### *** EO 12866 Review Draft

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– Do Not Quote, Cite, or Release During Review ***

**RIN2070**

**- AK02_EO12866_Lead_MinorAmendments_FRM_EA_2015** 

**- 10** 

**- 20.docx**  

### 1



# Draft document as submitted for review under EO 12866 2

3

4

5

6



# Economic Analysis for the Lead

- B ased Paint Program 7



# Minor Amendments Final Rule 8

9

10



# RIN 2070

- AK02 11

12

13

14



# EO 12866 REVIEW DRAFT 15

16

17

18

19

October 2015 20

21

22

23

24

25

26

27

28

Economic and Policy Analysis Branch 29

Chemistry, Economics, and Sustainable Strategies Division 30

Office of Pollution Prevention, and Toxics 31

U.S. Environmental Protection Agency 32

1200 Pennsylvania Avenue 33

Washington, DC 20460 34

### *** EO 12866 Review Draft

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## Acknowledgement 35

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

EP

- W

- 08

- 0100. 37

38

39

### *** EO 12866 Review Draft

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i 

## Table of Contents 40

Executive Summary

................................ ................................ ................................ ................................ . ES

- 1 41

1. Introduction

................................ ................................ ................................ ................................ ...... 1

- 1 42

1.1 Regulatory and Programmatic Background

................................ ................................ ............. 1

- 1 43

1.2 Summary of Analytic Approach

................................ ................................ .............................. 1

- 2 44

1.3 Organization of This Report

................................ ................................ ................................ ..... 1

- 3 45

2. Affected Entities

................................ ................................ ................................ ................................ 2

- 1 46

3. Industry Cost Savings

................................ ................................ ................................ ...................... 3

- 1 47

3.1 Abatement Multi

- jurisdiction Registration Fee Amendment

................................ ................... 3

- 1 48

3.2 Renovator Refresher Training Course Amendment

................................ ................................ . 3

- 2 49

3.3 RRP Training Provider Notification Amend ment

................................ ................................ .. 3

- 16 50

3.4 Total Industry Cost Savings

................................ ................................ ................................ ... 3

- 29 51

3.5 Other Industry Costs

................................ ................................ ................................ .............. 3

- 30 52

4. Agency Costs

................................ ................................ ................................ ................................ ..... 4

- 1 53

5. Social Cost Savings

................................ ................................ ................................ ........................... 5

- 1 54

6. Small Entity Impact Analysis

................................ ................................ ................................ ......... 6

- 1 55

7. Other Impact Analyses

................................ ................................ ................................ ..................... 7

- 1 56

7.1 Paperwork Reduction Act

................................ ................................ ................................ ........ 7

- 1 57

7.2 Unfunded Mandates Reform Act

................................ ................................ ............................. 7

- 8 58

7.3 Executive Order 13132

– Federalism

................................ ................................ ....................... 7

- 8 59

7.4 Executive Order 13175

– Consultation and Coordination with Indian Tribal Governments

... 7

- 8 60

7.5 Executive Order 13045

- Children’s Health

................................ ................................ ............. 7

- 9 61

7.6 Executive Order 13211

– Energy Supply, Distribution, or Use

................................ ............... 7

- 9 62

7.7 National Technology Transfer and Advance ment Act

................................ ............................. 7

- 9 63

7.8 Executive Order 12898

– Environmental Justice

................................ ................................ ..... 7

- 9 64

8. References

................................ ................................ ................................ ................................ ......... 8

- 1 65

Tr aining Courses Tuition Data

................................ ................................ .......................... A

- 1 66

Rule Amendment Options

- Derivation of Estimates for the Number of Individuals 67

Seeking Recertification

................................ ................................ ................................ ........ B

- 1 68

Detailed Exhibits of Total Renovator Training Costs

................................ ...................... C

- 1 69

70

### *** EO 12866 Review Draft

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ii 

## List of Exhibits 71

72

Exhibit ES

- 1 : Regulatory Options

................................ ................................ ................................ ............. ES

- 2 73

Exhibit ES

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

thousand)

................................ ................................ ................................ ............................... ES

- 3 75

Exhibit ES

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

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

................................ .................... ES

- 6 77

Exhibit ES

- 4: Pre

- and Post

- training Notification Cost Savings for Regulatory Options Over a T en Year 78

Period, 2016 through 2025 (2014$)

................................ ................................ ...................... ES

- 8 79

Exhibit ES

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

(millions of 2014$)

................................ ................................ ................................ .............. ES

- 10 81

Exhibit ES

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

2014$)

................................ ................................ ................................ ................................ . ES

- 11 83

Exhibit 1

- 1: Assumed Duration of Existing RRP Training Courses

................................ ............................. 1

- 2 84

Exhibit 2

- 1: Lead

- based Paint Activities Individuals and Firms Applying for (Re)certification and Training 85

Providers Applying for (Re)accreditation from 2011

- 2013

................................ ..................... 2

- 1 86

Exhibit 2

- 2: Renovator Initial Certifications under the RRP Program Rule from 2009

- 10 through 2014 and 87

Expiring Certifications Under the Extension Rule

................................ ................................ ... 2

- 2 88

Exhibit 2

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

............. 2

- 2 89

Exhibit 3

- 1: Annual Multi

- jurisdiction Registration Fees for Individuals and Firms Applying for 90

(Re)certification, and Training Providers Applying for (Re)acc reditation

.............................. 3

- 1 91

Exhibit 3

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

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

........... 3

- 2 93

Exhibit 3

- 3 : Regulatory Options

................................ ................................ ................................ ................... 3

