*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

1 RIN2070-AK02_EO12866_Lead_MinorAmendments_FRM_EA_2015-10-20.docx

2 Draft document as submitted for review under EO 12866

3

4

5

6

7 Economic Analysis for the Lead-Based Paint Program 

8 Minor Amendments Final Rule

9

10

11 RIN 2070-AK02

12

13

14

15 EO 12866 REVIEW DRAFT

16

17

18

19

20 October 2015

21

22

23

24

25

26

27

28

29 Economic and Policy Analysis Branch

30 Chemistry, Economics, and Sustainable Strategies Division

31 Office of Pollution Prevention, and Toxics

32 U.S. Environmental Protection Agency

33 1200 Pennsylvania Avenue

34 Washington, DC 20460
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

35 Acknowledgement

36 Analytical and draft preparation support was provided by Abt Associates Inc. under EPA Contract No. 

37 EP-W-08-0100.

38

39
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

i

40 Table of Contents

41 Executive Summary.................................................................................................................................ES-1

42 1. Introduction ......................................................................................................................................1-1

43 1.1 Regulatory and Programmatic Background .............................................................................1-1

44 1.2 Summary of Analytic Approach ..............................................................................................1-2

45 1.3 Organization of This Report.....................................................................................................1-3

46 2. Affected Entities................................................................................................................................2-1

47 3. Industry Cost Savings ......................................................................................................................3-1

48 3.1 Abatement Multi-jurisdiction Registration Fee Amendment...................................................3-1

49 3.2 Renovator Refresher Training Course Amendment.................................................................3-2

50 3.3 RRP Training Provider Notification Amendment..................................................................3-16

51 3.4 Total Industry Cost Savings...................................................................................................3-29

52 3.5 Other Industry Costs ..............................................................................................................3-30

53 4. Agency Costs.....................................................................................................................................4-1

54 5. Social Cost Savings...........................................................................................................................5-1

55 6. Small Entity Impact Analysis .........................................................................................................6-1

56 7. Other Impact Analyses.....................................................................................................................7-1

57 7.1 Paperwork Reduction Act ........................................................................................................7-1

58 7.2 Unfunded Mandates Reform Act .............................................................................................7-8

59 7.3 Executive Order 13132 – Federalism.......................................................................................7-8

60 7.4 Executive Order 13175 – Consultation and Coordination with Indian Tribal Governments...7-8

61 7.5 Executive Order 13045 - Children’s Health.............................................................................7-9

62 7.6 Executive Order 13211 – Energy Supply, Distribution, or Use...............................................7-9

63 7.7 National Technology Transfer and Advancement Act.............................................................7-9

64 7.8 Executive Order 12898 – Environmental Justice.....................................................................7-9

65 8. References .........................................................................................................................................8-1

66 Training Courses Tuition Data ..........................................................................................A-1

67 Rule Amendment Options - Derivation of Estimates for the Number of Individuals 

68 Seeking Recertification........................................................................................................ B-1

69 Detailed Exhibits of Total Renovator Training Costs......................................................C-1

70
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

ii

71 List of Exhibits

72

73 Exhibit ES-1: Regulatory Options............................................................................................................. ES-2

74 Exhibit ES-2: Expected Number of Renovators Seeking Training Each Year (rounded to the nearest 

75 thousand)............................................................................................................................... ES-3

76 Exhibit ES-3: Summary of Total Costs and Cost Savings for Refresher Training Regulatory Options Over a 

77 Ten Year Period, 2016 through 2025 (millions of 2014$).................................................... ES-6

78 Exhibit ES-4: Pre- and Post-training Notification Cost Savings for Regulatory Options Over a Ten Year 

79 Period, 2016 through 2025 (2014$) ...................................................................................... ES-8

80 Exhibit ES-5: Total and Annualized Social Cost Savings of Minor Amendments Rule Over 10 Years 

81 (millions of 2014$).............................................................................................................. ES-10

82 Exhibit ES-6: Itemized Total and Annualized Cost Savings of the Final Rule Over 10 Years (thousands of 

83 2014$) ................................................................................................................................. ES-11

84 Exhibit 1-1: Assumed Duration of Existing RRP Training Courses............................................................. 1-2

85 Exhibit 2-1: Lead-based Paint Activities Individuals and Firms Applying for (Re)certification and Training 

86 Providers Applying for (Re)accreditation from 2011-2013..................................................... 2-1

87 Exhibit 2-2: Renovator Initial Certifications under the RRP Program Rule from 2009-10 through 2014 and 

88 Expiring Certifications Under the Extension Rule................................................................... 2-2

89 Exhibit 2-3: Steady State Average Number of Renovator Certifications from 2016 through 2025 ............. 2-2

90 Exhibit 3-1: Annual Multi-jurisdiction Registration Fees for Individuals and Firms Applying for 

91 (Re)certification, and Training Providers Applying for (Re)accreditation .............................. 3-1

92 Exhibit 3-2: Ten Year Net Present Value and Annualized Cost Savings for Individuals and Firms Applying 

93 for (Re)certification, and Training Providers Applying for (Re)accreditation (2014$)........... 3-2

94 Exhibit 3-3: Regulatory Options................................................................................................................... 3-3

95 Exhibit 3-4: Refresher Training Requirements Under Regulatory Options................................................. 3-4

96 Exhibit 3-5: Procedure to Estimate In-person Classroom Refresher Training Course Tuition (2014$)....... 3-6

97 Exhibit 3-6: Summary of Refresher Course Tuitions (2014$)...................................................................... 3-7

98 Exhibit 3-7: Average Renovator Travel Cost (2014$).................................................................................. 3-8

99 Exhibit 3-8: Summary of Refresher Training Costs (2014$)........................................................................ 3-9

100 Exhibit 3-9: Expected Number of Renovators Seeking Refresher Training Each Year............................. 3-12

101 Exhibit 3-10: Summary of Total Costs and Cost Savings for Refresher Training Regulatory Options Over a 

102 Ten Year Period, 2016 through 2025 (2014$) ...................................................................... 3-14

103 Exhibit 3-11: Pre-training Notification Cost Savings for Regulatory Options Over a Ten Year Period, 2016 

104 through 2025 (2014$)............................................................................................................. 3-18

105 Exhibit 3-12: Initial and Recurring Burden Associated with Submitting Notifications via the CDX........ 3-20

106 Exhibit 3-13: Net Present Value and Annualized Costs Over a Ten Year Period of Initial and Recurring 

107 Notification Submissions via the CDX (2014$) .................................................................... 3-21

108 Exhibit 3-14: Post-training Notification Cost Savings for Regulatory Options Over a Ten Year Period, 2016 

109 through 2025 (2014$)............................................................................................................. 3-24

110 Exhibit 3-15: Pre- and Post-training Notification Cost Savings for Regulatory Options Over a Ten Year 

111 Period, 2016 through 2025 (2014$) ....................................................................................... 3-27

112 Exhibit 3-16: Total and Annualized Industry Cost Savings Over 10 Years (2014$).................................. 3-29
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

iii

113 Exhibit 4-1: EPA Wage Rate ........................................................................................................................ 4-1

114 Exhibit 4-2: Ten Year Net Present Value and Annualized Cost to EPA Under the Final Rule (2014$)..... 4-2

115 Exhibit 5-1: Total and Annualized Social Cost Savings Over 10 Years (2014$)......................................... 5-1

116 Exhibit 7-1: Incremental RRP Training Provider Burden Hours per Activity for the Final Rule,Scenario I7-3

117 Exhibit 7-2: Incremental RRP Training Provider Total Burden Hours for the Final Rule, Scenario I......... 7-4

118 Exhibit 7-3: Loaded RRP Training Provider Wage Rates............................................................................ 7-5

119 Exhibit 7-4: RPP Incremental Training Provider Cost for the Final Rule, Scenario I (2014$) .................... 7-6

120 Exhibit 7-5: Annual Respondent Burden and Cost Summary ...................................................................... 7-7

121 Exhibit A-1: Sample of Renovation (Re)certification Training Courses..................................................... A-1

122 Exhibit B-1: Option 2, Scenario I- 50% of Active Stock Chooses Online Refresher Training ................... B-3

123 Exhibit B-2: Option 2, Scenario - 50% of Active Stock Chooses Online Refresher Training .................... B-6

124 Exhibit C-1: Baseline- Ten Year Net Present Value and Annualized 

125 Costs for Renovators Seeking Recertification (2014$)........................................................... C-1

126 Exhibit C-2: Option 1- Ten Year Net Present Value and Annualized Costs for Renovators Seeking 

127 Recertification (2014$) ........................................................................................................... C-2

128 Exhibit C-3: Option 2- Ten Year Net Present Value and Annualized Costs for Renovators Seeking 

129 Recertification (2014$) ........................................................................................................... C-3

130 Exhibit C-4: Option 3(a)- Ten Year Net Present Value and Annualized Costs for Renovators Seeking 

131 Recertification (2014$) ........................................................................................................... C-4

132 Exhibit C-5: Option 3(b)- Ten Year Net Present Value and Annualized Costs for Renovators Seeking 

133 Recertification (2014$) ........................................................................................................... C-5

134 Exhibit C-6: Option 4(a)- Ten Year Net Present Value and Annualized Costs for Renovators Seeking 

135 Recertification (2014$) ........................................................................................................... C-6

136 Exhibit C-7: Option 4(b)- Ten Year Net Present Value and Annualized Costs for Renovators Seeking 

137 Recertification (2014$) ........................................................................................................... C-7

138 Exhibit C-8: Option 4(c)- Ten Year Net Present Value and Annualized Costs for Renovators Seeking 

139 Recertification (2014$) ........................................................................................................... C-8

140 Exhibit C-9: Option 4(d)- Ten Year Net Present Value and Annualized Costs for Renovators Seeking 

141 Recertification (2014$) ........................................................................................................... C-9

142
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

ES-1

143 Executive Summary

144 The United States Environmental Protection Agency (EPA) is promulgating amendments to the regulations 

145 for Lead-based Paint Poisoning Prevention in Certain Residential Structures, codified at 40 CFR part 745

146 under the authority of TSCA §402(a) and §402(c). This report estimates the changes in compliance costs 

147 due to the final rule that amends the Lead-Based Paint (LBP) Activities rule for lead abatement and the 

148 Renovation, Repair and Painting (RRP) rule. These amendments eliminate EPA’s multi-jurisdiction 

149 registration fee in the abatement program, amend the hands-on requirement for the renovator refresher 

150 training course, and revise the notification requirements for training providers.

151 The rule removes the multi-jurisdiction registration fee that individuals and firms pay for certification or 

152 recertification and that training programs pay for accreditation or reaccreditation in the lead abatement 

153 program. Under the existing regulations, there is a $35 fee for each additional EPA-administered 

154 jurisdiction for which organizations apply to perform LBP abatement activities or to provide lead abatement 

155 training. In a typical year, individuals, firms, and training providers apply to perform lead-based paint 

156 activities or provide training in a total of 431 additional EPA-administered jurisdictions. Removing the $35 

157 fee will result in total estimated cost savings of approximately $15,000 per year to these entities. 

158 The rule also modifies the refresher training course requirements for renovators under the RRP rule. Under 

159 the existing rule, both the initial and refresher renovator training courses must include a classroom 

160 component (which may be taken in person or online) and a hands-on component (which must be taken in 

161 person). 

Existing RRP Rule Refresher Training Requirements 

Training Component Existing Rule

Classroom component Can be taken either in person or online

Hands-on component Must be taken in person

Recertification is valid for 5 years

162

163 This report analyzes four primary options to amend the refresher training course requirements so that 

164 hands-on training would not be required every time the training is taken. This would allow renovators to 

165 take some or all of their refresher training solely by taking an online training course (although they can

166 always choose to take training in person with a hands-on component). The four options analyzed are:

167 Option 1: Refresher training without a hands-on component valid for 5 years;

168 Option 2: Refresher training without a hands-on component valid for 5 years, refresher training 

169 with a hands-on component required every other recertification period;

170 Option 3: Refresher training without a hands-on component valid for a shorter time frame; and

171 Option 4: Refresher training without a hands-on component valid for a shorter time frame;

172 refresher training with a hands-on component required at repeating intervals.

173 Options 3 and 4 include sub-options that vary both the length of time for which refresher training without a 

174 hands-on component is valid and the number of training cycles in which hands-on training must be taken. 

175 These training options and alternatives, as well as the other amendments that affect costs, are summarized 

176 in Exhibit ES-1. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

ES-2

Exhibit ES-1: Regulatory Options

Option

Period for which 

refresher training 

with hands-on 

component is valid

Period for which 

refresher training 

without hands-on 

component is valid

Number of training 

cycles in which 

hands-on training 

must be taken

Multijurisdiction 

registration 

fee removed

Changes to 

notification 

requirements for 

training providers

Existing rule 5 years Not allowed 1  

Option 1 5 years 5 years 0  

Option 2 5 years 5 years 2  

Option 3(a) 5 years 2 years 0  

Option 3(b) 5 years 3 years 0  

Option 4(a) 5 years 2 years 2  

Option 4(b) 5 years 2 years 3  

Option 4(c)1 5 years 3 years 2  

Option 4(d) 5 years 3 years 3  

1 177 The final rule is Option 4(c)

178

179 Renovator training and certification became mandatory in 2010 and a large number of renovators were 

180 trained that year, with smaller numbers becoming trained in each subsequent year. By 2015, approximately 

181 500,000 renovators were certified. In the baseline, a steady state average of 100,000 renovators (one fifth of 

182 the 500,000 certified renovators) are assumed to be trained each year over the ten year time frame 

183 considered in the analysis. There are 30,000 trained renovators assumed to exit the industry each year, and 

184 they are replaced by new entrants to the industry who take the 8-hour initial training course. Thus, a steady 

185 state average of 70,000 renovators are estimated to take the refresher training course each year. 

186 Amending the refresher training course hands-on requirement is expected to make online renovator 

187 refresher training more attractive to training providers and renovators. However, as previously noted,

188 renovators could still choose to take training in person with the hands-on component. This analysis 

189 considers three different scenarios for the number of renovators that will choose to take the online refresher 

190 training course if the hands-on requirement is removed. Scenarios I, II, and III assume that 50 percent, 75

191 percent, and 90 percent of the active stock of renovators, respectively, will choose to take the online 

192 refresher training course when eligible. (Note that under Options 2 and 4, renovators who choose to take the 

193 refresher training course without a hands-on component when eligible will have to take hands-on training in 

194 a subsequent training cycle.) This means that 50 percent, 25 percent, or 10 percent of the active stock of 

195 renovators will always choose to take their refresher training in person. Exhibit ES-2 presents the number of 

196 renovators seeking initial and refresher training each year, rounded to the nearest thousand. 

197 Note that the scenario percentages correspond to the percent of the active stock of renovators choosing the 

198 online refresher training course, not the percent of recertifications attained via the online refresher training 

199 course relative to all recertifications per year. Because online training requires more frequent 

200 recertifications for Options 3 and 4, online training is associated with a greater number of recertifications 

201 per year than in-person training for those options, even when equal numbers of renovators are in the online 

202 and in-person training cohorts (see Section 3.2.5 and Appendix B for a more detailed explanation of this 

203 effect). As a result, the number of total annual trainings increases from 100,000 per year in the baseline to 

204 between 110,000 and 118,000 per year under the final rule (Option 4(c)), because the certification from 

205 taking an online class is valid for 3 years, compared to 5 years for an in-person class.

206
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

ES-3

Exhibit ES-2: Expected Number of Renovators Seeking Training Each Year (rounded to the nearest thousand)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Option

Initial 

Training

due to 

Turnover

Renovator Always

Chooses In-person

Refresher Training

Renovator Chooses Online Refresher Training Total 

Refresher 

Training

Total 

Annual 

Training

Cycle with 

Hands-on 

Cycle w/out 

Hands-on Sub-Total

Option 1 30,000 35,000 - 35,000 35,000 70,000 100,000

Option 2 30,000 35,000 14,000 21,000 35,000 70,000 100,000

Option 3

(a) 2 Yr. Interval 30,000 35,000 - 88,000 88,000 123,000 153,000

(b) 3 Yr. Interval 30,000 35,000 - 58,000 58,000 93,000 123,000

Option 4

(a) 2 Yr. Interval & 2 Cycles 30,000 35,000 24,000 27,000 51,000 86,000 116,000

(b) 2 Yr. Interval & 3 Cycles 30,000 35,000 18,000 43,000 61,000 96,000 126,000

(c) 3 Yr. Interval & 2 Cycles1 30,000 35,000 20,000 25,000 45,000 80,000 110,000

(d) 3 Yr. Interval & 3 Cycles 30,000 35,000 13,000 36,000 49,000 84,000 114,000

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Option

Initial 

Training

due to 

Turnover

Renovator Always

Chooses In-person

Refresher Training

Renovator Chooses Online Refresher Training Total 

Refresher 

Training

Total 

Annual 

Training

Cycle with 

Hands-on 

Cycle w/out 

Hands-on Sub-Total

Option 1 30,000 18,000 - 53,000 53,000 70,000 100,000

Option 2 30,000 18,000 22,000 31,000 53,000 70,000 100,000

Option 3

(a) 2 Yr. Interval 30,000 18,000 - 131,000 131,000 149,000 179,000

(b) 3 Yr. Interval 30,000 18,000 - 88,000 88,000 105,000 135,000

Option 4

(a) 2 Yr. Interval & 2 Cycles 30,000 18,000 36,000 41,000 77,000 95,000 125,000

(b) 2 Yr. Interval & 3 Cycles 30,000 18,000 27,000 65,000 91,000 109,000 139,000

(c) 3 Yr. Interval & 2 Cycles1 30,000 18,000 30,000 37,000 67,000 85,000 115,000

(d) 3 Yr. Interval & 3 Cycles 30,000 18,000 20,000 54,000 74,000 92,000 122,000
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

ES-4

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Option

Initial 

Training

due to 

Turnover

Renovator Always

Chooses In-person

Refresher Training

Renovator Chooses Online Refresher Training Total 

Refresher 

Training

Total 

Annual 

Training

Cycle with 

Hands-on 

Cycle w/out 

Hands-on Sub-Total

Option 1 30,000 7,000 - 63,000 63,000 70,000 100,000

Option 2 30,000 7,000 26,000 37,000 63,000 70,000 100,000

Option 3

(a) 2 Yr. Interval 30,000 7,000 - 158,000 158,000 165,000 195,000

(b) 3 Yr. Interval 30,000 7,000 - 105,000 105,000 112,000 142,000

Option 4

(a) 2 Yr. Interval & 2 Cycles 30,000 7,000 43,000 49,000 93,000 100,000 130,000

(b) 2 Yr. Interval & 3 Cycles 30,000 7,000 32,000 78,000 110,000 117,000 147,000

(c) 3 Yr. Interval & 2 Cycles1 30,000 7,000 36,000 44,000 81,000 88,000 118,000

(d) 3 Yr. Interval & 3 Cycles 30,000 7,000 24,000 65,000 89,000 96,000 126,000

1The final rule is Option 4(c).
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

ES-5

207

Refresher Training under Existing Rule and Amended Final Rule – Option 4(c)

Requirements Existing Rule Minor Amendments Final Rule

Hands-on component Required every training cycle Required every other training cycle 

Renovator certification period 5 years 5 years for training with hands-on component

3 years for training without hands-on component

Pre-training notifications Required for all classes Not required for online classes

Post-training notifications Within 10 business days Monthly for online classes

208

209 Allowing refresher training to be taught without the hands-on component will reduce average costs for 

210 training providers by $45 per student. Some or all of these savings may be passed on to the students in the 

211 form of lower tuition. Refresher training without a hands-on component can be taken entirely online. 

212 Because renovators taking a course entirely online will avoid the time and associated expenses needed to 

213 travel to a training site, they will save an average of $144 per person.

214 Depending on the regulatory option and the scenario, amending the hands-on training requirement is 

215 estimated to reduce the total costs of recertification by between approximately $0.6 million and $12.2

216 million per year (see Exhibit ES-3). The revisions to the hands-on requirements in the final rule 

217 (Option 4(c)) reduces costs by $1.9 million to $3.4 million per year. Costs decrease despite the fact that the 

218 total number of renovators receiving training each year increases (due to the shorter certification period for 

219 online training), because training without a hands-on component is less expensive, particularly if it is taken 

220 online (see Exhibit ES-3).
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

ES-6

Exhibit ES-3: Summary of Total Costs and Cost Savings for Refresher Training Regulatory Options Over a 

Ten Year Period, 2016 through 2025 (millions of 2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Option

Cost of Regulatory Options Cost Savings of Regulatory Options

Net Present Value Annualized 

Costs 

(3% and 7%)

Net Present Value Annualized Cost

Savings

(3% and 7%) 3% 7% 3% 7%

Option 1 $97.6 $80.3 $11.4 $69.9 $57.6 $8.2 

Option 2 $134.3 $110.6 $15.7 $33.2 $27.3 $3.9 

Option 3

(a) 2 Yr. Interval $152.1 $125.3 $17.8 $15.4 $12.7 $1.8 

(b) 3 Yr. Interval $129.3 $106.5 $15.2 $38.2 $31.4 $4.5 

Option 4

(a) 2 Yr. Interval & 2 Cycles $162.7 $134.0 $19.1 $4.8 $4.0 $0.6 

(b) 2 Yr. Interval & 3 Cycles $159.9 $131.7 $18.7 $7.6 $6.2 $0.9 

(c) 3 Yr. Interval & 2 Cycles1 $151.4 $124.6 $17.7 $16.1 $13.3 $1.9 

(d) 3 Yr. Interval & 3 Cycles $143.9 $118.5 $16.9 $23.6 $19.4 $2.8 

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Option

Cost of Regulatory Options Cost Savings of Regulatory Options

Net Present Value Annualized 

Costs 

(3% and 7%)

Net Present Value Annualized Cost

Savings

(3% and 7%) 3% 7% 3% 7%

Option 1 $76.1 $62.7 $8.9 $91.4 $75.2 $10.7 

Option 2 $117.7 $96.9 $13.8 $49.8 $41.0 $5.8 

Option 3

(a) 2 Yr. Interval $144.4 $118.9 $16.9 $23.1 $19.0 $2.7 

(b) 3 Yr. Interval $110.3 $90.8 $12.9 $57.2 $47.1 $6.7 

Option 4

(a) 2 Yr. Interval & 2 Cycles $160.3 $132.0 $18.8 $7.2 $5.9 $0.8 

(b) 2 Yr. Interval & 3 Cycles $156.1 $128.6 $18.3 $11.4 $9.4 $1.3 

(c) 3 Yr. Interval & 2 Cycles1 $143.3 $118.0 $16.8 $24.2 $19.9 $2.8 

(d) 3 Yr. Interval & 3 Cycles $132.1 $108.7 $15.5 $35.4 $29.2 $4.2 

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Option

Cost of Regulatory Options Cost Savings of Regulatory Options

Net Present Value Annualized 

Costs 

(3% and 7%)

Net Present Value Annualized Cost

Savings

(3% and 7%) 3% 7% 3% 7%

Option 1 $63.3 $52.1 $7.4 $104.2 $85.8 $12.2 

Option 2 $107.8 $88.7 $12.6 $59.7 $49.2 $7.0 

Option 3

(a) 2 Yr. Interval $139.8 $115.1 $16.4 $27.7 $22.8 $3.2 

(b) 3 Yr. Interval $98.8 $81.4 $11.6 $68.7 $56.6 $8.1 

Option 4

(a) 2 Yr. Interval & 2 Cycles $158.9 $130.8 $18.6 $8.6 $7.1 $1.0 

(b) 2 Yr. Interval & 3 Cycles $153.9 $126.7 $18.0 $13.6 $11.2 $1.6 

(c) 3 Yr. Interval & 2 Cycles1 $138.5 $114.0 $16.2 $29.0 $23.9 $3.4 

(d) 3 Yr. Interval & 3 Cycles $125.0 $102.9 $14.7 $42.5 $35.0 $5.0 

1 The final rule is Option 4(c).

221

222 If the hands-on training requirement is revised, training providers currently accredited for the renovator 

223 refresher training course are expected to offer online refresher training courses. This would involve 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

ES-7

224 licensing an existing online course or developing a new course, and applying to EPA for accreditation to 

225 teach an online course. Training providers that currently offer both in-person courses and courses with an 

226 online component typically charge the same tuition for both types of classes, suggesting that the cost to 

227 offer the classroom component of the training online is similar to the cost of offering it in person. The 

228 tuition that training providers currently charge for in-person courses recoups the costs they incur to provide 

229 those courses, and the tuition for the online class will do the same. The training provider expenses to license 

230 or develop an online course and obtain an additional accreditation are not considered separately in 

231 estimating social costs because doing so would double-count these costs, which are already accounted for in 

232 the tuition that renovators pay. 

