## SUPPORTING STATEMENT FOR

EPA INFORMATION COLLECTION REQUEST NUMBER 2002.05 “ C ROSS - MEDIA ELECTRONIC REPORTING RULE ” June 2 2 , 2011

Office of Environmental Information U.S. Environmental Protection Agency Washington, D.C. 20 460

## TABLE OF CONTENTS

1. IDENTIFICAT ION OF TH E INFORMATION COLLEC TI ON
................................ ....................... 1 1(a) TI TLE AND NUMBER OF THE INFORMATION COLLECTION
................................ ...... 1 1(b) CHARACTERIZATION OF THE INFORMATION COLLECTION
................................ ..... 1 2. NEED FOR AND USE OF THE COLLECTION
................................ ................................ .............. 6 2(a) NEED AND AUTHORITY FOR THE COLLECTION
................................ ........................... 6 2(b) PRACTICAL UT IL IT Y AND USERS OF THE DATA
................................ .......................... 7 3. NONDUPL ICATION, CONSULTATIONS, AND OTHER COLLEC TI ON CRITERIA
................ 9 3(a) NONDUPLICATION
................................ ................................ ................................ ............... 9 3(b) PUBLIC NOT ICE
................................ ................................ ................................ ..................... 9 3(c) CONSULTATIONS
................................ ................................ ................................ .................. 9 3(d) EFFECTS OF LESS FREQUENT COLLECTION
................................ ................................ .. 9 3(e) GENERAL GUIDELINES
................................ ................................ ................................ ...... 10 3(f) CONFIDENT IALITY
................................ ................................ ................................ ............. 10 3(g) SENSITIVE QUESTIONS
................................ ................................ ................................ ...... 11 4. THE RESPOND ENTS AND THE INFORMA TI ON REQUESTED
................................ .............. 12 4(a) RESPONDENTS AND NAICS CODES
................................ ................................ ................ 12 4(b) INFORMATION REQUESTED
................................ ................................ ............................. 12 5. THE INFORMATION COLL ECTED: AGENCY ACTIV IT IES, COLLECT ION METHODOLOGY, AND INF ORMATION MANAGEMENT
................................ ...................... 19 5(a) AGENCY ACT IV IT IES
................................ ................................ ................................ ......... 19 5(b) COLLECTION METHODOLOGY AND MANAGEMENT
................................ ................ 20 5(c) SMALL ENTITY FLEXIBILITY
................................ ................................ ........................... 20 5(d) CO LLECTION SCHEDULE
................................ ................................ ................................ .. 20 6. ESTIMATING THE HOUR AND COST BURDEN OF T HE COLLECTION
.............................. 22 6(a) ESTIMATING RESPONDENT BURDEN HOURS
................................ .............................. 22 6(c) ESTIMATING AGENCY HOUR AND COST BURDEN
................................ .................... 25 6(d) ESTIMATING RESPOND ENT UNIVERSE AND TOTAL HOUR AND COST BURDEN
................................ ................................ ................................ ..................... 26 6(e) BOTTOM LINE HOUR AND COST BURDEN
................................ ................................ ... 35 6(f) REASONS FOR CHANGE IN BURDEN
................................ ................................ .............. 35 6 (g) PUBLIC BURDEN STATEMENT
................................ ................................ ......................... 39

### 1

1. IDENTIFICATION OF THE INFORMATION COLLECTION 1(a) TITLE AND NUMBER OF THE INFORMATION COLLECTION This Information Collection Request (ICR) is entitled “Cross
- Media Electronic Reporting Rule ,” EPA I CR Number 2002.05, OMB Control Number 2025
- 0003. 1(b) CHARACTERIZATION OF THE INFORMATION COLLECTION The U.S. Environmental Protection Agency (EPA) allows regulated entities to report electronically

to EPA by

allowing the use of electronic document receiving sy stems to receive electronic documents in satisfaction of certain document submission requirements in EPA ’ s regulations. 1 

### The Cross
- Media Electronic Reporting Rule (CROMERR) also allows State, Tribal, and local governments to seek EPA approval, as provided under 40 Code of Federal Regulations (CFR) 3.1000 , to accept electronic documents to satisfy reporting requirements under authorized or delegated environmental programs that they administer. In seeking EPA approval, these State, Trib al, and local governments must upgrade existing electronic document receiving s ys tems or develop new electronic document receiving s ys tems to satisfy the criteria laid out at 40 CFR 3.2000. Regulated entities that use an electronic signature device in sub mitting electronic documents to the EPA or a State , Tribal, or l ocal government receiving sy stem must comply

with identity

proofing requirements, as applicable. Inthe remainder of this document, we refer to State, Tribal, and local governments as “States /L ocals” because, at the current time, EPA is not aware of any Tribal governments that have electronic document receiving s ys tems or are planning to develop such sy stems during the next three years . CROMERR does not require an y regulated entity to report electronicall y to EPA or State s /L ocal s . CROMERR establishes requirements for utilizing electronic reporting as an alternative to paper
- based reporting. It does not require State s /L ocal s to implement electronic reporting; rather, it establishes the frame work for implementing the electronic reporting alternative for Federal laws that they administer. In this regard, regulated entities are affected only as follows:

 Entities that report electronically to EPA have to register with EPA’s electronic document receiving s ys tem (e.g., log on to the EPA Web site and enter requested information) , comply

with the identity

proofing provisions , and then commence electronic reporting. In this document, we refer to these entities as “direct reporters .”

 State s /L ocal s must upgrade existing electronic document receiving s ys tems or develop new electronic document receiving s ys tems to meet 40 CFR 3.2000 requirements. These State s /L ocal s must apply for EPA program modification approval under 40 CFR 3.1000. They also must i mplement the identity proofing requirements at 40 CFR 3.2000(b)(5).

1 In this document , EPA is using the term “electronic reporting” in a sense that excludes submission of a report via magnetic media, (i.e., via diskette, compact disc, or tape). EPA is also excluding transmission via hard copy facsimile. Likewise, EPA ’ s use of the term “electronic document” throughout this document refers exclusively to documents that are transmitted via a telecommunications network, excluding hard copy facsimile.

### 2

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

 Entities that opt to implement the local registration authority (LRA) alternative for identity proofing must identify

an individual who will collect subscriber agreements from each individual that intends to use an electronic signature device in reporting electronically

to a State/Local electronic document receiving s ys tem . In this document, we refer to these entities as “indirect reporting firms.”

 T he LRA must collect and store subscriber agreements from individual s in his/her indirect repo rting firm. The LRA also must prepare an agreement collection certification and submit a certification of receipt and secure storage to the corresponding State/Local agency . Sections 1 through 5 of this document describe the information collection requirements covered in this ICR (e.g., in regard to need and use of the information collected). Section 6 estimates the annual burden to respondents
. This ICR does not address the burden savings to respondents in reporting electronically under EPA programs. EPA’s programs will amend their program - specific ICRs to address these impacts. CROMERR establishes requirements applicable to electronic reporting and receiving sy stems, as specified. Many of the activities to be conducted by direct reporters will be d etermined b y the instructions associated with EPA’s electronic document receiving s ys tem. Specificall y, EPA has developed an Agency
- wide receiving s ys tem, the Central Data Exchange (CDX), which guides direct reporters through the registration and reportin g procedures. In developing this ICR, EPA referred to the regulatory text, as well as CDX, in describing direct reporters’ activities and associated burden. The following paragraphs describe the respondent activities examined in this I CR
. NOTE : A s used in this document , the term “respondent” includes:

 Direct reporters, indirect reporters, indirect reporting firms, and LRAs complying with the registration and identity proofing requirements cov ered in this ICR , as applicable . This includes:

 Private sect or entities; and

 State/L ocal agencies that are regulated entities 2



### .
 State/L ocal agencies administering electronic document receiving s ys tems subject to CROM E RR3 

### . In this document, we refer to these respondents as “ State/Local agencies acting as regulator s.”

2 Addressing State/Local agencies as “respondents” is consistent wi th EPA’s interpretation of the definition of respondent in the Paperwork Reduction Act (PRA).

3 Ibid
.

### 3

 State/L ocal agencies seeking EPA approval to allow electronic reporting under CROMERR

4 

### . In this document, we refer to these respondents as “ State/Local agencies that are regulated entities
. ” (1) Registering with EPA Electronic Document Receiving Syste m 40 CFR 3.10(a) and (b) establish Federal environmental reporting requirements that facilities must satisfy

to submit electronic documents to EPA. Among other things, Section 3.10(a) provides that a person may use an electronic document to satisfy a Fed eral reporting requirement, or otherwise substitute for a paper document or submission permitted or required under other provisions of 40 CFR only if the person submits the electronic document to EPA’s CDX, or to another EPA electronic document receiving s ys tem that the Administrator may designate for the receipt of specified submissions, complying with the sy stem’s requirements for submission. The electronic document must bear all valid electronic signatures as required under 40 CFR to sign the paper document for which the electronic document substitutes, unless EPA announces special provisions to accept the signature on separate paper submission. In accordance with the above requirements, as well as the requirements of CDX, direct reporters must registe r initially with CDX. They

also must update their registration information as needed. (2) Compliance with Identity Proofing Requirements Direct and indirect reporters must comply with the identity

proofing provisions of CDX and CROMERR , as applicable. As p rovided by CDX and 40 CFR 3.2000(a)(2), any electronic document must bear the valid electronic signature of a signatory if that signatory

would be required under the EPA or State/L ocal environmental program to sign the paper document for which the electron ic document substitutes, unless the program makes special provisions to accept a handwritten signature on a separate paper submission, as specified. In the case of an electronic document that must bear electronic signatures of individuals, as provided b y CDX or 40 CFR 3.2000(a)(2), each signatory must sign either an electronic signature agreement or a subscriber agreement with respect to the electronic signature device used to create their electronic signature on the electronic document. CDX and 40 CFR 3.2000(b)(5)(vii) require that, for each electronic signature device used to create an electronic signature on the document, the identity of the individual uniquely entitled to use the device and their relation to any entity for which they will sign electronic documents must be determined with legal certainty by EPA or State s /L ocal s , as applicable. In the case of priority reports, this determination must be made before the electronic document is received, b y means of:

4 Ibid.

### 4

 Id entifiers or attributes that are verified b y attestation of disinterested individuals to be uniquely

true of the individual in whose name the application is submitted, based on information or objects of independent origin, at least one item of which is not subject to change without governmental action or authorization.

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

 Collection of either a subscriber agreement or a certification from a LRA that such an agreement has been received and securel y stored. (3 ) Approval of State/Local Electronic Document Receiving System Applications State s /L ocal s that receive, or wish to begin receiving, electronic documents in lieu of paper documents to satisfy requirements under authorized programs must revise or modify the EPA
- approved State/L ocal environmental program to ensure that it meets the requirements of 40 CFR Part 3. In making these program revisions or modifications, State s /L ocal s must submit an application that complies with 40 CFR 3.1000(b)(1), and use either the applicable procedures for revision or modification of such programs in other parts of 40 CFR; or, at their option, the procedures provided in 40 CFR 3.1000(b) through (e). The procedures provided in Sections 3.1000(b) through (e) may onl y be used for revising or mo difying an authorized program to provide for electronic reporting and for subsequent revisions or modifications to the electronic reporting elements of the authorized program as provided under 40 CFR 3.1000(a)(4). (40 CFR 3.1000(a)(1)) State s /L ocal s that accept electronic documents in lieu of paper documents under an authorized program for which EPA has approved program revisions or modifications under the procedures provided in 40 CFR 3.1000(a)(1), must keep EPA apprised of those changes to laws, policie s, or the electronic document receiving s ys tems that have the potential to affect program conformance with 40 CFR 3.2000. Where the Administrator determines that such changes require EPA review and approval, EPA may request that State s/L ocal s submit an ap plication for program revision or modification . A dditionally , States /L ocal s may submit applications on their own initiative for program revision or modification respecting their receipt of electronic documents. (40 CFR 3.1000(a)(4)) To obtain EPA approv al of program revisions or modifications using procedures provided under 40 CFR 3.1000, State s /L ocal s must submit an application to the Administrator that includes the elements in Section 3.1000(b)(1)(i)
- (iv). (40 CFR 3.1000(b)(1)) State s /L ocal s that rev ise or modif y more than one (1) authorized program for receipt of electronic documents, in lieu of paper documents, may submit a consolidated application covering more than one (1) authorized program, provided the consolidated application complies with Sec tion 3.1000(b)(1) for each authorized program. (40 CFR 3.1000(b)(2)) State/L ocal program s must satisfy the requirements at 40 CFR 3.2000. Pursuant to Section 3.2000(a), authorized programs that receive electronic documents, in lieu of paper documents, t o satisfy

requirements under such programs must use an acceptable electronic

### 5

document receiving s ys tem as specified and require that any electronic document must bear the valid electronic signature of a signatory if that signatory

would be required under the authorized program to sign the paper document for which the electronic document substitutes unless the program makes special provisions to accept a handwritten signature on a separate paper submission, where such provisions are addressed in the application submitted under Section 3.1000(b)(1) and ensure that the paper submission contains references to the electronic document sufficient for legal certainty that the signature was executed with the intention to certify to, attest to, or agree to the content of that electronic document. As provided at 40 CFR 3.2000(b), an electronic document receiving s ys tem that receives electronic documents, submitted in lieu of paper documents, to satisfy requirements under an authorized program must be able to generate d ata with respect to any such electronic document, as needed and in a timel y manner, including a copy of record for the electronic document, that meets the criteria specified in Sections 3.2000(b)(1) through (5).

### 6

2. NEED FOR AND USE OF THE COLLECTION 2(a ) NEED AND AUTHORITY FOR THE COLLECTION EPA established the CROMERR requirements to ensure compliance with the Government Paperwork Elimination Act (GPEA). 5 

### GPEA requires that Federal agencies be prepared, b y October 21, 2003, to allow persons who are re quired to maintain, submit, or disclose information, the option of doing so electronically , when practicable, as a substitute for paper; and to use electronic authentication (electronic signature) methods to verify the identity of the sender and the integrity of electronic content. GPEA specifically provides that electronic records, and their related electronic signatures, are not to be denied legal effect, validity , or enforceability

merel y because they

are in electronic form. (1) Registering with EPA El ectronic Document Receiving System Regulated entities must initially register with the EPA electronic document receiving sy stem to establish a user account. EPA needs the registration information to identify the registrant, contact information, and regis trant’s organization. Registrants also select a password and user name during registration. This information is needed to ensure that only the registrant has access to his/her account. (2) Compliance with Identity Proofing Requirements The identity

proofin g provisions in 40 CFR 3.2000(b)(5) are needed to strengthen the non - repudiation provisions of CROMERR . The electronic signature agreement, required in Section 3.2000(b)(5)(v), establishes that the signatory was informed of their obligation to keep the si gnature device from compromise, by ensuring that it is not made available to anyone else. These provisions are intended to ensure that the Federal laws regarding the falsification of information submitted to the government still apply to any and all electronic transactions, and that fraudulent electronic submissions will be prosecuted to the fullest extent of the law. In establishing clear requirements for electronic reporting s ys tems, CROMERR helps to minimize fraud b y assuring that the responsible indiv iduals can be readily identified. (3 ) Approval of State/Local Electronic Document Receiving System Applications EPA needs information submitted by State s /L ocals in their program modification applications to evaluate the State s /L ocals’ upgraded or new ele ctronic document receiving sy stems to ensure they

satisfy the criteria at 40 CFR 3.2000. EPA also needs the information to evaluate whether the State/Local’s modified program has been satisfactoril y revised or modified in regard to their electronic docum ent receiving sy stem. In particular, the application must include a certification that the State/L ocal has sufficient legal authority

provided by

lawfull y enacted or promulgated statutes or regulations to implement the electronic reporting component of it s authorized program covered b y the

5 Title XVII of Pub. L. 105 277
.

### 7

application; and to enforce the affected programs using electronic documents collected under these programs. The certification must be signed by the governmental official who is legally competent to certify

with respect to legal authority on behalf of their government. In the case of a S tate, this official must be the Attorney General or designee. In the case of a T ribe or local government, this official must be the chief administrative official or officer or designee. As a legal matter, EPA ’s position is that Attorney s General or their designees are the only officials capable of certifying with respect to their States’ legal authority. Where there are substantial administrative obstacles involving the Attorney General in such certifications, EPA urges the State Attorney

General to provide for a legall y competent designee who is available to participate in the submission of the State’s application. 2(b) PRACTICAL UTILITY AND USERS OF THE DATA (1) Registering with E PA Electronic Document Receiving System Regulated entities must initially register with the EPA electronic document receiving sy stem to establish a user account and create a password. EPA uses the information to identify the registrant (e.g., b y name and /or organization), establish the account, and contact the registrant if needed. Regulated entities use the password to access their account and to protect it from unauthorized use. (2) Compliance with Identity Proofing Requirements EPA , State s /L ocals , and LRAs use the identity proofing information from registrants to determine each registrant’s identity and relationship to their regulated entity. The information may be used in an EPA or State/L ocal enforcement action to rebut a signatory ’s attempt to repudi ate their electronic signature and/or other elements of the document that was signed. When EPA or State/L ocal agency receives a subscriber agreement, certification of receipt and secure storage, or other identity
- proofing information, the agency will rev iew, process, and file the submittal. EPA or State/L ocal agency would then provide the registrant with access to the electronic document receiving s ys tem (e.g., open its account) so that it may begin using the electronic signature device in reporting elec tronically
. (3 ) Approval of State/Local Electronic Document Receiving System Applications EPA uses the information submitted by State s /L ocals in their program modification applications to evaluate the State s /L ocals’ upgraded or new electronic document re ceiving sy stems against the criteria at 40 CFR 3.2000(b)(1)
- (5). For example, EPA will review the application to determine if the sy stems are able to generate data as needed, and in a timely manner, including cop y of record for each electronic document re ceived, sufficient to prove that the electronic document was not altered without detection during transmission or at any time after receipt. EPA also reviews the application to ensure that the State/L ocal has taken all necessary steps to modify

its regulations and statutes, as needed, so that it has authority to implement

### 8

electronic reporting and enforce the affected programs using electronic documents collected under its programs. This includes, among other things, an evaluation of the Attorney General’s certification under 40 CFR 3.1000(b)(1)(i).