- 3 94

Exhibit 3

- 4: Refresher Training Requirements Under Regulatory Options

................................ ................. 3

- 4 95

Exhibit 3

- 5: Procedure to Estimate In

- person Classroom Refresher Training Course Tuition (2014$)

....... 3

- 6 96

Exhibit 3

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

................................ ................................ ...... 3

- 7 97

Exhibit 3

- 7 : Average Renovator Travel Cost (2014$)

................................ ................................ .................. 3

- 8 98

Exhibit 3

- 8: Summary of Refresher Training C osts (2014$)

................................ ................................ ........ 3

- 9 99

Exhibit 3

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

............................. 3

- 12 100

Exhibit 3

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

Ten Year Period, 2016 through 2025 (2014$)

................................ ................................ ...... 3

- 14 102

Exhibit 3

- 11: Pre

- training Notification Cost Savings for Regulatory Options Over a Ten Year Period, 2016 103

through 2025 (2014$)

................................ ................................ ................................ ............. 3

- 18 104

Exhibit 3

- 12: Initial and Recurring Burden Associated with Submitting Notifications via the CDX

........ 3

- 20 105

Exhibit 3

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

Notification Submissions via the CDX (2014$)

................................ ................................ .... 3

- 21 107

Exhibit 3

- 14: Post

- training Notification Cost Savings for Regulatory Options Over a Ten Year Period, 2016 108

through 2025 (2014$)

................................ ................................ ................................ ............. 3

- 24 109

Exhibit 3

- 15: Pre

- and Post

- training Notification Cost Savings for Regulatory Options Over a Ten Year 110

Period, 2016 through 2025 (2014$)

................................ ................................ ....................... 3

- 27 111

Exhibit 3

- 16: Total and Annualized Industry Cost Savings Over 10 Years (2014$)

................................ .. 3

- 29 112

### *** EO 12866 Review Draft

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iii Exhibit 4

- 1 : EPA Wage Rate

................................ ................................ ................................ ........................ 4

- 1 113

Exhibit 4

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

..... 4

- 2 114

Exhibit 5

- 1: Total and Annua lized Social Cost Savings Over 10 Years (2014$)

................................ ......... 5

- 1 115

Exhibit 7

- 1: Incremental RRP Training Provider Burden Hours p er Activity for the Final Rule, Scenario I 7

- 3 116

Exhibit 7

- 2: Incremental RRP Training Provider Total Burden Hours for the Final Rule, Scenario I

......... 7

- 4 117

Exhibit 7

- 3: Loaded RRP Training Provider Wage Rates

................................ ................................ ............ 7

- 5 118

Exhibit 7

- 4: RPP Incremental Training Provider Cost for the Final Rule, Scenario I (2014$)

.................... 7

- 6 119

Exhibit 7

- 5: Annual Respondent Burden and Cost Summary

................................ ................................ ...... 7

- 7 120

Exhibit A

- 1: Sample of Renovation (Re)certific ation Training Courses

................................ ..................... A

- 1 121

Exhibit B

- 1: Option 2, Scenario I

- 50% of Active Stock Chooses Online Refresher Training

................... B

- 3 122

Exhibit B

- 2: Option 2, Scenario

- 50% of Active Stock Chooses Online Refresher Training

.................... B

- 6 123

Exhibit C

- 1 : Baseline

- Ten Year Net Present Value and Annualized 124

Costs for Renovators Seeking Recertification (2014$)

................................ ........................... C

- 1 125

Exhibit C

- 2: Option 1

- Ten Year Net Present Value and Annualized Costs for Renovators Seeking 126

Recertification (2014$)

................................ ................................ ................................ ........... C

- 2 127

Exhibit C

- 3: Option 2

- Ten Year Net Present Value and Annualized Costs for Renovators Seeking 128

Recertification (2014$)

................................ ................................ ................................ ........... C

- 3 129

Exhibit C

- 4: Option 3(a)

- Ten Year Net Present Value and Annualized Costs for Renovators Seeking 130

Recertification (2014$)

................................ ................................ ................................ ........... C

- 4 131

Exhibit C

- 5: Option 3(b)

- Ten Year Net Present Value and Annualized Costs for Renovators Seeking 132

Recertification (2014$)

................................ ................................ ................................ ........... C

- 5 133

Exhibit C

- 6: Option 4(a)

- Ten Year Net Present Value and Annualized Costs for Renovators Seeking 134

Recertification (2014$)

................................ ................................ ................................ ........... C

- 6 135

Exhibit C

- 7: Option 4(b)

- Ten Year Net Present Value and Annualized Costs for Renovators Seeking 136

Recertification (2014$)

................................ ................................ ................................ ........... C

- 7 137

Exhibit C

- 8: Option 4(c)

- Ten Year Net Present Value and Annualized Costs for Renovators Seeking 138

Recertification (2014$)

................................ ................................ ................................ ........... C

- 8 139

Exhibit C

- 9: Option 4(d)

- Ten Year Net Present Value and Annualized Costs for Renovators Seeking 140

Recertification (2014$)

................................ ................................ ................................ ........... C

- 9 141

142

### *** EO 12866 Review Draft

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ES

- 1 

# Executive Summar y 143

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

for Lead

- b ased Paint Poisoning Prevention in Certain Residential Structures , codified at 40 CFR part 745 145