233 EPA will incur additional costs because the Agency must review and process applications submitted by 

234 training providers to become accredited for an online course. It is assumed that 400 training providers 

235 would apply for an online refresher training course accreditation as a result of the final rule. Reviewing and 

236 processing the additional accreditation applications is estimated to cost the EPA over $38,000 per year. 

237 Under the existing rule, training providers are required to submit notifications before and after each training 

238 course. The rulemaking changes the notification requirements for online refresher training courses. Training 

239 providers would not be required to submit pre-training notifications for online training courses that have no 

240 in-person component, and would only be required to submit post-training notifications for such courses 

241 once a month via EPA’s Central Data Exchange (CDX), an online data portal. Exhibit ES-4 presents the 

242 annual reduction in pre- and post-training notifications, as well as the total cost savings for each regulatory 

243 option. The number of pre-training notifications is estimated to decrease by 3,000 to 17,000 per year, 

244 depending on the option and scenario. The change in the annual number of post-training notifications 

245 ranges from a reduction of 4,200 to an increase of 3,200, depending on the option and scenario. The final 

246 rule, Option 4(c), is estimated to reduce the total number of pre-notifications by 4,100 to 7,300 per year, and 

to increase the total number of post-training notifications by 1,000 to 2,700 per year.1 247 The change in 

248 notification costs for the final rule ranges from an increase of $22,000 per year to a savings of $23,000 per 

249 year. But without the amendment to post-training notification requirements, training providers would 

250 submit a total of 5,600 additional post-training notifications per year, which would cost $90,000 per year.

251 The rule requires training providers to include the expiration date of the renovator’s certification in the post252 training notification, but the time required to do this is negligible. The rule also clarifies the requirements 

253 for post-training notifications for in-person training courses. Training providers are already required to 

254 submit post-training notifications for renovator training. The rule’s correction to the regulatory text 

255 (clarifying that the notifications must be submitted no later than ten business days following course 

256 completion) may affect the timing of when the notifications are submitted, but not the cost of compliance. 

257 Lastly, the rule adds clarifying language explaining that training providers must follow the regulations. This

258 does not affect the cost of compliance because it does not change any requirements for accredited training 

259 providers, and the analysis assumes that training providers already comply with the regulations. 

 

1 Although the rule allows less frequent post-training notifications for online classes, the annual number of 

notifications increases because more renovators are trained per year than under the baseline due to the shorter 

certification period for training without a hands-on component.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

ES-8

Exhibit ES-4: Pre- and Post-training Notification Cost Savings for Regulatory Options Over a Ten Year Period, 2016 through 2025 (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Option

Reduction in 

Pre-training 

Notifications

Reduction in 

Post-training 

Notifications

Total Reduction 

in Notifications

Annualized 

Cost Savings 

3%

Annualized 

Cost Savings 

7%

NPV of 

Savings 3%

NPV of 

Savings 7%

Option 1 9,660 200 9,860 $54,575 $54,529 $465,537 $382,989

Option 2 5,682 -1,859 3,823 $114 $68 $974 $478

Option 3

(a) 2 Yr. Interval 9,660 200 9,860 $54,575 $54,529 $465,537 $382,989

(b) 3 Yr. Interval 9,660 200 9,860 $54,575 $54,529 $465,537 $382,989

Option 4

(a) 2 Yr. Interval & 2 Cycles 3,019 -3,238 -219 -$36,355 -$36,401 -$310,115 -$255,665

(b) 2 Yr. Interval & 3 Cycles 4,759 -2,337 2,422 -$12,516 -$12,562 -$106,762 -$88,230

(c) 3 Yr. Interval & 2 Cycles1 4,082 -2,687 1,395 -$21,793 -$21,839 -$185,897 -$153,388

(d) 3 Yr. Interval & 3 Cycles 5,979 -1,705 4,274 $4,190 $4,144 $35,743 $29,106

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Option

Reduction in 

Pre-training 

Notifications

Reduction in 

Post-training 

Notifications

Total Reduction 

in Notifications

Annualized 

Cost Savings 

3%

Annualized 

Cost Savings

7%

NPV of 

Savings 3%

NPV of 

Savings 7%

Option 1 14,490 2,700 17,190 $120,701 $120,655 $1,029,605 $847,431

Option 2 8,523 -388 8,135 $39,023 $38,977 $332,875 $273,759

Option 3

(a) 2 Yr. Interval 14,490 2,700 17,190 $120,701 $120,655 $1,029,605 $847,431

(b) 3 Yr. Interval 14,490 2,700 17,190 $120,701 $120,655 $1,029,605 $847,431

Option 4

(a) 2 Yr. Interval & 2 Cycles 4,528 -2,456 2,072 -$15,679 -$15,725 -$133,744 -$110,446

(b) 2 Yr. Interval & 3 Cycles 7,139 -1,105 6,034 $20,064 $20,018 $171,151 $140,599

(c) 3 Yr. Interval & 2 Cycles1 6,123 -1,631 4,492 $6,148 $6,102 $52,445 $42,858

(d) 3 Yr. Interval & 3 Cycles 8,968 -158 8,810 $45,109 $45,063 $384,790 $316,504
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

ES-9

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Option

Reduction in 

Pre-training 

Notifications

Reduction in 

Post-training 

Notifications

Total Reduction 

in Notifications

Annualized 

Cost Savings 

3%

Annualized 

Cost Savings

7%

NPV of 

Savings 3%

NPV of 

Savings 7%

Option 1 17,388 4,200 21,588 $160,388 $160,342 $1,368,144 $1,126,176

Option 2 10,228 494 10,722 $62,351 $62,305 $531,868 $437,605

Option 3

(a) 2 Yr. Interval 17,388 4,200 21,588 $160,388 $160,342 $1,368,144 $1,126,176

(b) 3 Yr. Interval 17,388 4,200 21,588 $160,388 $160,342 $1,368,144 $1,126,176

Option 4

(a) 2 Yr. Interval & 2 Cycles 5,434 -1,988 3,446 -$3,290 -$3,336 -$28,064 -$23,430

(b) 2 Yr. Interval & 3 Cycles 8,566 -366 8,200 $39,585 $39,539 $337,670 $277,706

(c) 3 Yr. Interval & 2 Cycles1 7,347 -997 6,350 $22,908 $22,862 $195,411 $160,574

(d) 3 Yr. Interval & 3 Cycles 10,762 770 11,532 $69,645 $69,599 $594,087 $488,835

1 The final rule is Option 4(c).
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

ES-10

260 Exhibit ES-5 presents estimates for the net present value and annualized social cost savings associated with 

261 the implementation of the regulatory options. Exhibit ES-6 presents the cost savings of the final rule and its 

262 major components. Estimates in both exhibits are discounted at rates of 3 and 7 percent.

Exhibit ES-5: Total and Annualized Social Cost Savings of Minor Amendments 

Rule Over 10 Years (millions of 2014$)1

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Option

Net Present Value Annualized Cost Savings

3% 7% 3% 7%

Option 1 $70.2 $57.8 $8.2 $8.2 

Option 2 $33.0 $27.1 $3.9 $3.9 

Option 3

(a) 2 Yr. Interval $15.6 $12.9 $1.8 $1.8 

(b) 3 Yr. Interval $38.4 $31.6 $4.5 $4.5 

Option 4

(a) 2 Yr. Interval & 2 Cycles $4.3 $3.5 $0.5 $0.5 

(b) 2 Yr. Interval & 3 Cycles $7.3 $6.0 $0.9 $0.9 

(c) 3 Yr. Interval & 2 Cycles2 $15.7 $13.0 $1.8 $1.8 

(d) 3 Yr. Interval & 3 Cycles $23.5 $19.3 $2.8 $2.7 

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Option

Net Present Value Annualized Cost Savings

3% 7% 3% 7%

Option 1 $92.2 $75.9 $10.8 $10.8 

Option 2 $49.9 $41.1 $5.8 $5.8 

Option 3

(a) 2 Yr. Interval $23.9 $19.7 $2.8 $2.8 

(b) 3 Yr. Interval $58.1 $47.8 $6.8 $6.8 

Option 4

(a) 2 Yr. Interval & 2 Cycles $6.9 $5.7 $0.8 $0.8 

(b) 2 Yr. Interval & 3 Cycles $11.3 $9.3 $1.3 $1.3 

(c) 3 Yr. Interval & 2 Cycles2 $24.0 $19.8 $2.8 $2.8 

(d) 3 Yr. Interval & 3 Cycles $35.6 $29.3 $4.2 $4.2 

Scenario III: 90% of Active Stock Always Online Refresher Training

Option Net Present Value Annualized Cost Savings

3% 7% 3% 7%

Option 1 $105.4 $86.8 $12.4 $12.4 

Option 2 $60.1 $49.4 $7.0 $7.0 

Option 3

(a) 2 Yr. Interval $28.8 $23.7 $3.4 $3.4 

(b) 3 Yr. Interval $69.9 $57.5 $8.2 $8.2 

Option 4

(a) 2 Yr. Interval & 2 Cycles $8.4 $6.9 $1.0 $1.0 

(b) 2 Yr. Interval & 3 Cycles $13.8 $11.3 $1.6 $1.6 

(c) 3 Yr. Interval & 2 Cycles2 $29.0 $23.9 $3.4 $3.4 

(d) 3 Yr. Interval & 3 Cycles $42.9 $35.3 $5.0 $5.0 

1 Cost savings reflect the sum of the changes to the multi-jurisdiction fees, online refresher training, and training 

notification requirements.

2 The final rule is Option 4(c). 

263
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

ES-11

Exhibit ES-6: Itemized Total and Annualized Cost Savings of the Final Rule Over 10 

Years (thousands of 2014$)

Amendment Item Net Present Value Annualized Cost Savings

3% 7% 3% 7%

Multi-jurisdiction Registration Fee $129 $106 $15 $15

Option 4(c)- Scenario I

Renovator Refresher Training Course $16,127 $13,279 $1,891 $1,891

Pre-training Notifications $187 $154 $22 $22

Post-training Notifications -$373 -$307 -$44 -$44

Option 4(c)- Scenario II

Renovator Refresher Training Course $24,190 $19,917 $2,836 $2,836

Pre-training Notifications $280 $231 $33 $33

Post-training Notifications -$228 -$188 -$27 -$27

Option 4(c)- Scenario III

Renovator Refresher Training Course $29,028 $23,901 $3,403 $3,403

Pre-training Notifications $336 $277 $39 $39

Post-training Notifications -$141 -$116 -$17 -$17

Agency Cost Savings -$325 -$274 -$38 -$39

Total Cost Savings

Option 4(c)- Scenario I $15,745 $12,958 $1,846 $1,845

Option 4(c)- Scenario II $24,046 $19,792 $2,819 $2,818

Option 4(c)- Scenario III $29,027 $23,894 $3,402 $3,401

264

265 The rule allows training providers (many of which are small businesses) additional flexibility in how they 

266 offer training. Online training is already allowed for the classroom component of both initial and refresher 

267 training, and training providers can choose whether or not to offer it. The amended rule still allows training 

268 providers to choose what type of training to offer because they can continue to offer refresher training with 

269 a hands-on component, begin offering online training without the hands-on component, or offer both types 

270 of training.

271 Training providers that voluntarily choose to start offering online refresher training courses would incur 

272 additional costs for some activities (e.g., applying for a new accreditation), but they would reduce other 

273 expenses (e.g., supplies for the hands-on training component). Because there is no requirement mandating 

274 that training providers offer an online refresher training course, training providers will not choose to offer 

275 online training unless the savings from doing so exceed the costs or if they can recover their costs through 

276 tuition charges, increased volume of business, or other means. Although some accredited training providers 

277 may lose market share to other training providers that are more competitive in the online training market, 

278 that would be an indirect impact not a direct cost of complying with the rule.

279 The rule will reduce compliance costs for renovators. Renovators that take an online refresher training 

280 course without the hands-on training component will save the time and expense needed to travel to a 

281 training facility. And training providers may pass along to renovators some of the savings from offering 

282 classes without the hands-on training component. Renovators who are eligible to take an online refresher 

283 training course without the hands-on training component will have the flexibility to choose whether to 

284 continue taking the class with the hands-on training component or to trade the convenience and savings of 

285 taking an online course without the hands-on training component in exchange for a shorter recertification 

286 period. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

1-1

287 1. Introduction

288 This report assesses the cost savings expected to result from amendments to EPA’s Lead-based Paint (LBP) 

289 Activities rule and to the Renovation, Repair and Painting (RRP) rule. These amendments eliminate EPA’s 

290 multi-jurisdiction registration fee in the abatement program, amend the hands-on requirement from the 

291 renovator refresher training course curriculum, and revise the notification requirements for training 

292 providers. This chapter provides background information on EPA’s LBP regulations, a brief summary of 

293 the methodology used in the analysis, and a description of the organization of the remainder of this report.

294 1.1 Regulatory and Programmatic Background

295 1.1.1 Abatement Multi-jurisdiction Registration Fee

296 In 1996 EPA promulgated final regulations for Lead-based Paint Activities under TSCA §402(a) that 

297 govern LBP inspections, lead hazard screens, risk assessments, and lead abatements in target housing and 

298 child-occupied facilities (61 FR 45778, codified at 40 CFR part 745). On June 9th, 1999, EPA amended the 

299 regulations (64 FR 31092) to include a fee schedule for individuals and firms seeking EPA (re)certification

300 and for training programs seeking EPA (re)accreditation. The fee schedule created a multi-jurisdiction 

301 registration fee of $35 per discipline for each additional EPA-administered jurisdiction (e.g., a state) in 

302 which an individual, firm, or training program applies for (re)certification or (re)accreditation (40 CFR 

303 §745.238 (c)(3)). For purposes of this multi-jurisdiction registration fee, an EPA-administered jurisdiction 

304 is an individual state without an authorized program or all tribes without authorized programs in a given 

305 EPA Region. The EPA-administered jurisdictions for the lead abatement program are: 

306 • States – Alaska, Arizona, Florida, Idaho, Montana, Nevada, New Mexico, New York, South 

307 Carolina, South Dakota, and Wyoming;

308 • U.S. territories – American Samoa, Guam, and the Northern Marianas; and

309 • Tribal lands – tribal lands except the Bois Forte Band, Cherokee Nation, Lower Sioux Nation, and 

310 Upper Sioux Community.

311 All other states, U.S. territories, as well as the Cherokee Nation, Lower Sioux Nation, and Upper Sioux 

312 Community, have EPA-authorized LBP abatement programs (U.S. EPA 2014b).

313 1.1.2 Hands-on Refresher Training for Renovators

314 In 2008, EPA issued a final rule under the authority of §402(c)(3) of TSCA to address LBP hazards created 

315 by RRP activities that disturb LBP in target housing and child-occupied facilities (73 FR 21692). To 

316 become a certified renovator, an individual must successfully complete an appropriate training course

317 accredited by EPA (40 CFR §745.90). Individuals who have not previously been trained must complete an 

318 initial training course lasting a minimum of eight hours, including a minimum of two hours of hands-on 

319 training (see Exhibit 1-1). To maintain renovator certification, an individual must complete a refresher

320 training course from an accredited training provider within five years of completing the initial training 

321 course. The rule requires renovator refresher training courses to last a minimum of four hours (40 CFR 

322 §745.225 (e)(2)) and include a hands-on training component (40 CFR §745.225 (e)(3); see Exhibit 1-1)).

323 EPA manages the RRP program in most areas of the country. However, the states of Alabama, Delaware, 

324 Georgia, Iowa, Kansas, Massachusetts, Mississippi, North Carolina, Oklahoma, Oregon, Rhode Island, 

325 Utah, Washington, and Wisconsin are authorized to administer their own programs in lieu of the federal 

326 program. The final rule applies only in states that do not have authorized programs and therefore the scope 

327 of this analysis includes only those states.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

1-2

Exhibit 1-1: Assumed Duration of Existing RRP Training Courses

Training Components Initial Training Refresher Training

Classroom (Can be taken either in person or online) 6 hours 3 hours

Hands-on (Must be taken in person) 2 hours 1 hour

Total 8 hours 4 hours

Note: Unlike the initial training course, there is no mandatory duration for the hands-on component of the refresher 

training course. The hands-on portion of the initial course must be at least 2 hours, which is 25 percent of the total 8 

hours of training. So for the refresher course, the hands-on component is assumed to be 1 hour, which is 25 percent of 

the 4 hour duration of the refresher course.

328

329 1.2 Summary of Analytic Approach

330 This analysis seeks to quantify, to the extent possible, the changes in social costs due to this rule. The 

331 baseline costs to industry associated with the multi-jurisdiction registration fee include a $35 fee for each 

332 additional EPA-administered jurisdiction for which organizations apply to perform lead-based paint 

333 abatement activities or to provide lead abatement training. The cost savings to industry for eliminating the 

334 fee is the amount in fees that they would no longer be required to pay.

335 Offering refresher courses without a hands-on training component reduces the training providers’ costs, 

336 since they may be able to teach classes with a larger student-to-teacher ratio, they do not have to purchase 

337 hands-on training course supplies (such as EPA-recognized test kits, disposable plastic drop cloths, tape, 

338 electrostatically charged cleaning cloths, disposable wet cleaning wipes, garbage bags, and so on) for each 

339 student in every class, and there may be savings in travel and facility rental costs for traveling training. 

340 Costs to renovators associated with the refresher training course currently include course tuition and the 

341 travel cost to a training site to receive hands-on training. Recertification costs are estimated to decrease 

342 under each of the four regulatory options being considered. For those renovators choosing to take refresher 

343 training online, tuition costs may be reduced and travel costs are reduced or eliminated. 

344 In order to offer online refresher training courses, training providers would license an existing online course 

345 or develop a new course, and apply to EPA for accreditation to teach an online course. Training providers 

346 that currently offer both in-person courses and courses with an online component typically charge the same 

347 tuition for both types of classes, suggesting that the cost to offer the classroom component of the training 

348 online is similar to the cost of offering it in person. The tuition that training providers currently charge for 

349 in-person courses recoups the costs they incur to provide those courses and the tuition for the online class 

350 will do the same. The training provider expenses to license or develop an online course and obtain an 

351 additional accreditation are not considered separately in estimating social costs because doing so would 

352 double-count these costs, which are already accounted for in the tuition that renovators pay. 

353 The analysis also presents estimates for the changes in the notification costs incurred by training providers. 

354 As a simplifying assumption, the analysis simply estimates incremental costs or savings associated with the 

355 change in training provider notifications and adds or subtracts them to or from the other incremental cost 

356 changes to estimate the total incremental savings due to the rule. However, the training costs are estimated 

357 based on current tuition costs, and that tuition is designed to cover the training provider’s costs (including 

358 the existing notification requirements). Thus, the actual incremental costs for the rule are less than the sum 

359 of the estimated training and notification costs because all of the costs or savings associated with the change 

360 in training provider notifications may not be incremental.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

1-3

361 1.3 Organization of This Report

362 The entities affected by the amendments are characterized in Chapter 2. Chapter 3 includes the economic 

363 analysis of cost savings to regulated entities. Agency costs are discussed in Chapter 4. A summary of the 

364 total social cost savings is provided in Chapter 5. Chapter 6 describes the impact on small entities. Several 

365 additional impacts are described in Chapter 7. Cited references are listed in Chapter 8. Appendix A contains 

366 the tuition data for renovator initial and refresher training courses that were used in the analysis. Appendix 

367 B details the methods used to estimate the number of individuals seeking recertification for each of the 

368 regulatory options. Appendix C presents detailed exhibits of renovator training costs for each of the 

369 regulatory options. Note that all dollar values in this analysis are reported in 2014 dollars.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

2-1

370 2. Affected Entities

371 The multi-jurisdiction registration fee amendment may affect individuals, firms, and training providers 

372 regulated by the Lead-based Paint Activities rule, with the exception of non-profit training providers 

373 (which are exempt from the fee). The renovator refresher training course amendment directly affects 

374 individuals who must take a training course to comply with the RRP rule. The number of entities affected 

375 under both amendments is estimated from data in EPA’s Federal Lead-based Paint Program (FLPP) 

376 database (U.S. EPA 2014a).

377 Exhibit 2-1 presents the number of all applications submitted by individuals and firms engaging in lead378 based paint activities, and all training providers offering lead-based paint activities training courses, from 

379 2011 through 2013 (not just those applying to work in additional jurisdictions). Exhibit 2-1 also presents 

380 the number of additional jurisdictions in which individuals and firms are sought (re)certification and 

381 training providers are sought (re)accreditation. 

Exhibit 2-1: Lead-based Paint Activities Individuals and Firms Applying for (Re)certification 

and Training Providers Applying for (Re)accreditation from 2011-2013

Applicant Total Number of Applications Additional Jurisdictions Sought

Individuals 5,127 864

Firms 1,780 403

Training Providers (for-profit) 23 27

382

383 The RRP rule required that, starting in 2010, all regulated renovations disturbing LBP must be performed 

384 by renovators who have taken an initial 8-hour training course (including 2 hours of hands-on training).

385 Renovators must take a 4-hour refresher training course (which currently includes a required hands-on 

386 component) every five years. Exhibit 2-2 presents the number of renovator certifications from 2009-10

387 through 2014. Column 1 of Exhibit 2-2 lists the year the certification was issued, Column 2 lists number 

388 of initial certifications, Column 3 lists the year of expiration, and Column 4 lists the number of expiring 

certifications under EPA’s April 2015 extension rule.

2 389 The number of certifications was highest in 2010 

390 because that was the year that the renovator training requirement became effective.

391 The active stock of certified renovators is assumed to equal the total number of renovators certified from 

392 2009 through 2014, rounded to the nearest hundred thousand (500,000 renovators; see Exhibit 2-2). In the 

393 baseline scenario, the total number of renovators taking initial or refresher training each year is assumed 

394 to equal the average number of renovators certified each year from 2009-10 through 2014, rounded to the 

395 nearest hundred thousand (100,000 renovators; see Exhibit 2-2). Some trained renovators exit the industry 

396 each year, and are replaced by new entrants to the industry who take the 8-hour initial training course. 

397 The number of renovators seeking initial training each year is assumed to equal the average number of 

398 renovators certified in 2014 and 2015, rounded to the nearest ten thousand (30,000; see Exhibit 2-2). 

399 Thus, the number of renovators seeking refresher training each year equals 70,000 (100,000 - 30,000; see 

 

2 On April 8, 2015 EPA published a rule extending the certification dates for renovators with expiring certifications 

(80 FR 20444). Renovators who received certification on or before March 31, 2010 now have until March 31, 

2016, to get recertified. Renovators who received certification between April 1, 2010 and March 31, 2011, have 

one year added to their 5-year certification.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

2-2

400 Exhibit ES-5). These estimates represent a steady state average over the ten year analytical time frame in 

401 the analysis.