### 9

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 3(a) NONDUPLICATION CROMERR establishe s uniform, Agency
- wide criteria for electronic document receiving sy stems, thereby minimizing the potential for duplication or redundancy across EPA or State/L ocal programs. Inaddition , electronic reporting is voluntary , and will likely be used by facilities only

if cost
- effective and non
- duplicative with their other compliance activit ies. CROMERR does not alter the reporting requirements under existing regulations and statutes, and does not affect whether a document must be created, submitted, or retained under the existing provisions 40 CFR. 3(b) PUBLIC NOTICE In compliance with the Paperwork Reduction Act of 1995, EPA issued a public notice in the Federal Register on February 2, 2011 (76 FR 5802). The public comment period extended through April 4, 2011. EPA did not receive an y written comments on the ICR in response to the Fede ral Register notice. 3(c) CONSULTATIONS Most of the underl yi ng assumptions in this I CR (e.g., hour an d cost burden estimates) are based on EPA consultations with industry and States/L ocals during the development of CROMERR and renewal of previous CROMERR ICRs. For example, EPA anal yz ed State feedback on the number of electronic document receiving s ys tems and reporting facilities , and reflected updated input in the supporting statement. No additional consultations were conducted in the development of thi s I CR
. 3(d) EFFECTS OF LESS FREQUENT COLLECTION (1) Registering with EPA Electronic Document Receiving System Facilities must initially

register with the EPA electronic document receiving s ys tem to establish a user account. Registration information i s collected at the time of registration (i.e., a one - time event) and updated if needed. Because it is a one
- time activity , the information cannot be collected less frequentl y. If this information were not collected, EPA would not have a way to learn the identity

of the registrant and establish its account. (2) Compliance with Identity Proofing Requirements Facilities must comply

with the identity

proofing provisions of CDX and 40 CFR 3.2000(b)(5), as applicable. These provisions provide that, in the case o f priority reports for which an electronic signature device was used to create an electronic signature, a determination of identity

must be made before the electronic document is received. It is critical that registrants submit the identity

proofing paper

work in advance of their priority reports so that the Agency

### 10

can establish a link between each registrant and its electronic signature device to hold them accountable for their submittals. Facilities also must report an y compromise or surrender of its ele ctronic signature device to EPA or State/Local. LRAs must report an y breach of storage of its subscriber agreements. These are as
needed submittals. If these reports were not collected, EPA and State s /L ocals would not have a way to learn about the signature compromise/surrender or storage breaches. Hence, they would not be in a position to take follow up action as needed (e.g., to temporarily prevent access to an account whose signature device has been compromised). This could result in the unauthori zed use an electronic signature device. (3 ) Approval of State/Local Electronic Document Receiving System Applications CROMERR sets forth timeframes for EPA receipt, review, and approval of State/L ocal program modification applications to implement electronic document receiving s ys tems. State s /L ocal s that did not have an electronic document receiving s ys tem in use or substantially developed on or before October 13, 2005 must apply to EPA for program modification approval before receiving electronic documents ( 40 C FR 3.10000(a)(2)) . If this frequency were not specified, EPA would not have assurance that State s /L ocals are developing and using electronic document receiving s ys tems that comply with CROMERR ’s provisions at 40 CFR 3.2000. 3(e) GENERAL GUIDELI NES This I CR adheres to the guidelines stated in the Paperwork Reduction Act (PRA) , Office of Management and Budget’s (OMB ’ s) implementing regulations, applicable OMB guidance, and EPA ’ s ICR Handbook. EPA notes that subscriber agreements must be kept on file until five ye ars after deactivation of the associated electronic signature d evice. A five
- ye ar retention period is necessary to ensure that such records are available in case of an EPA or State/L ocal enforcement action. EPA recognizes that a registrant may use an electronic signature device in signing a range of enforcement
- sensitive reports. Certain reports may have relevance to an enforcement action long after it is submitted to EPA or State/Local. Because of this, EPA needed to establish a suff icientl y long retention period for the subscriber agreements so that they would available for such enforcement actions. 3(f) CONFIDENTIALITY If a confidentiality

claim were asserted, EPA would treat the information in accordance with the confidentiality regulations at 40 CFR Part 2, Subpart B. EPA also would ensure that the information collection procedures comply with the Privacy

Act of 1974 and the OMB Circular 108.

### 11

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

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4. THE RESPONDENTS AND THE INFORMATION REQUESTED 4(a) RESPONDENTS AND NAICS CODES The information collection requirements covered in this I CR will likely have broad applicability

across industries. R efer to Appendix A for a list of the North American Industry Classification System (NAI CS) codes associated with industries most likely affected by

these requirements. 4(b) INFORMATION REQUESTED Following is a description of the data items and activities associated with the information collection requirements covered in this I CR. Refer to Section 1(b) for the ty pes of respondents examined in this subsection. (1) Registering with EPA Electronic Document Receiving System Facilities must register their employees with CDX before reporting electronically to EPA. The employees must update their registration information if it changes. (i) Data Items :

 An on
- line registration application:

 Registrant name
.

 Organization name
.

 Address
.

 Knowledge
- based informatio n (e.g., user
- supplied secret question
- and
answer pair)
. (ii) Respondent Activities : Facility emplo yees must perform the following activities :

 Lo g on to receiving s ys tem site and enter requested information
.  Update the information, as needed
. ( 2 ) Compl iance with Identity Proofing Requirements Direct reporters, indirect reporters , indirect reporting firms, and LRAs must comply with the identity

proofing provisions of CDX and CROMERR , as applicable. In addition, State s/L ocals that accept electronic documents to satisfy reporting requirements under authorized or delegated environmental programs that they administer must process, review, and approve the identity proofing information submitted by indirect reporters
. CDX and 40 CFR 3.2000(a)(2) require that an y electronic document must bear the valid electronic signature of a signatory if that signatory

would be required under the authorized

### 13

program to sign the paper document for which the electronic document substitutes, except as otherwise specified. In the case of an electronic document that must bear electronic signatures of individuals as provided by CDX and 40 CFR 3.2000(a)(2), each signatory must sign either an electronic signature agreement, or a subscriber agreement with respect to the electronic si gnature device used to create their electronic signature on the electronic document. CDX and 40 CFR 3.2000(b)(5)(vii) require that the identity of the individual uniquely entitled to use the device and their relation to any entity for which he or she will sign electronic documents must be determined with legal certainty b y EPA or State/Local, as applicable. In the case of priority

reports, this determination must be made before the electronic document is received, b y means of:

 Id entifiers or attributes that are verified b y attestation of disinterested individuals to be uniquely

true of the individual in whose name the application is submitted, based on information or objects of indep endent origin, at least one item of which is not subject to change without governmental action or authorization.

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

 Collection of either a subscriber agreement or a certification from a LRA that such an agreement has been received and securel y stored. The t erm “subscriber agreement” means an electronic signature agreement signed b y an individual with a handwritten signature . The agreement must be signed by an individual with respect to an electronic signature device that the individual will use to create hi s/her electronic signature requiring such individual to protect the electronic signature device from compromise; to promptly

report to the agency

or agencies rel yi ng on the electronic signatures created any evidence discovered that the device has been comp romised; and to be held as legally bound, obligated, or responsible by the electronic signatures created as by a handwritten signature. This agreement must be stored until five ye ars after the associated electronic signature device has been deactivated. The term “Local Registration Authority” means an individual who is authorized by a State/L ocal to issue an agreement collection certification, whose identity has been established by notarized affidavit, and who is authorized in writing b y a regulated entity to issue agreement collection certifications on its behalf. Once approved by EPA or State/L ocal, the LRA would collect subscriber agreements from each individual in the regulated entity that intends to use an electronic signature device in reporting ele ctronically to EPA or State/Local electronic document receiving sy stem. The LRA would collect and store the subscriber agreements in a manner that prevents authorized or unauthorized access to these agreements b y an yone other than the LRA. The LRA would prepare an agreement collection certification and submit a certification of receipt and secure storage to the EPA or State/L ocal.

### 14

(i) Data Item s :

 Compliance with identity proofing requirements by means of i dentifiers, attributes, or alternative m ethod :

 I dentifiers or attributes that are verified by attestation of disinterested individuals to be uniquely true, as specified.

 Other information necessary to determine identity
.
 Compliance with s ubscriber agreement provisions :

 Subscriber agreement
.

 Report of c ompromised or surrendered electronic signature.

 Submission of subscriber agreement to LRA :

 Subscriber agreement
.

 Report of breach of security
.

 Report of compromised or surrendered electronic signature.

 Designation of LRA:

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

 Collection of subscriber agreements by LRA:

 Agreement collection certification. This is a signed statement by which a LRA certifies that a subscriber agreement has been received from a registrant; the agreement has been stored in a manner that prevents authorized or unauthorized access to these agreements by an yone other than the LRA ; and the LRA has no basis to b elieve that any of the collected agreements have been tampered with or prematurel y destro yed.

 Certification of receipt and secure storage. (ii) Respondent Activities : Direct and indirect reporters must perform the following activities , as applicable :

 C omply

with requirements for identifier , attribute , or alternative method :

 Prepare and submit information on identifiers , attributes , or other identity
proofing information.

 Comply

with subscriber agreement provisions:

 Prepare and submit a subscriber agree ment.

 File subscriber agreement.

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

 File new subscriber agreement, for emplo ye e turnover.

 Contact the Help D esk for technical support.

### 15

 Report compromised or surrendered electronic signature d evice and prepare/submit new subscriber agreement if necessary
.
 Submit subscriber agreement to LRA :

 Prepare subscriber agreement and send to LRA
.

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

 Report breach of security or compromise/ surrende r of electronic signature device.

 Prepare and submit new subscriber agreement to LRA subsequent to breach of security

or compromise of electronic signature device, if necessary .
 Conduct ongoing management:

 Id entify

and resolve problems
. Ind irect reporting firms and LRAs must perform the following activities , as applicable:

 D esignating a LRA :

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

 Register the LRA with the electronic d ocument receiving s ys tem.

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

 Register new LRA with electronic document receiving s ys tem
.
 Collect subscriber agreements from reporters:

 Collect and securely

store subscriber agreements

 Prepare agreement collection certification after securel y storing subscriber agreements, and submit certification of receipt and secure storage
.

 Collect and securely

store subscriber agreements, for employee turnover
.

 Prepare agreement collection certification aft er securel y storing subscriber agreements, and submit certification of receipt and secure storage, for employee turnover
.

 Collect and securely store subscriber agreements, for breach of security/ compromise of electronic signature device
.

 Prepare agreement collection certification after securel y storing subscriber agreements, and submit certification of receipt and secure storage, for breach of security

/compromise of electronic signature device
. State/Local agencies acting as regulators must perform the f ollowing activities:

 Collect identifiers , attributes , or alternative information :

 Receive, process, review , and approve identifier, attribute, or alternative information
.

### 16

 Collect subscriber agreements:

 Receive, process, review, approve, and file new subs criber agreements.

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

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

 Collect submittals from LRAs:

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

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

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

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

 Collect applications for designation of LRAs:

 Receive application to designate first
- time LRA.

 Receive application to designate LRA, for LRA turnover.

 Conduct ongoing management :

 Id entify

and resolve problems.

 Respond to information requests. (3 ) Approval of State/Local Electronic Document Receiving System Applications To obtain EPA approval of authorized program revision or modification using procedures provided under 40 CFR 3.1000, a State /L ocal must submit an application for program revision to EPA that includes the elements specified in Section s 3.10 00(b)(1)(i) through (iv). A State/L ocal that revises or modifies more than one (1) authorized program for receipt of electronic documents, in lieu of paper documents, may submit a consolidated application covering more than one authorized program, provide d the consolidated application complies with applicable requirements for each authorized program. If the State/Local receives a notice from EPA that its application is incomplete or does not satisfy

the requirements at 40 CFR 3.2000, the State/L ocal must submit an amendment to the original application that includes the missing information. A State/L ocal that accepts electronic documents in lieu of paper documents under an authorized program for which EPA has approved program revisions or modifications under the procedures provided in 40 CFR 3.2000(a)(1) must keep EPA apprised of those changes to laws,

### 17

policies, or the electronic document receiving s ys tems that have the potential to affect program conformance with Section 3.2000. The State/L ocal program must satisfy the requirements at 40 CFR 3.2000. Pursuant to Section 3.2000, authorized programs that receive electronic documents, in lieu of paper documents, to satisfy

requirements under such programs must use an acceptable electronic document receiv ing s ys tem as specified and require that any electronic document must bear valid electronic signatures to the same extent that the paper submission for which it substitutes would bear handwritten signatures under the authorized program, unless otherwise sp ecified. An electronic document receiving s ys tem that receives electronic documents, submitted in lieu of paper documents, to satisfy requirements under an authorized program must be able to generate data with respect to any s uch electronic document, as n eeded and in a timely manner, including a copy of record for the electronic document, that meets the criteria specified at Sections 3.2000(b)(1) through (5). (i) Data Items :

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

 A certification that the State/L ocal has sufficient legal authority provided by lawfully enacted or promulgated statutes or regulations that are in full force and effect on the date of certification to implement the electronic reportin g component of its authorized programs covered b y the application in conformance with Section 3.2000 and to enforce the affected programs using electronic documents collected under these programs , together with copies of the relevant statutes and regulati ons , signed by the State Attorney General or designee, or in the case of an authorized T ribal or local government program, by the C hief A dministrative O fficial or O fficer of the governmental entity or designee.

 A listing of all State/L ocal electronic docum ent receiving s ys tems to accept the electronic documents being addressed by the program modification or revisions that are covered b y the application, together with a description for each such sy stem that specifies how the sy stem meets the applicable crite ria in Section 3.2000(b) with respect to those electronic documents.

 A schedule of upgrades for electronic document receiving s ys tems that have the potential to affect the program’s continued conformance with Section 3.2000, if appropriate.

 Other such inf

ormation as the Administrator may request to fully

evaluate the application.

 Appraisals to EPA of changes to laws, policies, or electronic document receiving s ys tems.

### 18

(ii) Respondent Activities : State/Local agencies that are regulated entities must per form the following activities:

 Upgrade existing electronic document receiving sy stem or develop new electronic document receiving s ys tem to meet 40 CFR 3.2000 requirements and appl y for EPA program modification approval under 40 CFR 3.1000
.
 Submit amendm ent to original application for EPA program modification approval under 40 CFR 3.1000
.
 Submit notification to EPA about changes to laws, policies, or electronic document receiving s ys tems that have the potential to affect program conformance with 40 CFR 3 .2000
.

### 19

5. THE INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT 5(a) AGENCY ACTIVITIES (1) Registering with EPA Electronic Document Receiving System EPA activities associated with facility reporting to EPA’s electronic document receiving sy stem (i.e., CDX) include :

 Develop, o perate , and maintain CDX. (2) Compliance with Identity Proofing Requirements EPA activities associated with the identity proofing requirements covered in this I CR include:

 Collect identi fiers or attributes or other information :

 Receive, process, review , and approve identifier, attribute, or alternative information
.
 Collect subscriber agreements:

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

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

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

 Conduct ongoing management :

 Id entify

and resolve problems.

 Respond to informati on requests. (3 ) Approval of State/Local Electronic Document Receiving System Applications EPA activities associated with the approval of State/L ocal electronic document receiving sy stems include :

 Process and file applications submitted by State s /L ocal s seeking to modify their programs, as required b y 40 CFR 3.1000.

 Process and file amendments to program modification applications submitted by State s /L ocals.

 Process and file appraisals of changes to laws, policies, or electronic document receiving s ys t ems.

### 20

5(b) COLLECTION METHODOLOGY AND MANAGEMENT CDX serves as EPA’s primary gateway for electronic documents received by EPA. CDX functions include:

 Access management allowing or denyi ng an entity access to CDX.  Data interchange accepting and returning data via various file transfer mechanisms.  Signature/certification management providing devices and required scenarios for individuals to sign and certify what they

submit.  Submitter and data authentication assuring that electronic signatures are valid an d data is uncorrupted.  Transaction logging providing date, time, and source information for data received to establish “chain of custody
. ”  Acknowledgment and provision of copy of record providing the submitter with confirmations of the data received.  Archi ving placing files received and transmission logs into secure, long term storage.  Error checking flagging obvious errors in documents and document transactions, including duplicate documents and unauthorized submissions.  Translati ng , forwarding , and converting submitted documents into formats that will load to EPA databases, and forwarding them to the appropriate s ys tems.  Outreach providing educati on and other customer services to CDX users (e.g., user manuals, Help Desk)
. 5(c) SMALL ENTITY FLEXIBILITY C ROMERR allows electronic reporting b y permitting the use of electronic document receiving s ys tems to receive electronic documents in satisfaction of certain document submission requirements in EPA’s regulations. Electronic reporting under CROMERR is voluntary . These changes will reduce the burden on all affected entities, including small businesses. In addition, facilities will find that the initial set up process requires little expenditure of time and resources, and in the long run, this process will reduce the time spent on submissions each ye ar. 5(d) COLLECTION SCHEDULE The collection frequencies associated with CDX include the following:

 Registrants must initially register with the electronic document receiving s ystem and obtain electronic signature certification, if applicable.

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

 Registrants must submit a notice of compromise or surrender of electronic signature device promptl y, should this occur.

### 21

State s /L ocal s that did not have an electronic document receiving s ys tem in use or substantially

developed on or before October 13, 2005 must , using specified procedures, appl y for and receive EPA approval of revisions or modifications to the authorized program before the program may

receive electronic documents in lieu of paper documents to satisfy requirements of such program. Within 75 calendar day s of receiving an application for program revision or modification, the Administrator will respond with a letter that either notifies the State/L ocal that the application is complete or identifies deficiencies in the application that render the application incomplete. The State/Local receiving a notice of deficiencies may amend the application and resubmit it. Within 30 calendar day s of receiving the amended application, the Administrator will respond with a letter that either notifies the applicant that the amended application is complete or identifies remaining deficiencies that render the application incomplete. Except where an opportunity for public hearing is required, if the Administrator does not take an y action on a specific request for revision or modification of a specific authorized program addressed b y an application submitted within 180 calendar day s of notifying the State/L ocal that the application is complete, the speci fic request for program revision or modification for the specific authorized program is considered automatically approved by

EPA at the end of the 180 calendar day s unless the review period is extended at the request of the State/L ocal submitting the appli cation. If a State/Local submits material to amend its application after the date that the Administrator sends notification that the application is complete, this new submission will constitute withdrawal of the pending application and submission of a new , amended application for program revision or modification, and the 180
- day time period will begin again only when the Administrator makes a new determination and notifies the State/L ocal under that the amended application is complete.

### 22

6. ESTIMATING THE H OUR AND COST BURDEN OF THE COLLECTION 6(a) ESTIMATING RESPONDENT BURDEN HOURS Exhibit 1 provide s estimates of the respondent hourly burden associated with the information collection requirements co vered in this I CR. The exhibit include s burden hours (to tal and by

labor type) per respondent, as well as the overall burden hours for all respondents. The majority

of the ho ur estimates in Exhibit 1 are based on the Agency ’s technical background document, Cross Media Electronic Reporting Rule Cost Benefit Ana lysis
. 6(b) ESTIMATING RESPONDENT COSTS Exhibit 1 provide s estimates of the annual respondent costs associated with the information collection requirements covered in this I CR. These costs are based on the cost of labor, capital, and operation and maintenance (O&M). (1) Labor Costs Using the total burden hours discussed in Section 6(a) and the hourl y respondent labor costs outlined i n this section, Exhibit 1 illustrate s the labor costs associated with the information collection requirements covered in this I CR. (a) Direct Reporters, Indirect Reporters , Indirect Reporting Firms, and Local Registration Authorities EPA estimates an average hourly respondent labor cost (includin g fringe and overhead) of $57.87 for legal staff, $37.09 fo r managerial staff, $36.78 for technical staff, and $16.18 for clerical staff. These respondent l abor costs were obtained from the previously approved CROMERR IC R (i.e., EPA I CR Number 2002.04 , dated February 15, 2008), and updated to 2011 levels using Employ ment Cos t Index es developed by the Bureau of Labor Statistics. 6

6 Bureau of Labor Statistics; “ Table 4. Employment Cost Index for total compensation, for civilian workers , b y occupational and industry;” Employment Cost Index, Historical Listing, Continuous Occupational and Industry Series, September 1975

– March 2011 ; April 29, 2011. Available online at: http://www.bls.go v/web/eci/ecicois.pdf , last accessed on June 8, 2011. Civilian Workers, All Workers, March 2008=107.6 and March 2011=114.0.