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

due to the final rule that amends the L ead

- B ased P aint (LBP) A ctivities rule for lead abatement and the 147

R enovation, R epair and P ainting ( RRP) rule

. These amendments eliminate EPA’s multi

- jurisdiction 148

registration fee in the abatement program

, amend the hands

- on requirement for the renovator refresher 149

training course , and revise the notification requireme nts for training providers

. 150

The rule removes the multi

- jurisdiction registration fee that individuals and firms pay for certification or 151

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

program

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

- administered 153

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

training

. In a typical year, individuals, firms, and trainin g providers apply to perform l ead

- based paint 155

activities or provide training in a total of 431 additional EPA

- administered jurisdictions

. Removing the $35 156

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

. 157

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

. Under 158

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

component (which may be taken in person or onl ine) and a hands

- on component (which must be taken in 160

person). 161

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

Re certification is valid for 5 years



### 162

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

hands

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

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

always choose to take training in person with a hands

- on component ) . The four options analyzed are: 166

Option 1: Refresher training without a hands

- on compo nent valid for 5 years ; 167

Option 2: Refresher training without a hands

- on component valid for 5 years

, refresher training 168

with a h ands

- on component required every other recertification period ; 169

Option 3: Refresher training without a hands

- on component valid for a shorter time frame ; and 170

Option 4: Refresher training without a hands

- on component valid for a shorter time frame ; 171

refresher training with a h ands

- on component required at repeating intervals

. 172

Options 3 and 4 include sub

- opt ions that vary both the length of time for which refresher training withou t a 173

hands

- on component is valid and the number of training cycles in which ha nds

- on training must be taken. 174

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

in Exhibit ES

- 1

. 176

### *** EO 12866 Review Draft

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ES

- 2 Exhibit ES

- 1 : Regulatory Options

Option Period for which

r efresher training

with hands

- on

component is valid Period for which

r efresher training

without hands

- on

component is valid Number of training

cycles in which

hands

- on training

must be taken Multi

jurisdiction

registration

fee removed Changes to

notificatio n

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 The final rule is Option 4(c) 

### 177

178

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

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

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

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

considered in the analysis

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

they are replaced by new entrants to the industry who take the 8

- hour initial training course. Thus

, a steady 184

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

Amending the refresher training course hands

- on requirement is expected to make online renovator 186

refresher training more attractive to training providers and r enovators. However, a s previously noted

, 187

renovators could still cho o se to take training in person with the hands

- on component. This analysis 188

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

trai ning course i f the hands

- on requirement is removed

. S cenarios I

, II , and III assume that 50 percent , 75 190

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

refresher training course when eligible

. (Note that under Options 2 and 4, renovators who choose to take the 192

refresher training course without a hands

- on component when eligible will have to take hands

- on training in 193

a subsequent training cycle

. ) This means that 50 percent , 25 percent , or 10 per cent of the active stock of 194

renovators will always choose to take their refresher training in person. Exhibit ES

- 2 presents the number of 195

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

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

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

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

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

per year than in

- person training for those options, even when equal number s of renovators are in the online 201

and in

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

effect)

. As a result, t he number of total a nnual trainings increases from 100,000 per year in the baseline to 203

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

taking an online class is valid for 3 years, compared to 5 years for an in

- person cla ss

. 205

206

### *** EO 12866 Review Draft

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ES

- 3 Exhibit ES

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

Scenario I: 50% of Active Stock Choose s 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 Cycles 1 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 Cycles 1 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

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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 Cycles 1 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

1 The final rule is Option 4(c).

### *** EO 12866 Review Draft

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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

Allowing refresher training to be taught without the hands

- on component will reduce average costs for 209

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

form of lower tuition. Refresher training wi thout a hands

- on component can be taken entirely online. 211

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

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

Depending on the regu latory option and the scenario, amending the hands

- on training requirement is 214

estimated to reduce the total costs of recertification by between approximately $0. 6 million and $ 12

. 2 215

million per year (s ee Exhibit ES

- 3 )

. The revisions to the hands

- on requirements in the final rule 216

(Option 4(c)) reduces costs by $1. 9 million to $3.4 million per year . Costs decrease despite the fact that the 217

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

online training) , because training without a hands

- on component is less expensive, particularly if it is taken 219

online (s ee E xhibit ES

- 3 )

. 220

### *** EO 12866 Review Draft

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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 ( mill ions 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 Cycles 1 $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 Cycles 1 $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 Cycles 1 $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

If the hands

- on training requirement is revised

, t raining providers currently accredited for the renovator 222

refresher training course are expected to offer online refresher training course s

. This would involve 223

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ES

- 7 licensing an existing online course or developing a ne w course, and applying to EPA for accreditation to 224

teach an online course. T raining providers that currently offer both in

- person courses and courses with an 225

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

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

tuition that training providers currently charge for in

- person courses recoups the costs they incur to provide 228

those courses

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

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

estimating social costs because doing so would double

- count these cost s , wh ich are already accounted for in 231

the tuition that renovators pay

. 232

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

training providers to become accredited for an online course

. It is assumed that 40 0 training providers 234

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

. Reviewing and 235

processing the additional accreditation applications is estimated to cost the EPA over $ 3 8 ,000 per year

. 236

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

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

providers would not be required to submit pre

- training notification s for online training courses that have no 239

in

- person component

, and would only be required to submit post

- training notification s for such courses 240

once a month via EPA’s Central Data Exchange (CDX) , an online data portal

. Exhibit ES

- 4 presents the 241

annual reduction in pre

- and post

- training notifications, as well as the total cost savings for each regulatory 242

option. The number of pre

- training notification s is estimated to decrease by 3 ,000 to 1 7 ,000 per year

