cost impact analysis as part of the administrati ve 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

, s ome minor
differences such as a decrease in numbe r of entities covered under the draft 2016 PGP and inflation impacts are analyzed herein. Thus

, e ach 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 P GP includes requirements that impose an incremental

increase in costs , if any, on permittees above and beyond costs that are alr eady accounted for
in the 2011 P GP

, which define s 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

p esticides 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 ed ge, 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 pestic ide 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

.2

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 limitation s , (3) water quality

- based effluent limitations, (4) monitoring, (5) pesticide discharge management plan, (6) corre ctive action, (7) recordkeeping and annual reporting, (8) EPA contact information and mailing addresses, and (9) permit conditions applicable to specific states, Indian C ountry lands or territories. Additionally, the permit includes nine appendices with ad ditional 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) A nnual Reporting Template, (H) Adverse Incident template, and (I) Endangered species procedures.

Th e 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

w aters of the Unite d States, or (b) Decision

- maker who controls any decision to apply pesticides that results in a discharge to w aters of the United States. There may be instances when a single entity acts as both an Applicator and a Decision

- maker.

 All Applicators are requ ired 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 freq uency 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

- make rs (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 ot her entities that apply pesticides in excess of specified annual treatment area thresholds, and entities that discharge pesticides to Tier 3 waters or to

w aters 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 w aters of the United States. Certain large Decision

- maker s 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
lie u of the more comprehensive PDMP), an annual report (only for entities in NMFS area of concerns) , and detailed recordkeeping.3

January 14 , 2016 

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

2016 PGP includ es an electronic reporting r equirement 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 e NOI (Electronic Notice of Intent)

Center . The 2011 P GP 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 Te xas. 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. F acilities Subject to the draft 2016 P GP
The 2011 PGP was the first time that EPA issued an NPDES permit for discharges to w aters of the United States resulting from the applicati on of pesticides. EPA is relying on the analysis done for the 2011 PGP to estimate the potentially affected entities for th e 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 e conomic a nalysis titled, “Economic Analysis of the Pesticide General Permit (PGP) for Point Source Discha rges 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, a s 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, t he total estimated number of poten tially 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 pesticid e 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

.4

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 potential ly affected entities which overlap with NMFS Listed Resources of

Concern for the 2011 PGP. As in the 2011 PGP, t hese are potential ly affected entities who may (i n 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 an d 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

- ba sed 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 furth er discussion on assumptions used for the analysis.

A. Total Cost to Co mply with the Draft 2016 PG P Because the same requirements are required in the 2011 and 2016 PGPs, t he 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 e conomic analysis, t he total annual cost across all unauthorized NPDES areas and pesticide use patterns (including both technology

- based effluent limitations and5

January 14 , 2016 

### administrative costs) for the draft 2016 PGP is from a range of $ 10, 383 ,871 to $ 11, 078 ,871 1 

### 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 $ 9,5 87 ,617 to $ 10,2 82, 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
Table s 2 A and 2B

.

Though the total annual cost for the draft 2016 PGP decreased from the 2011 PGP, the cost
each entity inc urs 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

, 02 2 to $12, 454

, 345 in 2015 dollars] 2 

### with a potential additional cost of $ 11,3 2 0 [$12,524 in 2015 dollars] per year associated with corrective

actions

. The decrease is a result of re moving Alaska and Oklahoma from coverage under the
draft 2016 PGP

. See below for discussion of the technology

- based effluent lim itation costs and administrative and monitoring costs

.

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

- b ased e ffluent limitation c osts (specifically for pest management options in the weed and algae control use pattern ) were in low and high ranges. Th is incremental cost range was only applied to affected entities not already in compliance with certain permit requirements. See
the “Economi c 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 Techno logy

- 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.6

January 14 , 2016 Table 2A: Summary of Total Estimated Costs , Based on Assumptions in the 2011 PGP ’s

E conomic A nalysis ($/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 an d algae control use pattern) were in low and high

range s . This incremental cost range was only applied to affected entities not already in compliance with certain permit requirement s. See the “Economic Analysis of the Pesticide General Permit (PGP) for Poi nt Source Discharges from the Application of Pesticides”.7

January 14 , 2016 Table 2 B : 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 range s . 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 Applicati o n of
Pesticides”.