### 23

(b) State/Local Agencies EPA estimates an average hourly respondent labor cost (includin g fringe and overhead) of $38.95 for legal staff, $38.95 for managerial sta ff, $29.50 for technical staff, and $14.00 fo r clerical staff. These respondent labor costs were obtained from the previously approved CROMERR IC R (i.e., EPA I CR Number 2002.04, dated February 15, 2008), and updated to 2011 levels using Employ ment Cost Indexes developed by the Bureau of Labor Statis tics. 7 

### (2) Capital Costs Capital costs usually

include any

produced ph ys ical good needed to provide the needed information, such as machinery , c omputers, and other equipment. (a) Direct Reporters, Indirect Reporters , Indirect Reporting Firms, and Local Re gistration Authorities EPA does not anticipate that direct reporters, indirect reporters , indirect reporting firms, and LRAs will incur capital costs in carrying out the information collection requirements covered in this ICR. (b) State/Local Agencies EPA anticipates that State/L ocal agencies will incur capital costs in upgrading their existing electronic document receiving s ys tems or developing new electronic document receiving sy stems to satisfy

CROMERR standards at 40 CFR 3.2000 (e.g., cop y of record, S ecure Sockets Laye r (SSL), e
- mail notification, electronic signature, electronic signature agreement)
. In particular, EPA estimates that each State agency will incur a cost of $144,330 and that each Local agency

will incur a cost of $ 54 , 817
. These capital costs were obtained from the previously approved CROMERR IC R (i.e., EPA I CR Number 2002.04, dated February 15, 2008), and updated to 2011 levels using Consumer Pric e Indexes developed by the Bureau of Labor Statistics. 8 

### The above capital costs are shown in Exhibit 1 for all a pplicable respondent activities. EPA notes that c apital costs for L ocal agencies are estimated to be lower than the capital costs for State agencies because Local agencies are expected to have simpler electronic document receivin g sy stems that cover fewer programs and fewer electronic reports than S tate

7 Bureau of Labor Statistics, "Table 7. Employment Cost Index for total compensation, for State and local government workers, by occupational and industry," Employment Cost Index, Historical Listing, Continuous Occupational and Industry Series, September 1975

– March 2011; April 29, 2011. Available online at: http://www.bls.gov/web/eci/ecicois.pdf , last accessed on June 8, 2011. State and Local Government Workers, All Workers, March 2008=108.9 and March 2011=116.6.

8 Bureau of Labor Statistics, Table Containing History of CPI
- U U.S. All Items Indexes and Annual Percent Changes From

1913 to Present, May 13, 2011. Available online at: ftp://ftp.bls.gov/pub/special.requests/cpi/cpiai.txt , last accessed on June 8, 2011. All items, March 2008=213.528 and April 2 011=224.906.

### 24

sy stems. For example, EPA has receiv ed onl y one application from a L ocal agency under CROMERR, and that system only accepts reports under one authorized program
. (3) Operation an d Maintenance Costs O&M costs are those costs associated with an information collection requirement incurred continually

over the life of the ICR. (a) Direct Reporters, Indirect Reporters , Indirect Reporting Firms, and Local Registration Authorities O&M c osts include :

 EPA estimates that employee registrants that submit subscriber agreements to EPA or State s /L ocal s will incur a cost of $3.31 to mail a one
- ounce letter by certified mail ( i.e., $0.44 for first
- class letter postage , $2.85 for the certified
- mail f ee, and $0.02 for standard business envelope)
. 9 , 10 , 11



###  EPA estimates that employee registrants that submit subscriber agreements to their LRA will incur a cost of $0.46 to mail a one
- ounce letter using first
- class mail (i.e., $0.44 for first

- class lett er postage and $0.02 for standard business envelope)
. 12 , 13



###  EPA estimates that indirect reporting firms will incur a cost of $2.63 for obtaining a notarized affidavit to establish the identity of a LRA . This O&M cost was obtained from the previousl y approv ed CROMERR IC R (i.e., EPA I CR Number 2002.04, dated February

15, 2008), and updated to 2011 levels using Consumer Pric e Indexes developed b y the Bureau of Labor Statistics. 14 

### The above O&M costs are shown in Exhibit 1 for all a pplicable respondent activit ies.

9 U.S. Postal Service ; “ First
- Class Mail Prices .” Available online at: http://www.usps.com/prices/first
class
- mail
- prices.htm , la st accessed on June 8, 2011.

10 U.S. Pos tal Service; “Extra Services Prices.” Available online at: http://www.usps.com/prices/extra
services
- prices.htm , last accessed on June 8, 2011.

11 Standard business envelope cost based on current market price, as of March 7, 2011 (i.e., box of 500 standard business envelopes with gummed closure at $8.99).

12 U.S. Postal Service ; “ First
- Class Mail Prices .” Available online at: http://www.usps.com/prices/first
class
- mail
- prices.htm , la st accessed on June 8, 2011.

13 Standard business envelope cost based on current market price, as of March 7, 2011 (i.e., box of 500 standard business envelopes with gummed closure at $8 .99).

14 Bureau of Labor Statistics, Table Containing History of CPI
- U U.S. All Items Indexes and Annual Percent Changes From 1913 to Present, May 13, 2011. Available online at: ftp://f tp.bls.gov/pub/special.requests/cpi/cpiai.txt , last accessed on June 8, 2011. All items, March 2008=213.528 and April 2011=224.906.

### 25

(b) State/Local Agencies For State/Local agencies , O&M costs include mailing costs. In particular, EPA estimates that State/L ocal agencies submitting documentation to EPA (e.g., applications for program modification approval under 40 CFR 3.1000 ) will incur a cost of $5.42 to mail a nine
- ounce large e nvelope by

certified mail ($2.48 for first
- class large envelope postage, $2.85 for the certified
- mail fee, and $0.09 for catalog envelope). 15 , 16 , 17 

### These O&M cos ts are shown in Exhibit 1 for all applicable respondent activities. 6(c) ESTIMATING AGENCY HOUR AND COST BURDEN EPA estimates the Agency hour and cost burden associated with the information collection requirements covered in this I CR in Exhibit 2
. As shown i n the exhibit , EPA estimates an average hourly labor cost of $ 64.93 for legal staff (GS
- 14 , Step 5), $ 54.94 for manageri al staff (GS
- 13, Step 1), $46.21 for technical s taff (GS
- 12, Step 1), and $23.44 for clerical staff (GS
- 06, Step 1). To derive these hourly estimates, EPA referred to the Gen eral Schedule (GS) Salary

Table 2011
. 18 

### This publication summarizes the unloaded (base) hourl y rate for various labor categories in the Federal g overnment. EPA then applied the standard government overhead factor of 1.6 to the unloaded rate to derive load ed hourly rates. EPA estimates that , each year, the Agency will incur a capital cost of $159,360 in CDX development, operation , and maintenance activities
. 19 

### This capital cos t is shown in Exhibit 2
. O&M costs include electronic transaction f ee s associat ed with the processing of electronic subscriber agreement s (ESA) by a third party

vendor . In particular, EPA estimates that the Agency

will i ncur an electronic transaction cost of $1.20 per subscriber agreement. 20 

### This O&M cos t is shown in Exhibit 2 for all applicable activities.

15 U.S. Postal Service ; “ First
- Class Mail Prices .” Available online at: http://www.usps.com/prices/first
class
- mail
- prices.htm , la st accessed on June 8, 2011.

16 U.S. Postal Service; “Extra Services Prices.” Available online at: http:/ /www.usps.com/prices/extra
services
- prices.htm , last accessed on June 8, 2011.

17 Catalog envelope cost based on current market price, as of March 7, 2011 (i.e., box of 100 6” x 9” brown kraft catalog envelopes with gummed closure at $8.79).

18 US Office of Personnel Management, “ Base Hourly Rate, ” 2011 General Schedule (Base) , January 2011. Available online at: http://opm.gov/oca/11tables/indexgs.asp , last accessed on June 8 , 2011.

19 Based on EPA ’s Capital Planning and Investment Control (CPIC) for CDX. Data current as of May 26, 2011. 20 Based on data current as of May 26, 2011.

### 26

6(d) ESTIMATING RESPONDENT UNIVERSE AND TOTAL HOUR AND COST BURDEN In this section, EPA first describes the estimated respondent universe. EPA then estimates the annual burden to respondents under the information collection req uirements covered in this ICR. EPA notes that, a s used in this document , the term “respondent” includes:

 Direct reporters, indirect reporters , indirect reporting firms, and LRAs complying with the registration and identity proofing requirements cov ered in this ICR , as applicable . This includes:

 Private sector entities; and

 State/L ocal agencies that are regulated entities 21



### .
 State/L ocal agencies administering electronic document receiving s ys tems subject to CROM E RR

22 

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

 State/L ocal agencies seeking EPA approval to allow electronic reporting under CROMERR

23 

### . In this document, we refer to these respondents as “ State/Local agencies that are regulated entities. ” (1) Respondent Universe (a) Direct Reporters Table 1 presents information on the annual number of employee registrants expected to register with CDX during the three
- ye ar period covered b y the IC R. As shown in the table, EPA estimates that, on average, 28, 084 employees will register with CDX each year . Appendix B provides detailed information on the methodology used to estimate the average annual number of direct reporters expected to register with the CDX during the three
ye ar period covered by

this I CR
.

21 Addressing State/Local agencies as “respondents” is consistent with EPA’s interpretation of the definition of respo ndent in the Paperwork Reduction Act (PRA).

22 Ibid
. 23 Ibid.

### 27 Table 1 Annual Number of Direct Reporters Expected to Register with EPA ’s CDX during the Three - Year Period Covered by the ICR

Respondent Universe Average Annual Number of New Employee Registrants a Private Sector Entities 23,880 State /Lo cal Agencies that are Regulated Entities 4,204 Total 28,084
a Federal government employees are not reflected in the table because they are exempt from ICR requirements. 

### Table 2 presents information on the estimated annual number of subscriber agreements to be subm itted to EPA during the three
- ye ar period covered b y the ICR. As shown in the table, direct reporters have various options for c omplying with the subscriber agreement requirements covered in this ICR :

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

 Electronic subscriber agreement (ESA). Direct reporters have the option of completing and submitting an ESA directl y to CDX (i.e., without using a third party vendor)
. Thi s eli minates the requirement to prepare and mail new paper subscriber agreements.

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

 Third Party ESA . Direct reporters now have the option of completing and submitting an ESA through a third party vendor. CDX provides a volunt ary method for real
- time identity proofing using a third party vendor to validate government identification (ID) and additional personal information in comp liance with OMB Memorandum M
- 04
- 04 , while retaining repeatable digital evidence of validation using cryptographic hash technology and not retaining the highl y sensitive personally id entifying information. The third party process validates both identity and business affiliation. This eli minates the requirement to prepare and mail new paper subscriber agreements.

### 28

Appendix B provides detailed information on the methodology used to estimate the average annual number of subscriber agreements to be submitted to EPA during the three
- ye ar period covered b y this I CR. Table 2

Annual Number of Subscriber Agreeme nts to Be Submitted to EPA during the Three - Year Period Covered by the ICR
Type of Subscriber Agreement Annual Number of Subscriber Agreements a , b Average 2011 2012 2013 Private Sector Entities Non
- ESA Registrants 7,684 6,690 6,990 7,121 ESA Registrants 17,444 14,232 14,027 15,234 Reuse (Consolidated) ESA Registrants 4,077 5,301 5,317 4,898 Third Party ESA Registrants 496 1,060 1,047 868 Subtotal 29,701 27,283 27,381 28,122 State/Local Agencies that A re Regulated Entities Non
- ESA Registrants 1, 353 1,178 1,230 1,254 ESA Registrants 3,071 2,505 2,469 2,682 Reuse (Consolidated) ESA Registrants 718 933 936 862 Third Party ESA Registrants 87 187 184 153 Subtotal 5,229 4,803 4,819 4,950 Total Non
- ESA Registrants 9,037 7,868 8,220 8,375 ESA Regi strants 20,515 16,737 16,496 17,916 Reuse (Consolidated) ESA Registrants 4,795 6,234 6,253 5,761 Third Party ESA Registrants 583 1,247 1,231 1,020 Total 34,930 32,086 32,200 33,072
a Tab le contains data provided by EPA’s Office of Information Collecti on (OIC) , and are current as of May 26, 2011
. b Federal government employees are not reflected in the table because they are exempt from ICR requirements. 

### (b) Indirect Reporters Table 3 presents information on the annual number of employee registrants expe cted to register and comply

with identify

proofing requirements of State/L ocal electronic document receiving s ys tems during the three
- ye ar period covered b y the IC R. As shown in the table, EPA estimates that, on average, 25,924 employees from indirect rep orting facilities will register and comply with identify

proofing requirements of State/L ocal electronic document receiving sy stems each year. For indirect reporters, EPA assumes that only a portion of employee registrants from medium
- size and large firms will use the LRA alternative. The remaining facility employees will comply

with the subscriber agreement provisions. Thus, in order to perform the analy sis, EPA categorized emplo yee registrants based on the size of their firms (i.e., small firm or medium - size and large firm). Table 3 presents information on the annual number of employee registrants b y typ e of firm.

### 29

As shown in Table 3, EPA estimates that, on average, 13,960 employees from small firms and 11,964 employees from medium
- size and large firm s will register and comply with identify proofing requirements of State/L ocal electronic document receiving s ys tems each ye ar. Appendix C provides detailed information on the methodology used to estimate the average annual number of indirect reporters f or the three
- year period covered by this ICR. Table 3 Annual Number of Indirect Reporters Expected to Register and Comply with Identify Proofing Requirements during the Three - Year Period Covered by the ICR Type of Firm Average Annual Number of Employee R egistrants a Private Sector Entities Small Firms 11,870 Medium
- Size and Large Firms 10,173 Subtotal 22,043 State/Local Agencies that are Regulated Entities Small Firms 2,090 Medium
- Size and Large Firms 1,791 Subtotal 3,881 Total Small Firms 13,96 0 Medium
- Size and Large Firms 11,964 Total 25,924
a Federal government employees are not reflected in the table because they are exempt from ICR requirements. 

### (c) Indirect Reporting Firms As shown in Table 3, EPA estimates that, on average, 13,960 emplo ye es from small indirect reporting firms will register and compl y with identify proofing requirements of State/L ocal electronic document receiving s ys tems each ye ar. Each small firm is expected to have an average of three employees 24 

### , for a total of 4,654 small firms (i.e., 13,960 employees ÷ 3 employees/firm). EPA also estimates that, on average, 11,964 employees from medium
- size and large indirect reporting firms will register with State/Local electronic document receiving s ys tems each ye ar. Each medium
- size and large firm is expected to have an average of 18 emplo yees 25 

### , for a total of 665 medium
- size and large firms (i.e., 11,964 employees ÷ 18 employees/firm).

24 Th is assumption was taken from Cross

-Media Electronic Reporting and Records Rule (CROMERRR) Cost Benefit Analysis, Final , dated November 17, 2004.

25 Th is assumption was taken from Cross

-Media Electronic Reporting and Records Rule (CROMERRR) Cost Benefit Analysis, Final , dated November 17, 2004.

### 30

(d) State s /Local s Submitting Electronic Document Receiving System Applications to EPA B ased on information currently available to EPA on the submission and approval of program modification applications under 40 CFR 3.1000 (i.e., CROMERR applications), EPA estimates that , on average, five States/Locals (i.e., 4 States and 1 L ocal ) will upgrade their existing electronic document receiving s ys tems or develop new electronic document receiving sy stem s and submit CROMERR applications each year. EPA also estimates that, on average, 15 State s/Locals (i.e., 15 States and 0 Locals) will submit amendments to their original CROMERR applications each ye ar. In addition, EPA estimates that, on average, 4 States/L ocals (i.e., 4 States and 0 L ocals ) will submit notification s to EPA about changes to laws, policies, or electronic document receiving s ys tems each year. (2) Annual Respondent Burden (Exhibit 1) (a) Registering with EPA Electronic Document Receiving System

– Direct Reporters EPA estimates that, on average, 28,084 employees of direct reporting facilities will register with EPA’s electronic document re ceiving sy stem each ye ar. EPA also estimates that, of the 28,084 employee registrants , approximately 10 percent (or 2,808 ) will need to update their registration information each ye ar . (b ) Compliance with Identity Proofing Requirements

– Direct Reporte rs The following paragraphs discuss the ass umptions associated with compliance with the identity proofing requirements by direct reporters
. Comply with Requirements for I dentifier, Attribute, or Alternative Method EPA does not anticipate that direct rep orters will p repare and submi t information on identifiers or attributes , or other identity
- proofing information. Comply with Subscriber Agreement Provision s EPA assumes that all direct reporters will compl y with the subscriber agreement requirements. Non

-ESA Registrants. EPA estimates that, on average, emplo ye e registrants from direct reporting facilities will prepare, submit, and file a total of 8,375 paper subscriber agreements each ye ar. EPA also estimates that, of the 8,375 paper subscriber agree ments prepared each ye ar, 89 percent ( 7,454 ) will be from new and existing employee registrants (e.g., emplo yees registering for the first time with a data flow) ; 10 percent ( 837 ) will be associated with employee

### 31

turnover, which requires the submittal of a new subscriber agreement by the employee replacement; and one percent (84) will be associated with a compromised electronic signature, which requires the submittal of a new subscriber agreement. EPA anticipates that all employee registrants preparing a p aper subscriber agreement will contact the Help Desk for technical support. ESA Registrants. EPA estimates that, on average, employee registrants from direct reporting facilities will prepare, submit, and file a total of 17,916 ESAs each year. EPA als o estimates that, of the 17,916 ESAs prepared each year, 89 percent ( 15,945 ) will be from new and existing employee registrants (e.g., emplo ye es registering for the first time with a data flow) ; 10 percent ( 1,792 ) will be associated with employee turnover, which requires the submittal of a new subscriber agreement by

the employee replacement; and one percent ( 17 9 ) will be associated with a compromised electronic signature, which requires the submittal of a new subscriber agreement. EPA anticipates that all employee registrants preparing an ESA will contact the Help Desk for technical support. Reuse (Consolidated) ESA Registrants. EPA estimates that, on average, 5,761 employee registrants from direct reporting facilities will reuse their ESA each year. EPA also estimates that, of the 5,761 reuse (consolidated) ESAs, 89 percent ( 5,127 ) will be from existing employee registrants (e.g., existing employee registrant s registering for the first time with a data flow) ; 10 percent ( 576 ) will be associated with e mployee turnover, which requires the submittal of a new subscriber agreement by

the employee replacement; and one percent (58) will be associated with a compromised electronic signature, which requires the submittal of a new subscriber agreement. EPA anti cipates that all employee registrants reusing an ESA will contact the Help Desk for technical support. Third Party ESA Registrants. EPA estimates that, on average, emplo ye e registrants from direct reporting facilities will prepare, submit, and file a t otal of 1,020 third party ESAs each ye ar. EPA also estimates that, of the 1,020 third party ESAs prepared each year, 89 percent ( 908 ) will be from new and existing employee registrants (e.g., emplo yees registering for the first time with a data flow) ; 10 percent ( 102 ) will be associated with employee turnover, which requires the submittal of a new subscriber agreement by the employee replacement; and one percent ( 10 ) will be associated with a compromised electronic signature, which requires the submittal o f a new subscriber agreement. EPA anticipates that all employee registrants preparing a third party ESA will contact the Help Desk for technical support. Conduct On
- Going Management EPA assumes that, of the 33,072 employee registrants from direct rep orting facilities , three percent (992) will have to work with EPA to resolve problems involving their agreements or certif ications each ye ar.