, 243

depending on the option and scenario. The change in the annual number of post

- training notification s 244

ranges from a reduction of 4

, 2 00 to an increase of 3

, 2 00 , d epending on the option and scenario

. The final 245

rule

, Option 4 ( c)

, is estimated to reduce the total number of pre

- notification s by 4,100 to 7,300 per year, and 246

to increase the total number of post

- training notifications by 1,000 to 2,700 per year. 1 

### The change in 247

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

year. But w ithout the amendment to post

- training notification requirements, training providers would 249

submit a total of 5,600 additional post

- training notifications per year , which would cost $90,000 per year. 250

The rule requires training providers to include the expiration date of the renovator’s certification in the post

251

training notification, but the time required to do this is negligible

. T he rule also clarifies the requirements 252

for post

- training notifications for in

- person training courses. Training providers are already required to 253

submit post

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

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

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

Lastly, t he rule adds clarifying language explaining that training providers must follow the regulations

. This 257

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

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

. 259

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.

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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 Cycles 1 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 Cycles 1 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

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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 Cycles 1 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).

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ES

- 10 Exhibit ES

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

the implementation of the regulatory options

. Exhibit ES

- 6 presents the c ost s avings of the f inal rule and its 261

major components. Estimates in both e xhibits are discounted at rates of 3 and 7 percent

. 262

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 Cycles 2 $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 Cycles 2 $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 Cycles 2 $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

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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

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

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

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

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

a hands

- on component, beg in offering online training without the hands

- on component, or offer both types 269

of training. 270

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

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

expenses (e.g., supplies for the hands

- on training component). Because there is no requirement mandating 273

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

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

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

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

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

The rule will reduce compliance costs for renovators. Renovators that take a n online re fresher training 279

course without the hands

- on training component will save the time and expense needed to travel to a 280

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

classes without the hands

- on train ing component. Renovators who are e ligible to take an online refresher 282

training course without the hands

- on training component will have the flexibility to choose whether to 283

continue taking the class with the hands

- on training component or to trade the con venience and savings of 284

taking an online course without the hands

- on training component in exchange for a shorter recertification 285

period. 286

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1

- 1 

# 1. Introduction 287

This report assesses the cost savings expected to result from amendments to EPA’s Lead

- based P aint (LBP) 288

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

multi

- jurisdiction registration fee in the abatement program

, amend the hands

- on requirement from the 290

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

providers

. This chapter provides background information on EPA’s LBP r egulations

, a brief summary of 292

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



## 1.1 Regulatory and Programmatic Background 294

1.1.1 Abatement Multi

- j urisdiction Registration F ee 

### 295

In 1996 EPA promulgated final regulations for Lead

- based Paint Activities under TSCA § 402(a) that 296

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

child

- occupied facilities (61 FR 45778 , codified at 40 CFR part 745 )

. On June 9th, 1999, EPA amended the 298

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

and for training programs seeking EPA ( re ) accreditation

. The fee schedule created a multi

- jurisdiction 300

registration fee of $35 per discipline for each additional EPA

- administered jurisdiction (e.g., a state) in 301

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

§745.238 (c)(3))

. For purposes of this multi

- jurisdiction registration fee, an EPA

- administered jurisdiction 303

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

EPA Region

. The EPA

- administered jurisdictions for the lead abatement program are : 305

• States

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

Carolina, South Dakota, and Wyoming; 307

• U.S. territories

– American Samoa, Guam, and the Northern Marianas; and 308

• Tribal lands

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

Upper Sioux Community

. 310

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

Community

, have EPA

- authorized LBP abatement programs ( U.S. EPA 2014b )

. 312

1.1.2 Hands

- on Refresher T raining for Renovators 

### 313

In 2008

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

by RRP activities that disturb LBP in target housing and child

- occupied facilities (73 FR 21692)

. To 315

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

accredited by EPA (40 CFR §745.90)

. Individuals who have not previously been trained must complete an 317

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

- on 318

training (s ee Exhibit 1

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

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

course

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

§745.225 (e)(2)) and include a hands

- on training component ( 40 CFR §745.225 (e)( 3 ) ; s ee Exhibit 1

- 1 ) ). 322

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

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

Utah, Washington, and W isconsin are authorized to administer their own p rograms in lieu of the federal 325

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

of this analysis includes only those states

. 327

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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



## 1.2 Summary of Analytic Approach 329

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

. The 330

baseline c ost s to industry associated with the multi

- jurisdiction registration fee include a $35 fee for each 331

additional EPA

- administered jurisdictio n for which organizations apply to perform lead

- based paint 332

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

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

Offering refres her courses without a hands

- on training component reduces the training providers’ costs, 335

since they may be able to teach classes with a larger student

- to

- teacher ratio , they do not have to purchase 336

hands

- on training course supplies (such as EPA

- recognized test kits, disposable plastic drop cloths, tape, 337

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

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

. 339

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

travel cost to a training site to receive hands

- on training. Recertification costs are estimated to decrease 341

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

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

In order to offer online refresher training courses , training providers would licens e an exis ting online course 344

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

that currently offer both in

- person courses and courses with an online component typically charge the same 346

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

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

in

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

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

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

double

- count these cost s , which are already accounted for in the tuition that renovators pay

. 352

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

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

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

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

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

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

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

in training provider notifications may not be incremental. 360

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1

- 3 

## 1.3 Organization of This Report 361

The entities affected by the amendments are characterized in C hapter 2

. Chapter 3 includes the economic 362

analysis of cost saving s to regulated entities. Agency costs are discussed in Chapter 4