Exhibit 2-2: Renovator Initial Certifications under the RRP Program Rule from 2009-10 through 2014 

and Expiring Certifications Under the Extension Rule

Year Certified Number of Initial

Certifications Expiration Year Number of ExpiringCertifications

2009-10 358,932 2015 -

2011 52,180 2016 388,703

2012 39,587 2017 61,996

2013 29,293 2018 29,293

2014 30,848 2019 30,848

Active Stock of Certified Renovators ≈500,000 ≈500,000

Average Certifications per Year ≈100,000

402

403

Exhibit 2-3: Steady State Average Number of Renovator Certifications from 2016 through 2025 

Active Stock of Certified Renovators ≈500,000 

(Re)certifications per Year (= new certifications + recertifications) ≈100,000

New Certifications per Year ≈30,000

Recertifications per Year ≈70,000

404

405 Note that this analysis makes the simplifying assumptions that the active stock of renovators is constant 

406 under the baseline and all of the options, and that the same number of renovators seeks initial certification 

407 and recertification each year. In reality, one could expect that the number of recertifications might follow 

408 a cyclical pattern, at least initially. For example, a large number of renovators sought initial certification 

409 during the first year that the rule went into effect. Thus, one might expect a large number of 

410 recertifications 5 years after that first wave of initial certifications (assuming recertification is required 

411 every 5 years). The cyclicality might be expected to decline over time, as more firms leave the market and 

412 are replaced by new firms each year. While it would be possible to model this type of cyclicality for the 

413 economic analysis, it would add significant complexity to the analysis. More importantly, modeling 

414 cyclicality would make the relative costs of the options sensitive to the timeframe selected for the analysis 

415 unless a very long timeframe were selected, such as 50 years. For example, an option would tend to look 

416 relatively more attractive if the analysis timeframe ended right before a large wave of recertifications and 

417 relatively less attractive if the analysis timeframe ended right after a large wave of recertifications. Thus, 

418 assuming that the same number of renovators seeks initial certification and recertification each year 

419 provides a more accurate comparison of the options and also simplifies the analysis.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-1

420 3. Industry Cost Savings

421 This chapter presents estimates of the cost savings associated with the final rule. Section 3.1 presents

422 estimates for the multi-jurisdiction registration fee amendment and Section 3.2 presents estimates for the 

423 renovator refresher training course amendment. Section 3.3 presents the estimates for the notification 

424 amendment. Total cost savings of both amendments are summarized in Section 3.3.4. A ten year 

425 analytical period is used. Net present value and annualized costs and savings are presented for this time 

426 period using 3 and 7 percent discount rates.

427 3.1 Abatement Multi-jurisdiction Registration Fee Amendment

428 If jurisdictions are eliminated, regulated entities will no longer have to send an application and fees to 

429 EPA for the purpose of adding additional EPA-administered state jurisdictions to their certification or 

430 accreditation. Once a regulated entity applies and is approved in the Lead-based Paint Activities program, 

431 they will be able to work in any EPA-administered state, territory, or tribal land. EPA’s multi-jurisdiction 

432 registration fee data for 2011 through 2013 are presented in Exhibit 3-1. Column 2 and Column 3 of 

433 Exhibit 3-1 present the total and annual average number of additional EPA-administered jurisdictions for 

434 which organizations applied to perform lead-based paint activities or provide training from 2011 through 

435 2013, respectively. Note that non-profit training programs are excluded from the analysis because they are 

436 exempt from the multi-jurisdiction registration fee. The average annual costs borne by regulated entities 

437 are summarized in the last column of Exhibit 3-1 and are calculated by applying the $35 multi-jurisdiction 

438 registration fee to Column 3. Removing the multi-jurisdiction fee would save individuals, firms, and 

439 training providers a combined $15,085 per year.

Exhibit 3-1: Annual Multi-jurisdiction Registration Fees for Individuals and Firms 

Applying for (Re)certification, and Training Providers Applying for (Re)accreditation

Applicant

Additional Jurisdictions

Total Annual Fees

2011 - 2013 Average 

Annual

Individuals 864 288 $10,080

Firms 403 134 $4,690

Training Providers (for-profit) 27 9 $315

Total 431 $15,085

440

441 Exhibit 3-2 presents the ten year net present value and annualized cost savings under the final rule for 

442 individuals and firms applying for (re)certification, and training providers applying for (re)accreditation.

443 The cost savings are discounted using rates of 3 and 7 percent.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-2

Exhibit 3-2: Ten Year Net Present Value and Annualized Cost Savings for Individuals and Firms Applying 

for (Re)certification, and Training Providers Applying for (Re)accreditation (2014$)

Period Additional 

Jurisdictions

Unit 

Incremental 

Cost Savings

Incremental 

Cost Savings

Discounted Incremental

Cost Savings

3% 7%

2016 431 $35 $15,085 $14,646 $14,098

2017 431 $35 $15,085 $14,219 $13,176

2018 431 $35 $15,085 $13,805 $12,314

2019 431 $35 $15,085 $13,403 $11,508

2020 431 $35 $15,085 $13,012 $10,755

⁞

2025 (year 10) 431 $35 $15,085 $11,225 $7,668

Net Present Value $128,678 $105,951

Annualized Cost Savings $15,085 $15,085

444 3.2 Renovator Refresher Training Course Amendment

445 Costs and incremental training cost savings include tuition and travel cost. The cost of the time spent on 

446 training activities is not affected because the rule does not change the duration of the refresher training 

447 course.

448 3.2.1 Training Options

449 Under the existing rule, both the initial and refresher renovator training courses consist of both a 

450 classroom and a hands-on component. The classroom component can be taken in person or online, 

451 whereas the hands-on component must be taken in person. Removing or amending the hands-on 

452 requirement is expected to make online renovator refresher training more attractive to training providers 

and renovators.3 453 Four regulatory options (some of which include sub-options) were considered to amend 

454 this requirement, as depicted in Exhibit 3-3 and Exhibit 3-4. Each option provides renovators with an 

455 alternative refresher training course that either partially or completely removes the hands-on training 

456 requirement. Options that maintain a hands-on training requirement only require renovators to take 

457 hands-on training to become recertified according to the length of time for which the refresher training 

458 course is valid and the training cycle requirements associated with each option. The options vary based on 

459 the length of time for which refresher training without a hands-on training component is valid (2, 3, or 5 

460 years, depending on the option) and the number of training cycles in which hands-on training must be 

461 taken (every second cycle, every third cycle, or never). Option 1 allows renovators to take a refresher 

462 training course without a hands-on training component. Renovators would only be required to take a 

463 course with a classroom component every five years to maintain a valid certification, and the classroom 

464 component could be taken entirely online. Options 2 through 4 allow renovators to take a refresher 

465 training course without a hands-on training component on a periodic basis; the length of time such 

466 training would be valid for depends on the option. These options would also require renovators to take

 

3 There may be less incentive for training providers to offer an online option – or for renovators to take advantage of 

it – if there is a hands-on training requirement. If the renovator and/or the instructor are traveling to the training 

site, they are incurring the travel costs whether or not the classroom portion is taken in person or online. If the 

hands-on requirement is removed the renovator can take the entire refresher course online, eliminating these travel 

costs. This makes online training more attractive to both the renovator and the training provider. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-3

467 refresher training with a hands-on component after a certain number of training cycles; such training 

468 would be valid for five years. The training frequencies are depicted in Exhibit 3-4. When hands-on 

469 training is not required, many renovators are assumed to become recertified remotely, solely by taking the 

470 refresher training course online. However, some renovators are assumed to choose to take an in-person 

471 training course, even when they would be eligible for an online course. 

Exhibit 3-3: Regulatory Options

Option

Period for which 

refresher training 

with hands-on 

component is valid

Period for which 

refresher training 

without hands-on 

component is valid

Number of training 

cycles in which 

hands-on training 

must be taken

Existing rule 5 years Not allowed 1

Option 1 5 years 5 years 0

Option 2 5 years 5 years 2

Option 3(a) 5 years 2 years 0

Option 3(b) 5 years 3 years 0

Option 4(a) 5 years 2 years 2

Option 4(b) 5 years 2 years 3

Option 4(c) 5 years 3 years 2

Option 4(d) 5 years 3 years 3

1 The final rule is Option 4(c).

472

473 Amending the hands-on training requirement is expected to make online renovator refresher training more 

474 attractive to training providers and renovators, but renovators eligible to take an online course could still 

475 choose to take training in person with a hands-on training component. This analysis considers three 

476 different scenarios for the number of renovators that will choose to take online refresher training if the 

477 hands-on requirement is removed: 

478 Scenario I 50 percent of eligible renovators will take online refresher training;

479 Scenario II 75 percent of eligible renovators will take online refresher training; and

480 Scenario III 90 percent of eligible renovators will take online refresher training.

481 This means that 50 percent, 25 percent, or 10 percent, respectively, of renovators will choose to take all of 

482 their training in person. In addition, under Options 2 and 4, renovators who chose to take training without 

483 a hands-on component will have to take hands-on training in a subsequent training cycle. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-4

Exhibit 3-4: Refresher Training Requirements Under Regulatory Options

Year Baseline Option 1 Option 2 Option 3(a) Option 3(b) Option 4(a) Option 4(b) Option 4(c) Option 4(d)

1 With 

hands-on

Without 

hands-on

Without 

hands-on

Without 

hands-on

Without 

hands-on

Without 

hands-on

Without 

hands-on

Without 

hands-on

Without 

hands-on

2

3 Without 

hands-on

With 

hands-on

Without 

hands-on

4 Without 

hands-on

With 

hands-on

Without 

hands-on

5 Without 

hands-on

With 

hands-on

6 With 

hands-on

Without 

hands-on

With 

hands-on

7 Without 

hands-on

Without 

hands-on

With 

hands-on

8 Without 

hands-on

9 Without 

hands-on

Without 

hands-on

10 Without 

hands-on

With 

hands-on

Without 

hands-on

11 With 

hands-on

Without 

hands-on

Without 

hands-on

1 Course with hands-on component: Refresher training course requires both a classroom and a hands-on course component. With the exception of Option 1, in-person 

training is assumed to include a hands-on training component even for those renovators who took hands-on training in the previous training cycle but choose to take 

training in person again.

2 Course without hands-on component: Refresher training course requires only a classroom course component. Refresher training without a hands-on training component

is assumed to be taken online with one exception. For Option 1, the hands-on training component is never required, so training providers are assumed to stop offering it 

to students who wish to take the training in person. Thus, under Option 1, both the in-person and online refresher training courses are assumed to be limited to the 

classroom training component. 

3 Under Options 1 through 4, renovators eligible to take an online course could still choose to take a course in person.

4 The final rule is Option 4(c).
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-5

484 Note that it is assumed that all in-person refresher training courses under Options 2 through 4 would 

485 include a hands-on training component. Under these options, it would be possible for training providers to 

486 offer two versions of in-person refresher training, one with a hands-on component and one without. 

487 However, this would increase the number of different types of courses each training provider would offer 

488 and reduce class size, making the classes less profitable for the training provider. Instead, it is assumed 

489 that training providers would simplify their course offerings by including a hands-on training component 

490 with all in-person refresher training courses. Under Option 1 it is assumed that all in-person courses 

491 would be limited to a classroom component, and would not have a hands-on training component.

492 3.2.2 Tuition

493 It is expected to be less costly for training providers to offer the refresher training course without the 

494 hands-on training component, because they would not have to purchase supplies needed for the hands-on 

495 training modules and instructors would not be limited by the six to one student-teacher ratio requirement 

496 for the hands-on portion of the training course, and there may be savings in travel and facility rental costs 

497 for traveling training. Therefore, the rule is expected to lower training provider costs. To quantify the 

498 change in costs, the tuition of a refresher training course without the hands-on training component is 

499 estimated. Thus, the expected change in tuition is used to estimate training provider cost savings per 

500 refresher training course offered. Though tuition is the vehicle by which training provider cost savings are 

501 estimated, training providers would not necessarily pass any or all cost savings on to renovators taking the 

502 refresher training course without the hands-on component.

503 The refresher training course tuitions are estimated for three types of refresher training courses: an 

504 in-person course with a hands-on training component (under the baseline and Options 2 through 4); an in505 person course without a hands-on training component (under Option 1); and an online course without a 

506 hands-on training component (under Options 1 through 4). Estimates are based on tuition data collected 

507 from the websites of a sample of training providers offering refresher and/or initial renovator training. 

508 The tuition data and summary statistics can be found in Appendix A.

509 A renovator is currently able to enroll in an in-person refresher training course, which consists of a

510 classroom and a hands-on training component. (The existing rule allows training providers to offer a 

511 training course in which the classroom course component is taken online and the hands-on component is 

512 taken in-person. While online versions of the classroom component for the 8-hour initial training course

513 have been available for some time, no training providers were accredited for an online refresher training 

514 course until recently. Therefore, this analysis does not reflect any online refresher training in the 

baseline.

4 515 ) The mean tuition for an in-person refresher course is $136.97 (see Appendix A). 

516 The procedure to estimate the tuition for the in-person course without a hands-on component (under 

517 Option 1) relies on the current mean tuition for initial and refresher training courses, and the current mean 

 

4 The number and variety of refresher training courses has been more limited than initial training courses because 

renovators will not need to be recertified until 2016. The refresher course has so far only been offered to 

renovators with prior lead-safety training in order to receive certification under the RRP rule, or to renovators who 

chose to take their refresher training ahead of schedule. In 2016, when the refresher training course is in its highest 

demand, training providers may offer the course more frequently and some additional training providers might 

have offered an online option even without the changes to the hands-on requirement. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-6

518 tuition for the hands-on component of an initial training course. The estimated tuition for an in-person 

519 refresher course with no hands-on component is $91.61. The steps taken to produce this estimate are 

520 detailed in Exhibit 3-5.

521 It is assumed that the tuition for an online course is the same as an in-person course without the hands-on 

522 requirement because training providers currently tend to charge the same tuition for initial training 

courses whether the classroom component is taught in-person or online.5 523 (From the sample of training 

524 provider course tuitions, five training providers listed tuitions for both in-person and online initial 

525 classroom training on their websites. Four of the five training providers offered both versions of the 

course for the same tuition.6 526 ) However, it is worth noting that the online course could be less expensive. 

527 For example, lower overhead costs may allow training providers to offer the course at a lower price, or 

528 new firms that have a competitive advantage in providing online courses may begin offering the renovator 

refresher training course.7 529

Exhibit 3-5: Procedure to Estimate In-person Classroom Refresher Training

Course Tuition (2014$)

Estimation Steps Value Formula

Tuition data (mean)

(A) Current Initial Training Course Tuition $217.01

(B) Current Refresher Training Course Tuition $136.97

(C) Current Hands-on Training Course Tuition (2 hours) $165.01

Derived estimates

(D) Cost of 3 classroom hours and 1 hands-on training hour $80.04 (A) - (B)

(E) Fixed cost of Initial Course $56.93 (B) - (D)

(F) Incremental costs of 2 hours of hands-on training $108.08 (C) - (E)

(G) Hands-on training cost per hour $54.04 (F) ÷ 2

(H) Cost of 3 classroom hours $26.00 (D) - (G)

(I) Classroom cost per hour $8.67 (H) ÷ 3

In-person classroom refresher training course Tuition 

(4 hours) $91.61 (E) + [4 * (I)]

Note: Unlike the initial training course, there is no mandatory duration for the hands-on training component 

of the refresher course. The hands-on portion of the initial training course must be at least 2 hours, which is 

25 percent of the total 8 hours of training. So for the refresher course, the hands-on training component is 

assumed to be 1 hour, which is 25 percent of the 4 hour duration of the refresher training course.

530

531 Exhibit 3-6 presents a summary of the estimated refresher training course tuitions. The difference 

532 between the tuition for the current refresher training course ($136.97) and the refresher training course 

 

5 Unlike for the refresher training course, training providers have been offering the classroom portion of the initial 

renovator training course online for some time.

6 (1) AEHS, Inc. - $179.99 (online) and $200 (in-person); (2) National Econ Corporation - $185 (both in-person and 

online); (3) The Westside Environmental Plan of Action Committee, LLC (WEPAC) - $250 (both);

(4) TORF Environmental Management - $250 (both); and (5) American Indoor Air Quality Assessment Service, 

Ltd - $250 (both).

7 Currently, many online courses for initial training are developed by third party firms and are offered by training 

providers who package the course with their hands-on training course.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-7

533 without a hands-on training component ($91.61) is $45.36. This $45.36 in savings results from decreases 

in the cost of supplies and instruction if the hands-on training requirement is removed.8 534

Exhibit 3-6: Summary of Refresher Course Tuitions (2014$)

Course Tuition

In-person course with hands-on $136.97

In-person course without hands-on $91.61

Online course $91.61

535

536 3.2.3 Travel Cost

537 Travel cost consists of the cost for a renovator to travel to the training site, incidental expenses, and the 

538 value of the time spent traveling to and from the training site.

539 Travel Distance and Trip Duration

540 RPP certification data extracted from EPA’s FLPP database were used to identify the addresses of 

541 renovators and the training facility where they took their training class. The dataset consisted of 512,737 

542 student-facility pairs. The Environmental Systems Resource Institute’s (ESRI’s) ArcMap 10.2.1 was used 

543 to estimate the average distance a student travels to a training facility and the average duration of the trip

544 (ESRI 2013). The addresses were geocoded using the ArcMap 10.2.1 Geocode Addresses tool, with 

545 ESRI’s StreetMap North America Address Locator (ESRI 2005). Student-facility pairs that could not be 

546 geocoded or could not be geocoded at the street address level (e.g., they could only be geocoded by zip 

547 code) were dropped from the dataset. The resulting dataset contained 316,346 student-facility pairs. From

548 the 316,346 pairs, a random sample of 10,000 student-facility pairs was drawn using SAS Software 9.4 

549 (SAS Institute Inc. 2015). Travel distance and trip duration were estimated using the ArcMap 10.2.1 

550 Network Analyst extension. The analysis resulted in distance and duration estimates for 9,990 

student-facility pairs.9 551 Student-facility pairs where the distance between student and facility was 

estimated to be zero were dropped from the analysis.

10 552 The final dataset from which average travel 

553 distance and trip duration were estimated consisted of 9,865 student-facility pairs. ESRI’s StreetMap 

North America Network Dataset (ESRI 2005) was selected as the Network Dataset input.

11 554 The average 

 

8 The cost of providing instruction decreases if the hands-on training component is removed because the 

recommended student teacher ratio is 6-to-1 for the hands-on training component of the course, compared to 25-to1 for the rest of the in-person classroom course. The tuition for the hands-on training component also covers the 

cost of various supplies (such as EPA-recognized test kits, disposable plastic drop cloths, tape, electrostatically 

charged cleaning cloths, disposable wet cleaning wipes, garbage bags, and so on) for each student. 

9 The most likely reason why Network Analyst can fail to identify a route between two points is contiguity of the 

input Network Dataset. For example, Hawaii and the continental U.S. are not connected by a road network. 

However, it is possible to have two points that appear to be connected by a contiguous road network not to be 

because of data quality issues such as a gap between the line segments forming the road network. 

10 Some of the student-facility pairs shared the same address in FLPP.

11 The tool used to estimate travel distance and trip duration requires a Network Dataset as an input.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-8

555 one-way distance a student travels to a training facility was estimated to be 39 miles and the average 

one-way duration of the trip a student takes to a training facility was estimated to be 54 minutes.12 556

557 Estimated Costs

558 The estimated cost of driving to and from the training facility relies on the distance of the roundtrip and 

559 the Standard Mileage Rates published by the Internal Revenue Service (IRS). The IRS published a rate of 

$0.56 per mile, effective January 1st 560 , 2014 (IRS 2013). The total roundtrip cost of travel is estimated to be 

561 $43.68 (2 * 39 miles * $0.56 = $43.68). Expenses comprise the cost of lunch and are estimated using the 

562 Meals and Incidental Expenses Breakdown published by the General Services Administration. These 

563 expenses are estimated to be $14.17 and are calculated by averaging the six tiers of lunch reimbursement 

rates representing the lower 48 states (GSA 2014). 13 564

565 The duration of the roundtrip to the training site and the average renovator wage rate are used to estimate 

566 the cost of renovators’ time to travel to a training site. The wage rate assigned to renovators is derived 

567 with methods and from sources identical to or similar to those used in previous ICR renewals and 

568 economic analyses for EPA’s RRP program. A renovator’s fully loaded wage rate incorporates wages and 

569 salaries, benefits, and overhead. A renovator’s wages and salaries are represented by the mean hourly 

570 wage rate of First-Line Supervisors of Construction Trades and Extraction Workers, published by the 

571 Bureau of Labor Statistics (BLS) - Occupational Employment Statistics (OES). The mean hourly wage 

572 rate inflated to 2014 dollars is $31.12 for First Line Supervisors of Construction Trades and Extraction 

573 Workers (BLS 2012; BLS 2014). The base wage rate is inflated to 2014 dollars by applying the 

574 Consumer Price Index (CPI) for All Urban Consumers published by the Bureau of Labor Statistics (BLS 

575 2014). The September 2013 release of the BLS Employer Costs for Employee Compensation (ECEC) 

576 data indicates that wages and salaries constitute 69.1 percent of total employee compensations for civilian 

577 workers, implying a wage multiplier of 1.45 to account for benefits (BLS 2013). An overhead of 8.3

578 percent is derived from the 2012 publication of the Cost of Doing Business (NAHB Business 

579 Management & Information Technology 2012). By combining 1.45 and 8.3 percent, a multiplier of 1.53 

580 is used to estimate a fully loaded hourly wage rate of $47.61 for renovators. Based on the 1.8 hour 

581 duration of a roundtrip to the training site, the average cost of travel time for a renovator attending 

582 training is estimated to be $85.70.

583 Exhibit 3-7 summarizes the components of the travel cost to attend in-person training.

Exhibit 3-7: Average Renovator Travel Cost (2014$)

Category Cost

Mileage Cost $43.68

Expenses (lunch) $14.17

Cost of Travel Time $85.70

Travel Cost $143.55

584

 

12 To the extent that students who would otherwise have to travel the longest distances to training facilities are more 

likely to choose online classes, the savings due to the rule may be underestimated. 

13 Some training providers include lunch in the price of the tuition they charge for a training class. Thus, not all 

renovators will incur additional lunch expenses.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-9

585 3.2.4 Total Cost of Refresher Training

586 Exhibit 3-8 presents a summary of the estimated refresher training costs, which includes course tuition 

587 and the total cost of travel.

Exhibit 3-8: Summary of Refresher Training Costs (2014$)

Course Tuition Travel Cost Total Cost

In-person course with hands-on $136.97 $143.55 $280.52

In-person course without hands-on $91.61 $143.55 $235.16

Online course $91.61 $0.00 $91.61

588

589 3.2.5 Number of Individuals Seeking Renovator Recertification

590 Renovator training and certification for persons conducting covered renovation activities became 

591 mandatory in 2010, and a large number of renovators were trained that year. By 2015, approximately 

592 500,000 renovators were certified (see Exhibit 2-2). To estimate the number of renovators expected to 

593 seek recertification each year under the regulatory options, it is assumed that the active stock of certified 

594 renovators is 500,000. It is assumed that 30,000 renovators, or 6 percent of the active stock, drop out of 

the active stock each year and are replaced by newly certified renovators.14 595 The assumed dropout rate 

596 approximates the number of initial certifications in 2013 and 2014 (see Exhibit 2-2). Renovators are 

597 recertified at a rate that maintains an active stock of 500,000 renovators. Given these assumptions, the 

598 number of recertifications reaches a constant value, at which point the stock (total number of certified 

599 renovators) of renovators is equal to the active stock of renovators, 500,000. 