### 32

(c ) Compliance with Identity Proofing Requirements

– Indirect Reporters The following paragraphs discuss the a ssumptions associated with compliance with the identity proofing requirements by indirect reporters. Comply with Requirements for Identifier, Attribute, or Alternative Method EPA does not anticipate that indirect reporters will p repare and submi t inform ation on identifiers or attributes , or other identity
- proofing information. Comply with Subscriber Agreement Provision s For indirect reporters, EPA assumes that all employee registrants from small firms ( 13,960 ) and 98 percent of employee registrants fro m medium
- size and large firms ( 11,964 x 0.98 = 11 , 725 ) will comply with the subscriber agreement requirements
. In addition, EPA estimates that i ndirect reporters submit information to 1.3 State/L ocal electronic document receiving s ys tems, on average; henc e, their employees must submit subscriber agreements for 1.3 receiving sy stems, on average. 26 

### EPA assumes that all employee registrants from indirect reporting facilities will submit paper subscriber agreements. Based on the above assumptions, EPA estimat es that, on average, emplo ye e registrants from indirect reporting facilities will prepare, submit , and file a total of 33,391 subscriber agreements each year (i.e., [ 13,960 small firm employees + 11,725 medium
- size and large firm employees ] x 1.3 subscriber agreements/emplo ye e )
. EPA also estimates that, of the 33,391 subscriber agreements prepared each year, 89 percent ( 29,718 ) will be from new and existing employee registrants (e.g., emplo ye es registering for the first time with a data flow) ; 10 percent 27 

### ( 3 ,339 ) will be associated with employee turnover, which requires the submittal of a new subscriber agreement by the employee replacement; and one percent ( 334 ) will be associated with a c ompromised electronic signature, which requires the submittal of a new subscriber agreement EPA anticipates that all employee registrants preparing a subscriber agreement will contact the Help Desk for technical support. Submit Subscriber Agreements to Lo cal Registration Authority EPA assumes that two percent of medium
- size and large firms will use the LRA alternative
. EPA also assumes that indirect reporting firms submit information to 1.3 State/L ocal electronic document receiving s ys tems, on average; hence, their employees must submit subscriber agreements for 1.3 re ceiving sy stems, on average. 28 

### Based on th e s e assumption s ,

26 Ibid. 27 T h is assumption was taken from Secti on 2.3.4.2 (page 29) of Cross

-Media Electronic Reporting and Records Rule (CROMERRR) Cost Bene fit Analysis, Final , dated November 17, 2004. 28 Ibid.

### 33

EPA estimates that, on average, employees from indirect reporting firms will prepare and send to their LRA a total of 239 subscriber agreements each year (i.e., [ 11,964 medium
- size and large firm e mployees x 0.02] x 1.3 subscriber agreements/employee). EPA estimates that, of the 239 subscriber agreements prepared each year, 89 percent (213) will be from new employee registrants; 10 percent (24) will be associated with employee turnover, which requi res the submittal of a new subscriber agreement by the employee replacement; and one percent (2) will be associated with a compromised electronic signature, which requires the submittal of a new subscriber agreement. Conduct On
- Going Management EPA as sumes that, of the 25,685 employee registrants from indirect reporting facilities ( 13,960 + 11 , 725 = 25,685 ) , three percent (771) will have to work with States/L ocals to resolve problems involving their agreements each year. (c ) Implementation of Local Registration Authority Alternative

– Indirect Reporting Firms and Local Registration Authorities The following paragraphs discuss the assumptions associated with implementation of the LRA alternative b y indirect reporting firm s and LRAs. Designating a L o cal Registration Authority As stated above, EPA assumes that two percent of medium
- size and large indirect reporting firms (665 x 0.02 = 14) will use the LRA alternative . These firms will develop a process or plan to implement the LRA alternative , design ate the LRA, submit the LRA application to the agency, and register the LRA with the electronic document receiving s ys tem. Of the 14 medium
- size and large indirect reporting firms that will use the LRA alternative , two percent (1) will need to redesignate the LRA annuall y due to turnover, which requires registration of the new LRA with the electronic document receiving s ys tem. Collect Subscriber Agreements from Reporters EPA estimates that, on average, LRAs will collect a total of 239 subscriber agreem ents each ye ar. Of these 239 subscriber agreements, 213 will be from new employee registrants, 24 will be associated with employee turnover, and 2 will be associated with a compromised electronic signature. For each of these subscriber agreements, LRA s w ill need to prepare an agreement collection certification after securel y storing the subscriber agreements, and submit a certification of receipt and secure storage
.

### 34

( d ) Compliance with Identity Proofing Requirements

– State/Local Agencies Acting as Re gulators Collect Id entifier, Attribute, or Alternative Information EPA does not anticipate that indirect reporters will p repare and submi t information on identifiers or attributes , or other identity
- proofing information. Collect Subscriber Agreements E PA estimates that, on average, employee registrants from indirect reporting facilities will prepare, submit, and file a total of 33,391 subscriber agreements each year. This includes 29,718 subscriber agreements from new emplo ye e registrants, 3,339 subscriber agreements associated with emplo ye e turnover, and 334 subscriber agreeme nt s associated with a c ompromised electronic signature. State/L ocal agencies will re ceive, process, review, approve , and file all these subscriber agreements
. Collect Submittals from Local Registration Authority EPA estimates that, each year, employee registrants from indirect reporting facilities will submit 239 subscriber agreements to their LRAs. This includes 213 subscriber agreements from new employee registrants, 24 subsc riber agreements associated with employee turnover , and 2 subscriber agreements associated with a compromised electronic signature. State/L ocal agencies will need to receive, process, review, and approve the certification of receipt and secure storage sub mitted by

the LRA s . Collect Applications for Designation of L ocal Registration Authority EPA estimates that, each year, 14 indirect reporting firms will use the LRA alternative
. EPA also estimates that, each ye ar, one of these firms will need to redesignate the LRA due to turnover. State/Local agencies will need to receive and approve these LRA applications. Conduct On
- Going Management EPA estimates that, each year, State/Local agencies will have to work with 771 employee registrants to resolve probl ems involving their agreements or certif ications , and respond to information requests
. ( e ) Approval of State/Local Electronic Document Receiving System Applications

– State/Local Agencies that Are Regulated Entities Read the Regulations EPA estim ates that, on average, 24 States/Locals will submit documentation to EPA associated with the approval of State/L ocal electronic document receiving sy stems each year. These States/Locals are expected to read the regulations at 40 CFR Part 3.

### 35

Submit Electronic Document Receiving S ys tem Application EPA estimates that, on average, five States/Locals will upgrade their existing electronic document receiving s ys tems or develop new electronic document receiving sy stem s and submit a CROMERR application eac h year. Th is includes four States and one Lo cal
. Submit Amendment to Original Application EPA estimates that, on average, 15 States will submit amendments to their original CROMERR application each ye ar. E PA does not anticipate that Locals will submit amendments to their original CROMERR applications during the three
- year period covered b y this I CR. Submit Notification on Changes to Laws, Policies, or Electronic Document Receiving Sy stem EPA estimates that, on average, four States will submit a notification about changes to laws, policies, or electronic document receiving sy stems that have the potential to affect program conformance with 40 CFR 3.2000
. EPA does not anticipate that Locals will submit this notification during the three
- ye ar period covered by this ICR. 6(e) BOTTOM LINE HOUR AND COST BURDEN (1) Respondent Tally Exhibit 3 summarizes the total annual respondent hour and cost burden associated with all the requirements covered in this I CR
. As used in this document, the term “respondent” includes private sector and State/L ocal entities. 29 

### As shown in the exhibit , EPA estimates the annual respondent burden to be 39,7 63 hours and $2,167, 446 . The bottom lin e burden to respondents over three years is estimated to be 119,2 89 hours and $6,50 2 , 338
. (2) Agency Tally Exhibit 4 summarizes the total annual EPA hour and cost burden associated with all the requirements covered in this I CR. As shown in the exhibit , EPA estimates the annual a gency burden to be 21,771 hours and $1,169,096

. The bottom line burden to the agency over three ye ars is estimated to be 65,313 hours and $3,507,288

. 6(f) REASONS FOR CHANGE IN BURDEN The annual respondent burden estimate in the previously approved CROMERR IC R (EPA I CR Number 2002.04) was 78,035 hours. The annual respondent burden estimate for this ICR (EPA ICR Number 2002.05) is 39,7 63 hours. This represents a decrease of 38,27 2 hours.

29 Refer to Section 6(d) for additional clarification on the types of respondents examined in this ICR
.

### 36

This decrease occurred for two primary reasons. First, there was a decrease in the annualized number of respondent s. The total number of emplo ye es registering with EPA’s electronic document receiving s ys tem and/or complying with CROMERR’s identity proofing requirements decreased from 93,325 in the previously approved ICR to 87,080 in this I CR. In addition, the total number of State/L ocal authorized programs upgrading their existing electronic document receiving s ys tems or developing new electronic document receiving s ys tems, and submitting documentation associated with the approval of CROMERR applications decreased f rom 61 in the previousl y approved ICR to 24 in this I CR. EPA conducted a thorough examination of available information (e.g., number of application received over the past three ye ars) in estimating the number of respondents subject to the requirements of this I CR. EPA thinks that the number of respondents included in this I CR is a reasonable approximation of the actual respondent universe. Second, in developing this I CR, EPA carefull y reviewed the respondent activities associated with compliance with id entify proofing requirements. EPA made a few changes to the assumptions associated with subscriber agreement and LRA alternatives to be consistent with actual compliance of respondents with these requirements. For example, EPA reduced the proportion of respondents that use the LRA alternative while increasing the proportion of respondents that compl y with subscriber agreement requirements. This resulted in a burden decrease because the burden associated with subscriber agreements is less than the LRA burden. EPA notes that few, if any, respondents opted to use the LRA alternative over the past three ye ars. Table 4 provides information on changes in burden. As shown in Table 4, all changes are considered “adjustments,” since they resulted from changes i n the size of the respondent universe and refinements to the assumptions used in the development of the ICR.

### 37 Table 4 Reasons for Change in Respondent Burden Hours from EPA ICR Number 2002.04 to EPA ICR Number 2002.05 a
Changes in EPA ICR Number 2002.05 Type of Change Burden Hours in EPA ICR Number 2002.04 Burden Hours in

EPA ICR Number 2002.05 Change in Total

Annual Burden Hours in EPA ICR Number 2002.05 Registering with EPA Electronic Document Receiving System - Direct Reporters Increase in the number of employees that will register with EPA's electronic document receiving system (CDX) Adjustment 1,477 4,269 2,792 Compliance with Identity Proofing Requirements - Direct and Indirect Reporters Comply with Subscriber Agreem ent Provisions Decrease in the number of first
- time subscriber agreements Adjustment 23,583 17,762 (5,821) Decrease in the number of subscriber agreements, due to employee turnover Adjustment 2,359 1,996 (363) Decrease in the number of subscriber agreements, due to compromised elec tronic signature Adjustment 76 53 (23) Decrease in the number of employee registrants that contact the Help Desk for technical support Adjustment 7,439 3,988 (3,451) Submit Subscriber Agreement to Local Registration Authority Decrease in the number of n ew employee registrants that prepare subscriber agreements Adjustment 5,830 70 (5,760) Decrease in the number of subscriber agreements, due to employee turnover Adjustment 593 8 (585) Decrease in the number of subscriber agreements, due to compromised el ectronic signature Adjustment 1,173 1 (1,172) Conduct On - Going Management Decrease in the number of employee registrants that will have to work with EPA or State/Locals to resolve problems involving their agreements or certifications Adjustment 5,770 1,7 63 (4,007) Imple mentation of Local Registration Authority Alternative - Indirect Reporting Firms and Local Registration Authorities Designating a Local Registration Authority Decrease in the number of firms that opt to use the LRA alternative Adjustment 13,652 184 (13,468) Decrease in the number of redesignated LRAs, due to turnover Adjustment 157 1 (156)

### Table 4 (continued)

Reasons for Change in Respondent Burden Hours from EPA ICR Number 2002.04 to EPA ICR Number 2002.05 a 

### 38

Changes in EPA ICR Number 2002.05 Type of Change Burden Hours in EPA ICR Number 2002.04 Burden Hours in

EPA ICR Number 2002.05 Change in Total

Annual Burden Hours in EPA ICR Number 2002.05 Collect Subscriber Agreements fromReporters Decrease in the number of new employee registrants that prepare subscriber agreements Adjustment 1,016 72 (944) Decrease in the number of subscriber agreements, due to employee turnover Adjustment 190 8 (182) Decrease in the number of subscriber agreements, due to compromised electronic signature Adjustment 2 1 (1) Compliance with Identity Proofing Requi rements - State/Local Agencies Acting as Regulators Inclusion of State/Local burden associated with compliance with subscriber agreement provisions as "respondent burden" Adjustment 0 5,676 5,676 Inclusion of State/Local burden associated with the LRA a lternative as "respondent burden" Adjustment 0 43 43 Inclusion of State/Local burden associated with designating a LRA as "respondent burden" Adjustment 0 8 8 Inclusion of State/Local burden associated with on
- going management as "respondent burden" Ad justment 0 1,928 1,928 Approval of State/Local Electronic Docum ent Receiving SystemApplication - State/Local Agencies as Regulated Entities Decrease in the number of States/Locals reading the regulations Adjustment 92 36 (56) Decrease in the number of States/Locals upgrading their existing electronic document receiving systems or developing ne w electronic document receiving systems and submitting CROMERR applications to EPA Adjustment 14,625 1,534 (13,091) Addition of new activity under w hich States/L ocals submit amendment to original CROMERR application to EPA Adjustment 0 360 360 Increase in number of States/Locals submitting notification to EPA about changes to laws, policies, or electronic document receiving systems that have the potential to aff

ect program conformance with 40 CFR 3.2000 Adjustment 0 3 3 Total Change in Burden Hours (38,272) a Exhibit includes rounding error.

### 39

6(g) PUBLIC BURDEN STATEMENT (1) Registering with EPA Electronic Document Receiving System

– Direct Reporters The reporting burden is estimated to be 10 minutes for a facility employee to register with CDX. This includes time for preparing the on
- line application and calling the CDX Help Desk. There are no recordkeeping requirements associated with registering w ith the CDX application. (2) Compliance w ith Identity Proofing Requirement s – Direct and Indirect Reporters The report ing burden is estimated to be 80 minutes for a facility employee to p repare and submit identifier, attribute, or alternative information
. There are no recordkeeping requirements associated with this requirement , and as such, there is no recordkeeping burden. The report ing burden is estimated to range from 15 minutes to 20 minutes for a facility employee to prepare and submit a subscriber a greement. The recordkeeping burden for the facility employee is estimated to be 5 minutes to file an agreement on site. (3) Implementation of Local Registration Authority Alternative

– Indirect Reporting Firms and Local Registration Authorities The repo rt ing burden is estimated to be 13 hours for a firm to develop a process or plan to use the LRA alternative , designate the LRA, submit the LRA application to the agency , and register the LRA with the electronic document receiving s ys tem. There are no reco rdkeeping requirements associated with this requirement , and as such, there is no recordkeeping burden. The report ing burden is estimated to be 1 hour for a firm to redesignate the LRA, due to turnover; send the LRA application to the agency ; and register the new LRA with the electronic document receiving s ys tem. There are no recordkeeping requirements associated with this requirement , and as such, there is no recordkeeping burden. The report ing burden is estimated to be 10 minutes for a LRA to p repare and submit a certification of re ceipt and secure storage after receiving a subscriber agreement . The recordkeeping burden is estimated to be 10 minutes for a LRA to compile subscriber agreements from employee registrants within the LRA’s firm and place th em in secure storage. (4) Compliance w ith Identity Proofing Requirement s – State/Local Agencies Acting as Regulators The reporting burde n is estimated to be 30 minutes for a State/Local agency to receive, process, review , and approve identifier, attribute, or alternative information
. There are no recordkeeping requirements associated with this requirement , and as such, there is no recordkeeping burden.

### 40

The reporting burde n is estimated to be 10 minutes for a State/Local agency to receive, process, review , and approve subscriber agreements
. There are no recordkeeping requirements associated with this requirement , and as such, there is no recordkeeping burden. The reporting burde n is estimated to be 3 0 minutes for a State/Local agency to receive, process, review , and approve an LRA application
. There are no recordkeeping requirements associated with this requirement , and as such, there is no recordkeeping burden. The reporting burde n is estimated to be 2.5 hours for a State/Local agency to resolve problem s involving subscriber agreements or certifications, and respond to information requests. There are no recordkeeping requirements associated with this requirement , and as such, there is no recordkeeping burden. ( 5 ) Approval of State/Local Electronic Docu ment Receiving System Applications

– State/Local Agencies that Are Regulated Entities The reporting burde n is estimated to range from 210 hours to 331 hours for a State/L ocal agency to prepare and submit the CROMERR application to EPA. The recordkeeping burden is estimated to be 90 minutes to read the regulations. The reporting burde n is estimated to be 24 hours for a State/Local agency to prepare and submit an amendment to its original CROMERR application to EPA. The recordkeeping burden is estimated t o be 90 minutes to read the regulations. The reporting burde n is estimated to be 45 minutes for a State/Local agency to notify EPA about changes to laws, policies, or electronic document receiving s ys tems that have the potential to affect program conforma nce with 40 CFR 3.2000
. The recordkeeping burden is estimated to be 90 minutes to read the regulations. Burden means the total time, effort, or financial resources expended b y 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 sy stems for the purposes of collecting, validating, and verifying information, processing and maintaining information, an d disclosing and providing information; adjust the existing way s to comply with an y previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the coll ection 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 display s 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 t his I CR under Docket ID Number EPA

–HQ

–OEI

–2011

–0096 , which is available for online viewing at

### 41

www.regulations.go v, or in person viewing at the Office of Environmental In formation (OEI) Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday , excluding legal holiday s. The telephone number for the Reading Room is (202) 566
- 1744, and the telephone number for the OEI Docket is (202) 566
- 1752 . An electronic version of the public docket is available at www.regulations.gov. This site can be used to submit or view public c omments, 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 sy stem, select “search,” then key in the Docket ID Number identified above. Also, yo u 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

–OE I

– 2011

–0096 and OMB Co ntrol Number 2025

–0003 in any correspondence.