. A summary of the 363

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

additional impact s are described in Chapt er 7 . Cited references are listed in Chapter 8

. Appendix A contains 365

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

. Appendix 366

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

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

regulatory options. Note that all dollar values in this analysis are reported in 2014 dollars. 369

### *** EO 12866 Review Draft

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2

- 1 

# 2. Affected Entities 370

T he multi

- jurisdiction registration fee amendment may affect individual s , firm s

, and training providers 371

regulated by the L ead

- based Paint A ctivities rule , with the exception of non

- profit training providers 372

(which are exempt from the fee )

. T he renovator refresher training course amendment directly affects 373

individuals who must take a training course to comply with the RRP rule

. The number of entities affected 374

under both amendments is estimated from data in EPA’s Federal Lead

- based Paint Progra m (FLPP) 375

database ( U.S. EPA 2014a )

. 376

Exhibit 2

- 1 presents the number o f all applications submitted by individuals and firms engaging in lead

377

based paint activities, and all training providers offering lead

- based paint activities training courses

, from 378

2011 through 2013 (not just those applying to work in additional jurisdict ions)

. Exhibit 2

- 1 also presents 379

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

training providers are sought (re)accreditation

. 381

Exhibit 2

- 1 : Lead

- based Paint Activities Individuals and Firms Applying for (Re)certification

and Training Providers Applying for (Re)a ccreditation 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

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

by renovators who have taken an initial 8

- hour training course (including 2 hours of hands

- on training)

. 384

Renovators must take a 4

- hour refresher training course ( which currently includes a required hands

- on 385

component) every five years. Exhibit 2

- 2 presents the number of renovator certifications from 20 09

- 10 386

through 201 4

. Column 1 of Exhibit 2

- 2 lists the year the certification wa s issued , C olumn 2 lists number 387

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

ce rtifications under EPA’s April 2015 e xtension rule

. 2 

### T he number of certifications was highest in 2010 389

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

. 390

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

2009 through 2014, rounded to the nearest hundred thousand (500,000 renovators ; s ee Exhibit 2

- 2 )

. In the 392

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

to equal the average number of renovators certified each year from 2009

- 10 through 2014, rounded to the 394

nearest hundred thousand (100,000 renovators ; s ee Exhibit 2

- 2 ). Some trained renovators exit the industry 395

each year, and are replaced by new entrants to the industry who take the 8

- hour initial training course. 396

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

renovators certified in 2 01 4 and 201 5 , rounded to the nearest te n thousand (30,000; s ee Exhibit 2

- 2 ). 398

Thus, the number of renovators seeking refresher training each year equals 70,000 (100,000

- 30,000 ; s ee 399

2 

### On April 8 , 2015 EPA published a rule extend ing 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 re ceived certification between April 1, 2010 and March 31, 2011, have

one year added to their 5

- year certification.

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2

- 2 Exhibit ES

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

the analysis. 401

Exhibit 2

- 2 : Renovator Initial Cer tifications under the RRP Program Rule from 20 09

- 10 through 2014

and Expiring Certifications Under the Extension Rule

Year Certified Number of Initial

Certifications Expiration Year Number of Expiring

Certifications

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 ≈ 5 0 0, 000 ≈ 5 0 0, 000

Average C ertifications per Year ≈ 10 0

, 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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

provides a more accurate comparison of the options and also simplifies the analysis. 419

### *** EO 12866 Review Draft

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3

- 1 

# 3. Industry Cost Savings 420

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

estimates for the multi

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

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

amendment. Total cost savings of both amendments are summarized in Section 3.3.4

. A ten year 424

analytical period is used

. Net present value and annualized costs and savings are presented for this time 425

period using 3 and 7 percent discount rates

. 426



## 3.1 Abatement Multi

- j urisdiction Registration Fee A mendment 427

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

EPA for the purpose of adding additional EPA

- administered state jurisdictions to their certification or 429

accreditation. Once a regulated entity applies and is approved in the Lead

- based Paint Activities program, 430

they will be a ble to work in any EPA

- administered state , territory, or tribal land

. EPA’s multi

- jurisdiction 431

registration fee data for 2011 through 2013 are presented in Exhibit 3

- 1

. Column 2 and Column 3 of 432

Exhibit 3

- 1 present the total and annual average number of additional EPA

- administered jurisdictions for 433

wh ich organizations applied to perform lead

- based paint activities or provide training from 2011 through 434

2013 , respectively

. Note that non

- profit training programs are excluded from the analysis because they are 435

exempt from the multi

- jurisdiction registration fee. The a verage annual costs borne by regulated entities 436

are summarized in the last c olumn of Exhibit 3

- 1 and are calculated by applying the $35 multi

- jurisdiction 437

registration fee to Column 3

. Removing the multi

- jurisdiction fee would save individuals, firms, and 438

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

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

Annua l

Individuals 864 288 $10,080

Firms 403 134 $4,690

Training Providers (for

- profit) 27 9 $315

Total 431 $15,085



### 440

Exhibit 3

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

i ndividuals and f irms a pplying for ( r e)certification, and t raining p roviders a pplying for ( r e)accr editation

. 442

The cost savings are discounted using rates of 3 and 7 percent. 443

### *** EO 12866 Review Draft

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- 2 Exhibit 3

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

for (Re)certification, and T raining 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