600 Because the regulatory options have different training intervals and cycle requirements for hands-on 

601 training, the methodology to calculate the number of renovators taking the in-person course (either by 

602 choice or as part of the periodic hands-on requirement stipulated in the option) and the online course

603 differs by option. The annual number of renovators that are required to take a course with a hands-on 

604 training component depends on the length of time and number of training cycles for which the course 

605 without a hands-on training component is valid. The annual number of renovators taking the in-person 

606 course by choice is the same for each option, although it varies by scenario (10 percent, 25 percent, or 50

607 percent). The derivation of estimates for annual recertifications for the existing rule is described in Part 

608 (A). The derivation of estimates for annual recertifications for the rule amendment options is discussed in 

609 Part (B) and described in detail in Appendix B. The total number of renovators expected to seek refresher 

610 training each year beginning in 2016 is presented in Exhibit 3-9 for each regulatory option.

611 (A) Existing Rule - Number of Individuals Seeking Recertification

612 Renovator Always Chooses In-person Refresher Training 

613 Baseline: Refresher training course with hands-on training valid for 5 years 

614 The following equation is used to estimate the steady state number of renovators taking the refresher 

615 training course with hands-on training every 5-year training cycle:

616 InP = (S / 5) * PREC5Y = 70,000 renovators

 

14 This analysis subsequently refers to trained renovators exiting the active stock and being replaced by new entrants 

as the “turnover” in the industry.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-10

617 where, 

618 InP = The number renovators taking the refresher course with hands-on training in the steady 

619 state, 

620 S = The active stock of certified renovators (500,000), and

621 PREC5Y = The percent of renovators with expiring certifications that become recertified given a 

5-year training cycle (70%).

15 622

623 (B) Rule Amendment Options - Number of Individuals Seeking Recertification 

624 The total number of renovators seeking refresher training is estimated under three scenarios: (I) 50

625 percent of the active stock of renovators choose the online refresher training course, (II) 75 percent of the 

626 active stock of renovators choose the online refresher training course, and (III) 90 percent of the active 

627 stock of renovators choose the online refresher training course (see Exhibit 3-9). A series of equations are 

628 solved to estimate the steady state number of renovators taking the refresher training course for the rule 

629 amendment options. Each equation is presented in Appendix B. Under the rule amendments, it is assumed 

630 that a portion of renovators seeking recertification will always choose to travel to the training facility to 

631 become recertified, whether hands-on training is required or not, and a portion of renovators seeking 

632 recertification will choose to take the refresher training course online to become recertified, avoiding 

633 travel when possible. It is also assumed that for most of the options, training providers offering in-person 

634 training would always include a hands-on component. One exception is that under Option 1, training 

635 providers are not expected to offer a refresher training course with hands-on training because renovators 

636 would never be required to take hands-on training to become recertified. Therefore, under Option 1, 

637 renovators opting to travel to the training facility would take the refresher training course without 

638 hands-on training. Finally, since they are already traveling to a training facility, it is assumed that 

639 renovators taking training with a hands-on component take the classroom portion in person as well, rather 

640 than taking a hybrid with the classroom portion online and the hands-on portion in person. 

641 Though the total number of renovators seeking refresher training is estimated under three scenarios, the 

642 scenario percentages correspond to the percent of the active stock of renovators choosing the online 

643 refresher training course not the percent of recertifications attained via the online refresher training course 

644 relative to all recertifications per year. Because online training requires more frequent recertifications for 

645 Options 3 and 4, online training is associated with a greater number of recertifications per year than 

646 in-person training for those options, even when equal numbers of renovators are in the online and 

647 in-person training cohorts.

648 For example, under each option, the initial cohort of renovators with expiring certifications is composed 

of approximately 350,000 individuals.16 649 Scenario I assumes that 50 percent of the initial cohort (175,000 

650 renovators) always selects the in-person refresher training course and 50 percent of the initial cohort 

651 selects the online refresher training course. Under Option 4(a), the cohort that selects the online refresher 

 

15 The percent of renovators with expiring certifications that become recertified is calculated by assuming that 6 

percent of certified renovators drop out of the industry each year and are replaced by new entrants. Over a 5-year 

training cycle, 30 percent of certified renovators drop out and the remaining 70 percent are recertified.

16 There are 500,000 renovators in the active stock. Since 30 percent of them drop out over a 5 year period and 70 

percent are recertified, 350,000 renovators (= 70% * 500,000) out of the active stock get recertified over 5 years.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-11

652 training course will have to be recertified after two years by taking the in-person refresher training course, 

653 which will be valid for five years. Ignoring turnover, each renovator in this cohort would take the 

654 refresher training course twice in seven years. Thus, the 175,000 renovators selecting the online refresher 

655 training course would account for a total enrollment of 350,000 students over seven years. On average, 

656 50,000 (=350,000 students / 7 years) renovators from the cohort that selects the online refresher training 

657 course would take the refresher training course each year.

658 Under Option 4(a), the cohort that always selects the in-person refresher training course will have to be 

659 recertified after five years by again taking the in-person refresher training course, which will be valid for 

660 five years. Ignoring turnover, each renovator in this cohort would take the refresher training course twice 

661 in ten years. Thus, the 175,000 renovators always selecting the in-person refresher training course would 

662 account for a total enrollment of 350,000 students over ten years. On average, 35,000 renovators

663 (=350,000 renovators / 10 years) from the cohort that always selects the in-person refresher training 

664 course would take the refresher training course each year. Therefore, even though each cohort is 

665 composed of 175,000 renovators under Scenario I, on average, a greater number of renovators from the 

666 cohort selecting the online refresher training course are recertified each year (50,000 compared to 

667 35,000). Due to turnover, the actual number of renovators choosing online refresher training each year is 

668 estimated to be 51,406 rather than 50,000 under Option 4(a), Scenario I.

669 Summary of Average Annual Refresher Training Attendance

670 The total number of renovators expected to seek refresher training each year beginning in 2016 is 

671 presented in Exhibit 3-9 for each regulatory option and scenario. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-12

Exhibit 3-9: Expected Number of Renovators Seeking Refresher Training Each Year

Scenario I: 50% of Active Stock Always Chooses Online Refresher Training

Option

Renovator Always 

Chooses In-person

Refresher Training

Renovator Chooses Online Refresher Training Total 

Refresher 

Training

Cycle with 

Hands-on 

Cycle w/out 

Hands-on Sub-Total

Option 1 35,000 - 35,000 35,000 70,000

Option 2 35,000 14,412 20,588 35,000 70,000

Option 3

(a) 2 Yr. Interval 35,000 - 87,500 87,500 122,500

(b) 3 Yr. Interval 35,000 - 58,333 58,333 93,333

Option 4

(a) 2 Yr. Interval & 2 Cycles 35,000 24,063 27,343 51,406 86,406

(b) 2 Yr. Interval & 3 Cycles 35,000 17,757 43,108 60,865 95,865

(c) 3 Yr. Interval & 2 Cycles1 35,000 20,211 24,648 44,859 79,859

(d) 3 Yr. Interval & 3 Cycles 35,000 13,338 36,103 49,441 84,441

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Option

Renovator Always 

Chooses In-person 

Refresher Training

Renovator Chooses Online Refresher Training Total 

Refresher 

Training

Cycle with 

Hands-on 

Cycle w/out 

Hands-on Sub-Total

Option 1 17,500 - 52,500 52,500 70,000

Option 2 17,500 21,618 30,882 52,500 70,000

Option 3

(a) 2 Yr. Interval 17,500 - 131,250 131,250 148,750

(b) 3 Yr. Interval 17,500 - 87,500 87,500 105,000

Option 4

(a) 2 Yr. Interval & 2 Cycles 17,500 36,094 41,015 77,109 94,609

(b) 2 Yr. Interval & 3 Cycles 17,500 26,635 64,663 91,298 108,798

(c) 3 Yr. Interval & 2 Cycles1 17,500 30,317 36,972 67,289 84,789

(d) 3 Yr. Interval & 3 Cycles 17,500 20,007 54,155 74,162 91,662

Scenario III: 90% of Active Stock Always Online Refresher Training

Option

Renovator Always 

Chooses In-person 

Refresher Training

Renovator Chooses Online Refresher Training Total 

Refresher 

Training

Cycle with 

Hands-on 

Cycle w/out 

Hands-on Sub-Total

Option 1 7,000 - 63,000 63,000 70,000

Option 2 7,000 25,941 37,059 63,000 70,000

Option 3

(a) 2 Yr. Interval 7,000 - 157,500 157,500 164,500

(b) 3 Yr. Interval 7,000 - 105,000 105,000 112,000

Option 4

(a) 2 Yr. Interval & 2 Cycles 7,000 43,313 49,218 92,531 99,531

(b) 2 Yr. Interval & 3 Cycles 7,000 31,962 77,595 109,557 116,557

(c) 3 Yr. Interval & 2 Cycles1 7,000 36,380 44,367 80,747 87,747

(d) 3 Yr. Interval & 3 Cycles 7,000 24,009 64,985 88,994 95,994

1 672 The final rule is Option 4(c).

673
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-13

674 3.2.6 Total Renovator Training Costs 

675 Exhibit 3-10 presents a summary of the net present value and annualized costs and cost savings under 

676 Options 1 through 4, over a ten year period from 2016 through 2025, for in-person and online training. 

677 The costs are discounted using rates of 3 and 7 percent. See Appendix C for detailed exhibits presenting 

678 baseline training costs and training costs associated with Options 1 through 4. 

679
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-14

Exhibit 3-10: Summary of Total Costs and Cost Savings for Refresher Training Regulatory Options Over a Ten Year Period, 

2016 through 2025 (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Option

Cost of Regulatory Options Cost Savings of Regulatory Options

Net Present Value Annualized Costs 

(3% and 7%)

Net Present Value Annualized Cost

Savings

(3% and 7%) 3% 7% 3% 7%

Option 1 $97,559,503 $80,328,351 $11,436,950 $69,942,972 $57,589,506 $8,199,450

Option 2 $134,326,135 $110,601,187 $15,747,121 $33,176,340 $27,316,670 $3,889,279

Option 3

(a) 2 Yr. Interval $152,128,277 $125,259,080 $17,834,075 $15,374,198 $12,658,777 $1,802,325

(b) 3 Yr. Interval $129,335,670 $106,492,148 $15,162,086 $38,166,805 $31,425,709 $4,474,314

Option 4

(a) 2 Yr. Interval & 2 Cycles $162,698,648 $133,962,491 $19,073,245 $4,803,827 $3,955,366 $563,155

(b) 2 Yr. Interval & 3 Cycles $159,928,657 $131,681,742 $18,748,518 $7,573,818 $6,236,115 $887,882

(c) 3 Yr. Interval & 2 Cycles1 $151,375,213 $124,639,024 $17,745,793 $16,127,262 $13,278,833 $1,890,607

(d) 3 Yr. Interval & 3 Cycles $143,880,394 $118,467,954 $16,867,172 $23,622,081 $19,449,903 $2,769,228

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Option

Cost of Regulatory Options Cost Savings of Regulatory Options

Net Present Value Annualized Costs 

(3% and 7%)

Net Present Value Annualized Cost

Savings

(3% and 7%) 3% 7% 3% 7%

Option 1 $76,130,568 $62,684,236 $8,924,825 $91,371,907 $75,233,621 $10,711,575

Option 2 $117,737,966 $96,942,854 $13,802,481 $49,764,509 $40,975,003 $5,833,919

Option 3

(a) 2 Yr. Interval $144,441,178 $118,929,692 $16,932,913 $23,061,297 $18,988,165 $2,703,487

(b) 3 Yr. Interval $110,252,659 $90,779,616 $12,924,975 $57,249,816 $47,138,241 $6,711,425

Option 4

(a) 2 Yr. Interval & 2 Cycles $160,295,930 $131,984,145 $18,791,573 $7,206,545 $5,933,712 $844,827

(b) 2 Yr. Interval & 3 Cycles $156,141,334 $128,563,342 $18,304,527 $11,361,141 $9,354,515 $1,331,873

(c) 3 Yr. Interval & 2 Cycles1 $143,312,780 $118,000,593 $16,800,630 $24,189,695 $19,917,264 $2,835,770

(d) 3 Yr. Interval & 3 Cycles $132,069,746 $108,743,326 $15,482,604 $35,432,729 $29,174,531 $4,153,796
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-15

Exhibit 3-10: Summary of Total Costs and Cost Savings for Refresher Training Regulatory Options Over a Ten Year Period, 

2016 through 2025 (2014$)

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Option

Cost of Regulatory Options Cost Savings of Regulatory Options

Net Present Value Annualized Costs 

(3% and 7%)

Net Present Value Annualized Cost

Savings

(3% and 7%) 3% 7% 3% 7%

Option 1 $63,273,206 $52,097,767 $7,417,550 $104,229,269 $85,820,090 $12,218,850

Option 2 $107,784,096 $88,747,057 $12,635,584 $59,718,379 $49,170,800 $7,000,816

Option 3

(a) 2 Yr. Interval $139,828,918 $115,132,059 $16,392,215 $27,673,557 $22,785,798 $3,244,185

(b) 3 Yr. Interval $98,802,695 $81,351,968 $11,582,690 $68,699,780 $56,565,889 $8,053,710

Option 4

(a) 2 Yr. Interval & 2 Cycles $158,855,099 $130,797,798 $18,622,664 $8,647,376 $7,120,059 $1,013,736

(b) 2 Yr. Interval & 3 Cycles $153,868,636 $126,692,054 $18,038,098 $13,633,839 $11,225,803 $1,598,302

(c) 3 Yr. Interval & 2 Cycles1 $138,474,352 $114,016,738 $16,233,419 $29,028,123 $23,901,119 $3,402,981

(d) 3 Yr. Interval & 3 Cycles $124,983,854 $102,908,959 $14,651,921 $42,518,621 $35,008,898 $4,984,479

1 The final rule is Option 4(c).
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-16

680 3.3 RRP Training Provider Notification Amendment

681 3.3.1 Background

682 Training providers are currently required to provide EPA with notifications regarding renovator training 

683 courses (40 CFR 745.225). EPA must receive a pre-training notification at least 7 business days prior to 

684 the start date of any renovator training course. The training provider must notify EPA of any changes to 

685 the date of the training course. If the new start date for the training course is prior to the original date, 

686 EPA must receive an updated notification at least 7 business days prior to the new start date. If the new 

687 start date for the training course is after the original date, EPA must receive an updated notification at 

688 least 2 business days prior to the new start date. If the training course is canceled, EPA must receive an 

689 updated notification at least 2 business days prior to the original start date. After the completion of the 

690 training course, the training provider must provide EPA with a list of the students who passed the course

691 along with a digital photo of each student. EPA must receive this post-training notification no later than 

692 10 business days after the completion of the training course. The notifications can be submitted via U.S. 

693 Postal Service, fax, commercial delivery service, hand delivery, or by using EPA’s CDX.

694 3.3.2 Pre-training Notification Amendment

695 Under the amended rule, EPA is removing the requirement for training providers to submit pre-training 

696 notifications for online courses without a hands-on training component. Therefore, online training results 

697 in a reduction in the number of pre-training notifications that must be submitted. The number of 

698 pre-training notifications is estimated using FLPP pre-training notification and renovator certification 

699 data. The total number of pre-training notifications is estimated as the sum of original, update, and 

700 cancelation pre-training notifications. Because the number of courses offered (and thus the number of 

701 pre-training notifications) depends on the annual number of certifications, and the estimated annual

702 number of renovator recertifications varies by option, the number of original pre-training notifications 

703 needs to be estimated as a function of the annual number of renovator certifications. The first step is to 

704 calculate the ratio of the number of renovator certifications to the number of original pre-training 

705 notifications, which is equal to 5 (based on FLPP data for the RRP program from 2012 to 2014). The 

706 number of cancelation pre-training notifications is equal to 25 percent of the number of original 

707 pre-training notifications, and the number of update pre-training notifications is equal to 13 percent of the 

708 number of original pre-training notifications (FLPP data from 2012 to 2014). Thus, given the 70,000 

709 baseline number of annual recertifications, there would be 19,320 total annual pre-training notifications:

710 (70,000 / 5) * (100% + 25% + 13%) = 19,320.

711 Exhibit 3-11 presents the cost savings for the pre-training notification amendment under the different 

712 options. Column 2 is equal to the reduction in the total number of recertifications requiring hands-on 

713 training (the baseline (70,000) - [Column 2 + Column 3 of Exhibit 3-9]). Column 3 is equal to the 

estimated reduction in the number of pre-training notifications due to the amendment.

17 714

715 Column 4 is equal to the associated reduction in burden hours. It takes a clerical worker 0.2 hours to 

716 prepare and submit a pre-training notification (U.S. EPA 2011). Column 5 is equal to the total cost

717 savings associated with reductions in burden, where the total cost of the burden is equal to the total 

718 burden multiplied by the loaded wage rate of an RPP training provider clerical worker ($26.79 per hour, 

 

17 For example, the 9,660 in the third column of Exhibit 3-11 for Option 1, Scenario I is calculated as 

35,000 / 5 * (100% + 25% + 13%).
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-17

719 see Exhibit 7-3 for the derivation of the wage rate). Column 6 is equal to total cost savings of materials. 

720 According to the FLPP pre-training notification data from 2014, 91.6 percent of pre-training notifications 

721 were submitted via CDX and 8.4 percent were faxed. (Less than 1 percent of pre-training notifications 

722 were mailed and less than 1 percent were hand delivered, thus both methods of delivery were assumed to 

723 be 0 percent.) Each pre-training notification submitted by fax requires a document to be printed, which is 

724 assumed to be equivalent to the cost of a photocopy ($0.10 per pre-training notification (U.S. EPA 

2011))18 725 . There is no cost of material for pre-training notifications submitted via CDX. Column 7 is equal 

726 to the total annual cost savings and Column 8 and Column 9 are equal to the net present value of cost 

727 savings discounted using rates of 3 and 7 percent, respectively. 

 

18 For example, the $81 in the sixth column of Exhibit 3-11 for Option 1, Scenario I is calculated as 

9,660 * 8.4% * $0.10.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-18

Exhibit 3-11: Pre-training Notification Cost Savings for Regulatory Options Over a Ten Year Period, 2016 through 2025 (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Option

Reduction in Renovators 

Choosing In-person 

Refresher Training

Reduction in

Pre-training 

Notifications

Burden

Savings

Labor 

Savings

Materials

Savings

Annualized 

Savings

(3% and 7%)

NPV of 

Savings 3%

NPV of 

Savings 7%

Option 1 35,000 9,660 1,932 $51,758 $81 $51,839 $442,197 $364,095

Option 2 20,588 5,682 1,136 $30,433 $48 $30,481 $260,009 $214,086

Option 3

(a) 2 Yr. Interval 35,000 9,660 1,932 $51,758 $81 $51,839 $442,197 $364,095

(b) 3 Yr. Interval 35,000 9,660 1,932 $51,758 $81 $51,839 $442,197 $364,095

Option 4

(a) 2 Yr. Interval & 2 Cycles 10,937 3,019 604 $16,181 $25 $16,206 $138,240 $113,824

(b) 2 Yr. Interval & 3 Cycles 17,243 4,759 952 $25,504 $40 $25,544 $217,896 $179,410

(c) 3 Yr. Interval & 2 Cycles1 14,789 4,082 816 $21,861 $34 $21,895 $186,769 $153,781

(d) 3 Yr. Interval & 3 Cycles 21,662 5,979 1,196 $32,041 $50 $32,091 $273,743 $225,394

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Option

Reduction in Renovators 

Choosing In-person 

Refresher Training

Reduction in 

Pre-training 

Notifications

Burden

Savings

Labor 

Savings

Materials

Savings

Annualized 

Savings 

(3% and 7%)

NPV of 

Savings 3%

NPV of 

Savings 7%

Option 1 52,500 14,490 2,898 $77,637 $122 $77,759 $663,300 $546,147

Option 2 30,882 8,523 1,705 $45,677 $72 $45,749 $390,248 $321,322

Option 3

(a) 2 Yr. Interval 52,500 14,490 2,898 $77,637 $122 $77,759 $663,300 $546,147

(b) 3 Yr. Interval 52,500 14,490 2,898 $77,637 $122 $77,759 $663,300 $546,147

Option 4

(a) 2 Yr. Interval & 2 Cycles 16,406 4,528 906 $24,272 $38 $24,310 $207,369 $170,743

(b) 2 Yr. Interval & 3 Cycles 25,865 7,139 1,428 $38,256 $60 $38,316 $326,843 $269,116

(c) 3 Yr. Interval & 2 Cycles1 22,183 6,123 1,225 $32,818 $51 $32,869 $280,379 $230,858

(d) 3 Yr. Interval & 3 Cycles 32,493 8,968 1,794 $48,061 $75 $48,136 $410,610 $338,087
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-19

Exhibit 3-11: Pre-training Notification Cost Savings for Regulatory Options Over a Ten Year Period, 2016 through 2025 (2014$)

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Option

Reduction in Renovators 

Choosing In-person 

Refresher Training

Reduction in 

Pre-training 

Notifications

Burden

Savings

Labor 

Savings

Materials

Savings

Annualized 

Savings 

(3% and 7%)

NPV of 

Savings 3%

NPV of 

Savings 7%

Option 1 63,000 17,388 3,478 $93,176 $146 $93,322 $796,056 $655,455

Option 2 37,059 10,228 2,046 $54,812 $86 $54,898 $468,291 $385,581

Option 3

(a) 2 Yr. Interval 63,000 17,388 3,478 $93,176 $146 $93,322 $796,056 $655,455

(b) 3 Yr. Interval 63,000 17,388 3,478 $93,176 $146 $93,322 $796,056 $655,455

Option 4

(a) 2 Yr. Interval & 2 Cycles 19,687 5,434 1,087 $29,121 $46 $29,167 $248,800 $204,857

(b) 2 Yr. Interval & 3 Cycles 31,038 8,566 1,713 $45,891 $72 $45,963 $392,074 $322,825

(c) 3 Yr. Interval & 2 Cycles1 26,620 7,347 1,469 $39,355 $62 $39,417 $336,235 $276,849

(d) 3 Yr. Interval & 3 Cycles 38,991 10,762 2,152 $57,652 $90 $57,742 $492,551 $405,556

1 The final rule is Option 4(c)
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-20

728 3.3.3 Post-training Notification Amendment

729 There are two changes to the rule that have competing effects on the notification burden: (1) options that 

730 require more frequent refresher training result in more post-training notifications, which increases post731 training notification burden; and (2) post-training notification burden is reduced because training 

732 providers will be allowed to submit post-training notifications for their online courses once per month. 

733 Under some option/scenario combinations, these effects produce a net reduction in post-training 

734 notification burden while under other option/scenario combinations, including the final rule – Option 

735 Option 4(c) – these effects produce a net increase in the post-training notification burden. Since the total 

736 notification burden for pre- and post-training notifications combined is reduced, the tables present the 

737 burden changes in terms of the burden reduction. Thus, a negative burden reduction indicates an increase 

in burden.19 738

739 Under the amended rule, training providers will be allowed to submit post-training notifications for their 

740 online courses once per month instead of after each course, although they will be required to submit them 

via the CDX. 741 20 Allowing post-training notifications to be submitted once per month is expected to reduce 

742 training provider burden and material costs associated with preparing and submitting post-training 

743 notifications. Exhibit 3-12 presents the initial burden associated with enrolling in the CDX system and the 

744 recurring burden associated with employee turnover and compromised or surrendered electronic 

745 signatures. For this analysis, managerial and technical worker classes have been combined into the 

746 professional worker class to be consistent with economic analyses and ICRs related to the RRP rule. 