### 42

EXHIB IT 1 CR OS S- ME DI A ELEC TR

ONIC REP OR

TI NG RUL E

Le g. Mgr. Te ch . Cler . Re spon. La bo r Capi tal / Number of Total Total $57.87/ $37.09/ $36.78/ $16.18/ Hou rs / Cost/ St artup O& M Re spon. Hou rs / Cost/ IN FO RMAT IO N CO LLEC TI ON ACTI

VIT Y Hou r Hou r Hou r Hou r Acti vi ty Acti vi ty Cost Co st Acti vi ti es Ye ar Ye ar Log on t o t he receiving

sy st em s it e and ent er reques te d informat ion 0.00 0.00 0.15 0.00 0.15 $5.52 $0.00 $0.00 28,084 4,212.60 $155,023.68 Up dat e t he

informat ion as needed 0.00 0.00 0.02 0.00 0.02 $0.74 $0.00 $0.00 2,808 56.16 $2,077.92 Su bt ot al Varies Varies Varies Varies Varies Varies Varies Varies Va ries 4,268.76 $157,101.60 Complyw

it h R equirem en ts for I

de nti fi er, A

ttri bu te , or A

lt ernati ve Met hod Prep ar e and submit reques te d informat ion 0.00 0.25 1.00 0.10 1.35 $47.67 $0.00 $0.00 0 0.00 $0.00 Complyw

it h S ubsc ri be r A

gre em en t Prov

is io ns - N on-ESA

R eg ist rants Prep ar e and submit a subscriber ag reement 0.00 0.00 0.25 0.00 0.25 $9.20 $0.00 $3.31 7,454 1,863.50 $93,249.54 Fi le subscriber ag

re ement 0.00 0.00 0.08 0.00 0.08 $2.94 $0.00 $0.00 7,454 596.32 $21,914.76 Prep ar e and submit a new s ubscriber ag reement , for emp loy ee t urnover 0.00 0.00 0.25 0.00 0.25 $9.20 $0.00 $3.31 837 209.25 $10,470.87 Fi le new subsc

riber ag reement , for emp loy ee t urnover 0.00 0.00 0.08 0.00 0.08 $2.94 $0.00 $0.00 837 66.96 $2,460.78 Rep ort comp romis ed or surrendered elect ronic s ig na tu redevice and p rep are/s ubmit new s ubscriber ag

reement if neces sa

ry 0.00 0.00 0.08 0.00 0.08 $2.94 $0.00 $3.31 84 6.72 $525.00 Cont act t he H elp D es k for t echnical s up po rt 0.00 0.00 0.06 0.00 0.06 $2.21 $0.00 $0.00 8,375 502.50 $18,508.75 Complyw

it h S ubsc ri be r A

gre em en t Prov

is io ns - E SA

R eg is tran ts Prep ar e and submit a subscriber ag reement 0.00 0.00 0.17 0.00 0.17 $6.25 $0.00 $0.00 15,945 2,710.65 $99,656.25 Fi le subscriber ag

re ement 0.00 0.00 0.08 0.00 0.08 $2.94 $0.00 $0.00 15,945 1,275.60 $46,878.30 Prep ar e and submit a new s ubscriber ag reement , for emp loy ee t urnover 0.00 0.00 0.17 0.00 0.17 $6.25 $0.00 $0.00 1,792 304.64 $11,200.00 Fi le new subsc

riber ag reement , for emp loy ee t urnover 0.00 0.00 0.08 0.00 0.08 $2.94 $0.00 $0.00 1,792 143.36 $5,268.48 Rep ort comp romis ed or surrendered elect ronic s ig na tu redevice and p rep are/s ubmit new s ubscriber ag

reement if neces sa

ry 0.00 0.00 0.08 0.00 0.08 $2.94 $0.00 $0.00 179 14.32 $526.26 Cont act t he H elp D es k for t echnical s up po rt 0.00 0.00 0.06 0.00 0.06 $2.21 $0.00 $0.00 17,916 1,074.96 $39,594.36 Prep ar e and submit a subscriber ag reement 0.00 0.00 0.17 0.00 0.17 $6.25 $0.00 $0.00 5,127 871.59 $32,043.75 Fi le subscriber ag

re ement 0.00 0.00 0.08 0.00 0.08 $2.94 $0.00 $0.00 5,127 410.16 $15,073.38 Prep ar e and submit a new s ubscriber ag reement , for emp loy ee t urnover 0.00 0.00 0.17 0.00 0.17 $6.25 $0.00 $0.00 576 97.92 $3,600.00 Fi le new subsc

riber ag reement , for emp loy ee t urnover 0.00 0.00 0.08 0.00 0.08 $2.94 $0.00 $0.00 576 46.08 $1,693.44 Rep ort comp romis ed or surrendered elect ronic s ig na tu redevice and p rep are/s ubmit new s ubscriber ag

reement if neces sa

ry 0.00 0.00 0.08 0.00 0.08 $2.94 $0.00 $0.00 58 4.64 $170.52 Cont act t he H elp D es k for t echnical s up po rt 0.00 0.00 0.06 0.00 0.06 $2.21 $0.00 $0.00 5,761 345.66 $12,731.81 Prep ar e and submit a subscriber ag reement 0.00 0.00 0.17 0.00 0.17 $6.25 $0.00 $0.00 908 154.36 $5,675.00 Fi le subscriber ag

re ement 0.00 0.00 0.08 0.00 0.08 $2.94 $0.00 $0.00 908 72.64 $2,669.52 Prep ar e and submit a new s ubscriber ag reement , for emp loy ee t urnover 0.00 0.00 0.17 0.00 0.17 $6.25 $0.00 $0.00 102 17.34 $637.50 Fi le new subsc

riber ag reement , for emp loy ee t urnover 0.00 0.00 0.08 0.00 0.08 $2.94 $0.00 $0.00 102 8.16 $299.88 Rep ort comp romis ed or surrendered elect ronic s ig na tu redevice and p rep are/s ubmit new s ubscriber ag

reement if neces sa

ry 0.00 0.00 0.08 0.00 0.08 $2.94 $0.00 $0.00 10 0.80 $29.40 Cont act t he H elp D es k for t echnical s up po rt 0.00 0.00 0.06 0.00 0.06 $2.21 $0.00 $0.00 1,020 61.20 $2,254.20 Cond uct O n-Goi ng Manage me nt Ident ify and re solve p roblems 0.00 0.00 1.00 0.00 1.00 $36.78 $0.00 $0.00 992 992.00 $36,485.76 Su bt ot al Varies Varies Varies Varies Varies Varies Varies Varies Va ries 11,851.33 $463,617.51 a Ex hibit includes rounding

error. ES TIMATE

D A NNU AL RES PO NDE

NTHOU R AN D COS T BU

RD EN a Hou rs an d Costs P er R esp ondent Pe r A

ct iv it y

Re gi ste ri ng w

it h E PA E lectronic Document R

ec eiv ing Sy stem - Di re ct R

ep orte rs
Complia nc e wi th Ide ntity P roofi ng R eq uirem en ts - Di re ct R

ep orte rs Total Hour s and Costs

Complyw

it h S ubsc ri be r A

gre em en t Prov

is io ns - Thi rd

Party ESA

R eg istr ants Complyw

it h S ubsc ri be r A

gre em en t Prov

is io ns - R

eu se (Consolidate d) ESA R eg istrants

### 43

EXHIB IT 1 (CO NTI

NU ED ) CR OS S- ME DI A ELEC TR

ONIC R EP OR TI NG R ULE

Le g. Mgr. Tec h. Cler . Re sp on. La bo r Cap it al / Numb er of Total Total $57.87/ $37.09/ $36.78/ $16.18/ Hou rs / Cost/ St artup O& M Re sp on. Hours / Cost/ IN FO RMAT IO N CO LLEC TION AC TI VIT Y Hour Hour Hou r Hou r Act iv ity Act iv

it y Cost Cost Act iv it ies Ye ar Ye ar Complyw

it h R eq uir em ent s for Ide nti fi er, A ttri bu te , or A

lt ernati ve Met ho d Pr ep ar e and s ubmit reques te d informat io n 0.00 0.25 1.00 0.10 1.35 $47.67 $0.00 $0.00 0 0.00 $0.00 Complyw

it h S ub sc ri be r Ag re em en t P rov isio ns - Non-ESA

R eg ist rants Pr ep ar e and s ubmit a s ubsc ri ber ag reement 0.00 0.00 0.25 0.00 0.25 $9.20 $0.00 $3.31 29,718 7,429.50 $371,772.18 File s ubscriber ag

reement 0.00 0.00 0.08 0.00 0.08 $2.94 $0.00 $0.00 29,718 2,377.44 $87,370.92 Pr ep ar e and s ubmit a new s ubscriber ag reement , for emp lo ye e t urnove r 0.00 0.00 0.25 0.00 0.25 $9.20 $0.00 $3.31 3,339 834.75 $41,770.89 File new s ubscriber ag

reement , for emp loy ee t urnover 0.00 0.00 0.08 0.00 0.08 $2.94 $0.00 $0.00 3,339 267.12 $9,816.66 Repo rt comp romis ed or surrende re d elect ronic s ig

nat ure device and p rep are/submit new s ubscriber ag

reement i f neces sa

ry 0.00 0.00 0.08 0.00 0.08 $2.94 $0.00 $3.31 334 26.72 $2,087.50 Cont act t he

He lp De sk for t echnical sup po rt 0.00 0.00 0.06 0.00 0.06 $2.21 $0.00 $0.00 33,391 2,003.46 $73,794.11 Pr ep ar e s ubscriber ag

reement and se

nd t o LRA (non-ES

A reg is trant ) 0.00 0.00 0.33 0.00 0.33 $12.14 $0.00 $0.46 213 70.29 $2,683.80 Pr ep ar e new s ubscriber ag reement and send t o LRA, for emp lo ye e t urnover (nonESA reg is trant ) 0.00 0.00 0.33 0.00 0.33 $12.14 $0.00 $0.46 24 7.92 $302.40 Repo rt breach of s ecurit y or comp rimis e/s urrender of elect ronic sign at ure device 0.00 0.00 0.08 0.00 0.08 $2.94 $0.00 $0.00 2 0.16 $5.88 Pr ep ar e new s ubscriber ag reement and send t o LRA subse que nt t o breach of se curit y/ comp romis e of elect ronic s ig nat ure device (non-ESA reg is trant ) 0.00 0.00 0.33 0.00 0.33 $12.14 $0.00 $0.46 2 0.66 $25.20 Cond uct O n- Goi ng Manage me nt Ident if y and res ol

ve p roblems 0.00 0.00 1.00 0.00 1.00 $36.78 $0.00 $0.00 771 771.00 $28,357.38

Develop a p rocess or p lant o imp lement t he requirement , des ig nat e t he LRA , and submit LRA a

pplicat io n t o ag

ency 1.00 0.00 12.00 0.00 13.00 $499.23 $0.00 $5.94 14 182.00 $7,072.38 Re gi ster LRA witht he elect ronic document receiving sy stem 0.00 0.00 0.17 0.00 0.17 $6.25 $0.00 $0.00 14 2.38 $87.50 Re des ig nat e LRA , due t o t urnover, and send a ppl icat ion mat er ials 0.00 0.00 1.00 0.00 1.00 $36.78 $0.00 $5.94 1 1.00 $42.72 Re gi ster new LRA withelect ronic document receiving sy stem 0.00 0.00 0.17 0.00 0.17 $6.25 $0.00 $0.00 1 0.17 $6.25 Collect a nd securely s to re s ubscriber ag reement s 0.00 0.00 0.17 0.00 0.17 $6.25 $0.00 $0.00 213 36.21 $1,331.25 Pr ep ar e ag

reement collect ion certi ficat io n aft er s ecurely s to ring subscriber ag

reement s, and submit cert ificat ion of receip t and secure s to rag e 0.00 0.00 0.17 0.00 0.17 $6.25 $0.00 $2.57 213 36.21 $1,878.66 Collect a nd securely s to re s ubscriber ag reement s, for emp lo ye e t urnover 0.00 0.00 0.17 0.00 0.17 $6.25 $0.00 $0.00 24 4.08 $150.00 Pr ep ar e ag

reement collect ion certi ficat io n aft er s ecurely s to ring subscriber ag

reement s, and submit cert ificat ion of receip t and secure s to rag e, for emp loy ee t urnover 0.00 0.00 0.17 0.00 0.17 $6.25 $0.00 $2.57 24 4.08 $211.68 Collect a nd securely s to re s ubscriber ag reement s, for breach of securit y/ comp romise of elect ronic s ig

nat ure device 0.00 0.00 0.17 0.00 0.17 $6.25 $0.00 $0.00 2 0.34 $12.50 Pr ep ar e ag

reement collect ion certi ficat io n aft er s ecurely s to ring subscriber ag

reement s, and submit cert ificat ion of receip t and secure s to rag e, for brea

ch of se curit y/ comp romis e of elect ronic s ig nat ure device 0.00 0.00 0.17 0.00 0.17 $6.25 $0.00 $2.57 2 0.34 $17.64 Su bt ot al Varies Var ies Varies Varies Varies Varies Varies Varies Varies 14,055.83 $628,797.50
a Ex hibit includes rounding

error. Col lect S ub sc ri be r Ag re em en ts from R eporte rs Desig nati ng a L

ocal R egistrati on A

ut ho ri ty Su bm itS ub sc ri be r Ag re em en t to L ocal R eg ist rati on A

ut hority

Impl em en tati on of L

ocal R eg ist rati on A

ut hority A

lt ernati ve - I

nd irect R eporti ng Firms and

L ocal R eg ist rati on A

uthorit ies ES TIMAT ED A

NNU AL RES PO NDE

NT H OU R AN D CO ST BU

RD EN Hou rs and Costs Pe r Re spond

entPe r Act iv

ity Total Hour s and Costs

Complia nc e wi th Ide nt ity Proofi ng R eq ui re me nts - I

nd irect R eporte rs

### 44

EX HI BIT 1 (CO NT IN UE

D) ES TI MA TE D A NNU AL RES PO NDE

NT H OU R AN D COS T BU

RD EN
Le g. Mgr. Te ch . Cler . Re spon. La bo r Ca pi tal / Number of Total Total $38.95/ $38.95/ $29.50/ $14.00/ Ho ur s/ Co st/ St artu p O& M Re spon . Hou rs / Cost/ IN FO RMAT IO N CO LLEC TION A CT IVIT Y Hou r Hou r Hou r Hou r Acti vi ty Act iv it y Cost Co st Act iv it ies Ye ar Ye ar Receive, p roce ss, review a nd ap pr ove ident ifier, at trib ut e, or al ternat ive in format io n 0.00 0.00 0.50 0.00 0.50 $14.75 $0.00 $0.00 0 0.00 $0.00 Receive, p roce ss, review , ap pr ove and file new s ubs cr ib er ag reement s 0.00 0.00 0.17 0.00 0.17 $5.02 $0.00 $0.00 29,718 5,052.06 $149,184.36 Receive, p roce ss, review , ap pr ove and file new s ubs cr ib er ag reement s, for emp loy ee t urnove

r 0.00 0.00 0.17 0.00 0.17 $5.02 $0.00 $0.00 3,339 567.63 $16,761.78 Receive, p roce ss, review , ap pr ove rep ort comp romis e/s urrende r elect ronic si gn at ure de

vice 0.00 0.00 0.17 0.00 0.17 $5.02 $0.00 $0.00 334 56.78 $1,676.68 Receive, p roce ss, review , and ap prove cert if icat ion of receip t and s ecur e st orag e 0.00 0.00 0.17 0.00 0.17 $5.02 $0.00 $0.00 213 36.21 $1,069.26 Receive, p roce ss, review a nd ap pr ove up da

te d ce rt if icat ion of receip t and se cure s to ra

ge , for em pl oy ee turnover 0.00 0.00 0.17 0.00 0.17 $5.02 $0.00 $0.00 24 4.08 $120.48 Receive not if

icat io n of breach of s ecuri ty or comp romis e/s urrender of elect ronic sign at ure device and t ake act ion 0.00 0.00 1.00 0.00 1.00 $29.50 $0.00 $0.00 2 2.00 $59.00 Receive, p roce ss, review a nd ap pr ove cert ificat io n of receip t and secure st orag e, for breach of s ecuri

ty 0.00 0.00 0.17 0.00 0.17 $5.02 $0.00 $0.00 2 0.34 $10.04 Receive ap pl icat ion t o desig na te first -t ime LRA 0.00 0.00 0.50 0.00 0.50 $14.75 $0.00 $0.00 14 7.00 $206.50 Receive ap pl icat ion t o desig na te LRA , for LRA t urnove

r 0.00 0.00 0.50 0.00 0.50 $14.75 $0.00 $0.00 1 0.50 $14.75 Ident ify and resol

ve p roblems 0.00 0.00 1.00 0.00 1.00 $29.50 $0.00 $0.00 771 771.00 $22,744.50 Res po nd t o informat ion reques ts 0.00 0.00 1.50 0.00 1.50 $44.25 $0.00 $0.00 771 1,156.50 $34,116.75 Subt ot al Va

ries Va ries Va ries Varies Va

ries Va

ries Varies Va

ries Varies 7,654.10 $225,964.10 a Ex hi bit i ncludes rounding

e rror. Complia nce wi th Ide nti ty P roofi ngR eq uir em ent s - S tate /L

ocal A ge ncies Act ingas R

eg ul ators

Col lect S ubmi ttal s from L ocal R eg ist ra ti on A

ut hor it y

Conduct O n- Goi ngM an age me nt Col lect S ubscri be r Ag re em ent s

Col lect A

ppl ic ati on s for D esig na ti on of L oc al R eg ist rati on A

ut ho ri ty CR OS S- ME DI A ELEC TR

ONIC R EP OR TI NG R UL E
Hou rs and C osts P er

R esponden t Pe r A

ct iv ity Total Hou rs and Costs

Col lect Ide nt if

er, A ttri bu te , or

A lt ernati ve I

nf ormati on

### 45

EX HI BIT 1 (CO NT IN UE

D) CR OS S- ME DI A ELEC TR

ONIC R EP OR TI NG R UL E ES TI MA TE D A NNU AL RES PO NDE

NT H OU R AN D COS T BU

RD EN

Le g. Mgr. Te ch . Cler . Re spon. La bo r Ca pi tal / Number of Total Total $38.95/ $38.95/ $29.50/ $14.00/ Ho ur s/ Co st/ St artu p O& M Re spon . Hou rs / Cost/ IN FO RMAT IO N CO LLEC TION A CT IVIT Y Hou r Hou r Hou r Hou r Acti vi ty Act iv it y Cost Co st Act iv it ies Ye ar Ye ar

Readt he reg ulat ions 0.00 0.75 0.75 0.00 1.50 $51.34 $0.00 $0.00 24 36.00 $1,232.16 Up gr ade ex

is ting elect ronic document receiving s ys te m or develop new elect ronic document rec eivin g sy stem t o meet 40 CFR 3.2000 a nd ap ply for EPA p rog

ra m modificat ion a

pproval under 40 CFR 3.1000 (Sta te s) 0.00 31.00 300.00 0.00 331.00 $10,057.45 $144,330.00 $5.42 4 1,324.00 $617,571.48 Up gr ade ex

is ting elect ronic document receiving s ys te m or develop new elect ronic document rec eivin g sy stem t o meet 40 CFR 3.2000 a nd ap ply for EPA p rog

ra m modificat ion a

pproval under 40 CFR 3.1000 (Loc als ) 0.00 20.00 190.00 0.00 210.00 $6,384.00 $54,817.00 $5.42 1 210.00 $61,206.42

Su bmit a mendment t o orig

inal ap pl icat ion for EPA p rog ra m modificat io n ap proval under 40 CF R 3.1000 (Sta te s/ Locals ) 0.00 8.00 16.00 0.00 24.00 $783.60 $0.00 $5.42 15 360.00 $11,835.30
Su bmit not ificat ion t o EPA a bout cha ng es t o la ws, p olicies , or elect ronic document receiving

sy stems t hat ha

ve t he p ot ential t o affect p rog ram co nformance w it h 40 CFR 3.2000 (Sta te s/ Locals w it h a

pproved ap plicat io ns) 0.00 0.25 0.50 0.00 0.75 $24.49 $0.00 $5.42 4 3.00 $119.64
Subt ot al Va

ries Va ries Va ries Varies Va

ries Va

ries Varies Va

ries Varies 1,933.00 $691,965.00 TO TA L Va ri es Va ri es Va ri es Va ri es Va ri es Va ri es Va ri es Va ri es Va ri es 39,763.02 $2,167,445.71
a Ex hi bit i ncludes rounding

e rror. Su bm itE

lectron icD ocu me ntR

ec eiv ingS ys te m A

ppl ic ati on

Su bm itN oti fi ca ti on on Change s to Laws, Pol icies,or E lectron icD ocu me ntR

ec eiv ingS ys te m Su bm itA

me nd me nt to O ri gi nal A

ppl ic ati on Re ad th e Re gul ati on s Hou rs and C osts P er

R esponden t Pe r A

ct iv ity Total Hou rs and Costs

Appr ov al of S tate /L

oc al E lectron icD ocu me ntR

ec eiv ingS ys te m A

ppl ic ati on - S tate /L

ocal A ge ncies that A

re R eg ula te d En ti ti es

### 46

EXHIB IT 2 ES TI MA TE D A NNU AL EPA HO UR AN D CO ST BU RD EN a

Le g. Mgr. Te ch . Cler . Re spon. La bo r Capit al / Number of Total Total $64.93/ $54.94/ $46.21/ $23.44/ Hou rs / Co st/ St artup O& M Re sp on. Hou rs / Co st/ IN FO RMAT IO N COL