## 3.2 Renovator Refresher Training Course A mendment 444

Costs and i ncremental training cost savings include tuition and travel cost

. The cost of the time spent on 445

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

course. 447

3.2.1 Training Options 

### 448

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

classroom and a hands

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

whereas the h ands

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

- on 451

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

and renovators. 3 

### Four regulatory options (some of which include sub

- optio ns) were considered to amend 453

this requirement, as depicted in Exhibit 3

- 3 and Exhibit 3

- 4

. E ach option provides renovators with an 454

alternative refresher training course that e ither partially or completely removes the hands

- on training 455

requirement. Options that maintain a hands

- on training requirement only require renovators to take 456

hands

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

course is valid and the training cycle requirements associated with each option

. The options vary based on 458

the length of time for which refresher training without a hands

- on training component is valid (2, 3, or 5 459

years, depending on the option) an d the number of training cycles in which hands

- on training must be 460

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

training course with out a hands

- on training component . R enovators would only be requi red to take a 462

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

component could be taken entirely online

. O ption s 2 through 4 allow renovators to take a refresher 464

training course without a hands

- on training component on a periodic basis; the length of time such 465

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

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 ha nds

- 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 renova tor 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

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3

- 3 refresher training with a hands

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

would be valid for five years

. The training frequencies are depicted in Exhibit 3

- 4

. When hands

- on 468

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

refresher training course online

. However, some renovators are assumed to choose to take an in

- person 470

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

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

Amending the hands

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

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

ch o ose to take training in person with a hands

- on training component. Thi s analysis considers three 475

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

h ands

- on requirement is removed: 477

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

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

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

This means that 50 percent

, 25 percent , or 10 percent , respectively, of renovators wi ll choose to take all of 481

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

a hands

- on component will have to take hands

- on training in a subsequent training cycle. 483

### *** EO 12866 Review Draft

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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

h ands

- 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 : R efr esher training course requir es 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 renovator s who took hands

- on training in the previous training cycle but choose to take

trai ning in person again

.

2 Course without hands

- on component : R efresher training course requir es only a classroom course component. Refresher t raining without a hands

- on training component

i s assumed to be taken online with one exception . F or Option 1, the ha nds

- 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 a n online course could still choose to take a course in person

.

4 The final rule is Option 4(c).

### *** EO 12866 Review Draft

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3

- 5 Note that i t is assumed that all in

- person refresher training courses under Options 2 through 4 would 484

include a hands

- on training component

. Under these options

, it would be possible for training providers to 485

offer two versions of in

- person refresher training, one with a hands

- on component and one without. 486

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

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

that training providers would simp lify their course offerings by including a hands

- on training component 489

with all in

- person refresher training courses

. Under Option 1 it is assumed that all in

- person courses 490

would be limited to a classroom component, and would not have a hands

- on training component. 491

3.2.2 Tuition 

### 492

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

hands

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

- on 494

training modules and instruc tors would not be limited by the six to one student

- teacher ratio requirement 495

for the hands

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

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

change in costs, the tuition of a refresher training course without the hands

- on training component is 498

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

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

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

refresher training course without the hands

- on component. 502

T he refresher training course tuition s are estimated for three types of refresher training course s : an 503

in

- person course with a hands

- on training component ( under the baseline and Options 2 through 4) ; an in

504

person course without a hands

- on train ing component (under Option 1); and an online course without a 505

hands

- on training component (under Options 1 through 4)

. Estimates are based on tuition data collected 506

from the websites of a sample of training providers offering refresher and/or initial reno vator training

. 507

T he t uition data and summary statistics can be found in Appendix A

. 508

A renovator is currently able to enroll in an in

- person refresher training course

, which consists of a 509

classroom and a hands

- on training component

. ( T he existing rule allows training providers to offer a 510

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

- on component is 511

taken in

- person

. While online versions of the classroom component for the 8

- hour initial training course 512

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

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

baseline

. 4 

### ) The mean tuition for an in

- person refresher course is $13 6

. 97 (see Appendix A )

. 515

The procedure to estimate the tuition for the in

- person course without a hands

- on component (under 516

Option 1 ) re lies on the current mean tuition for initial and refresher training course s

, and the current mean 517

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 w ho

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 o ption even without the changes to the hands

- on requirement.

### *** EO 12866 Review Draft

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3

- 6 tuition for the hands

- on component of an initial training course. The estimated tuition for an in

- person 518

refresher course with no hands

- on component is $91.61

. The s teps taken to produce this estimate are 519

detailed in Exhibit 3

- 5

. 520

It is assumed that the tuition for an online course is the same as an in

- person course without the hands

- on 521

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

courses whether the classroom component is taught in

- person or online. 5 

### (From the sample of training 523

provider course tuitions, five training providers listed tuition s for both in

- person and online initial 524

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

course for the same tuition. 6 

### ) However, it is worth noting that the online course could be less expensive. 526

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

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

refresher training course. 7 

### 529

Exhibit 3

- 5 : Procedure to E stimate I n

- person C las sroom R efresher T raining

C ourse T uition (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 H ands

- 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 C ourse $56.93 (B)

- (D)

(F) Incremental costs of 2 hours of hands

- on training $108.08 (C)

- (E)

(G) H ands

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

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

- (G)

(I) Class room 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

Exhibit 3

- 6 presents a summary of the estimated refresher training course tuitions

. The difference 531

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

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

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3

- 7 without a hands

- on training component ($91.61) is $45.36. This $45.36 in savings results from decreases 533