Exhibit 3-12: Initial and Recurring Burden Associated with Submitting Notifications via the CDX

Activity

Per Activity Burden Hours Number of 

Annual Activities Total Burden (hours) Clerical Professional

(a) (b) (c) (d) = (c)*[(a)+(b)]

1. CDX Electronic Reporting (First Year)

CDX Registration 0.00 0.84 1.00 0.84

Electronic Subscriber Agreements 0.00 0.25 1.00 0.25

Help Desk 0.00 0.34 1.00 0.34

Problem Resolution 0.00 1.00 0.03 0.03

2. CDX Electronic Reporting (Subsequent Years)

CDX Registration 0.00 0.84 0.10 0.08

Electronic Subscriber Agreements 0.00 0.25 0.10 0.03

Help Desk 0.00 0.34 0.10 0.03

Report Compromised Signature 0.00 0.40 0.01 0.00

747

748 Exhibit 3-13 presents the net present value and annualized costs of using the CDX to submit notifications. 

749 Column 2 and Column 3 of Exhibit 3-13 are calculated by taking the product of the clerical and 

750 professional burden and their wage rates, $26.79 and $53.66, respectively (see Exhibit 7-3 for the 

 

19 Since the increase in burden is due to an increase in the number of renovators trained, this increase in post-training 

notification burden should not cause offering training to become unprofitable for training providers.

20 If this change were not made, training providers offering online refresher training would have to comply with the 

existing regulations, which require submitting a post-training notification within 10 business days of when a 

renovator took their class. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-21

751 derivation of the wage rates). Column 4 is equal to the product of training providers offering online 

752 courses (400) and 8.4 percent- the percent of training providers that currently do not submit notifications 

via the CDX.21 753

754

Exhibit 3-13: Net Present Value and Annualized Costs Over a Ten Year Period of Initial and Recurring 

Notification Submissions via the CDX (2014$)

Activity Per Activity Cost Number of 

Firms Total Costs

Clerical Professional

1. CDX Electronic Reporting (First Year)

CDX Registration $0 $45 34 $1,530 

Electronic Subscriber Agreements $0 $13 34 $442 

Help Desk $0 $18 34 $612 

Problem Resolution $0 $54 1 $54 

Subtotal $2,638 

2. CDX Electronic Reporting (Subsequent Years)

CDX Registration $0 $45 3 $135 

Electronic Subscriber Agreements $0 $13 3 $39 

Help Desk $0 $18 3 $54 

Report Compromised Signature1 $0 $21 1 $21 

Subtotal $249 

NPV

3% $4,443 

7% $3,982 

Annualized Cost

3% $521 

7% $567 

1 Number of firms is rounded up to one.

755

756 The number of post-training notifications associated with in-person recertifications is equal to the number 

757 of in-person courses, which is estimated using FLPP pre-training notification and certification data for the 

758 RRP program from 2012 to 2014. Because the number of classes offered (and thus the number of 

759 post-training notifications) depends on the annual number of certifications, and the estimated annual

760 number of renovator recertifications varies by option, the number of post-training notifications needs to 

761 be estimated as a function of the number of renovator certifications. The first step is to calculate the ratio 

762 of the number of renovator certifications to the number of courses. The number of courses is equal to the 

763 number of original pre-training notifications minus cancelation pre-training notifications. The average 

764 number of renovator certifications per course from 2012 to 2014 is 7. That is, the average class size is 7 

 

21 Four hundred training providers is an approximation that is based on the total number of training providers 

accredited to teach the initial and refresher training courses and the number of training providers that are not 

expected to renew their current accreditation or apply for an accreditation to teach the refresher training course. 

While some training providers that are currently accredited for the refresher course may not choose to become 

accredited for an online refresher course, these may be offset by new entrants (that are not currently accredited) 

who may apply for accreditation to provide an online refresher course.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-22

765 students. Thus, given 35,000 certifications, there would be 5,000 courses and therefore 5,000

766 post-training notifications (35,000 / 7 = 5,000). 

767 The number of post-training notifications associated with online recertifications is equal to the product of 

768 the number of training providers offering online recertifications and the number of annual submissions. 

769 Four hundred training providers are assumed to offer online refresher training courses. Under the 

770 amended rule they would only be required to submit post-training notifications once a month (i.e., 12 

771 times a year). Thus, training providers are estimated to submit 4,800 post-training notifications per year 

for online classes regardless of which regulatory option is selected (12 * 400 = 4,800). 772 22 Without the 

773 amendment to post-training notification requirements, training providers would submit approximately 

774 10,400 post-training notification per year, or 5,600 additional notifications per year. This is estimated by 

assuming that 400 training providers would submit online post-training notifications every 14 days23 775 :

Online post-training notifications = 400 training providers * �

365 day

year

14 day

submission� = 10,400

submission

year

776 .

777 Assuming each post-training notification takes a clerical worker 0.6 hours to prepare and submit at a 

778 loaded wage rate of $26.79 per hour, the amendment would save training providers approximately 

779 $90,000 per year ($90,000 ≈ $26.79/hr * 5,600 notifications/yr * 0.6 hours/notification). 

780 The rule requires training providers to include the expiration date of the renovator’s certification in the 

781 post-training notification, but the time required to do this is negligible. The rule also clarifies the 

782 requirements for post-training notifications for in-person training courses. Training providers are already 

required to submit post-training notifications for renovator training.24 783 The correction to the regulatory text 

784 clarifies that the notifications must be submitted no later than ten business days following course 

785 completion. The amendment may affect the timing of when the notifications are submitted, but not the 

786 cost of compliance. Thus, and because this requirement is already accounted for in a previous economic 

787 analyses and Information Collection Requests (ICRs) for the lead program, there is no incremental 

788 burden, cost, or impact estimated.

789 Exhibit 3-14 presents the cost savings of the changes to the post-training notification requirements. 

790 Column 2 is equal to the reduction in the total number of recertifications requiring hands-on training 

791 (baseline - [Column 2 + Column 3 of Exhibit 3-9]). Column 3 is equal to the estimated reduction in the 

 

22 The 4,800 post-training notifications associated with online refresher training courses is equivalent to the number 

of post-training notifications associated with 33,600 renovators taking the in-person refresher training course 

(33,600 = 7 renovators per class * 4,800 classes). Therefore, an option must result in a reduction of more than 

33,600 renovators taking the in-person refresher training course for the number of post-training notifications to 

decline thirdrelative to the baseline. Assuming that all 400 training providers offering refresher training will also 

offer an online class may overestimate the burden and cost of post-training notifications.

23 The regulatory requirement to submit a notification within 10 business days after completion of the course is 

equivalent to 14 calendar days when accounting for weekends.

24 The existing regulatory text at 40 CFR 745.225(c)(14) states that “The training manager must provide notification 

following completion of renovator, dust sampling technician, or lead-based paint activities courses” and 

745.225(c)(14)(ii)(D)(6) requires that for renovator or dust sampling technician courses, the notification must 

include a digital photograph of the student. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-23

792 number of post-training notifications. For example, Option 4(c), Scenario I, is associated with a reduction 

793 of 14,789 renovators taking the in-person refresher training course with the hands-on training component:

794 14,789 = 70,000 (baseline) - [35,000 + 20,211 from Exhibit 3-9 ]. 

795 This equates to a reduction of 2,113 post-training notifications associated with the in-person refresher 

796 training course:

797 2,113 post-training notifications or courses = 14,789 renovators / 7 students per course. 

798 However, there are 4,800 additional post-training notifications associated with refresher training courses 

799 taught online. Thus, the net reduction in post-training notifications is equal to -2,687 (i.e., there is a net 

800 increase of 2,687 post-training notifications compared to the baseline). As illustrated in Exhibit 3-14, 

801 some options result in additional post-training notifications (e.g., Option 4(c), Scenario I) while other 

802 options result in a reduction in post-training notifications (e.g., Option 1, Scenario I) relative to the 

803 number of post-training notifications represented in the baseline. Column 4 equals the reduction in post804 training notification burden. Note that the burden and associated costs of enrollment into the CDX are 

805 only included in the last four columns. It takes a clerical worker an average of 0.6 hours to prepare and 

806 submit a post-training notification (U.S. EPA 2011). Thus, Option 4(c), Scenario I, is associated with a 

807 reduction in burden equal to -1,612 hours (i.e., an increase in burden):

808 -1,612 tot. reduction in burden = -2,687 post-training notifications * 0.6 hours of burden.

809 Column 5 is equal to the total cost savings of the reductions in burden, where the total cost of the burden 

810 is equal to the total reduction in burden multiplied by the loaded wage rate of an RPP training provider 

811 clerical worker ($26.79 per hour, see Exhibit 7-3 for the derivation of the wage rate). Column 6 is equal to 

812 total cost savings of materials. According to the FLPP pre-training notification data from 2014, 91.6 

813 percent of pre-training notifications were submitted via CDX and 8.4 percent were faxed. (Less than 1 

814 percent of pre-training notifications were mailed and less than 1 percent were hand delivered, so the 

815 analysis makes the simplifying assumption that pre-training notifications are either submitted via CDX or 

816 faxed. Each post-training notification submitted by fax requires a document to be printed, which is 

817 assumed to be equivalent to the cost of a photocopy ($0.10 per post-training notification (U.S. EPA 

818 2011)). There is no cost of material for post-training notifications submitted via CDX. Thus, Option 4(c), 

819 Scenario I, is associated with a reduction in the cost of materials equal to $18:

820 $18 = 2,113 reduction in in-person post-training notifications * 8.4 percent of 

821 post-training notifications faxed * $0.10 cost per post-training notification faxed.

822 Column 7 and Column 8 are equal to the annualized cost savings, which account for CDX costs, 

823 discounted using rates of 3 and 7 percent, respectively. Column 9 and Column 10 are equal to the net 

824 present value of savings, including CDX costs, discounted using rates of 3 and 7 percent, respectively.

825 When training providers submit notifications via CDX, it also reduces the time and expense needed for 

826 EPA to enter the information into the FLPP database. 

827
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-24

Exhibit 3-14: Post-training Notification Cost Savings for Regulatory Options Over a Ten Year Period, 2016 through 2025 (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Option

Reduction in Renovators 

Choosing In-person 

Refresher Training

Reduction in 

Post-training 

Notifications

Burden

Savings

Labor 

Savings

Materials

Savings

Annualized 

Savings w/

CDX, 3% 

Annualized 

Savings w/

CDX, 7% 

NPV of 

Savings 

w/

CDX, 3%

NPV of 

Savings 

w/

CDX, 7%

Option 1 35,000 200 120 $3,215 $42 $2,736 $2,690 $23,340 $18,894

Option 2 20,588 -1,859 -1,115 -$29,871 $25 -$30,367 -$30,413 -$259,035 -$213,608

Option 3

(a) 2 Yr. Interval 35,000 200 120 $3,215 $42 $2,736 $2,690 $23,340 $18,894

(b) 3 Yr. Interval 35,000 200 120 $3,215 $42 $2,736 $2,690 $23,340 $18,894

Option 4

(a) 2 Yr. Interval & 2 Cycles 10,937 -3,238 -1,943 -$52,053 $13 -$52,561 -$52,607 -$448,355 -$369,489

(b) 2 Yr. Interval & 3 Cycles 17,243 -2,337 -1,402 -$37,560 $21 -$38,060 -$38,106 -$324,658 -$267,640

(c) 3 Yr. Interval & 2 Cycles1 14,789 -2,687 -1,612 -$43,185 $18 -$43,688 -$43,734 -$372,666 -$307,169

(d) 3 Yr. Interval & 3 Cycles 21,662 -1,705 -1,023 -$27,406 $26 -$27,901 -$27,947 -$238,000 -$196,288

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Option

Reduction in Renovators 

Choosing In-person 

Refresher Training

Reduction in 

Post-training 

Notifications

Burden

Savings

Labor 

Savings

Materials

Savings

Annualized 

Savings w/

CDX, 3% 

Annualized 

Savings w/

CDX, 7% 

NPV of 

Savings 

w/ 

CDX, 3%

NPV of 

Savings 

w/ 

CDX, 7%

Option 1 52,500 2,700 1,620 $43,400 $63 $42,942 $42,896 $366,305 $301,284

Option 2 30,882 -388 -233 -$6,242 $37 -$6,726 -$6,772 -$57,373 -$47,563

Option 3

(a) 2 Yr. Interval 52,500 2,700 1,620 $43,400 $63 $42,942 $42,896 $366,305 $301,284

(b) 3 Yr. Interval 52,500 2,700 1,620 $43,400 $63 $42,942 $42,896 $366,305 $301,284

Option 4

(a) 2 Yr. Interval & 2 Cycles 16,406 -2,456 -1,474 -$39,488 $20 -$39,989 -$40,035 -$341,113 -$281,189

(b) 2 Yr. Interval & 3 Cycles 25,865 -1,105 -663 -$17,762 $31 -$18,252 -$18,298 -$155,692 -$128,517

(c) 3 Yr. Interval & 2 Cycles1 22,183 -1,631 -979 -$26,227 $27 -$26,721 -$26,767 -$227,934 -$188,000

(d) 3 Yr. Interval & 3 Cycles 32,493 -158 -95 -$2,545 $39 -$3,027 -$3,073 -$25,820 -$21,583
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-25

Exhibit 3-14: Post-training Notification Cost Savings for Regulatory Options Over a Ten Year Period, 2016 through 2025 (2014$)

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Option

Reduction in Renovators 

Choosing In-person 

Refresher Training

Reduction in 

Post-training 

Notifications

Burden

Savings

Labor 

Savings

Materials

Savings

Annualized 

Savings w/

CDX, 3% 

Annualized 

Savings w/

CDX, 7% 

NPV of 

Savings 

w/ 

CDX, 3%

NPV of 

Savings 

w/ 

CDX, 7%

Option 1 63,000 4,200 2,520 $67,511 $76 $67,066 $67,020 $572,088 $470,721

Option 2 37,059 494 296 $7,930 $44 $7,453 $7,407 $63,577 $52,024

Option 3

(a) 2 Yr. Interval 63,000 4,200 2,520 $67,511 $76 $67,066 $67,020 $572,088 $470,721

(b) 3 Yr. Interval 63,000 4,200 2,520 $67,511 $76 $67,066 $67,020 $572,088 $470,721

Option 4

(a) 2 Yr. Interval & 2 Cycles 19,687 -1,988 -1,193 -$31,960 $24 -$32,457 -$32,503 -$276,864 -$228,287

(b) 2 Yr. Interval & 3 Cycles 31,038 -366 -220 -$5,894 $37 -$6,378 -$6,424 -$54,404 -$45,119

(c) 3 Yr. Interval & 2 Cycles1 26,620 -997 -598 -$16,020 $32 -$16,509 -$16,555 -$140,824 -$116,275

(d) 3 Yr. Interval & 3 Cycles 38,991 770 462 $12,377 $47 $11,903 $11,857 $101,536 $83,279

1 The final rule is Option 4(c).
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-26

828 3.3.4 Summary of Notification Cost Savings

829 Exhibit 3-15 presents a summary of pre- and post-training notification cost savings associated with the 

830 amendments to the training provider notification requirements. Depending on the option and scenario, the 

831 effect of these changes is estimated to range from an increase in costs of $36,355 to a cost savings of 

832 $160,388 (annualized using a rate of 3 percent; see Exhibit 3-15). For the final rule, Option 4(c), the result 

833 is estimated to range from an increase in costs of $21,793 per year to a cost savings of $22,908 per year.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-27

Exhibit 3-15: Pre- and Post-training Notification Cost Savings for Regulatory Options Over a Ten Year Period, 2016 through 2025 (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Option

Reduction in 

Pre-training 

Notifications

Reduction in 

Post-training 

Notifications

Total Reduction 

in Notifications

Annualized 

Cost Savings 

3%

Annualized 

Cost Savings 

7%

NPV of 

Savings 

3%

NPV of 

Savings 7%

Option 1 9,660 200 9,860 $54,575 $54,529 $465,537 $382,989

Option 2 5,682 -1,859 3,823 $114 $68 $974 $478

Option 3

(a) 2 Yr. Interval 9,660 200 9,860 $54,575 $54,529 $465,537 $382,989

(b) 3 Yr. Interval 9,660 200 9,860 $54,575 $54,529 $465,537 $382,989

Option 4

(a) 2 Yr. Interval & 2 Cycles 3,019 -3,238 -219 -$36,355 -$36,401 -$310,115 -$255,665

(b) 2 Yr. Interval & 3 Cycles 4,759 -2,337 2,422 -$12,516 -$12,562 -$106,762 -$88,230

(c) 3 Yr. Interval & 2 Cycles1 4,082 -2,687 1,395 -$21,793 -$21,839 -$185,897 -$153,388

(d) 3 Yr. Interval & 3 Cycles 5,979 -1,705 4,274 $4,190 $4,144 $35,743 $29,106

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Option

Reduction in 

Pre-training 

Notifications

Reduction in 

Post-training 

Notifications

Total Reduction 

in Notifications

Annualized

Cost Savings 

3%

Annualized 

Cost Savings 

7%

NPV of 

Savings 

3%

NPV of 

Savings 7%

Option 1 14,490 2,700 17,190 $120,701 $120,655 $1,029,605 $847,431

Option 2 8,523 -388 8,135 $39,023 $38,977 $332,875 $273,759

Option 3

(a) 2 Yr. Interval 14,490 2,700 17,190 $120,701 $120,655 $1,029,605 $847,431

(b) 3 Yr. Interval 14,490 2,700 17,190 $120,701 $120,655 $1,029,605 $847,431

Option 4

(a) 2 Yr. Interval & 2 Cycles 4,528 -2,456 2,072 -$15,679 -$15,725 -$133,744 -$110,446

(b) 2 Yr. Interval & 3 Cycles 7,139 -1,105 6,034 $20,064 $20,018 $171,151 $140,599

(c) 3 Yr. Interval & 2 Cycles1 6,123 -1,631 4,492 $6,148 $6,102 $52,445 $42,858

(d) 3 Yr. Interval & 3 Cycles 8,968 -158 8,810 $45,109 $45,063 $384,790 $316,504
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-28

Exhibit 3-15: Pre- and Post-training Notification Cost Savings for Regulatory Options Over a Ten Year Period, 2016 through 2025 (2014$)

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Option

Reduction in 

Pre-training 

Notifications

Reduction in 

Post-training 

Notifications

Total Reduction 

in Notifications

Annualized 

Cost Savings 

3%

Annualized 

Cost Savings 

7%

NPV of 

Savings 

3%

NPV of 

Savings 7%

Option 1 17,388 4,200 21,588 $160,388 $160,342 $1,368,144 $1,126,176

Option 2 10,228 494 10,722 $62,351 $62,305 $531,868 $437,605

Option 3

(a) 2 Yr. Interval 17,388 4,200 21,588 $160,388 $160,342 $1,368,144 $1,126,176

(b) 3 Yr. Interval 17,388 4,200 21,588 $160,388 $160,342 $1,368,144 $1,126,176

Option 4

(a) 2 Yr. Interval & 2 Cycles 5,434 -1,988 3,446 -$3,290 -$3,336 -$28,064 -$23,430

(b) 2 Yr. Interval & 3 Cycles 8,566 -366 8,200 $39,585 $39,539 $337,670 $277,706

(c) 3 Yr. Interval & 2 Cycles1 7,347 -997 6,350 $22,908 $22,862 $195,411 $160,574

(d) 3 Yr. Interval & 3 Cycles 10,762 770 11,532 $69,645 $69,599 $594,087 $488,835

1 The final rule is Option 4(c).

834
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-29

835 3.4 Total Industry Cost Savings

836 The net present value and annualized industry cost savings for the amended rule are summarized in 

837 Exhibit 3-16. These savings reflect a 10 year period from 2016 through 2025, and are discounted using 

838 rates of 3 and 7 percent. 

Exhibit 3-16: Total and Annualized Industry Cost Savings Over 10 Years (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Option

Net Present Value Annualized Cost Savings

3% 7% 3% 7%

Option 1 $70,537,187 $58,078,446 $8,269,110 $8,269,064

Option 2 $33,305,992 $27,423,099 $3,904,478 $3,904,432

Option 3

(a) 2 Yr. Interval $15,968,413 $13,147,717 $1,871,985 $1,871,939

(b) 3 Yr. Interval $38,761,020 $31,914,649 $4,543,974 $4,543,928

Option 4

(a) 2 Yr. Interval & 2 Cycles $4,622,390 $3,805,652 $541,885 $541,839

(b) 2 Yr. Interval & 3 Cycles $7,595,734 $6,253,836 $890,451 $890,405

(c) 3 Yr. Interval & 2 Cycles1 $16,070,043 $13,231,396 $1,883,899 $1,883,853

(d) 3 Yr. Interval & 3 Cycles $23,786,502 $19,584,960 $2,788,503 $2,788,457

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Option Net Present Value Annualized Cost Savings

3% 7% 3% 7%

Option 1 $92,530,190 $76,187,003 $10,847,361 $10,847,315 

Option 2 $50,226,062 $41,354,713 $5,888,027 $5,887,981 

Option 3

(a) 2 Yr. Interval $24,219,580 $19,941,547 $2,839,273 $2,839,227 

(b) 3 Yr. Interval $58,408,099 $48,091,623 $6,847,211 $6,847,165 

Option 4

(a) 2 Yr. Interval & 2 Cycles $7,201,479 $5,929,217 $844,233 $844,187 

(b) 2 Yr. Interval & 3 Cycles $11,660,970 $9,601,065 $1,367,022 $1,366,976 

(c) 3 Yr. Interval & 2 Cycles1 $24,370,818 $20,066,073 $2,857,003 $2,856,957 

(d) 3 Yr. Interval & 3 Cycles $35,946,197 $29,596,986 $4,213,990 $4,213,944 

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Option

Net Present Value Annualized Cost Savings

3% 7% 3% 7%

Option 1 $105,726,091 $87,052,217 $12,394,323 $12,394,277 

Option 2 $60,378,925 $49,714,356 $7,078,252 $7,078,206 

Option 3

(a) 2 Yr. Interval $29,170,379 $24,017,925 $3,419,658 $3,419,612 

(b) 3 Yr. Interval $70,196,602 $57,798,016 $8,229,183 $8,229,137 

Option 4

(a) 2 Yr. Interval & 2 Cycles $8,747,990 $7,202,580 $1,025,531 $1,025,485 

(b) 2 Yr. Interval & 3 Cycles $14,100,187 $11,609,460 $1,652,972 $1,652,926 

(c) 3 Yr. Interval & 2 Cycles1 $29,352,212 $24,167,644 $3,440,974 $3,440,928 

(d) 3 Yr. Interval & 3 Cycles $43,241,386 $35,603,684 $5,069,209 $5,069,163 

1 The final rule is Option 4(c).

839

840
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-30

841 3.5 Other Industry Costs

842 3.5.1 Abatement Multi-jurisdiction Registration Fee Amendment

843 EPA does not anticipate other direct or indirect impacts resulting from the final rule that would cause 

844 entities regulated under the abatement program to experience increases or reductions in their costs.

845 3.5.2 Renovator Refresher Training Course Amendment

846 Individual training providers offering RRP training courses could be negatively impacted by the final rule 

847 if (1) their profit margins are lower for the online course, or (2) they lose market share with the 

848 introduction of the online course.

849 Under the regulatory options, a much larger portion of renovators are expected to enroll in the online 

850 refresher training course than the online component of the initial training course. This is because 

851 renovators would not have to travel or travel as frequently to a training facility if the hands-on refresher

852 training requirement were amended. (By contrast, renovators taking the initial training course will still 

853 have to travel to take the hands-on portion.) If training providers do not develop their own online course, 

854 they must contract a third-party firm to offer the course online. In this scenario, training providers will 

855 incur costs in the form of fees paid to the third-party firms to develop and administer the online courses. 