LEC TIO N ACTI

VITY Hou r Ho ur Ho ur Hou r Act iv it y Acti vi ty Co st Cost Acti vi ti es Ye ar Ye ar Develop , op erat e, and maint ain CD X 0.00 285.00 8,598.00 0.00 8,883.00 $412,971.48 $159,360.00 $0.00 1 8,883.00 $572,331.48 Subt ot al 0.00 285.00 8,598.00 0.00 8,883.00 $412,971.48 $159,360.00 $0.00 1 8,883.00 $572,331.48
Receive, p roces s, review and ap prove ident ifier, at tr ib ut e, or alt ernat ive informat ion 0.00 0.00 0.50 0.00 0.50 $23.11 $0.00 $0.00 0 0.00 $0.00 Receive, p roces s, review , ap pr ove and file new s ubscriber ag reement s b 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $0.00 7,454 0.00 $0.00 Receive, p roces s, review , ap pr ove and file new s ubscriber ag reement s, for emp loy ee t urnover b 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $0.00 837 0.00 $0.00 Receive, p roces s, review , ap pr ove rep ort comp romis e/s urrender elect ronic si gn at ure device 0.00 0.00 0.17 0.00 0.17 $7.86 $0.00 $0.00 84 14.28 $660.24 Receive, p roces s, review , ap pr ove and file new s ubscriber ag reement s 0.00 0.00 0.52 0.00 0.52 $24.03 $0.00 $0.00 15,945 8,291.40 $383,158.35 Receive, p roces s, review , ap pr ove and file new s ubscriber ag reement s, for emp loy ee t urnover 0.00 0.00 0.52 0.00 0.52 $24.03 $0.00 $0.00 1,792 931.84 $43,061.76 Receive, p roces s, review , ap pr ove rep ort comp romis e/s urrender elect ronic si gn at ure device 0.00 0.00 0.17 0.00 0.17 $7.86 $0.00 $0.00 179 30.43 $1,406.94 Receive, p roces s, review , ap pr ove and file new s ubscriber ag reement s c 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $0.00 5,127 0.00 $0.00 Receive, p roces s, review , ap pr ove and file new s ubscriber ag reement s, for emp loy ee t urnover c 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $0.00 576 0.00 $0.00 Receive, p roces s, review , ap pr ove rep ort comp romis e/s urrender elect ronic si gn at ure device 0.00 0.00 0.17 0.00 0.17 $7.86 $0.00 $0.00 58 9.86 $455.88 Receive, p roces s, review , ap pr ove and file new s ubscriber ag reement s d 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $1.20 908 0.00 $1,089.60 Receive, p roces s, review , ap pr ove and file new s ubscriber ag reement s, for emp loy ee t urnover d 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $1.20 102 0.00 $122.40 Receive, p roces s, review , ap pr ove rep ort comp romis e/s urrender elect ronic si gn at ure device 0.00 0.00 0.17 0.00 0.17 $7.86 $0.00 $0.00 10 1.70 $78.60
Ident ify and resolve p roblems 0.00 0.00 1.00 0.00 1.00 $46.21 $0.00 $0.00 992 992.00 $45,840.32 Res po nd t o informat ion reques ts 0.00 0.00 1.50 0.00 1.50 $69.32 $0.00 $0.00 992 1,488.00 $68,765.44 Subt ot al Varies Var ies Va ries Varies Var ies Varies Var ies Varies Varies 11,759.51 $544,639.53
a Ex hi bit includes rounding

error. CR OS S- ME DI A ELEC TR

ONIC R EP OR TIN G RUL

E

Hou rs and L ab or C os ts P er

R espond en t Pe r A

cti vi ty Total Hour s and Costs

Re gi sterin g w

it h E PA El ectroni c D ocu me nt R ec eiv ing S ys tem
Comp lia nc e wi th I

de nti ty Proofi ngR

equi re me nts

Coll ect S ub sc ri be r Ag re em ent s - ESA R eg ist rants Coll ect S ub sc ri be r Ag re em ent s - Non-ESA R eg is trants Coll ect Ide ntife r, A

ttri bu te, or

A lt ernati ve In formati on

Coll ect S ub sc ri be r Ag re em ent s - R euse (C on so lidate d) ESA R eg is trants

bLabor cost as soc iat ed w it h t he collect io n of subscriber ag re ements from non-ES

A re gi stra nt s is equal t o $0.00 because it is included in t he reg is tr at ion cos ts covered under "Rep ort ing t o EP A Elect ronic Document Receiving Sys tem."
c Labor cost as soc iat ed w it h t he collect io n of subscriber ag re ements from reuse (consolidat ed) ESA reg is tr ant s is equal t o $0.00 because, under t his op ti on, reg is tr ant s can us e t heir ex

is ting CD X credent ial. As a res ult , EPA does not need t o receive, p roces s, review, ap prove, and file new p ap ers ubscriber ag reement s from t hes e reg

is trant s. d Labor cost as soc iat ed w it h t he collect io n of subscriber ag re ements from t hird p arty ESA reg is trant s i s equal t o $0.00 because, under t hi s op ti on, a t hi rd p arty vendor p roces se s thesubscriber ag reement s for an elect ronic t rans act ion fee of $1.20 p er s ubscriber ag

re ement. Coll ect S ub sc ri be r Ag re em ent s - Thi rd Pa rty ESA R eg istr an ts

Conduct O n-Goi ng Manage me nt

### 47

EX HIB IT 2 (CO NTI

NU ED ) ES TI MATE D A NNU AL EPA HO UR AN D COS T BU RD EN a

Le g. Mgr. Te ch . Cler . Re spon . La bo r Capi tal / Numb er of Total Total $64.93/ $54.94/ $46.21/ $23.44/ Hou rs / Cost/ S t artup O& M Re spon. Hours / Co st/ IN FO RMAT IO N COL

LEC TION AC TI

VIT Y Hou r Ho ur Ho ur Hou r Acti vi ty Acti vi ty Cost Cost Acti vi ti es Ye ar Ye ar Proc es s a nd file receiving

sy st em document at ion submit te d by Sta te/Local se eking t o modify t heir p rog

ra ms , as required by 40 CF R 3.1000 (Sta te s) 0.00 0.00 160.00 0.00 160.00 $7,393.60 $0.00 $0.00 4 640.00 $29,574.40 Proc es s a nd file receiving

sy st em document at ion submit te d by Sta te/Local se eking t o modify t heir p rog

ra ms , as required by 40 CF R 3.1000 (Locals ) 0.00 0.00 80.00 0.00 80.00 $3,696.80 $0.00 $0.00 1 80.00 $3,696.80 Proc es s a nd file amendment t o orig inal ap plicat ion for EP A pr og ram modificat ion ap proval under 40 CF R 3.1000 (Sta te s/ Lo cals ) 0.00 0.00 24.00 0.00 24.00 $1,109.04 $0.00 $0.00 15 360.00 $16,635.60 Proc es s a nd file not ificat ions about chang es t o law s, p olicies , or elect ronic document receiving

sy st ems t hat have t he p ot ent ial t o affect p rog ram conformance w it h 40 CFR 3.2000 (Sta te s/ Lo cals wit h ap pr oved ap plicat ions) 0.00 0.00 12.00 0.00 12.00 $554.52 $0.00 $0.00 4 48.00 $2,218.08
Subt ot al Var ies Var ies Var ies Va ries Va

ries Varies Varies Varies Var ies 1,128.00 $52,124.88 TO TA L 0.00 Va ri es Vari es Va ri es Va ri es Va ri es Va ri es Va ri es Va ri es 21,770.51 $1,169,095.89
a Ex hibit includes rounding

error. Appro va l of S tate /L

ocal E lectron ic Docume ntR

ec eiv in g S yste m A

ppl ic ati ons CR OS S - ME DI A ELEC TR

ONIC R EP OR TI NG R ULE

Hours and L abor C osts P er

R espondentPe r A

ct iv ity Total Hou rs and Costs

### 48

EXHIB IT

3 CR OS S-MEDIA ELECTR ON IC R EPOR TIN G TOTAL ES TIM ATED RE SPON DENT HOURA

ND C OS T BU

RDEN SUMMA

RY a

Annual B ur de n Ho ur s Annual Lab or Cos t Annual Cap it al / Star tup Cos t Annual O&M

Cos t Total Annual C os t
Re giste rin g wit h E

PA E le ctronic Do cum

ent Re cei vi ng Sy st em

- Dire ct R

epor ters 3,629.76 $133,584.72 $0. 00 $0.00 $133,584.72 Co mp lia nce w

it h Id entity Pro of

in g Re qui re me nts - Dire ct Re por

ters 10,077.74 $370,662.97 $0. 00 $23,570.51 $394,233.48 Co mp lia nce w

it h Id entity Pro of

in g Re qui re me nts - In di

rect R epor ters 11,952.26 $440,019.89 $0. 00 $94,669.83 $534,689.72 Subtotal 25, 659. 76 $944, 267. 58 $0. 00 $118, 240. 34 $1, 062, 507. 92 Re por ti ng to EP A Electronic Do cum ent Re cei vi ng Sy st em

- Dire ct Re por

ters 639.00 $23,516.88 $0. 00 $0.00 $23,516.88 Co mp lia nce w

it h Id entity Pro of

in g Re qui re me nts - Dire ct Re por

ters 1,773.59 $65,233.29 $0. 00 $4,150.74 $69,384.03 Co mp lia nce w

it h Id entity Pro of

in g Re qui re me nts - In di

rect R epor ters 2,103.57 $77,440.13 $0. 00 $16,667.65 $94,107.78 Co mp lia nce w

it h Id entity Pro of

in g Re qui re me nts - St ate/L

ocal A gencies A cti

ng as R egulators 7,654.10 $225,964.10 $0. 00 $0.00 $225,964.10 Approval o f St ate/L

ocal E le ctr onic Do cum

ent Re cei vi ng Sy ste m Appl

ic ation - St ate/L

ocal A gencies t hat Are R

egulated En ti

ti es 1,933.00 $59,697.92 $632,137.00 $130.08 $691,965.00 Subtotal 14, 103. 26 $451, 852. 32 $632, 137. 00 $20, 948. 47 $1, 104, 937. 79 Re giste rin g wit h E

PA E le ctronic Do cum

ent Re cei vi ng Sy st em

- Dire ct R

epor ters 4,268.76 $157,101.60 $0. 00 $0.00 $157,101.60 Co mp lia nce w

it h Id entity Pro of

in g Re qui re me nts - Dire ct Re por

ters 11,851.33 $435,896.26 $0. 00 $27,721.25 $463,617.51 Co mp lia nce w

it h Id entity Pro of

in g Re qui re me nts - In di

rect R epor ters 14,055.83 $517,460.02 $0. 00 $111,337.48 $628,797.50 Co mp lia nce w

it h Id entity Pro of

in g Re qui re me nts - St ate/L

ocal A gencies A cti

ng as R egulators 7,654.10 $225,964.10 $0. 00 $0.00 $225,964.10 Approval o f St ate/L

ocal E le ctr onic Do cum

ent Re cei vi ng Sy ste m Appl

ic ation - St ate/L

ocal A gencies t hat Are R

egulated En ti

ti es 1,933.00 $59,697.92 $632,137.00 $130.08 $691,965.00 Total 39, 763. 02 $1,396, 119. 90 $632, 137. 00 $139, 188. 81 $2, 167, 445. 71 3- ye arTotal 119, 289 $4, 188,360 $1, 896, 411 $417, 567 $6, 502,338 aE xh ib it in cl udes ro undi

ng erro r. Al l Res po nd

ents (i .e., Pr iv

ate S ector and

S tate /Loc al ) Priv ate S ector Res pond

ents

St ate /Loc al R

es po nd ents

Note: The exhibit presents hour and cost burden for private sector and State/Local respondents. Information is needed in this format for submission of the ICR into EPA’s

Information Collection Request, Review, and Approval System (ICRAS) , the electronic system that EPA uses to transmit ICRs to OMB for approval.

### 49

EXHIB IT

4 CR OS S-MEDIA ELECTR ON IC R EPOR TIN G TOTAL ES TIM ATED EPA HOURAN D COST BURDEN SU MMARY a

Annual B ur de n Ho ur s Annual Lab or Cos t Annual Cap it al / Star tup Cos t Annual O&M

Cos t Total Annual C os t Re giste rin g wit h E

PA E le ctronic Do cum

ent Re ceivi

ng Sy st em 8,883.00 $412,971.48 $159,360.00 $0.00 $572,331.48 Co mp lia nce wit h Id entity Pro of in g Re qui re me nts 11,759.51 $543,427.53 $0. 00 $1,212.00 $544,639.53 Approval o f St ate/L

ocal E le ctr onic Do cum

ent Re cei vi ng Sy ste m Applic ations 1,128.00 $52,124.88 $0. 00 $0.00 $52,124.88 Total 21, 770. 51 $1, 008, 523. 89 $159, 360. 00 $1, 212. 00 $1, 169, 095. 89 3- ye arTotal 65,313 $3, 025, 572 $478, 080 $3, 636 $3, 507, 288 aE xh ib it in cl udes ro unding erro r.

### 50

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### A
- 1 Appendix A List of North American Industry Classification Syste m (NAICS) Codes Associated with Industries Most Likely Affected by the Information Collection Requirements Covered in this ICR 11 Agriculture, Forestry, Fishing and Hunting 111 Crop Production 112 Animal Production 113 Forestry and Logging 114 Fishin g, Hunting and Trapping 115 Support Activities for Agriculture and Forestry 21 Mining 211 Oil and Gas Extraction 212 Mining (except Oil and Gas) 213 Support Activities for Mining 22 Utilities 221 Utilities 23 Construction 233 Building, Developing , and General Contracting 234 Heavy Construction 235 Special Trade Contractors 31 Manufacturing 311 Food Manufacturing 312 Beverage and Tobacco Product Manufacturing 313 Textile Mills 314 Textile Product Mills 315 Apparel Manufacturing 316 Leathe r and Allied Product Manufacturing 321 Wood Product Manufacturing 322 Paper Manufacturing 323 Printing and Related Support Activities 324 Petroleum and Coal Products Manufacturing 325 Chemical Manufacturing 326 Plastics and Rubber Products Manufacturing 327 Nonmetallic Mineral Product Manufacturing 331 Primary Metal Manufacturing 332 Fabricated Metal Product Manufacturing 333 Machinery Manufacturing 334 Com

puter and Electronic Product Manufacturing 335 Electrical Equipment, Appliance, and Com p onent Manufacturing 336 Transportation Equipment Manufacturing 337 Furniture and Related Product Manufacturing 339 Miscellaneous Manufacturing 42 Wholesale Trade 421 Wholesale Trade, Durable Goods 422 Wholesale Trade, Nondurable Goods 44
- 45 Retail Trade 441 Motor Vehicle and Parts Dealers 442 Furniture and Home Furnishings Stores 443 Electronics and Appliance Stores 444 Building Material and Garden Equipment and Supplies Dealers 445 Food and Beverage Stores 446 Health and Personal Care Stores 447 Gasoline Stations 448 Clothing and Clothing Accessories Stores 451 Sporting Goods, Hobby, Book, and Music Stores 452 General Merchandise Stores 453 Miscellaneous Store Retailers 454 Nonstore Retailers 48
- 49 Transportation and Warehousing 481 Air Transportation 482 Rail Transportation 483 Water Transportation 484 Truck Transportation 485 Transit and Ground Passenger Transportation 486 Pipeline Transportation 487 Scenic and Sightseeing Transportation 488 Support Activities for Transport ation 491 Postal Service 492 Couriers and Messengers 493 Warehousing and Storage 51 Information 511 Publishing Industries 512 Motion Picture and Sound Recording Industries 513 Broadcasting and Telecommunications 514 Information Services and Data Processing Services 52 Finance and Insurance 521 Monetary Authorities Central Bank 522 Credit Intermediation and Related Activities 523 Securities, Commodity Contracts, and Other Financial Investments and Related Activities 524 Insurance Carriers and Related Activities 525 Funds, Trusts, and Other Financial Vehicles

### A
- 2

53 Real Estate and Rental and Leasing 531 Real Estate 532 Rental and Leasing Services 533 Lessors of Nonfinancial Intangible Assets (except Copyrighted Works) 54 Professional, Sci entific, and Technical Services 541 Professional, Scientific, and Technical Services 55 Management of Companies and Enterprises 551 Management of Companies and Enterprises 56 Administrative and Support and Waste Management and Remediation Services 5 61 Administrative and Support Services 562 Waste Management and Remediation Services 61 Educational Services 611 Educational Services 62 Health Care and Social Assistance 621 Ambulatory Health Care Services 622 Hospitals 623 Nursing and Residentia l Care Facilities 624 Social Assistance 71 Arts, Entertainment, and Recreation 711 Performing Arts, Spectator Sports, and Related Industries 712 Museums, Historical Sites, and Similar Institutions 713 Amusement, Gambling, and Recreation Industries 72 Accommodation and Food Services 721 Accommodation 722 Food Services and Drinking Places 81 Other Services (except Public Administration) 811 Repair and Maintenance 812 Personal and Laundry Services 813 Religious, Grantmaking, Civic, Professional, and Similar 814 Private Households 92 Public Administration 921 Executive, Legislative, and Other General Government Support 922 Justice, Public Order, and Safety Activities 923 Administration of H uman Resource Programs 924 Administration of Env ironmental Quality Programs 925 Administration of Housing Programs, Urban Planning, and C 926 Administration of Economic Programs 927 Space Research and Technology 928 National Security and International Affair

### B
- 1 Appendix B Methodology for Estima ting the Annual Number of Fa cility Employees Expected to Register and Comply with the Identity Proofing Requirements of EPA’s Electronic Document Receiving System during the Three - Year Period Covered by the ICR This appendix describes the methodology for estimating the annual number of facility employees expected to register and compl y with the identity proofing requirements of EPA’s electronic document receiving s ys tem (i.e., CDX) during the three
- ye ar period covered b y the ICR. 1. Annual Number of New E mployee Registrants This section describes the methodology for estimating the annual number of facility employees expected to register with CDX during the three
- year period covered b y the ICR (i.e., new emplo ye e registrants)
. Section 1 .1 provides an over view of the methodology , Section 1. 2 provides a detailed discussion of the methodology , and Section 1. 3 presents the results. 1.1. Overview In estimating the annual number of facility employees expected to register with CDX, EPA first compiled historical i nformation on the cumulative number of employee registrants for ye ars 2007 through 2010. We then estimated the annual number of new employee registrants for the three
- ye ar period covered b y the IC R (i.e., ye ars 2011 through 2013) based on anal ys is of new registrant growth rates. 1.2. Detailed Discussion EPA took the following steps to carry out the methodology
. A. Compile historical information on cumulative number of employee registrant s . EPA referred to CDX in order to compile historical information on the cumulative number of registrants for ye ars 2007 through 2010.
Year Cumulative Number of

Employee Registrants 2007 70,669 2008 91,761 2009 120,653 2010 150,820

### B
- 2

B. Estimate cumulative number of employee registrants for years 2011 through 2013 (i.e., the three

-

year period covered in the ICR )

. W e estimated the cumulative number of registrants for ye ars 2011 through 2013 b y using the following equation: Cumulative Numbe r of Registrants f or Year Y 

### = Registrants Y

- 1 

### + ([3 x (Registrants Y

- 1 – Registrants Y

- 2 )] + [2 x (Registrants Y

- 2 – Registrants Y

- 3 )] + [Registrants Y

- 3

- Registrants Y

- 4 ]) / 6 

### The table below shows the results of using the above equation for ye ars 2011 through 2013:

Year Calculation Cumulative Number of Employee Registrants a 2011 150,820 + ([3 x ( 150,820
- 120,653 )] + [2 x ( 120,653
- 91,761 )] + [ 91,761
- 70,669 ]) / 6 179 , 050 2012 179,050 + ([3 x ( 179,050
- 150,820 )] + [2 x ( 150,820
- 120,653 )] + [ 120,653
- 91,761 ]) / 6 208 , 036 2013 208,036 + ([3 x ( 208 , 036
- 179 , 050 )] + [2 x ( 179 , 050
- 150,820 )] + [ 150,820
- 120,653 ]) / 6 236 , 967 a Includes rounding error.