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 with out hands

- on $91.61

Online course $91.61



### 535

3.2.3 Travel Cost 

### 536

T ravel cost consist s of the cost for a renovator to travel to the training site, incidental expenses, and the 537

value of the time spent travel ing to and from the training site

. 538

Travel Distance and Trip Duration 

### 539

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

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

student

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

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

( ESRI 2013 )

. The addresses were geocoded using the ArcMap 10.2.1 Geocode Addresses tool , with 544

ESRI’s StreetMap North America Address Locator ( ESRI 2005 )

. Student

- facility pairs that could not be 545

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

code) were dropped from the dataset. The resulting dataset contained 316,346 student

- facility pairs. From 547

the 316,346 pairs, a random sample of 10,000 student

- facility pairs was drawn using SAS Software 9.4 548

( SAS Institute Inc. 2015 )

. Travel distance and trip duration were estimated using the ArcMap 10.2.1 549

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

student

- facility pa irs. 9 

### Student

- facility pairs where the distance between student and facility was 551

estimated to be zero were dropped from the analysis

. 10 

### The final dataset from which average travel 552

distance and trip duration were estimated consisted of 9,865 student

- facility pairs. ESRI’s StreetMap 553

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

. 11 

### The average 554

8 

### The cost of prov iding 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

- to

1 for the rest of the in

- person classroom course. The tui tion 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) fo r 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 possi ble 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 F LPP.

11 

### The tool used to estimate travel distance and trip duration requires a Network Dataset as an input.

### *** EO 12866 Review Draft

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3

- 8 one

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

one

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

### 556

Estimated Costs 

### 557

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

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

$0.56 per mile

, effective January 1 st 

### , 2014 ( IRS 2013 )

. The total roundtrip cost of travel is estimated to be 560

$ 43.68 (2 * 39 miles * $0.56

= $43.68)

. E xpenses comprise the cost of lunch and are estimated using the 561

Meals and Incidental Expenses Breakdown published by the G eneral S ervices A dministration

. These 562

e xpenses are estimated to be $14.17 and are calcul ated by averaging the six tiers of lunch reimbursement 563

rates representing the lower 48 states ( GSA 2014 )

. 13 

### 564

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

the cost of renovators’ time to travel to a training site

. The wage rate assigned to renovators is derived 566

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

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

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

wage rate of First

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

Bureau of Labor Statistics (BLS)

- Occupational Employment Statistics (OES)

. T he mean hourly wage 571

rate inflated to 2014 dollars is $ 31

. 12 for First Line Supervisors of Construction Trades and Ext raction 572

Workers ( BLS 2012 ; BLS 2014 )

. The base wage rate is inflated to 2014 dollars by applying the 573

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

2014 )

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

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

workers , implying a wage multiplier of 1.45 to account for benefits ( BLS 2013 )

. An overhead of 8.3 577

percent is derived from the 201 2 publication of the Cost of Doing Business ( NAHB Business 578

Management & Information Technology 2012 )

. By combining 1.45 and 8.3 percent , a multiplier of 1.53 579

is used to estimate a fully loaded hourly wage rate of $4 7

. 6 1 for renovators

. B ased on the 1.8 hour 580

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

training is estimated to be $ 85

. 70

. 582

Exhibit 3

- 7 summarizes the components of the travel cost to attend in

- person traini ng

. 583

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 classe s, 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

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3

- 9 3.2.4 Total Cost of Refresher Training 

### 585

Exhibit 3

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

and the total cost of travel

. 587

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 with out hands

- on $91.61 $143.55 $235.16

Online course $91.61 $0.00 $91.61



### 588

3.2.5 Number of Individuals Seeking Renovator Recertification 

### 589

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

mandatory in 2010, and a large number of renovators were trained that year

. By 2015, approximately 591

500, 000 renovators were certified (s ee Exhibit 2

- 2 ). To estimate the number of renovators expected to 592

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

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

the active stock each year and are replaced by newly certified renovators. 14 

### The ass umed dropout rate 595

approximates the number of initial certifications in 2013 and 2014 (s ee Exhibit 2

- 2 ) . Renovators are 596

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

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

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

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

- on 600

training, the methodology to calculate the number of renovators taking the in

- person course (either by 601

choice or as part of the periodic hands

- on requirement stipulated in the option ) and the online course 602

differs by option. The annual number of renovators that are required to take a course wit h a hands

- on 603

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

with out a hands

- on training component is valid

. The annual number of renovators taking the in

- person 605

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

percent )

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

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

Part (B) and described in detail in Appendix B

. The total number of renovators expected to seek refresher 609

training each year beginning in 2016 is presented in Exhibit 3

- 9 for each regulatory option. 610

(A) Existing Rule

- Number of Individuals Seeking Recertification 

### 611

Renovator Always Chooses In

- person Refresher Training 612

Baseline : Refresher training course with hands

- on training valid for 5 years 613

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

training course with hands

- on training every 5

- year training cycle: 615

InP = (S / 5) * PREC 5Y

= 70,000 renovators 616

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

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3

- 10 where, 617

InP = The number renovators taking the refresher course with hands

- on training in the steady 618

state

, 619

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

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

5

- year training cycle (7 0 % )