856 At the same time, offering refresher courses without a hands-on training component reduces the training 

857 providers’ costs, since they may be able to teach classes with a larger student-to-teacher ratio, they do not 

858 have to purchase hands-on training course supplies (such as EPA-recognized test kits, disposable plastic 

859 drop cloths, tape, electrostatically charged cleaning cloths, disposable wet cleaning wipes, garbage bags, 

860 and so on) for each student in every class, and there may be savings in travel and facility rental costs for 

861 traveling training. Training providers will not choose to offer online training unless the savings from 

862 doing so exceed the costs or if they can recover their costs through tuition charges or other means.

863 Many uncertainties and data gaps exist about the extent to which individual training provider profit 

864 margins might change. Some training providers may exit the market, others may add market share, and 

865 new entrants might also seek training provider accreditation. While there would not be a net loss to the 

866 economy if market shares shift, training providers unable to compete in the online market might 

867 experience reduced profits. Alternatively, if many renovators choose to take refresher training from the 

868 provider of their initial training, there may be little change in market shares.

869

870 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

4-1

871 4. Agency Costs

872 EPA will incur costs resulting from the new rule associated with reviewing the expedited online course

873 applications submitted by training providers to attain accreditation. It is estimated to take an average of 4 

874 hours apiece for an Agency employee to review each of the 400 applications. The base wage rate of the 

875 federal government employee reviewing applications is taken from the 2014 General Schedule (GS) 

876 Locality Pay Table for Washington-Baltimore-Northern Virginia, published by the Office of Personnel 

877 Management (OPM). A loaded wage rate of $78.13 is then derived by applying a 1.6 fringe benefits and 

878 overhead multiplier to the base wage rate of a GS-13 Step 5 government employee (see Exhibit 4-1)

879 (OPM 2014). The 1.6 fringe benefits and overhead multiplier is taken from the ICR Handbook- EPA’s 

880 Guide to Writing Information Collection Requests, published in 2009 (U.S. EPA 2009).

Exhibit 4-1: EPA Wage Rate

Labor 

Category Date

Base

Wage1

Fringe Benefits and 

Overhead Multiplier2

Loaded 

Wages

(a) (b) (c)=(a)*(b)

GS-13 Step 5 1/14 $48.83 1.6 $78.13

1 Office of Personal Management (2014). 2014 General Schedule (GS) Locality Pay 

Tables: WASHINGTON-BALTIMORE-NORTHERN VIRGINIA, DC-MD-VAWV-PA. SALARY TABLE 2014-DCB .

2 U.S. EPA (2009). "ICR Handbook- EPA’s Guide to Writing Information Collection 

Requests."

881

882 Exhibit 4-2 presents net present value and annualized cost accrued by EPA over a ten year period from 

883 2016 through 2025, under the final rule. Costs are discounted using rates of 3 and 7 percent. It is not 

884 known how many training providers will only offer refresher training online and how many will maintain 

885 dual accreditations (one for in-person training and one for online training). Therefore, it is unknown 

886 whether there will be a change in the number of reaccreditation applications after 2016. If most training 

887 providers begin offering refresher training only online, EPA’s work load for reviewing accreditation 

888 applications would not change much in future years since the training providers would be substituting an 

889 online accreditation for one that is in-person. Conversely, if most training providers begin offering 

890 refresher training online in addition to the in-person course, EPA’s work load for reviewing accreditation 

891 applications would increase and remain higher in future years. To produce more conservative cost 

892 estimates, it is assumed that training providers maintain accreditation for both the online and in-person 

893 refresher training courses. As a result, the analysis considers EPA’s costs for reviewing additional 

894 accreditation applications through 2025. Course accreditation is valid for four years, thus it is assumed 

895 that each of the 400 training providers will apply for reaccreditation of their online refresher training 

896 course in 2020 and 2024.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

4-2

Exhibit 4-2: Ten Year Net Present Value and Annualized Cost to EPA Under the Final Rule 

(2014$)

Application 

Review Costs

Hours per 

Application

Cost per 

Application

($78.13/hour)

Applications 

Reviewed Total Cost

Discounted Total Cost

3% 7%

2016 4 $312.52 400 $125,008 $121,367 $116,830 

2020 4 $312.52 400 $125,008 $107,833 $89,129 

2024 4 $312.52 400 $125,008 $95,808 $67,996 

Net Present Value $325,008 $273,955 

Annualized Cost $38,101 $39,005 897
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

5-1

898 5. Social Cost Savings

899 The estimated total social cost savings is equal to the sum of industry cost savings less Agency costs.

900 Exhibit 5-1 presents the net present value and annualized equivalent value of expected cost savings to 

901 society over a ten year period ranging from 2016 to 2025. Estimates are discounted using rates of 3 and 7 

902 percent.

Exhibit 5-1: Total and Annualized Social Cost Savings Over 10 Years (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Option

Net Present Value Annualized Cost Savings

3% 7% 3% 7%

Option 1 $70,212,179 $57,804,491 $8,231,009 $8,230,059 

Option 2 $32,980,984 $27,149,144 $3,866,377 $3,865,427 

Option 3

(a) 2 Yr. Interval $15,643,405 $12,873,762 $1,833,884 $1,832,934 

(b) 3 Yr. Interval $38,436,012 $31,640,694 $4,505,873 $4,504,923 

Option 4

(a) 2 Yr. Interval & 2 Cycles $4,297,382 $3,531,697 $503,784 $502,834 

(b) 2 Yr. Interval & 3 Cycles $7,270,726 $5,979,881 $852,350 $851,400 

(c) 3 Yr. Interval & 2 Cycles1 $15,745,035 $12,957,441 $1,845,798 $1,844,848 

(d) 3 Yr. Interval & 3 Cycles $23,461,494 $19,311,005 $2,750,402 $2,749,452 

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Option Net Present Value Annualized Cost Savings

3% 7% 3% 7%

Option 1 $92,205,182 $75,913,048 $10,809,260 $10,808,310 

Option 2 $49,901,054 $41,080,758 $5,849,926 $5,848,976 

Option 3

(a) 2 Yr. Interval $23,894,572 $19,667,592 $2,801,172 $2,800,222 

(b) 3 Yr. Interval $58,083,091 $47,817,668 $6,809,110 $6,808,160 

Option 4

(a) 2 Yr. Interval & 2 Cycles $6,876,471 $5,655,262 $806,132 $805,182 

(b) 2 Yr. Interval & 3 Cycles $11,335,962 $9,327,110 $1,328,921 $1,327,971 

(c) 3 Yr. Interval & 2 Cycles1 $24,045,810 $19,792,118 $2,818,902 $2,817,952 

(d) 3 Yr. Interval & 3 Cycles $35,621,189 $29,323,031 $4,175,889 $4,174,939 

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Option

Net Present Value Annualized Cost Savings

3% 7% 3% 7%

Option 1 $105,401,083 $86,778,262 $12,356,222 $12,355,272 

Option 2 $60,053,917 $49,440,401 $7,040,151 $7,039,201 

Option 3

(a) 2 Yr. Interval $28,845,371 $23,743,970 $3,381,557 $3,380,607 

(b) 3 Yr. Interval $69,871,594 $57,524,061 $8,191,082 $8,190,132 

Option 4

(a) 2 Yr. Interval & 2 Cycles $8,422,982 $6,928,625 $987,430 $986,480 

(b) 2 Yr. Interval & 3 Cycles $13,775,179 $11,335,505 $1,614,871 $1,613,921 

(c) 3 Yr. Interval & 2 Cycles1 $29,027,204 $23,893,689 $3,402,873 $3,401,923 

(d) 3 Yr. Interval & 3 Cycles $42,916,378 $35,329,729 $5,031,108 $5,030,158 

1 The final rule is Option 4(c).

903
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

6-1

904 6. Small Entity Impact Analysis

905 The Regulatory Flexibility Act (RFA) of 1980, amended by the Small Business Regulatory Enforcement 

906 Fairness Act (SBREFA) of 1996, requires regulators to assess the effects of regulations on small entities 

907 including businesses, nonprofit organizations, and governments. In some instances, agencies are also 

908 required to examine regulatory alternatives that may reduce adverse economic effects on significantly 

909 impacted small entities. The RFA requires agencies to prepare an initial and final regulatory flexibility 

910 analysis for each rule unless the Agency certifies that the rule will not have a significant economic impact 

911 on a substantial number of small entities. 

912 The rule allows training providers (many of which are small businesses) additional flexibility in how they 

913 offer training. Online training is already allowed for the classroom component of both initial and refresher 

914 training, and training providers can choose whether or not to offer it. The amended rule still allows 

915 training providers to choose what type of training to offer because they can continue to offer refresher 

916 training with a hands-on component, begin offering online training without the hands-on component, or 

917 offer both types of training. 

918 Training providers that voluntarily choose to start offering online refresher training without a hands-on 

919 component would incur costs for some activities (e.g., applying for a new accreditation) but they would 

920 reduce other expenses (e.g., supplies for the hands-on training). Because there is no requirement 

921 mandating that training providers offer an online refresher course, training providers will not choose to 

922 offer online training unless the savings from doing so exceed the costs, or if they can recover their costs 

923 through tuition charges, increased volume of business, or other means. Although some accredited training 

924 providers may lose market share to other training providers that are more competitive in the online 

925 training market, this would be an indirect impact not a direct cost of complying with the rule.

926 Eliminating multi-jurisdiction registration fees saves money for entities that wish to perform LBP 

927 activities in multiple jurisdictions. The rule requires training providers to include the expiration date of 

928 the renovator’s certification in the post-training notification, but the time required to do this is negligible. 

929 The clarification in the rule that post-training notifications must be submitted no later than ten business 

930 days following course completion may affect the timing of when the notifications are submitted, but not 

931 the cost of completing and submitting them. The changes in this action to the regulatory language on the 

932 training provider applications is a clarification of the existing requirement, not a new requirement.

933
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

7-1

934 7. Other Impact Analyses

935 Several statutes and executive orders (EOs) pertain to the final rule. This chapter presents 

936 statements discussing unfunded mandates, environmental justice, children’s health, and 

937 paperwork burden, among others.

938 7.1 Paperwork Reduction Act

939 The Paperwork Reduction Act of 1995 (PRA) (superseding the PRA of 1980), as implemented by 

940 the Office of Management and Budget (OMB), requires that agencies submit a supporting 

941 statement to OMB for any information collection that solicits the same data from more than nine 

942 parties. The PRA seeks to ensure that Federal agencies balance their need to collect information 

943 with the paperwork burden imposed on the public by the collection. The definition of 

944 “information collection” includes activities required by regulations such as permit development, 

945 monitoring, recordkeeping, and reporting. The term “burden” refers to the “time, effort, or

946 financial resources” the public expends to provide information to or for a Federal agency, or to 

947 otherwise fulfill statutory or regulatory requirements. PRA paperwork burden is measured in 

948 terms of annual time and financial resources the public devotes to meet one-time and recurring 

949 information requests (44 U.S.C. 3502(2); 5 C.F.R. 1320.3(b)). Information collection activities 

950 may include:

951 • reviewing rule requirements;

952 • using technology to collect, process, and disclose information;

953 • adjusting existing practices to comply with requirements;

954 • searching data sources;

955 • completing and reviewing the response; and

956 • transmitting or disclosing information.

957 Agencies must provide information to OMB on the parties affected, the annual reporting burden, 

958 and the annual cost of responding to the information collection.

959 7.1.1 Industry Burden

960 RPP Training Provider Burden

961 Currently accredited training providers that wish to add an already reviewed and accepted RRP 

962 online course from another training provider to their training curriculum are eligible for an 

963 expedited online course approval. All requests to add an already-reviewed online course

964 curriculum to an already-accredited training providers' record must include a cover letter; a 

965 training provider application to amend their accreditation; and an online course quality control 

966 (QC) plan. The QC plan must address issues such as how the trainer will ensure that students 

967 successfully complete the online modules and the online course module final assessment. 

968 Training providers that are already accredited are not charged a fee when adding an 

969 already reviewed online course curriculum.

970 Training providers currently accredited for the renovator refresher training course are assumed to 

971 apply for an online refresher training course accreditation if the hands-on requirement is removed

972 or amended in accordance with the proposed regulatory options. Therefore, they would incur an 

973 incremental paperwork burden. Training providers applying for accreditation incur a one-time 

974 burden associated with becoming familiar with the new rule’s requirements, as well as the burden 

975 of completing the accreditation application. Training providers would also incur an incremental 

976 burden associated with training course notifications. They would incur a recurring burden 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

7-2

977 associated with pre-training notifications, pre-training re-notifications, and post-training 

978 notifications. (Note that the recurring burden associated with the changes to the pre-training 

979 notification and pre-training re-notification requirements is always negative, indicating a 

980 reduction in annual burden.) Training providers who do not currently submit notifications via the 

981 CDX would incur the initial and recurring burden associated with registration and ongoing 

982 administrative activities.

983 The rule requires training providers to include the expiration date of the renovator’s certification 

984 in the post-training notification, but the time required to do this is negligible. The rule also 

985 clarifies the requirements for post-training notifications for in-person training courses. Training 

986 providers are already required to submit post-training notifications for renovator training. The 

987 rule’s correction to the regulatory text (clarifying that the notifications must be submitted no later 

988 than ten business days following course completion) may affect the timing of when the 

989 notifications are submitted, but not the cost of compliance. Furthermore, the burden and cost of 

990 this requirement was already accounted for in previous Information Collection Requests (ICRs)

991 for the lead program. 

992 There are assumed to be 400 training providers with accredited renovator refresher training 

993 programs. It is estimated that renovation training providers will spend half as long on becoming 

994 accredited for an online refresher training course as on initial accreditation for an initial training 

995 course. (Less information needs to be provided for an expedited online course application, given 

996 that the training provider has already been accredited for an in-person course.) Burden for the 

997 initial accreditation of an initial renovation training course is taken from the previously approved 

998 ICR (EPA No. 1715.13). Burden hour estimates were rounded to one decimal place for this ICR.

999 The resulting burden is estimated to be 4 hours for training providers to familiarize themselves 

1000 with the rule requirements; 4.8 hours to complete the accreditation statement; and 5 hours to 

1001 complete the Quality Control Plan (see Exhibit 7-1). Exhibit 7-2 presents estimates of total 

1002 burden for each activity for the first three years of the final rule. These estimates are based on 

1003 Scenario I (50% of the active stock of renovators chooses online refresher training), which yields 

1004 a conservative estimate of reporting and recordkeeping burden.

1005 Wage rates for each category of personnel are derived with methods and from sources either 

1006 identical or very similar to those used in previous ICRs and economic analyses. Loaded wage 

1007 rates of $53.66 and $26.79 represent training provider wages for professional and clerical 

1008 workers, respectively. Wage and fringe benefits data are taken from the Employer Cost for 

1009 Employee Compensation data series published by the Bureau of Labor Statistics (BLS 2013). 

1010 Both the professional and clerical base wage rates are inflated to 2014 dollars by applying the CPI 

1011 for All Urban Consumers published by the Bureau of Labor Statistics (BLS 2014). The overhead 

1012 data is taken from Wage Rates for Economic Analyses of The Toxics Release Inventory Program

1013 (U.S. EPA 2002). The overhead loading factor is added to the benefits loading factor, and the 

1014 total is then applied to the base wage to derive the fully loaded wage. See Exhibit 7-3 for a 

1015 detailed derivation of the training provider loaded wage rates.

1016
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

7-3

Exhibit 7-1: Incremental RRP Training Provider Burden Hours per Activity for the Final Rule, Scenario I

Activity Number of 

Respondents

Number of Activities per Respondent Reporting Hours per Activity

Year 1 Year 2 Year 3 Professional Clerical Total

Accreditation1,2

Rule Familiarization 400 1.00 0.00 0.00 4.00 0.00 4.00

Accreditation Statement 400 1.00 0.00 0.00 3.80 1.00 4.80

Quality Control Plan 400 1.00 0.00 0.00 4.00 1.00 5.00

CDX Electronic Reporting

CDX Registration 34 1.00 0.10 0.10 0.84 0.00 0.84

Electronic Subscriber Agreements 34 1.00 0.10 0.10 0.25 0.00 0.25

Help Desk 34 1.00 0.10 0.10 0.34 0.00 0.34

Problem Resolution 34 0.03 0.00 0.00 1.00 0.00 1.00

Report Compromised Signature 34 0.00 0.01 0.01 0.40 0.00 0.40

Notification

Pre-training Notification 400 -7.40 -7.40 -7.40 0.00 0.20 0.20

Pre-training Renotification 400 -2.81 -2.81 -2.81 0.00 0.20 0.20

Post-training Notification and

Digital Photo 400 6.72 6.72 6.72 0.00 0.60 0.60

1Burden hour estimates per activity for an expedited online course application are assumed to be half the burden in the previously approved ICR EPA No. 1715.13. The hour 

estimates were rounded to one decimal place for this ICR.

2 Number of activities are from the previously approved ICR EPA No. 1715.13.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

7-4

Exhibit 7-2: Incremental RRP Training Provider Total Burden Hours for the Final Rule, Scenario I

Activity Number of 

Respondents

Burden per Respondent Total Burden

Year 1 Year 1 Year 1 Year 1 Year 2 Year 3 Average

Accreditation

Rule Familiarization 400 4.000 0.000 0.000 1,600.00 0.00 0.00 533.33

Accreditation Statement 400 4.800 0.000 0.000 1,920.00 0.00 0.00 640.00

Quality Control Plan 400 5.000 0.000 0.000 2,000.00 0.00 0.00 666.67

CDX Electronic Reporting

CDX Registration 34 0.840 0.084 0.084 28.56 2.86 2.86 11.43

Electronic Subscriber 

Agreements 34 0.250 0.025 0.025 8.50 0.85 0.85 3.40

Help Desk 34 0.340 0.034 0.034 11.56 1.16 1.16 4.63

Problem Resolution 34 0.030 0.000 0.000 1.02 0.00 0.00 0.34

Report Compromised Signature 34 0.000 0.004 0.004 0.00 0.14 0.14 0.09

Notification

Pre-training Notification 400 -1.480 -1.480 -1.480 -592.00 -592.00 -592.00 -592.00

Pre-training Renotification 400 -0.562 -0.562 -0.562 -224.80 -224.80 -224.80 -224.80

Post-training Notification and

Digital Photo 400 4.032 4.032 4.032 1,612.80 1,612.80 1,612.80 1,612.80

Total Burden 6,365.64 801.01 801.01 2,655.89
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

7-5

Exhibit 7-3: Loaded RRP Training Provider Wage Rates

Labor 

Category

Occupation 

Category (BLS)1 Date

Base

Wage1

Fringe 

Benefits

Benefits

(% of 

Wage)1

Overhead

(% of 

Wage)2

Wage 

Multiplier

Loaded 

Wages3

(a) (b) (c)

=(b)/(a)

(d) (e)

=1+(c)+(d)

(f)

=(a)*(e)

Professional Professional

and related 9/12 $33.96 $13.92 41% 17% 1.58 $53.66

Clerical Office and 

administrative 

support 9/12 $16.64 $7.32 44% 17% 1.61 $26.79

1 Bureau of Labor Statistics (BLS). (2013, Dec. 11). "Employer Costs for Employee Compensation - September 2013." 

Private industry workers, goods-producing and service-producing.

2 U.S. EPA (2002). Wage Rates for Economic Analyses of The Toxics Release Inventory Program, U.S. Environmental 

Protection Agency, Office of Environmental Information, Environmental Analysis Division, Analytical Support Branch.

3 Wage rates are rounded to the closest penny.

1017

1018 As shown in Exhibit 7-2, training providers would incur an incremental burden of 6,366 hours in 

1019 Year 1 and an incremental burden of 801 hours in Year 2 and Year 3. Exhibit 7-4 presents the 

1020 incremental costs to training providers associated with training program accreditation. Training 

1021 providers would incur incremental costs of $298,677 in Year 1 and incremental costs of $21,574

in Year 2 and Year 3. 1022 25 Wage rates of $53.66 and $26.79 are applied to the professional and 

1023 clerical hour burdens, respectively, to calculate costs. Exhibit 7-5 presents bottom line burden and 

1024 cost estimates. The average annual aggregate burden for training providers over three years is 

1025 2,656 hours. The average annual aggregate cost for training providers over three years is 

1026 $113,942.

 

25 The cost of training providers becoming accredited is incorporated into the tuition they charge their 

students, so the labor cost of the accreditation is not listed separately in the social cost estimate for the 

rule. But since the activity involves disclosing information, it is accounted for separately as part of the 

paperwork burden analysis.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

7-6

Exhibit 7-4: RPP Incremental Training Provider Cost for the Final Rule, Scenario I (2014$)

Activity

Reporting Costs per Activity Total Costs

Professional

($53.66/hour)

Clerical

($26.79/hour) Total Year 1 Year 2 Year 3 Average

Accreditation

Rule Familiarization $214.64 $0.00 $214.64 $85,856.00 $0.00 $0.00 $28,618.67

Accreditation Statement $203.91 $26.79 $230.70 $92,280.00 $0.00 $0.00 $30,760.00

Quality Control Plan $214.64 $26.79 $241.43 $96,572.00 $0.00 $0.00 $32,190.67

CDX Electronic Reporting

CDX Registration $45.07 $0.00 $45.07 $1,532.38 $153.24 $153.24 $612.95

Electronic Subscriber Agreements $13.42 $0.00 $13.42 $456.28 $45.63 $45.63 $182.51

Help Desk $18.24 $0.00 $18.24 $620.16 $62.02 $62.02 $248.07

Problem Resolution $53.66 $0.00 $53.66 $54.73 $0.00 $0.00 $18.24

Report Compromised Signature $21.46 $0.00 $21.46 $0.00 $7.30 $7.30 $4.87

Notification

Pre-training Notification $0.00 $5.36 $5.36 -$15,865.60 -$15,865.60 -$15,865.60 -$15,865.60

Pre-training Renotification $0.00 $5.36 $5.36 -$6,024.64 -$6,024.64 -$6,024.64 -$6,024.64

Post-training Notification and

Digital Photo $0.00 $16.07 $16.07 $43,196.16 $43,196.16 $43,196.16 $43,196.16

Total Costs $298,677.47 $21,574.11 $21,574.11 $113,941.90
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

7-7

Exhibit 7-5: Annual Respondent Burden and Cost Summary

Activity Number of 

Respondents

Number of Small 

Respondents1

Responses per 

Respondent

Total Annual 

Number of 

Responses

Burden per 

Response

Total 

Annual 

Burden

Total Annual 

Costs

Accreditation

Rule Familiarization 400 376 0.33 133.33 4.00 533.33 $28,618.67

Accreditation Statement 400 376 0.33 133.33 4.80 640.00 $30,760.00

Quality Control Plan 400 376 0.33 133.33 5.00 666.67 $32,190.67

CDX Electronic Reporting

CDX Registration 34 32 0.40 13.60 0.84 11.43 $612.95

Electronic Subscriber 

Agreements 34 32 0.40 13.60 0.25 3.40 $182.51

Help Desk 34 32 0.40 13.60 0.34 4.63 $248.07

Problem Resolution 34 32 0.01 0.34 1.00 0.34 $18.24

Report Compromised 

Signature 34 32 0.01 0.23 0.39 0.09 $4.87

Notification

Pre-training Notification 400 376 -7.40 -2,960.00 0.20 -592.00 -$15,865.60

Pre-training Renotification 400 376 -2.81 -1,124.00 0.20 -224.80 -$6,024.64

Post-training Notification and 

Digital Photo 400 376 6.72 2,688.00 0.60 1,612.80 $43,196.16

Total 2,655.89 $113,941.90

1 Consistent with the previously approved EPA ICR No. 1715.13, 94% of training providers are assumed to be small entities.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

7-8

1027 7.2 Unfunded Mandates Reform Act 

1028 Title II of the Unfunded Mandates Reform Act of 1995 (UMRA), 2 U.S.C. 1531-1538, directs agencies to 

1029 assess the effects of significant regulatory actions that impose Federal mandates on State, local, and tribal 

1030 governments, and the private sector. This action does not contain an unfunded mandate of $100 million or 

1031 more as described in UMRA, 2 U.S.C. 1531–1538. Therefore, this action is not subject to the 

1032 requirements of UMRA sections 202 or 205. 