### C. Estimate total number of new employee registrants for years 2011 through 2013

. W e estimated the total number of new registrants for years 2011 through 2013 by using the following equation: Number

New Registrants For Year Y 

### = Registrants Y – Registrants Y

- 1 

### The table below shows the results of using the above equation for ye ars 2011 through 2013:

Year Calculation Number of New Employee Registrants a 2011 179,050
- 150,820 28,230 2012 208,036
- 179,050 28986 2013 236,967
- 208,036 28931 Total for Years 2011 through 2013 86,147 a Includes rounding error.


### D. Estimate annual number of new employee registrants over the three

- year period covered in the ICR

. We assumed that one third of the total three
- ye ar projection will register with CDX in each ye ar of the ICR. That is, we assumed that 28 , 716 new registrants (i.e., 86,147 ÷ 3) will register with CDX each ye ar.

### B
- 3

E. Estimate annual number of new registrants by type of ownership (i.e. , private sector vs. State/Local) and remove Federal government employee registrants from this analysis. We referred to data published by the Bureau of Labor Stat istics on the number of employees in the U.S. T hese data indicate that 83.16 percent of U.S. employees work for the private sector, 14.64 percent of employees work for States/Locals, and 2.20 percent of employees work for the Federal g overnment. We applied these percentages to the annual number of new employee registrants in Step D . We then exc luded Federal Government employees from the analy sis because they are exempt from I CR requirements
. 1.3. Results Exhibit B
- 1 presents information on the average annual number of facility employees expected to register with CDX
. Exhibit B - 1

Annual Number of Facility Employees Expected to Register with EPA ’s CDX during the Three - Year Period Covered by the ICR
Respondent Universe Average Annual Number of New Employee Registrant s a Private Sector 23 , 881 States/Locals 4 , 205 Total 28 , 086

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


### 2. Annual Number of S ubscriber Agreements This section describes the methodology for estimating the annual number of subscriber agreements submitted to EPA to co mply with the identity

proofing requirements of CDX during the three
- ye ar period covered b y the IC R. Section 2.1 provides an overv iew of the methodology , Section 2. 2 provides a detailed discussion of the methodology , and Section 2. 3 presents the results. 2.1. Overview In estimating the annual number of subscriber agreements submitted to CDX , EPA first compiled information on the number of ESAs for years 200 7 through 2010. We then estimated the annual number of subscriber agreements (i.e., paper subscriber agreements, electronic subscriber agreements (ESAs), reuse (consolidated) ESAs, and third party ESAs) for the three
ye ar period covered by

the I CR (i.e., years 2011 through 2013) based on analy sis of growth rates and implementation rates.

### B
- 4

2.2. Detailed Discus sion EPA took the following steps to carry out the methodology
. Non
- Electronic Subscriber Agreements A. Compile historical information on number of non -ESAs (i.e., paper subscriber agreements) , by CROMERR data flow

. Some of the CROMERR data flows do not s upport ESAs. For purposes of this anal ys is, the subscriber agreements associated with these data flows are categorized as “non
- ESAs” or paper subscriber agreements
. To estimate the number of paper subscriber agreements for years 2011 through 2013, we referred to CDX in order to compile historical information on the number of non - ESAs , by CROMERR data flow, for years 200 7 through 2010.

CROMERR Data Flow Number of Paper Subscriber Agreem ents 2007 2008 2009 2010 e - GGRT 552 1,072 1,924 4,442 EM TS 157 288 550 1,319 SDWIS 235 225 200 196 UCMR2 3,525 3,276 2,919 1,861

Total 4 , 469 4 , 861 5 , 593 7 , 818


### B. Estimate total number of paper subscriber agreements, by CROMERR data flow, for years 2011 through 2013 (i.e., the three

- year period covered in the ICR )

. W e estimated the total number of paper subscriber agreements, by CROMERR data flow, for years 2011 through 2013 b y using the following equations: For year 2011: Total Numbe r of Subscriber Agreements f or Year Y 

### = Subscriber Agreements Y

- 1 + ([3 x (Subs criber Agreements Y

- 1 - Subscriber Agreements Y

- 2 )] + [2 x (Subscriber Agreements Y

- 2 - Subscriber Agreements Y

- 3 ] + [ Subscriber Agreements Y

- 4 ]) / 6 

### For year s 2012 and 2013 : Total Numbe r of Subscriber Agreements f or Year Y 

### = ([3 x Subscriber Agreements Y

- 1 ] + [2 x Subscriber Agreements Y

- 2 ] + [ Subscriber Agreements Y

- 3 ]) / 6

### B
- 5

The table below shows the estimated number of paper subscriber agreements , by CROMERR data flow, for years 2011 through 2013. Note that, for certain data flows, we revised the estimated number of subscriber agreements based on available program information.
CROMERR

Data Flow Number of Paper Subscriber Agreem ents a 2011 2012 2013 e - GGRT 6,072 4,837 5,183 EM TS 1,813 1,319 b 1,484 SDWIS 184 196 b 192 UCMR2 1,172 1,693 1,547

Total 9 ,240 8,045 8,405
a Table includes rounding error
. b Estimate is based on available program information, not on use of equation. 

### Electronic Subscriber Agreements C. Compile historical information on number of ESAs, by CROMERR data flow

. EPA referred to C DX in order to compile historical information on the number of ESAs , by CROMERR data flow, for years 2008 through 2010.

CROMERR Data Flow N umber of ESAs a 2008 2009 2010 OTAQ 387 367 610 ODS - CBI 35 23 13 TRIMEWeb 10,043 11,779 8,994 RMPeSubmit 694 5,483 1,976 eTSCA 19 34 293 eTSCA - PDS b eIUR 94 145 32 eIUR2 b Total 11,272 17,831 11,918
a Table includes rounding error
. b New CROMERR data flow for years 2011 through 2013
. Data flow is included in this table to facilitate discussion in subsequent steps. 

### D. Estimate number of ESAs, by CROMERR data flow, for years 2011 through 2013 (i.e., the three

-

year period covered in the ICR )

. W e estimated the number of ESAs, by CROMERR data flow, for years 2011 through 2013 by using the following equat ion: Numbe r of ESA s f or Year Y 

### = ([3 x Registrants Y

- 1 ] + [2 x Registrants Y

- 2 ] + [Registrants Y

- 3 ]) / 6

### B
- 6

The table below shows the estimated number of ESAs, by CROMERR data flow, for ye ars 2011 through 2013. Note that, for certain data flows, we revised the estimated number of ESAs based on available program information.

CROMERR Data Flow N umber of ESAs a 2011 2012 2013 OTAQ 1,71 9 c 1,124 1,23 6 ODS - CBI 20 18 18 TRIMEWeb 10,097 10,010 9,870 RMPeSubmit 2,931 3,038 2,826 eTSCA 161 184 194 eTSCA - P DS 5,000 c 2,500 c 2,500 c eIUR b 80 eIUR2 968 c 240 c 225 c

Total 20,97 6 17,114 16,86 8
a Table includes rounding error
. b eIUR was discontinued and replaced by eIUR2. c Estimate is based on available program information, not on use of equation.


### E. Estimate number of reuse (consolidated) ESAs, by CROMERR data flow, for years 2011 through 2013

. We estimated the number of reuse (consolidated) ESAs , for participating data flows , by

appl yi ng implementation rates provided by CDX to the number of ESAs ob tained in Step D . The implementation rates are presented in the table below:

CROMERR Data Flow Imple mentation Rates for Reuse (Consolidated) ESAs 2011 2012 2013 OTAQ 100% ODS - CBI TRIMEWeb 50% 50% RMPeSubmit eTSCA 50% eTSCA - PDS 50% 50% 50% eIUR eIUR2 70 .7 % 50% 50%

### B
- 7

The table below shows the estimated number of reuse (consolidated) ESAs, by CROMERR data flow, for years 2011 through 2013.

CROMERR Data Flow Number of Reuse (Consolidated) ESAs a 2011 2012 2013 OTAQ 1,71 9 ODS - C BI TRIMEWeb 5 , 005 4 , 935 RMPeSubmit eTSCA 97 eTSCA - PDS 2,500 1,250 1,250 eIUR eIUR2 684 120 112

Total 4,90 3 6, 3 7 5 6, 394
a Table includes rounding error
. 

### F. Estimate number of third party ESAs, by CROMERR data flow, for years 2011 through 2013. We estimated the number of third party ESAs for participating data flows by applying implementation rates provided by CDX to the number of ESAs obtained in Step D . Specificall y, we estimated that third party ESAs are 10 percent of the estimated ES As for the following data flows :

 For ye ar 2011: eTSCA
- PDS and eIUR2
.

 For ye ars 2012 and 2013: eTSCA
- PDS , eIUR2 , and TRIMEWeb
. The table below shows the estimated number of third party ESAs, b y CROMERR data flow, for ye ars 2011 through 2013.

CROMERR Data Flow Number of Third Party ESAs a 2011 2012 2013 OTAQ ODS - CBI TRIMEWeb 1,001 987 RMPeSubmit eTSCA eTSCA - PDS 500 250 250 eIUR eIUR2 97 24 22

Total 597 1,275 1,259
a Table includes rounding error
.

### B
- 8

All Subscriber Agreement s G. Estimate annual number of subscriber agreements for the three

- year period covered by the ICR

. Using the number of subscriber agreements obtained in Steps B , D, E, and F , w e estimated the annual number of subscriber agreements for the three
- year period covered b y the ICR. To do this, we averaged the number of subscriber agreements for ye ars 2011 through 2013. The results are presented in the table below.
Type of Subscriber Agreement Number of Subscriber Agreem ents Year 2011 Year 2012 Year 2013 Avera ge Non
- ESA s (Paper Subscriber A greements) 9,240 8,045 8,405 8,563 ESA s 20,976 17,114 16,868 18,319 Reuse (Consolidated) ESA s 4,903 6,375 6,394 5,891 Third Party ESA s 597 1,275 1,259 1,044


### H. Estimate number of subscriber agreements by type of ownership (i.e., private sector vs. State/Local) and remove subscriber agreements from Federal government employee registrants from this analysis. We referred to data published by the Bureau of Labor Stat istics on the number of employees in the U.S. T hese data in dicate that 83.16 percent of U.S. employees work for the private sector, 14.64 percent of employees work for States/L ocals, and 2.20 percent of employees work for the Federal g overnment. We applied these percentages to the number of ESAs o btained in Step G . We then excluded the subscriber agreements from Federal Government employees from the analy sis because Federal government employees are exempt from I CR requirements
. 2.3. Results Exhibit B
- 2 presents information on the average annual number of subscriber agreements to be submitted to CDX during the three
- ye ar period covered b y this ICR
.

### B
- 9 Exhibit B - 2 Annual Number Subscriber Agreements to be Submitted to EPA ’s CDX during the Three - Year Period Covered by the ICR Type of Subscriber Agreement Average Annual Number of Subscriber Agreements a Private Sector Non
- ESA s (Paper Subscriber Agreements) 7,121 ESAs 15,234 Reuse (Consolidated) ESAs 4,898 Third Party ESAs 868 Subtotal 28,122 States/Locals Non
- ESA s (Paper Subscriber Agreements) 1,254 ESAs 2,682 Reuse (Consolidated) ESAs 862 Third Party ESAs 153 Subtotal 4,950 All (Private Sector and States/Locals) Non
- ESA s (Paper Subscriber Agreements) 8,375 ESAs 17,916 Reuse (Consolidated) ESAs 5,761 Third Party ESAs 1,020 Total 33,072
a Federal government employees are exempt from ICR requirements. As a result, their subscriber agreements are not included in the exhibit.

### B
- 10

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### C
- 1 Appendix C Methodology for Estimating the Annu al Number of Facility Employees Expected to Register and Comply with Identity Proofing Requirements of State/Local Electronic Document Receiving System s d uring the Three - Year Period Covered by the ICR This appendix describes the methodology for estimating the annual number of facility employees expected to register and compl y with identity proofing requirements of State/L ocal electronic document receiving systems during the three
- ye ar period covered by the ICR . Section 1 provides an overview of the methodology , Section 2 provides a det ailed discussion of the methodology , and Section 3 presents the results
. 1. Overview EPA estimated the number of facilities reporting to State/L ocal electronic document receiving sy stems by

first identifying States with existing and new sy stems and compili ng them into a table (referred to as the “Master Table” in this analy sis). 30 , 31 

### We then referred to survey data compiled b y EPA in 2002 from States that estimated the number of facilities subject to their respective receiving s ys tems by environmental progr am. We updated these State estimates to current (2011) levels based on anal ys is of respondent universe growth rates in EPA program ICRs. We then extrapolated the updated survey data to the States in the Master Table to estimate their number of facilities . The extrapolation was performed b y first finding the total number of commercial establishments in each State based on U.S. Census data, comparing the number of establishments in the survey States to the States in the Master Table, and using a scaling fa ctor to extrapolate the number of facilities in the survey States to the States in the Master Table based on their respective number of commercial establishments. We performed this extrapolation by environmental program for all States in the Master Table. Finally , we estimated the number of employees based on the number of facilities.

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

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

### C
- 2

2. Detailed Discussion EPA took the following steps to carry out the methodology
. Find the Number of States with Receiving Sy stems , by State Environmental Program A. Identify States with existing and new electronic document receiving systems. T o identify States with existing electronic document receiving sy stems , we referred to EPA’s “ Status of C ROMERR Applications from States” Web site (http://www.epa.gov/cromerr/application_status.html ) , which contains data current as of December 2010. To identify

States with new electronic document receiving s ys tems, we referred to EPA’s CROMERR universe tracking spreadshe et, which contains data current as of S eptember 14, 2010. For purposes of this anal ys is, “ new electronic document receiving sy stems” are those that meet the following criteria, as indicated in the spreadsheet:

 Name of the s ys tem is available;

 Sy stem is subject to CROMERR; and

 Sy stem is categorized as “planned.” B. Estimate the numb er of existing and new State receiving systems, by environmental program. Existing and new receiving s ys tems were categorized into State environmental programs based on the statut e associated with the authorized program (e.g., Clean Air Act (CAA), Clean Water Act (CWA)). Attachment C
- 1 presents a table of the States with existing and new receiving s ys tems, by State environmental program. This table is called the “Master Table” in this memorandum. Estimate the Number of Facilities, by State Environmental Program C. Estimate number of facilities by State environmental program, based on CROMERR cost

benefit analysis (CBA) survey data. To obtain information on the number of facilities by State environmental program, we referred to “Table V
- 2. Existing State Receiving Sy stems” of Cross

-

Media Electronic Reporting and Records Rule (C ROMERRR) Cost Benefit Analysis

- Final ; dated November 17, 2004. This table contains information on the number of facilities associated with State receiving s ys tems reported in a survey conducted b y EPA during the summer of 2002. Attachment C
- 2 shows the number of facilities by

State environmental program based on CBA survey data. D. Update CBA’s facility estim ate for each State environmental program, based on ICR respondent data. The data on number of facilities developed under Step C are based on 2002 data. In order to bring these numbers to the present (2011), we took the following steps:

 Referred to the In formation Collection Request, Review, and Approval S ys tem (I CRAS) to obtain data on annual number of respondents in the IC Rs listed in Attachment C
- 3. For each I CR, we obtained respondent universe estimates for at

### C
- 3 least two different years (e.g., 2002 and 2008) to enable us to estimate the annual percent change in the universe.

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

 Multiplied the annual percent change b y 9 to estimate percent change over the 2002
- 2011 period.

 Applied th e 2002
- 2011 percent change to facility estimates in order to update the number of facilities for each environmental program. Attachment C
- 4 shows the I CR data used to u pdate the CBA’s facility

estimates, by

State environmental program. Extrapolate Update d State Survey Data on Number of Facilities to All States in Master Table E. Develop a scaling factor for use in extrapolation. We referred to U.S. Census Bureau data on number of establishments by employ ment size for States. 32 

### Based on these data, which are presented in Attachment C
- 5, we obtained the following information for each environmental program:

 Number of commercial establishments in the survey States for which respondent data were available; and

 Number of commercial establishments in States in the Master Table with existing and/or planned receiving sy stems. We then used these data to derive a scaling factor to be used in Step F. This scaling factor was derived using the following equation: Scaling Factor = Number of establishments in States in Master Table Number of establishments in survey States F. Extrapolate the CBA’s updated facility estimates to States with existing and new receiving systems. In deriving the total number of facilities in all States in the Master Table, we first estim ated the total number of facilities associated with each environmental program. To do this, we multiplied the updated survey data (Step D) b y the corresponding scaling factor derived in Step E. This gave us the total number of facilities reporting to the receiving sy stems of States in the Master Table, b y environmental program. We then add ed up the total number of facilities in States in the Master Table across all environmental programs. G. Estimate annual number of facilities subject to the ICR requirements . In estimating the annual number of facilities subject to the ICR requirements, we made the following assumptions:

 Existing receiving s ys tems: For purposes of this anal ys is, w e assume that existing sy stems have been in operation since 2005
. EPA es timates that 30 percent of

32 U.S. Census Bureau, “Number of Firms, Number of Establishments, Employment, and Annual Payroll by Enterprise Employment Size for the United States and States, Totals: 2008,” February 15, 2011. Available online at: http://www.census.gov/econ/susb/, last accessed on February 23, 2011. These are the latest Statistics of U.S. Businesses (SUSB) annual data.

### C
- 4 facilities began to use the receiving s ys tem in the first year (i.e., 2005) and 10 percent in each subsequent year .

 New receiving s ys tems: We assume that one third of facilities will begin reporting in each ye ar of the three
- ye ar period covered b y the ICR . In each ye ar of the ICR, EPA estimates that 30 percent of facilities will begin to use the receiving system in the first ye ar and 10 percent in each subsequent year. The above implementation rates for use of an electronic re ceiving sy stem were taken from the CBA (Exhibit 2
- 5). H. Estimate average annual number of facilities subject to the ICR requirements, by employment size . In estimating the average annual number of facilities by employ ment size, we referred to the U.S. C ensus Bureau data presented in Attachment C
- 5. Based on these data, in the U.S. , 70 percent of establishments have less than 20 employees and 30 percent of establishments have 20 or more emplo yees. We applied these percentages to the annual number of fac ilities in Step G. Once we estimated the annual number of facilities for each ye ar from 2011 through 2013 (i.e., the three
- ye ar period covered b y the ICR), we obtained the average over three ye ars. I. Estimate average annual number of facility employees sub

ject to the ICR requirements
. In estimating the average annual number of facility employees , we assumed that small firm facilities have three employee s and that medium/large firm facilities have six employees. These estimates were taken from the CBA (Sec tion 2.3.3, “Facilities;” page 26). J. Estimate average annual number of f acility employees subject to the ICR requirements by type of ownership (i.e., private sector vs. State/Local) and remove Federal government facilities from this analysis. Inestim ating the average annual number of facility employees by

ty pe of ownership , we referred to data published by the Bureau of Labor Statistics on the number of employees in the U.S. 33 

### These data indicate that 83.16 percent of U.S. employees work for the private sector, 14.64 percent of employees work for States/L ocals, and 2.20 percent of employees work for the Federal government. We applied these percentages to the annual number of facility employees in Step I . We then excluded Federal government employees from the anal ys is because they are exempt from ICR requirements. Attachments C
- 6 and C
- 7 present details on the application of the above m ethodology to existing and new receiving s ys tems, respectivel y.

33 Bureau of Labor Statistics; Quarterly Census of Employment and Wages; Number of Employees (US Total, All Industries, All Establishment Sizes); 2009 (Annual). Available online at: http://data.bls.gov/pdq/querytool.jsp?survey=en , last accessed on April 27 , 2011.