### B . Cost Impact Analysi s of Technology

- Based Effluent Limitation s The method for estimating the potential incremental costs associated with the technology

based effluent limitation provisions in the PGP involves identifying entities that may be affected by the particular provision, determining incremental control activit ies (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 pe rforming 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 assumption s and unit costs estimated for
the technology

- based effluent limitat ion 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 efflu ent limitation unit costs used in the 2011 PGP from 20098

January 14 , 2016 

### to 2015 dollars. 3 

### T he costs presented in Tabl e 3 also account for the reduc tion 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.

Tabl e 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 range s . 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 mo nitoring 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 valu es 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% f or the West region. (CPI, 2015)9

January 14 , 2016 

### likely level of effort (e.g., n umber 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 infla tion. 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 eit her 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 Empl oyee 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

commerci al/engineering fir ms. Labor r ates 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, s tate government labor categories use NAICS code 9992000 ( State Government, excluding schools and hospitals ), local government labor categories use NAICS code 999300 ( Local Governm ent, 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 update d values in 2015 dollars used to estimate administrative and monitoring costs for the draft 2016 PGP.10

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, 20 14; BLS ECI

, 20 15 ; BLS ECEC, 20 15

. 1. Mean annual 20 14 wages, updated to 20 15 dollars; includes cost of employee benefits.

2. Mean annual 20 14 wages, updated to 20 15 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 unch anged 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 e NOI 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 source s to estimate the potential costs that may be associated with the
administrative and mo nitoring provisions of the dra ft 2016 PGP: 1) the level of effort assumptions used for the 2011 PGP’s cost analysis, and 2) the NOI and annual report da ta
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 peri od 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)

, t he 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 Techno logy

- Based Effluent Limitations, Total potential annual administrative and monitoring costs were inflated to 2015 dollars using Bureau of Labor Statistics’

Consum er Price Index (CPI). See Section B for further discussion.11

January 14 , 2016 Table 5A: Summary of Potenti al Annual Admi nistrative and Monitoring Costs Based on

Assumptions in the 2011 PGP ’s E conomic A nalysis ($/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 us es 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. D ata collected under the 2011 PGP are available in the docket

EPA

- HQ

- OW

- 2015

- 0499 at www.regulations.g ov . (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 Oklahoma 5



### . Based on the annual report data , EPA received 366 annual reports in 2012, 2013 and 2014 from 169 unique permi t tees, excluding Alaska and Oklahoma 6

, 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

co sts 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 s mall). 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), t he 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. T herefore , 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 required12

January 14 , 2016 

### 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 M osquito C ontrol D istrict s (MCDs) , Large Entities Exceeding Thresholds

or S mall 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 submis sion
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 e conomic a nalysis

. EPA calculated costs using the new baseline of affected entities and
the same level of effort assumed under the 2 011 PGP (with updated 2015 wage rates ). Assumptions regarding PGP administrative requirements by entity type remain unchanged (i.e. only large entities or p ermittees with pesticide discharges in NMFS Areas of Concern will submit annual reports , etc. ). The p otential annual administrative and monitoring costs using

NOI and annual report data from the 2011 PGP are presented in Table 5 B 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).13

January 14 , 2016 Table 5 B : Summary of Potential Annual Admi nistrative 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 a nd 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. 20 15 . 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. 20 15 . Employment Cost Index (ECI). June 2015 Release. Available electronically at: http://www.bls.gov/news.release/archives/eci_07312015.pdf

Bureau of Labor Statistics. 20 14 . Occupationa l Employment Statistics (OES). May 20 14 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
Snaps hot.