1033 This action is also not subject to the requirements of UMRA section 203 because it contains no regulatory 

1034 requirements that might significantly or uniquely affect small governments. The rule amendments do not 

1035 preempt regulations by states, territories, or tribal governments that have their own authorized lead 

1036 programs, so those jurisdictions are not required to change their programs. Those training providers (both 

1037 those in the private sector, as well as State, local or tribal governments) that choose to offer online 

1038 refresher renovator training would incur costs for some activities (e.g., applying for a new accreditation) 

1039 but they would reduce other expenses (e.g., supplies for the hands-on training). However, there is no 

1040 requirement mandating that training providers offer an online refresher course. So training providers will 

1041 not choose to offer online training unless the savings of doing so exceed the costs, or if they can recover 

1042 their costs through tuition charges or other means.

1043 7.3 Executive Order 13132 – Federalism

1044 Executive Order 13132 (64 FR 43255, August 10, 1999) applies to policies that have substantial direct 

1045 effects on the States, on the relationship between the national government and the States, or on the 

1046 distribution of power and responsibilities among the various levels of government. This final rule does 

1047 not have substantial direct effects on the States, on the relationship between the national government and 

1048 the States, or on the distribution of power and responsibilities among the various levels of government.

1049 The rule amendments do not preempt regulations by states, territories, or tribal governments that have 

1050 their own authorized lead programs, so those jurisdictions are not required to change their programs. 

1051 Government entities can serve as training providers, and those training providers that choose to offer 

1052 online refresher renovator training would incur costs for some activities (e.g., applying for a new 

1053 accreditation) but they would reduce other expenses (e.g., supplies for the hands-on training). However, 

1054 there is no requirement mandating that training providers offer an online refresher course. So training 

1055 providers will not choose to offer online training unless the savings of doing so exceed the costs, or if 

1056 they can recover their costs through tuition charges or other means.

1057 7.4 Executive Order 13175 – Consultation and Coordination with Indian Tribal 

1058 Governments

1059 Executive Order 13175 (65 FR 67249, November 9, 2000) directs agencies to consult and collaborate 

1060 with tribal officials in Federal policy decisions that have tribal implications. This final rule does not have 

1061 tribal implications. The rule amendments do not preempt regulations by tribal governments that have their 

1062 own authorized lead programs, so those jurisdictions are not required to adopt these amendments. Tribal 

1063 governments can serve as training providers, and those training providers that choose to offer online 

1064 refresher renovator training would incur costs for some activities (e.g., applying for a new accreditation) 

1065 but they would reduce other expenses (e.g., supplies for the hands-on training). However, there is no 

1066 requirement mandating that training providers offer an online refresher course. So training providers will 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

7-9

1067 not choose to offer online training unless the savings of doing so exceed the costs, or if they can recover 

1068 their costs through tuition charges or other means.

1069 7.5 Executive Order 13045 - Children’s Health 

1070 Executive Order 13045 (62 FR 19885, April 23, 1997) applies to rules that are economically significant 

1071 and that concern health or safety risks that EPA has reason to believe may disproportionately affect 

1072 children. This final rule is not an economically significant regulatory action as defined by Executive 

1073 Order 12866. Furthermore, EPA interprets Executive Order 13045 as applying only to those regulatory 

1074 actions that concern health or safety risks, such that the analysis required under section 5-501 of the 

1075 Executive Order has the potential to influence the regulation. This final rule does not establish an 

1076 environmental standard intended to mitigate health or safety risks. Therefore, this action is not subject to 

1077 the requirements of Executive Order 13045.

1078 7.6 Executive Order 13211 – Energy Supply, Distribution, or Use

1079 Executive Order 13211 (66 FR 28355, May 22, 2001) addresses actions that effect the supply, 

1080 distribution, or use of energy. This final rule is not likely to have any adverse effect on the supply, 

1081 distribution, or use of energy.

1082 7.7 National Technology Transfer and Advancement Act

1083 Section 12(d) of NTTAA, 15 U.S.C. 272 note, directs agencies to use voluntary consensus standards in 

1084 their regulatory activities unless to do so would be inconsistent with applicable law or otherwise 

1085 impractical. Voluntary consensus standards are technical standards (e.g., materials specifications, test 

1086 methods, sampling procedures, and business practices) that are developed or adopted by voluntary 

1087 consensus standards bodies. This final rule does not involve technical standards.

1088 7.8 Executive Order 12898 – Environmental Justice

1089 Executive Order 12898 (59 FR 7629, February 16, 1994) establishes federal executive policy on

1090 environmental justice. Its main provision directs federal agencies, to the greatest extent practicable and 

1091 permitted by law, to make environmental justice part of their mission by identifying and addressing, as 

1092 appropriate, disproportionately high and adverse human health or environmental effects of their programs, 

1093 policies, and activities on minority populations and low-income populations in the United States. 

1094 This action does not directly affect the level of protection provided to human health or the environment. 

1095 The rule removes multi-jurisdiction fees for the LBP Activities program, revises the hands-on 

1096 requirement for refresher renovator training, and changes the notification requirements for training

1097 providers. However, renovators will still be required to take an 8 hour initial training that includes a 

1098 hands-on component; they will still have to take regular refresher training; the refresher training will have 

1099 to include a hands-on component every other training cycle; refresher training without a hands-on 

1100 component will only be valid for three years; and renovators will still have to comply with the work 

1101 practice requirements for renovation, repair or painting activities that disturb lead-based paint.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

8-1

1102 8. References

1103 Bureau of Labor Statistics (BLS). (2012, Mar. 29, 2013). "Occupational Employment Statistics -

1104 Occupational Employment and Wages, May 2012, 47-1011 First-Line Supervisors of 

1105 Construction Trades and Extraction Workers." Retrieved Jan. 30, 2014, 

1106 from http://www.bls.gov/oes/current/oes471011.htm#(2).

1107 Bureau of Labor Statistics (BLS). (2013, Dec. 11). "Employer Costs for Employee Compensation -

1108 September 2013." Retrieved Jan. 30, 2014, 

1109 from http://www.bls.gov/news.release/archives/ecec_12112013.pdf.

1110 Bureau of Labor Statistics (BLS). (2014). "Consumer Price Index - All Urban Consumers, U.S. City 

1111 Average (2004 to 2014)." CUSR0000SA0 Retrieved Mar. 21, 2014.

1112 Environmental Systems Resource Institute (ESRI) (2005). StreetMap North America (ESRI Data). 

1113 Redlands, CA.

1114 Environmental Systems Resource Institute (ESRI) (2013). ArcMap 10.2.1. Redlands, CA, ESRI.

1115 Internal Revenue Service (IRS). (2013, Dec. 6). "2014 Standard Mileage Rates." Retrieved Mar. 19, 

1116 2014, from http://www.irs.gov/2014-Standard-Mileage-Rates-for-Business,-Medical-and1117 Moving-Announced.

1118 NAHB Business Management & Information Technology (2012). Cost of Doing Business Study, 2012 

1119 Edition, NAHB BuilderBooks.com®.

1120 Office of Personal Management (OPM) (2014). 2014 General Schedule (GS) Locality Pay Tables: 

1121 WASHINGTON-BALTIMORE-NORTHERN VIRGINIA, DC-MD-VA-WV-PA. SALARY 

1122 TABLE 2014-DCB 

1123 SAS Institute Inc. (2015). SAS Software 9.4. Cary, NC, SAS Institute Inc., 2002-2012.

1124 U.S. EPA (2002). Wage Rates for Economic Analyses of The Toxics Release Inventory Program, U.S. 

1125 Environmental Protection Agency, Office of Environmental Information, Environmental Analysis 

1126 Division, Analytical Support Branch.

1127 U.S. EPA (2009). "ICR Handbook- EPA’s Guide to Writing Information Collection Requests."

1128 U.S. EPA (2011). ICR 1715.13: TSCA Sections 402 and Section 404 Training, Certification, 

1129 Accreditation and Standards for Lead-Based Paint Activities and Renovation, Repair, and 

1130 Painting. Washington, DC.

1131 U.S. EPA (2014a). "Federal Lead-Based Paint Program (FLPP) Database."

1132 U.S. EPA. (2014b, Jan. 15). "Lead-Based Paint Activities Professionals." Retrieved Mar. 7, 2014, 

1133 from http://www2.epa.gov/lead/lead-based-paint-activities-professionals#map.

1134 U.S. General Services Administration (GSA). (2014, Jan. 14). "Meals and Incidental Expenses (M&IE) 

1135 Breakdown." Retrieved Jan. 30, 2014, from www.gsa.gov/mie.

1136
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

A-1

1137 Training Courses Tuition Data

Exhibit A-1: Sample of Renovation (Re)certification Training Courses

Company1,2 Initial Training Refresher 

Training

Complete Hands-on Complete

1-4ABE.com $225.00 $150.00 

1st All Around Company $300.00 $180.00 

AAA Construction School, Inc. $225.00 $139.00 

ACC Environmental Consultants, Inc. $200.00 $100.00 

ACC Environmental Consultants, Inc. $225.00 $130.00 

Access Training $195.00 $150.00 

Accredited Environmental Solutions $295.00 $195.00 

AEHS, Inc. $140.00 

AEHS, Inc. $200.00 

Airtek Environmental Corp. $275.00 

Alchemy Lead Management $175.00 $125.00 

American Indoor Air Quality Assessment Service, Ltd $250.00 

AMWS / 1st All Around Company $300.00 $180.00 

Analytical Testing and Consulting Services, Inc. $150.00 

Apex Lead Solutions, L.L.C. $275.00 

Benchmark Environmental Training $165.00 

Benchmark Environmental Training $200.00 

Building Performance Center $195.00 

BWI Lead Safety RRP Institute $160.00 

Calypso Continuing Education $250.00 $125.00 

Cardno ATC $225.00 $135.00 

CDS Inspections & Beyond $175.00 $98.00 

CEI CNY Environmental Institute $150.00 $135.00 

CEI CNY Environmental Institute $175.00 

CES Environmental & Safety Training Center $290.00 $200.00 

Chem Scope $180.00 $125.00 

Childhood Lead Action Project $175.00 

Churchill Environmental $110.00 

Community College of Allegheny County $249.00 $149.00 

Contractor Training via Contractor Harbor3 $160.04 

ConTrax LLC $125.00 $99.00 

ConTrax LLC $199.00 

Cornerstone Training Institute $195.00 $135.00 

Criterion Environmental Training $225.00 $215.00 

Criterion Environmental Training $325.00 

Derby City Safety $225.00 $125.00 

ENCORP $131.25 $56.25 

ENCORP $175.00 $75.00 

ENCORP $90.00 

Environmental Compliance Management Corporation $150.00 

Environmental Education $145.00 

Environmental Management Institute $280.00 $180.00 

Environmental Management, Inc $285.00 

Environmental Solutions Association $250.00 $195.00 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

A-2

Exhibit A-1: Sample of Renovation (Re)certification Training Courses

Company1,2 Initial Training Refresher 

Training

Complete Hands-on Complete

ERC Lead Inc $275.00 

ETC Training Services Group $125.00 $100.00 

EverGreen Environmental Health & Safety, Inc $195.00 $130.00 

Evergreen Safety Council $240.00 

Ferguson: UAMS $150.00 

Fibertec Industrial Hygiene Services, Inc $175.00 $100.00 

Flatly Read LLC $150.00 

Florida State College at Jacksonville $175.00 $100.00 

Fuss & O'Neill EnviroScience, LLC $190.00 $100.00 

GEBCO Associates, LP $220.00 $200.00 

Global Green Property Solutions, LLC $195.00 $90.00 

Globeteck Group, Inc. $309.00 

Glynite Construction Services $150.00 $100.00 

Glynite Construction Services $200.00 $125.00 

Great Lakes Safety Training Center $180.00 

Greentree Environmental Services, Inc. $225.00 $165.00 

Greentree Environmental Services, Inc. $250.00 $175.00 

Greenville Technical College $215.00 $150.00 

Hazard Management Services, Inc $120.00 

High Environmental Health & Safety Consulting Services Ltd. $275.00 $195.00 

Highland Environmental Institute $250.00 $200.00 

Ideal Environmental Engineering, Inc $275.00 $180.00 

Industrial Hygiene Resources, Ltd $250.00 $150.00 

Ingraham Environmental $225.00 

Inspection Associates Independent Services $175.00 $100.00 

Institute for Environmental Education, Inc. $179.00 $150.00 

Institute for Environmental Education, Inc. $195.00 

Institute of Environmental Management and Technology, Inc $195.00 $145.00 

Jackson-Morris Environmental Technology and Consulting, LLC $245.00 $125.00 

L.G. White Safety Corporation $200.00 

Lake States Environmental, Ltd. $225.00 $150.00 

Lawrence Training School $180.00 

Lead Experts $189.00 $95.00 

Lead Renovator Training, LLC $200.00 $150.00 

Lead Safe, LLC $150.00 $115.00 

LeadSmart $225.00 $125.00 

LeadSmart $150.00 

LeadSmart $155.00 

Leadtec Services, Inc. $100.00 

LEW Corporation $200.00 $120.00 

Lianna Development Corporation Training Program (LDCTP) $190.00 $100.00 

Los Angeles Trade Technical College $150.00 

MDK Technology $195.00 $100.00 

Michigan Builders Test School / Michigan Institute of Real Estate $195.00 $99.00 

Middle Tennessee State University $100.00 

Midwest Environmental Consulting, LLC $195.00 $95.00 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

A-3

Exhibit A-1: Sample of Renovation (Re)certification Training Courses

Company1,2 Initial Training Refresher 

Training

Complete Hands-on Complete

Midwest Training Institute $175.00 $100.00 

Miller Environmental Group $225.00 

Mohawk Valley Community Action Agency, Inc $180.00 $120.00 

NATEC International, Inc $170.00 $105.00 

NATEC International, Inc $190.00 $120.00 

National Econ Corporation $185.00 $135.00 

New York Environmental Training Institute $275.00 $150.00 

New York State Weatherization Directors Assoc. $250.00 

North Star Center for Human Development $160.00 $110.00 

Northern Environmental Consultants, LLC $295.00 $145.00 

Northern Environmental Consultants, LLC $185.00 

Northern Environmental Consultants, LLC $200.00 

Northwest Independent Contractors Association (NICA) $250.00 $200.00 

Northwest Independent Contractors Association (NICA) $295.00 

Northwest Independent Contractors Association (NICA) $300.00 

NVL Laboratories $250.00 $150.00 

OAI, Inc $200.00 

Occupational Training & Supply, Inc. $300.00 $127.00 

Occupational Training and Supply OTS $301.00 $152.00 

Oklahoma Association of Community Action Agencies $200.00 $120.00 

Omaha Healthy Kids Alliance $175.00 $100.00 

Pathways-VA, Inc. $199.00 

Petroleum & Automation Consultants $250.00 $125.00 

Positive Energy Environmental Services $199.00 

Public Health and Safety Inc. $260.00 

Quality Environmental Solutions & Technologies, Inc $250.00 $175.00 

Real Estate Training for U $270.00 $220.00 

Rental Property Owners Association $150.00 $125.00 

Resolution, Inc. $225.00 $95.00 

RGA Environmental, Inc $225.00 $195.00 

RGA Environmental, Inc $275.00 

S&R Environmental Consulting, Inc $190.00 

Santa Fe Community College $225.00 

SCS Engineers $249.00 $89.00 

Southwest Missouri Safety Company, LLC $225.00 $95.00 

Sun City Analytical, Inc $275.00 $275.00 

Technical Environmental Services, Inc $200.00 

TES, LLC (Tennessee Environmental Services) $150.00 

The Environmental Institute $250.00 $125.00 

The Western Regional Lead Training Center $217.00 

The Westside Environmental Plan of Action Committee, LLC (WEPAC) $225.00 

Think People, Inc $300.00 

Titan Environmental Services, Inc. $150.00 $99.00 

TORF Environmental Management $250.00 

Truckee Meadows Community College $195.00 $95.00 

TSC Training Academy, LLC $285.00 $150.00 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

A-4

Exhibit A-1: Sample of Renovation (Re)certification Training Courses

Company1,2 Initial Training Refresher 

Training

Complete Hands-on Complete

UNC-Chapel Hill, NC Occupational Safety and Health Education and Research 

Center $195.00 

United Parents Against Lead's (UPAL's) Community Training Center $200.00 

University of Illinois-Hazardous Materials Training Program $259.00 

University of Tennessee $200.00 

University of Utah (Rocky Mountain Center for Occupational and Environmental 

Health) $195.00 

Unlimited Choices $200.00 $125.00 

Vortex, Inc $200.00 $125.00 

Weecycle Environmental Consulting $200.00 

Weecycle Environmental Consulting $250.00 

WeL Support Services LLC $199.00 

West Virginia University Safety and Health Extension $250.00 

Windy Ridge Enterprises, LLC $200.00 $150.00 

Wisdom and Associates, Inc. $350.00 $225.00 

Wunderlin Environmental Training Services LLC $209.00 $99.00 

ZOTA Safety Services, LLC $199.00 $135.00 

Number of Courses 138 3 97

Mean $217.01 $165.01 $136.97

Median $200.00 $160.04 $127.00

Minimum $100.00 $140.00 $56.25

Maximum $350.00 $195.00 $275.00

Standard Deviation $47.25 $27.84 $38.93

1 The values listed here represent the basic tuition costs reported by training providers. Some training providers offer price reductions, such as 

coupon codes or specials, discounts for students taking multiple different classes, discounts for multiple students from a firm taking the same 

course, referral discounts, and discounts (or even free training) for members of the training organization or area residents. Thus, the average 

tuition actually paid may be less than the estimates here. In addition, some training providers include lunch in the price of the tuition they 

charge for a training class. 

2 Some training providers are listed more than once because they offer training in multiple locations and the tuition differs by location. 

3 Initial hands-on training course tuition is derived by taking the tuition for the initial online classroom and hands-on training course and 

subtracting the online classroom component ($160.04 = $199.99 - $39.95). The online classroom component was developed by a third-party 

firm, Contractor Harbor.

1138
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

B-1

1139 Rule Amendment Options - Derivation of Estimates for the 

1140 Number of Individuals Seeking Recertification

1141 Because the regulatory options have different training intervals and cycle requirements for 

1142 hands-on training, the methodology to calculate the number of renovators taking the in-person 

1143 course (either by choice or as part of the periodic hands-on training requirement stipulated in the 

1144 option) and the online course differs by option. The annual number of renovators that are required 

1145 to take a course with a hands-on training component depends on the length of time and number of 

1146 training cycles for which the course without a hands-on training component is valid. A series of 

1147 equations are solved to estimate the steady state number of renovators taking the refresher 

1148 training course for the rule amendment options. These equations are presented in this appendix. 

1149 (i) Renovator Always Chooses In-person Refresher Training

1150 Option 1-4: Refresher training course with hands-on training valid for 5 years

1151 For Options 1 through 4, the following equation is used to estimate the steady state number of 

1152 renovators taking the refresher training course with hands-on training every 5-year training cycle:

1153 InP = (S / 5) * PREC5Y * (100% - EPCT)

1154 where, 

1155 InP = The number renovators taking the refresher training course with hands-on training 

1156 in the steady state, 

1157 S = The active stock of certified renovators (500,000), 

1158 PREC5Y = The percent of renovators with expiring certifications that become recertified 

1159 given a 5-year training cycle (70%), and

1160 EPCT = The online refresher training course scenario percentage (50%, 75%, or 90%).

1161 Thus, for Scenario I (50% of the active stock of renovators choose online refresher training), 

1162 InP = (500,000 / 5) * 70% * (100% - 50%) = 35,000.

1163 Note that under Option 1, renovators take the refresher training course without the hands-on 

1164 training component whether they travel to the training facility or take the course online because it 

1165 is assumed that the refresher hands-on training component is not offered by training providers.

1166 For the other options, the in-person course is assumed to always include the hands-on component.

1167 (ii) Renovator Chooses Online Refresher Training

1168 Option 1: Refresher training course without hands-on training valid for 5 years

1169 Under Option 1, the number of renovators taking the refresher training course online to become 

1170 recertified is estimated according to the following equation:

1171 E = (S / 5) * PREC5Y * (EPCT)

1172 where, 

1173 E = The number of renovators taking the refresher training course online, 

1174 S = The active stock of certified renovators (500,000), 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

B-2

1175 PREC5Y = The percent of renovators with expiring certifications that become recertified 

1176 given a 5-year training cycle (70%), and

1177 EPCT = The online refresher training course scenario percentage (50%, 75%, or 90%).

1178 Option 2: Refresher training without hands-on valid for 5 years; Hands-on required every 2 

1179 cycles 

1180 The following equation is used to estimate the steady state number of renovators taking the 

1181 refresher training course in person among those individuals taking the online training course 

1182 every other training cycle under option 2:

1183 InP = (PREC2nd * EPCT * I) / (100% - PREC2nd),

1184 where, 

1185 InP = The number of renovators taking the refresher training course in person (hands-on 

1186 cycle) among those individuals taking the online training course every other 

1187 training cycle,

1188 PREC2nd =The percent of renovators with expiring certifications that become recertified 

1189 for the second time given two 5-year recertifications periods 

1190 ((PREC2nd = 70% * 70% = 49%),

1191 EPCT = The online refresher training course scenario percentage (50%, 75%, or 90%), 

1192 and

1193 I = The number of initial certifications each year (30,000).

1194 Thus, for Scenario I (50 percent of the active stock of renovators choose online refresher training) 

1195 under Option 2, 

1196 InP = (49% * 50% * 30,000) / (100% – 49%) = 14,412.

1197 The following equation is used to estimate the number of renovators taking the refresher training 

1198 course online:

1199 E = ((PREC5Y * EPCT * I) + (PREC5Y * InP) - InP) / (100% - PREC5Y),

1200 where, 

1201 E = The number of renovators taking the refresher training course online (no hands-on 

1202 cycle),

1203 InP = The number of renovators taking the refresher training course in person (hands-on 

1204 cycle) among those individuals taking the online training course every other 

1205 training cycle,

1206 PREC5Y = The percent of renovators with expiring certifications that become recertified 

1207 given a 5-year training cycle (70%),

1208 EPCT = The online refresher training course scenario percentage (50%, 75%, or 90%), 

1209 and

1210 I = The number of initial certifications each year (30,000)
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

B-3

1211 Thus, for Scenario I (50 percent of the active stock of renovators choose online refresher training) 

1212 under Option 2, 

1213 E = ((70% * 50% * 30,000) + (70% * 14,412) - 14,412) / (100% - 70%)) = 

1214 20,588.

1215 Therefore, in the steady state under Option 2, Scenario I:

1216  One fifth of the active stock of 500,000 renovators (100,000 renovators) will have an 

1217 expiring recertification in a given year. Seventy percent of them (70,000 per year) are 

1218 estimated to seek recertification and the balance of 30,000 per year are assumed to exit 

1219 the industry and be replaced by newly certified renovators who take initial training. Of 

1220 the 70,000 renovators per year estimated to seek recertification, 50 percent (35,000 per 

1221 year) are assumed to always choose the in-person refresher training course under this 

1222 scenario.