### C
- 5

3. Results Exhibit C
- 1 present s information on the av erage annual number of facility employees expected to register with existing and new State/Local receiving s ys tems. Exhibit C - 1 Average Annual Number of Fa cility Employees Expected to Register with Existing and New State/Local Receiving Sy stems d uring t he Three - Year Period Covered by the ICR

Type of Firm Average Annual Number of Facility Employees Existing Receiving Systems New Receiving System All Receiving System s (i.e., Existing and New) Private Sector Small Firms 8,714 3,156 11,870 Medium
- Size and Large Firms 7,469 2,704 10,173

Subtotal 16,183 5,860 22,043 States/Locals Small Firms 1,534 556 2,090 Medium
- Size and Large Firms 1,315 476 1,791

Subtotal 2,849 1,032 3,881 All (Private Sector and States/Locals) Small Firms 10,248 3,712 13,960 Medium
- Size and Large Firms 8,784 3,180 11,964 Total 19,032 6,892 25,924

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

### C
- 6

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

State Existing System s New System s Air Water Waste Air Water Waste Alabama X X Alaska X X X American Samoa Arizona X Arkansas X X California X Colorado X X Connecticut X Delaware X X X District of Columbia Florida X X X Georgia X X X Guam Hawaii X X Idaho X Illinois X X Indiana X X X Iowa X X Kansas X X X Kentucky X X X Louisiana X Maine X X Maryland X X Massachusetts X X X X Michigan X X X Minnesota X X X Mississippi X X X Missouri b X X X X Montana X X X Nebraska X Nevada X X New Hampshire X X New Jersey X X X

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

State Existing System s New System s Air Water Waste Air Water Waste New Mexic o X New York X X X North Carolina X X X North Dakota X Northern Mariana Islands Ohio X X X Oklahoma X X X Oregon X X Pennsylvania X X X Puerto Rico Rhode Island X X South Carolina X X South Dakota X X X X Tennessee X X Texas X X X U.S. Virgin Islands Utah X Vermont X X X Virginia X Washington X X X West Virginia X Wisconsin X X X Wyo ming X X X Sources: (1) U.S. Environmental Protection Agency (USEPA), “Status of CROMERR Applications from States” Web site

( http://www.epa.gov/cromerr/application_status.html ), d ata current as of December 2010. (3) U.S. Environmental Protection Agency (USEPA), “Master Sprdsht with EPA sprdsht” worksheet of the “Summary CROMERR Universe 20100914 Draft V1.xls” Excel file, dated September 14, 2010.

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- 9 Attachment C - 2 Number of Facilities Associated with Existing State Electr onic Document Receiving Systems in the CROMERR Cost - Benefit Analysis Survey, by State Environmental Program (Data Current as of Summer 2002)

State Air Water Waste, USTs, Emergency Planning

Air (CEM) Air

Permits Air

(NEI) Air

Title V E mi ssions Emission

Reports (Non - Title V) Air

Quality PTO

Applications Asbestos

Notification EDMR Drink ing/ Ground Water Wastewater UIC HW Annual Report UST Risk

Management Florida 3 New Jersey 12 1,500 1,000 New Mexico 200 North Dak ota 250 Ohio 200 780 2,400 780 5,700 1,550 480 500 Pennsylvania 125 6,000 Wisconsin 5,200 22 600
a For purposes of this analysis, data for Wisconsin’s “Consolidated (air, haz waste)” program was divided among the “Air” and “HW Annual Report” categories. Specifically, 90 percent of the facilities were allocated to the “Air” category and the remaining 10 percent were allocated to the “HW Annual Report” cat egory. This allocation was based on Ohio’s data and availab le information on the number of hazardous waste handlers that reported to the 2007 Hazardous Waste Report. Source: U.S. Environmental Protection Agency (USEPA), “Table V
- 2. Existing State Receiving Systems” of Cross
- Media Electronic Reporting and Records Rule (CROMERRR) Cost Benefit Analysis, Final; November 17, 2004. Acronym s CEM Continuous Emissions Monitoring EDMR Electronic Discharge Monitoring Report HW Hazardous Waste NEI National Emission Inventory PT O Permit to Operate UIC Underground Injection Control UST Underground Storage Tank

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- 10 Attachment C - 3 List of ICRs Used in Analysis, by Environmental Program
ICR Numbers ICR Name Air 916.12 916.13 Consolidated Emissions Reporting (NEI) 1587.06 1587.07 State Operating Permit Regulations 111.10 111.12 N ESHAP for Asbestos 1088.10 1088.12 NSPS for Industrial
- Commercial
- Institutional Steam Generating Units Water 229.15 229.16 NPDES and Sewage Sludge Monitoring Reports (DMR) 1842.04 1842.05 Notice of Intent for Storm Water Discharges Associated with Cons truction Activity Under

a NPDES General Permit 2.11 2.14 National Pretreatment Program 270.42 270.43 Public Water System Supervision Program Waste, USTs, Emergency Planning 261.14 Notification of Regulated Waste Activity 976.11 2007 Hazardous Waste Re port 976.14 Notification of Regulated Waste Activity and 2009 Hazardous Waste Report 1380.07 1380.08 Underground Storage Tanks: Technical and Financial Requirements, and State Program

Approval Procedures Source: U.S. Environmental Protection Agency (US EPA), Information Collection Request, Review, and Approval System (ICRAS) . Data obtained on February 22
- 28, 2011.

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- 11 Attachment C - 4a ICR Data Used to Update Number of Facilities Obtained from CROMERR CBA Air Programs
Consolidate d Emissions Re porting (NEI)

EPA ICR Numbe r 916. 12 EPA ICR Numbe r

916. 13 2006 2009 Industry Re spondents and State s/T er ri tori es /Local A genc ies 2, 038 1, 863 -8 .6 % 3 -2 .9 % 0. 06 -0 .2 % -1 .1 % State Operating Permit Re gulations

EPA ICR Numbe r 1587. 06 EPA ICR Numbe r

1587. 07 2004 2007 Per mitting Authorities and Source s Subject to Pe rmi tti ng unde r 40 CFR P art 70 17, 738 16, 930 -4 .6 % 3 -1 .5 % 0. 57 -0 .9 % NESHAP f or Asbestos

EPA ICR Numbe r 111. 10 EPA ICR Numbe r

111. 12 2003 2009 Re spondents 9, 848 9, 432 -4 .2 % 6 -0 .7 % 0. 32 -0 .2 % NSPS for In dustrial-Comme rc ial-I nstitutional Stea m G enerating Units

EPA ICR Numbe r 1088. 10 EPA ICR Numbe r

1088. 12 2003 2010 Re spondents 1, 230 1, 500 22. 0% 7 3. 1% 0. 05 0. 2% Total Numbe r Re spondents for All ICRs 29, 725 Number of Yea rs Weight

Weight

Weight

Weight Ave rage Annual Percent Change for Environme ntal Program Weighted Annual Percent Change in Number of Re spondents

Weighted Annual Percent Change in Number of Re spondents

Weighted Annual Percent Change in Number of Re spondents

Weighted Annual Percent Change in Number of Re spondents Annual Number of Re spondents Percent Change in Numbe r of Re spondents Annual Pe rce nt Change i n Number of Re spondents Percent Change in Numbe r of Re spondents Annual Pe rce nt Change i n Number of Re spondents

Re spondent Universe Re spondent Universe

Re spondent Universe

Re spondent Universe Annual Number of Re spondents

Annual Number of Re spondents Annual Number of Re spondents

Percent Change in Numbe r of Re spondents Annual Pe rce nt Change i n Number of Re spondents

Percent Change in Numbe r of Re spondents Annual Pe rce nt Change i n Number of Re spondents Number of Yea rs

Number of Yea rs

Number of Yea rs

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- 12 Attachment C - 4b ICR Data Used to Update Number of Facilities Obtained from CROMERR CBA Water Programs
NP DES and Sewage Sludge Monitoring Reports (DMR)

EPA ICR Numbe r 229. 15 EPA ICR Numbe r

229. 16 2001 2005 Pe rmi tte es and State s/T ri bes/Ter ri tori es 86, 135 81, 988 -4 .8 % 4 -1 .2 % 0. 19 -0 .2 % -3 .4% Notice of Inte nt for

St orm Water Discharges Associate d with Construction Activity Under a NPDES Gene ral Permit

EPA ICR Numbe r 1842. 04 EPA ICR Numbe r

1842. 05 2003 2006 Pe rmi tte es and State s/T ri bes/Ter ri tori es 201, 259 157, 546 -2 1. 7% 3 -7 .2 % 0. 37 -2 .7 % Na tional Pre tre atme nt Program

EPA ICR Numbe r 2.11 EPA ICR Numbe r

2. 14 2004 2007 Industrial users (IU s), PO TWs , and State s 28, 285 24, 740 -1 2. 5% 3 -4 .2 % 0. 06 -0 .3 % Public Water Syste m Su per vision Program

EPA ICR Numbe r 270. 42 EPA ICR Numbe r

270. 43 2004 2008 Ex ist ingP WS s, Pr ima ry A ge nc ies, and Laboratori es 161, 682 158, 113 -2 .2 % 4 -0 .6 % 0. 37 -0 .2 % Total N umbe r Re spondents for All ICRs 422, 387 Weig hte d Annual Percent Change in Number of Re spondents Percent Change in Number

of Re spondents Number

of Yea rs

Number of Yea rs Weig ht Weig hte d Annual Percent Change in Number of Re spondents

Number of Yea rs Weig ht Weig hte d Annual Percent Change in Number of Re spondents

Number of Yea rs Weig ht Re spondent Unive rs e Annual Number of Respondents

Re spondent Unive rs e Annual Number of Respondents Re spondent Unive rs e Annual Number of Respondents

Re spondent Unive rs e Annual Number of Respondents

Annual Percent Change in Number of Re spondents Average Annual Percent Change for Environmental Program Percent Change in Number

of Re spondents Annual Percent Change in Number of Re spondents

Percent Change in Number

of Re spondents Annual Percent Change in Number of Re spondents

Percent Change in Number

of Re spondents Annual Percent Change in Number of Re spondents Weig ht Weig hte d Annual Percent Change in Number of Re spondents

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- 13 Attachment C - 4c ICR Data Used to Update Number of Facilities Obtained from CROMERR CBA

Waste, USTs, Emergency Planning Programs
Notif ication ofRegulated Waste Activity

EPA ICR Number 261.14 EPA ICR Numbe r

976. 14 2003 2009 Initial and Subse quent Notifications under RCRA Se cti on 3010; 40 CF R P art 273, S ubpart C; and 40 CF R P art 279 31, 125 46,186 48. 4% 6 8. 1% 0. 16 1.3% -0 .2 % Hazardous Waste Repor

t

EPA ICR Number 976.11 EPA ICR Numbe r

976. 14 2003 2009 Re spondents to the Hazardous Waste Re port 10, 178 8, 542 -1 6. 1% 6 -2 .7 % 0. 03 -0 .1 % Un de rground Storage Tanks: Technical and Financial Requirements, and State Program Approval Procedures

EPA ICR Number 1360. 07 EPA ICR Numbe r

1360. 08 2004 2008 Pri vate and Gove rnments 254, 705 237,578 -6 .7 % 4 -1 .7 % 0. 81 -1 .4% Total Numbe r Re sponde nts for All ICRs 292,306 Weighted Annual Pe rce nt Change in Number of Respondents

Numbe r of Years Annual Pe rce nt

Change i n Number of Respondents Weight Weighted Annual Pe rce nt Change in Number of Respondents

Numbe r of Years Annual Pe rce nt

Change i n Number of Respondents Weight Weighted Annual Pe rce nt Change in Number of Respondents Re spondent Universe Annual Numbe r of Re spondents Re spondent Universe Annual Numbe r of Re spondents

Re spondent Universe Annual Numbe r of Re spondents Per cent Change in Number of Respondents Ave rage Annual Percent Change f or Environmental Program

Per cent Change in Number of Respondents

Per cent Change in Number of Respondents Numbe r

of Years Annual Pe rce nt

Change i n Number of Respondents Weight

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- 14 Attachment C - 5 Number of Establishments (Faciliti es) by Employment Size, 2008 STATE Less than 20 Employees 20 or More Employees Total United States 5,349,024 2,252,145 7,601,169 Alabama 68,196 35,679 103,875 Alaska 14,718 5,216 19,934 Arizona 94,436 45,645 140,081 Arkansas 45,595 21,073 66,668 Cal ifornia 638,535 240,490 879,025 Colorado 115,392 41,292 156,684 Connecticut 65,132 27,465 92,597 Delaware 16,475 8,699 25,174 District of Columbia 12,554 8,527 21,081 Florida 379,105 127,922 507,027 Georgia 156,600 70,993 227,593 Hawaii 22,584 10,32 0 32,904 Idaho 34,635 11,611 46,246 Illinois 226,845 95,097 321,942 Indiana 98,736 51,365 150,101 Iowa 56,204 26,149 82,353 Kansas 52,079 24,017 76,096 Kentucky 60,675 31,912 92,587 Louisiana 70,230 33,777 104,007 Maine 30,944 10,811 41,755 Maryland 96,416 42,191 138,607 Massachusetts 123,065 51,225 174,290 Michigan 160,153 69,157 229,310 Minnesota 104,812 44,033 148,845 Mississippi 40,811 20,107 60,918 Missouri 103,753 48,687 152,440 Montana 29,247 8,071 37,318 Nebraska 36,457 15,695 52,152 Nevada 41,596 20,230 61,826 New Hampshire 27,520 11,386 38,906 New Jersey 179,269 59,171 238,440 New Mexico 31,797 14,403 46,200 New York 399,765 118,867 518,632 North Carolina 153,708 71,450 225,158 North Dakota 15,221 6,337 21,558 Ohio 171,583 9 2,178 263,761 Oklahoma 63,606 27,776 91,382

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- 15 Attachment C - 5 (continued) Number of Establishments (Facilities) by Employment Size, 2008
STATE Less than 20 Employees 20 or More Employees Total Oregon 81,131 30,419 111,550 Pennsylvania 205,633 97,482 303,115 Rhode Island 22,096 7,663 29,759 South Carolina 72,043 34,635 106,678 South Dakota 18,839 6,850 25,689 Tennessee 86,991 49,594 136,585 Texa s 346,045 176,291 522,336 Utah 52,244 19,189 71,433 Vermont 16,829 5,292 22,121 Virginia 134,612 63,104 197,716 Washington 133,446 48,761 182,207 West Virginia 26,362 13,279 39,641 Wisconsin 98,516 45,565 144,081 Wyo ming 15,788 4,997 20,785 Source: U.S. Census Bureau, “Number of Firms, Number of Establishments, Employment, and Annual Payroll by Enterprise Employment Size for the United States and States, Totals: 2008,” February 15, 2011. Available online at: http://www.census.gov/econ/susb/, las t accessed on February 23, 2011. These are the latest Statistics of U.S. Businesses (SUSB) annual data.

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- 16 Attachment C - 6 Application of Methodology to Existing Receiving Systems

Envi ronme ntal P rogram State s wi th Facil ity Data i n CBA To tal N umbe r of

Fa cilities in CBA Ave rage Annual

Pe rce nt Change f or Envi ronme ntal Program 2002- 2011 P erce nt

Change f or Envi ronme ntal Program Upda te d Total

Numbe r of Fa cilities in CBA Air NJ, NM , OH , PA, WI 17, 197 -1 .1 % -9 .9 % 15, 494 Wat er FL, ND , OH , WI 7, 525 -3 .4% -3 0. 6% 5, 222 Was te , US Ts , Eme rge ncy Pl anni ng NJ, OH, WI 2, 580 -0 .2 % -1 .8 % 2, 534

Envi ronme ntal P rogram Numbe r of Establ ishm ent s for State s wi th Facil ity Data i n CBA Numbe r of

Establ ishm ent s for State s wi th Ex isting Re ce iving Syste ms Sc al ing Factor
Air 995, 597 5, 067, 196 5. 09 Wat er 936, 427 6, 879, 540 7. 35 Was te , US Ts , Eme rge ncy Pl anni ng 646, 282 4, 181, 706 6. 47

Envi ronme ntal P rogram Upda te d Total N umbe r of Facil ti esi n CBA Scal ing Factor Total Numbe r o f Fa ci lit iesf or State s with Ex is ti ng Re ce iving Syste ms Air 15, 494 5. 09 78, 864 Wat er 5, 222 7. 35 38, 382 Was te , US Ts , Eme rge ncy Pl anni ng 2, 534 6. 47 16, 395 133, 641 Total N umbe r of Faci lities fo r Al l Envi ronme ntal Programs

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- 17 Attachment C - 6 (continued) Application of Methodology to Existin g Receiving Systems

Ye ar Numbe r o f Fa ci lit ies 2005 40, 092 2006 9, 355 2007 8, 419 2008 7, 578 2009 6, 820 Le gend: 2010 6, 138 2011 5, 524 2012 4, 972 2013 4, 474 2014 4, 027 2015 3, 624 2016 3, 262 2017 2, 936 2018 2, 642 2019 2, 378 2020 2, 140

Yea r 1 Yea r 2 Ye ar 3 Smal l Fi rms 3, 867 3, 480 3, 132 3, 493 10, 479 Me di um-Size and Large Fi rms 1, 657 1, 492 1, 342 1, 497 8, 982 To tal 5, 524 4, 972 4, 474 4, 990 19, 461 Type o f Fir m Num ber ofF aci lit ies pe r Y ea r Ave rage A nnual Nu mbe r of Fa ci lities Ave rage Annua l

Nu mbe r of Fa ci lity Empl oye es Yea rs C ove re d in the I CR

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- 18 Attachment C - 7 Application of Methodology to New Receiving System s

Envi ronme ntal P rogram State s wi th F aci lity Data i n CBA Total N umbe r of

Faci lit iesi n CBA Ave rage Annual

Perce nt Change f or Envi ronme ntal Program 2002- 2011 P ercent

Cha nge for Envi ronme ntal Program Upda ted Total

Nu mbe r of Faci lit iesi n CBA Air NJ, NM , OH , PA, WI 17, 197 -1 .1 % -9 .9 % 15, 494 Wate r FL, ND , OH , WI 7, 525 -3 .4% -3 0. 6% 5, 222 Was te , US Ts, Eme rgency Pl an ning NJ, OH, WI 2, 580 -0 .2 % -1 .8 % 2, 534

Envi ronme ntal P rogram Num be r of Es tabl ish me nts for State s wi th F aci lity Data i n CBA Nu mbe r of

Es tabl ish me nts for State s wi th New Re ce iv ing Syste ms Scal in g Factor
Air 995, 597 330, 587 0. 33 Wate r 936, 427 1, 499, 092 1. 60 Was te , US Ts, Eme rgency Pl an ning 646, 282 323, 158 0. 5

Envi ronme ntal P rogram Upda te d Total Numbe r of Fa cilties in CBA Scal ing Factor Total Number of Fa cilities for State s wi th New Re ce iv ing Systems Air 15, 494 0. 33 5, 113 Wate r 5, 222 1. 60 8, 355 Was te , US Ts, Eme rgency Pl an ning 2, 534 0. 50 1, 267 14, 735 4, 912

Yea r 1 Yea r 2 Yea r 3 Ye ar 1 1, 474 344 309 Ye ar 2 0 1, 474 344 Ye ar 3 0 0 1, 474

Total 1, 474 1, 818 2, 127

Yea r 1 Yea r 2 Yea r 3 Smal l Fir ms 1, 032 1, 273 1, 489 1, 265 3, 795 Me dium-Size and Large Fi rms 442 545 638 542 3, 252 Total 1, 474 1, 818 2, 127 1, 807 7, 047 Annua l Numbe r ofF aci lities that W ill Come Onl ine To tal N umbe r of Faci lit iesf or Al l Envi ronme ntal Programs

Ty pe o f Firm Numbe r ofF aci lit iespe r Y ea r Yea r System W ill Come Onl in e Numbe r ofF aci lit iespe r Y ea r

Ave rage Annual Number of Fa cilities Ave rage Annual

Nu mbe r of Faci lity Empl oye es