1223  The other fifty percent (35,000) choose the online refresher training course. However, as 

1224 shown in Exhibit B-1, within that group of 35,000, more renovators take the online 

1225 training without hands-on training (20,588) than take the in-person training with hands1226 on training (14,412) in an average year because renovators drop out of the active stock 

1227 over time. For example, more renovators will have dropped out of the active stock 10 

1228 years after their initial training compared to 5 years after their initial training (and they 

1229 would take the online course without hands-on training 5 years after their initial training 

1230 and the hands-on in-person course 10 years after their initial training).

Exhibit B-1: Option 2, Scenario I- 50% of Active Stock Chooses Online 

Refresher Training 

Initial 

Certifications (I)

Renovator Always

Chooses In-person 

Refresher Training

Renovator Chooses Online Refresher Training

Cycle with 

Hands-on

(InP)

Cycle w/out Hands-on 

(E)

30,000 35,000 14,412 20,588

1231

1232 Option 3: Refresher training without hands-on valid for 2 or 3 years

1233 Under Option 3(a) (online course recertification valid for 2 years), the number of renovators 

1234 taking the online refresher training course to become recertified is estimated according to the 

1235 following equation:

1236 E = (S * EPCT * PREC5Y) / 2,

1237 Where, 

1238 E = The number renovators taking the refresher training course online,

1239 S = The active stock of certified renovators (500,000)

1240 PREC5Y = The percent of renovators with expiring certifications that become recertified 

1241 given a 5-year training cycle (70%), and

1242 EPCT = The online refresher training course scenario percentage (50%, 75%, or 90%).
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

B-4

1243 Under Option 3(b) (online course recertification valid for 3 years), the annual number of 

1244 renovators taking the online refresher training course to become recertified is estimated according 

1245 to the following equation:

1246 E = (S * EPCT * PREC5Y) / 3, 

1247 where, 

1248 E = The number renovators taking refresher training course online,

1249 S = The active stock of certified renovators (500,000)

1250 PREC5Y = The percent of renovators with expiring certifications that become recertified 

1251 given a 5-year training cycle (70%), and

1252 EPCT = Online refresher training course scenario percentage scenario percentage (50%, 

1253 75%, or 90%).

1254 Option 4: Cyclical hands-on requirement; online course training valid for 2 or 3 years

1255 The methodology for estimating the steady state number of recertifications for Options 4(a) 

1256 through 4(d) is similar to that of Option 2. Because the methodology is essentially the same for 

1257 Option 4(a) through Option 4(d), only the methodology for Option 4(a) will be described in 

1258 detail; however the equations for Options 4(b) through 4(d) are provided following Exhibit B-2.

1259 The following equation is used to estimate the steady state number of renovators taking the 

1260 refresher training course in person (hands-on cycle) among those individuals taking the online 

1261 training course every other training cycle:

1262 InP = (PREC2nd * EPCT * I) / (100% - PREC2nd),

1263 where, 

1264 InP = The number of renovators taking the refresher training course in person (hands-on 

1265 cycle) among those individuals taking the online training course every other 

1266 training cycle,

1267 PREC2nd = The percent of renovators with expiring certifications that become recertified 

1268 for the second time given one 5-year recertification period (PREC5Y = 70%)

1269 and one 2-year recertification period 

1270 (PREC2Y = [100% - (((100% - PREC5Y) / 5) * 2)])

1271 (PREC2nd = PREC5Y * PREC2Y = 61.6%),

1272 EPCT = Online refresher training course scenario percentage (50%, 75%, or 90%), and

1273 I = The number of initial certifications each year (30,000).

1274 Thus, for Scenario I (50 percent of the active stock of renovators choose online refresher training) 

1275 under Option 4(a),

1276 InP = (61.6% * 50% * 30,000) / (100% - 61.6%) = 24,063.

1277 The following equation is used to estimate the number of renovators taking the refresher training 

1278 course online under Option 4(a):

1279 E = ((PREC5Y * EPCT * I) + (PREC5Y * InP) - InP) / (100% - PREC2Y),
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

B-5

1280 where, 

1281 E = The number of renovators taking the refresher training course online (no hands-on 

1282 cycle),

1283 InP = The number of renovators taking the refresher training course in person (hands-on 

1284 cycle) among those individuals taking the online training course every other 

1285 training cycle,

1286 PREC5Y = The percent of renovators with expiring certifications that become recertified 

1287 given a 5-year training cycle (70%),

1288 PREC2Y = The percent of renovators with expiring certifications becoming recertified 

1289 given a two year recertification period 

1290 (PREC2Y = [100% - (((100% - PREC5Y) / 5) * 2] = 88%), 

1291 EPCT = Online refresher training course scenario percentage (50%, 75%, or 90%), and

1292 I = The number of initial certifications each year (30,000).

1293 Thus, for Scenario I (50 percent of the active stock of renovators choose online refresher training) 

1294 under Option 4(a), 

1295 E = ((70% * 50% * 30,000) + (70% * 24,063) - 24,063) / (100% - 88%)) = 

1296 27,343.

1297 In the steady state under Option 4(a) and what is termed the 50 percent scenario, the total number 

1298 of renovators choosing online refresher training each year (51,406) is greater than 50 percent of 

1299 the total number of renovators taking refresher training each year (86,406). This is because 

1300 renovators choosing online refresher training must be recertified more frequently. For example, a 

1301 renovator choosing online refresher training must take the training course twice every seven 

1302 years, whereas a renovator always choosing the in-person refresher training course must only take 

1303 the training course once every five years. However, 50 percent of the active stock of recertified 

1304 renovators is recertified by taking the refresher training course online every other training cycle.

1305 • The total number of recertified renovators that become recertified by taking online 

1306 refresher training is equal to 120,315 (24,063 renovators per year taking the in-person 

1307 training course, which is valid for five years) plus 54,686 (27,343 renovators per year 

1308 taking the online training, which is valid for two years), which equals 175,000 when 

1309 rounded to the ten thousand digit. The active stock of recertified renovators is equal to 

1310 350,000 (70 percent recertification rate for the 500,000 active stock of renovators). Thus, 

1311 50 percent of the recertified renovators take the online refresher training course 

1312 ((175,000 / 350,000)*100 = 50%).

1313 • Under Option 4(a) Scenario I, approximately 23 percent or 116,406 renovators out of the 

1314 active stock of 500,000 renovators will have an expiring recertification in a given year. 

1315 Approximately 74 percent or 86,406 of them are estimated to seek recertification and the 

1316 balance of 30,000 are assumed to leave the industry and be replaced by newly certified 

1317 renovators.

1318 o While 50 percent of the active stock chooses online refresher training, the 

1319 number of renovators in this group accounts for a higher percentage of the total 

1320 number of renovators seeking refresher training in a given year because 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

B-6

1321 renovators choosing online refresher training must be recertified more frequently 

1322 compared to renovators always choosing in-person refresher training. Of the 

1323 86,406 renovators estimated to seek recertification in a given year:

1324  Approximately 41 percent (35,000) are assumed to always choose the 

1325 in-person refresher training course and

1326  Approximately 59 percent (51,406) choose the online refresher training 

1327 course training cycle. However, as shown in Exhibit B-2,in an average 

1328 year, more renovators take the online training course without hands-on 

1329 training (27,343) than take the in-person training with hands-on training 

1330 (24,063) because renovators drop out of the active stock over time. For 

1331 example, more renovators will have dropped out of the active stock 7 

1332 years after their initial training compared to 5 years after their initial 

1333 training (and they would take the online course without hands-on training 

1334 5 years after their initial training and the hands-on in-person course 7 

1335 years after their initial training). 

Exhibit B-2: Option 2, Scenario - 50% of Active Stock Chooses Online

Refresher Training

Initial 

Certifications (I)

Renovator Always

Chooses In-person 

Refresher Training

Renovator Chooses Online Refresher Training

Cycle with 

Hands-on

(InP)

Cycle w/out Hands-on 

(E)

30,000 35,000 24,063 27,343

1336

1337 • Option 4(b) Equations (2 year interval and 3 cycles):

1338 InP = (PREC3rd * EPCT * I) / (100% - PREC3rd)

1339 E = ((PREC5Y * EPCT * I) + (PREC5Y * InP) - InP) / (100% - PREC2Y)

1340 PREC3rd = The percent of renovators becoming recertified for the third time 

1341 given one 5-year recertification period and two 2-year recertification 

1342 periods 

1343 (PREC3rd = PREC5Y * PREC2Y * PREC2Y = 54.2%)

1344 • Option 4(c) Equations (3 year interval and 2 cycles):

1345 InP = (PREC2nd * EPCT * I) / (100% - PREC2nd)

1346 E = ((PREC5Y * EPCT * I) + (PREC5Y * InP) - InP) / (100% - PREC3Y)

1347 PREC3Y = The percent of renovators becoming recertified given a 3-year 

1348 recertification period (100 - (((100 - PREC5Y) / 5) * 3))

1349 PREC2nd = The percent of renovators becoming recertified for the second time 

1350 given one 5-year recertification period and one 3-year recertification 

1351 period 

1352 (PREC2nd = PREC5Y * PREC3Y = 57.4%)

1353 • Option 4(d) Equations (3 year interval and 3 cycles):

1354 InP = (PREC3rd * EPCT * I) / (100% - PREC3rd)
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

B-7

1355 E = ((PREC5Y * EPCT * I) + (PREC5Y * InP) - InP) / (100% - PREC3Y)

1356 PREC3rd = The percent of renovators becoming recertified for the third time 

1357 given one 5-year recertification period and two 3-year recertification 

1358 periods 

1359 (PREC3rd = PREC5Y * PREC3Y * PREC3Y = 47.1%)
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

C-1

1360 Detailed Exhibits of Total Renovator Training Costs

1361 Exhibit C-1 presents the net present value and annualized costs under the baseline (refresher 

1362 training with the hands-on component valid for 5 years), over a ten year period from 2016

1363 through 2025. The costs are discounted using rates of 3 and 7 percent. The estimates in Exhibit 

1364 C-1 are used to estimate cost savings for Options 1 through 4, presented in Exhibit 3-10. Exhibit 

1365 C-2 through Exhibit C-9 present the net present value and annualized costs for Options 1 through 

1366 4.

Exhibit C-1: Baseline- Ten Year Net Present Value and Annualized 

Costs for Renovators Seeking Recertification (2014$)

Baseline1 In-person Training with

a Hands-on Component

Net Present Value

3% $167,502,475 

7% $137,917,857 

Annualized Costs (3% and 7%) $19,636,400 

1 It is estimated that 70,000 renovators seek refresher training each year under the baseline 

training schedule.

1367

1368 Exhibit C-2 presents the net present value and annualized costs under Option 1 (refresher training 

1369 course without the hands-on component valid for 5 years), over a ten year period from 2016

1370 through 2025, for in-person and online training. The costs are discounted using rates of 3 and 7 

1371 percent. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

C-2

Exhibit C-2: Option 1- Ten Year Net Present Value and Annualized Costs for 

Renovators Seeking Recertification (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Renovator Always 

Chooses In-person

Refresher Training

Online Refresher 

Training No 

Hands-on Cycle

Total

Refresher 

Training

Net Present Value

3% $70,208,687 $27,350,816 $97,559,503 

7% $57,808,290 $22,520,061 $80,328,351 

Annualized Costs

(3% and 7%) $8,230,600 $3,206,350 $11,436,950 

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Renovator Always 

Chooses In-person

Refresher Training

Online Refresher 

Training No 

Hands-on Cycle

Total

Refresher 

Training

Net Present Value

3% $35,104,344 $41,026,224 $76,130,568 

7% $28,904,145 $33,780,091 $62,684,236 

Annualized Costs

(3% and 7%) $4,115,300 $4,809,525 $8,924,825 

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Renovator Always 

Chooses In-person

Refresher Training

Online Refresher 

Training No 

Hands-on Cycle

Total

Refresher 

Training

Net Present Value

3% $14,041,737 $49,231,469 $63,273,206 

7% $11,561,658 $40,536,109 $52,097,767 

Annualized Costs

(3% and 7%) $1,646,120 $5,771,430 $7,417,550 

1372

1373 Exhibit C-3 presents the net present value and annualized costs under Option 2 (refresher training 

1374 course without the hands-on component valid for 5 years; refresher training course with the 

1375 hands-on component required every other training cycle), over a ten year period from 2016

1376 through 2025, for in-person and online training. The costs are discounted using rates of 3 and 7 

1377 percent.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

C-3

Exhibit C-3: Option 2- Ten Year Net Present Value and Annualized Costs for Renovators 

Seeking Recertification (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In-person

Refresher Training

Renovator Chooses Online Refresher Training Total 

Refresher 

Training

Cycle with 

Hands-on

Cycle w/out 

Hands-on Sub-Total

Net Present Value

3% $83,751,237 $34,486,367 $16,088,531 $50,574,898 $134,326,135

7% $68,958,928 $28,395,316 $13,246,943 $41,642,259 $110,601,187

Annualized Costs

(3% and 7%) $9,818,200 $4,042,854 $1,886,067 $5,928,921 $15,747,121 

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In-person

Refresher Training

Renovator Chooses Online Refresher Training Total 

Refresher 

Training

Cycle with 

Hands-on

Cycle w/out 

Hands-on Sub-Total

Net Present Value

3% $41,875,619 $51,729,550 $24,132,797 $75,862,347 $117,737,966

7% $34,479,464 $42,592,975 $19,870,415 $62,463,390 $96,942,854 

Annualized Costs

(3% and 7%) $4,909,100 $6,064,281 $2,829,100 $8,893,381 $13,802,481 

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In-person

Refresher Training

Renovator Chooses Online Refresher Training Total 

Refresher 

Training

Cycle with 

Hands-on

Cycle w/out 

Hands-on Sub-Total

Net Present Value

3% $16,750,247 $62,074,024 $28,959,825 $91,033,849 $107,784,096

7% $13,791,786 $51,110,387 $23,844,884 $74,955,271 $88,747,057 

Annualized Costs

(3% and 7%) $1,963,640 $7,276,969 $3,394,975 $10,671,944 $12,635,584 

1378

1379 Exhibit C-4 and Exhibit C-5 present the net present value and annualized costs under Option 3(a) 

1380 and 3(b) (refresher training course without the hands-on component valid for 2 or 3 years), over a 

1381 ten year period from 2016 through 2025, for in-person and online training. The costs are 

1382 discounted using rates of 3 and 7 percent.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

C-4

Exhibit C-4: Option 3(a)- Ten Year Net Present Value and Annualized Costs 

for Renovators Seeking Recertification (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In-person

Refresher Training

Online Refresher 

Training Cycle 

w/out Hands-on

Total

Refresher 

Training

Net Present Value

3% $83,751,237 $68,377,040 $152,128,277 

7% $68,958,928 $56,300,152 $125,259,080 

Annualized Costs 

(3% and 7%) $9,818,200 $8,015,875 $17,834,075 

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In-person

Refresher Training

Online Refresher 

Training Cycle 

w/out Hands-on

Total

Refresher 

Training

Net Present Value

3% $41,875,619 $102,565,559 $144,441,178 

7% $34,479,464 $84,450,228 $118,929,692 

Annualized Costs 

(3% and 7%) $4,909,100 $12,023,813 $16,932,913 

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In-person

Refresher Training

Online Refresher 

Training Cycle 

w/out Hands-on

Total

Refresher 

Training

Net Present Value

3% $16,750,247 $123,078,671 $139,828,918 

7% $13,791,786 $101,340,273 $115,132,059 

Annualized Costs 

(3% and 7%) $1,963,640 $14,428,575 $16,392,215 

1383
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

C-5

Exhibit C-5: Option 3(b)- Ten Year Net Present Value and Annualized Costs 

for Renovators Seeking Recertification (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In-person

Refresher Training

Online Refresher 

Training Cycle 

w/out Hands-on

Total

Refresher 

Training

Net Present Value

3% $83,751,237 $45,584,433 $129,335,670 

7% $68,958,928 $37,533,220 $106,492,148 

Annualized Costs 

(3% and 7%) $9,818,200 $5,343,886 $15,162,086 

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In-person

Refresher Training

Online Refresher 

Training Cycle 

w/out Hands-on

Total

Refresher 

Training

Net Present Value

3% $41,875,619 $68,377,040 $110,252,659 

7% $34,479,464 $56,300,152 $90,779,616 

Annualized Costs 

(3% and 7%) $4,909,100 $8,015,875 $12,924,975 

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In-person

Refresher Training

Online Refresher 

Training Cycle 

w/out Hands-on

Total

Refresher 

Training

Net Present Value

3% $16,750,247 $82,052,448 $98,802,695 

7% $13,791,786 $67,560,182 $81,351,968 

Annualized Costs 

(3% and 7%) $1,963,640 $9,619,050 $11,582,690 

1384

1385 Exhibit C-6, Exhibit C-7, Exhibit C-7, and Exhibit C-7 present the net present value and 

1386 annualized costs under Option 4 (cyclical hands-on training requirement; refresher training course 

1387 without the hands-on component valid for 2 or 3 years), over a ten year period from 2016 through 

1388 2025, for in-person and online training. The costs are discounted using rates of 3 and 7 percent.
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

C-6

Exhibit C-6: Option 4(a)- Ten Year Net Present Value and Annualized Costs for Renovators 

Seeking Recertification (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In-person

Refresher Training

Renovator Chooses Online Refresher Training Total 

Refresher 

Training

Cycle with 

Hands-on

Cycle w/out 

Hands-on Sub-Total

Net Present Value

3% $83,751,237 $57,580,172 $21,367,239 $78,947,411 $162,698,648

7% $68,958,928 $47,410,248 $17,593,315 $65,003,563 $133,962,491

Annualized Costs 

(3% and 7%) $9,818,200 $6,750,153 $2,504,892 $9,255,045 $19,073,245 

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In-person

Refresher Training

Renovator Chooses Online Refresher Training Total 

Refresher 

Training

Cycle with 

Hands-on

Cycle w/out 

Hands-on Sub-Total

Net Present Value

3% $41,875,619 $86,369,062 $32,051,249 $118,420,311 $160,295,930

7% $34,479,464 $71,114,387 $26,390,294 $97,504,681 $131,984,145

Annualized Costs 

(3% and 7%) $4,909,100 $10,125,089 $3,757,384 $13,882,473 $18,791,573 

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In-person

Refresher Training

Renovator Chooses Online Refresher Training Total 

Refresher 

Training

Cycle with 

Hands-on

Cycle w/out 

Hands-on Sub-Total

Net Present Value

3% $16,750,247 $103,643,353 $38,461,499 $142,104,852 $158,855,099

7% $13,791,786 $85,337,659 $31,668,353 $117,006,012 $130,797,798

Annualized Costs 

(3% and 7%) $1,963,640 $12,150,163 $4,508,861 $16,659,024 $18,622,664 

1389
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

C-7

Exhibit C-7: Option 4(b)- Ten Year Net Present Value and Annualized Costs for Renovators 

Seeking Recertification (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In-person

Refresher Training

Renovator Chooses Online Refresher Training Total 

Refresher 

Training

Cycle with 

Hands-on

Cycle w/out 

Hands-on Sub-Total

Net Present Value

3% $83,751,237 $42,490,592 $33,686,828 $76,177,420 $159,928,657 

7% $68,958,928 $34,985,820 $27,736,994 $62,722,814 $131,681,742 

Annualized Costs 

(3% and 7%) $9,818,200 $4,981,194 $3,949,124 $8,930,318 $18,748,518 

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In-person

Refresher Training

Renovator Chooses Online Refresher Training Total 

Refresher 

Training

Cycle with 

Hands-on

Cycle w/out 

Hands-on Sub-Total

Net Present Value

3% $41,875,619 $63,734,692 $50,531,023 $114,265,715 $156,141,334 

7% $34,479,464 $52,477,744 $41,606,134 $94,083,878 $128,563,342 

Annualized Costs 

(3% and 7%) $4,909,100 $7,471,650 $5,923,777 $13,395,427 $18,304,527 

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In-person

Refresher Training

Renovator Chooses Online Refresher Training Total 

Refresher 

Training

Cycle with 

Hands-on

Cycle w/out 

Hands-on Sub-Total

Net Present Value

3% $16,750,247 $76,481,630 $60,636,759 $137,118,389 $153,868,636 

7% $13,791,786 $62,973,293 $49,926,975 $112,900,268 $126,692,054 

Annualized Costs 

(3% and 7%) $1,963,640 $8,965,980 $7,108,478 $16,074,458 $18,038,098 

1390
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

C-8

Exhibit C-8: Option 4(c)- Ten Year Net Present Value and Annualized Costs for Renovators 

Seeking Recertification (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In-person

Refresher Training

Renovator Chooses Online Refresher Training Total 

Refresher 

Training

Cycle with 

Hands-on

Cycle w/out 

Hands-on Sub-Total

Net Present Value

3% $83,751,237 $48,362,750 $19,261,226 $67,623,976 $151,375,213 

7% $68,958,928 $39,820,826 $15,859,270 $55,680,096 $124,639,024 

Annualized Costs 

(3% and 7%) $9,818,200 $5,669,590 $2,258,003 $7,927,593 $17,745,793 

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In-person

Refresher Training

Renovator Chooses Online Refresher Training Total 

Refresher 

Training

Cycle with 

Hands-on

Cycle w/out 

Hands-on Sub-Total

Net Present Value

3% $41,875,619 $72,545,322 $28,891,839 $101,437,161 $143,312,780 

7% $34,479,464 $59,732,224 $23,788,905 $83,521,129 $118,000,593 

Annualized Costs 

(3% and 7%) $4,909,100 $8,504,525 $3,387,005 $11,891,530 $16,800,630 

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In-person

Refresher Training

Renovator Chooses Online Refresher Training Total 

Refresher 

Training

Cycle with 

Hands-on

Cycle w/out 

Hands-on Sub-Total

Net Present Value

3% $16,750,247 $87,053,429 $34,670,676 $121,724,105 $138,474,352 

7% $13,791,786 $71,677,880 $28,547,072 $100,224,952 $114,016,738 

Annualized Costs 

(3% and 7%) $1,963,640 $10,205,318 $4,064,461 $14,269,779 $16,233,419 

1391
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

C-9

Exhibit C-9: Option 4(d)- Ten Year Net Present Value and Annualized Costs for Renovators 

Seeking Recertification (2014$)

Scenario I: 50% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In-person

Refresher Training

Renovator Chooses Online Refresher Training Total 

Refresher 

Training

Cycle with 

Hands-on

Cycle w/out 

Hands-on Sub-Total

Net Present Value

3% $83,751,237 $31,916,400 $28,212,757 $60,129,157 $143,880,394 

7% $68,958,928 $26,279,262 $23,229,764 $49,509,026 $118,467,954 

Annualized Costs 

(3% and 7%) $9,818,200 $3,741,576 $3,307,396 $7,048,972 $16,867,172 

Scenario II: 75% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In-person

Refresher Training

Renovator Chooses Online Refresher Training Total 

Refresher 

Training

Cycle with 

Hands-on

Cycle w/out 

Hands-on Sub-Total

Net Present Value

3% $41,875,619 $47,874,600 $42,319,527 $90,194,127 $132,069,746 

7% $34,479,464 $39,418,894 $34,844,968 $74,263,862 $108,743,326 

Annualized Costs 

(3% and 7%) $4,909,100 $5,612,364 $4,961,140 $10,573,504 $15,482,604 

Scenario III: 90% of Active Stock Chooses Online Refresher Training

Renovator Always

Chooses In-person

Refresher Training

Renovator Chooses Online Refresher Training Total 

Refresher 

Training

Cycle with 

Hands-on

Cycle w/out 

Hands-on Sub-Total

Net Present Value

3% $16,750,247 $57,450,956 $50,782,651 $108,233,607 $124,983,854 

7% $13,791,786 $47,303,855 $41,813,318 $89,117,173 $102,908,959 

Annualized Costs 

(3% and 7%) $1,963,640 $6,735,005 $5,953,276 $12,688,281 $14,651,921 

1392