. 15 

### 622

(B) Rule Amendment Options

- Number of Individuals Seeking Recertification 

### 623

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

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

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

stock of renovators choose the online refresher training course (see Exhibit 3

- 9 ). A series of equations are 627

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

amendment options. Each equation is presented in Appendix B

. Under the rule amendments, it is assumed 629

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

become recertified, whether hands

- on training is required or not, and a portion of renovators seeking 631

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

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

- person 633

training would always include a hands

- on component. One exception is that under Option 1, training 634

providers are not expect ed to offer a refresher training course with hands

- on training because renovators 635

would never be required to take hands

- on training to become recertified. Therefore, under Option 1, 636

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

hands

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

renovators taking training with a hands

- on component take the classroom portion in person as well, rather 639

than taking a hybr id with the classroom portion online and the hands

- on portion in person. 640

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

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

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

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

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

in

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

in

- person training cohorts

. 647

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

of approximately 350,000 individuals. 16 

### Scenario I assumes that 50 percent of the initial cohort ( 175,000 649

renovators ) always selects the in

- person refresher training course and 50 pe rcent of the initial cohort 650

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

15 

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

percent of certified reno vators 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 3 0 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

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3

- 11 training course will have to be recertified after two years by taking the in

- person refresher training course, 652

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

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

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

50,000 (

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

course would take the refresher training course each year. 657

Under Option 4(a), the cohort that always selects the in

- person refresher training course will have to be 658

recertified after five years by again taking the in

- person refresher training course, which will be valid for 659

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

in ten years. Thus, the 175,000 renovators always selecting the in

- person refresher training course would 661

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

(

= 350,000 renovators / 10 y ears) from the cohort that always selects the in

- person refresher training 663

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

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

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

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

estimated to be 51,406 rather tha n 50,000 u nder Option 4(a) , Scenario I. 668

Summary of Average Annual Refresher Training Attendance 

### 669

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

presented in Exhibit 3

- 9 for each regulatory option and scenario

. 671

### *** EO 12866 Review Draft

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3

- 12 Exhibit 3

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

Scenario I: 50% of Active Stock Always Choose s 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 Cycles 1 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 Cycles 1 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 Cycles 1 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 The final rule is Option 4(c). 

### 672

673

### *** EO 12866 Review Draft

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3

- 13 3.2.6 Total Renovator Training Costs 

### 674

Exhibit 3

- 10 present s a summary of the net present value and annualized cost s and cost savings under 675

O ption s 1 through 4 , over a ten year period from 201 6 through 2025 , for in

- person and online training. 676

The costs are discounted using rates of 3 and 7 percent. See Appendix C for detailed exhibits presenting 677

baseline training costs and training costs associated with Options 1 through 4. 678

679

### *** EO 12866 Review Draft

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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 Cycles 1 $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 Cycles 1 $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

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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 Cycles 1 $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

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3

- 16 

## 3.3 RRP Training Provider Notification Amendment 680

3.3.1 Background 

### 681

Training providers are currently required to provide EPA with notifications regarding renovator training 682

courses (40 CFR 745.225). EPA must receive a pre

- training notification at least 7 business days prior to 683

the start date of any renovator training course. The training provider must notify EPA of any changes to 684

the date of the training course . If the new start date for the training course is prior to the original date, 685

EPA must receive an updated notification at least 7 business days prior to the new start date. If the new 686

start date for the training course is after the original date, EPA must receive an updated notification at 687

least 2 business days prior to the new start date. If the training course is canceled, EPA must receive an 688

updated notification at least 2 business days prior to the original start date. After the completion of the 689

training course

, the training provider must provide EPA with a list of the students who passed the course 690

along with a digital photo of each student . EPA must receive this post

- training notification no later than 691

10 business days after the completion of the training course

. The notifications can be submitted via U.S. 692

Posta l Service, fax, commercial delivery service, hand delivery, or by using EPA’s CDX. 693

3.3.2 Pre

- training N otification Amendment 

### 694

Under the amended rule

, EPA is removing the requirement for training providers to submit pre

- training 695

notification s for online courses wi thout a hands

- on training component

. Therefore, online training results 696

in a reduction in the number of pre

- training notification s that must be submitted. The number of 697

pre

- training notification s is estimated using FLPP pre

- training notification and renova tor certification 698

data. The total number of pre

- training notification s is estimated as the sum of original, update, and 699

cancelation pre

- training notification s. Because the number of courses offered (and thus the number of 700

pre

- training notification s) depend s on the annual number of certifications , and the estimated annual 701

number of renovator recertifications varies by option, the number of original pre

- training notification s 702

needs to be estimated as a function of the annual number of renovator certifications. The first step is to 703

calculate the ratio of the number of renovator certifications to the number of original pre

- training 704

notification s , which is equal to 5 ( based on FLPP data for the RRP program from 2012 to 2014 )

. Th e 705

number of c ancelation pre

- training notification s is equal to 2 5 percent of the number of original 706

pre

- training notification s

, and the number of update pre

- training notification s is equal to 1 3 percent of the 707

number of original pre

- training notification s (FLPP data from 2012 to 2014) . Thus, given the 70,000 708

baseline number of annual recertifications, there would be 1 9

, 320 total annual pre

- training notification s: 709

(70,000 / 5) * (1 00% + 25 % + 1 3 %) = 19,320

. 710

Exhibit 3

- 11 presents the cost savings for the pre

- training notification amendment under the different 711

options

. Column 2 is equal to the reduction in the total number of recertifications requiring hands

- o n 712

training ( the baseline (70,000)

- [ Column 2 + Column 3 of Exhibit 3

- 9 ] ) . Column 3 is equal to the 713

estimated reduction in the number of pre

- training notification s due to the amendment

. 17 

### 714

Column 4 is equal to the associated reduction in burden hours . It takes a clerical worker 0 .2 hours to 715

prepare and submit a pre

- training notification ( U.S. EPA 2011 )

. Column 5 is equal to the total cost 716

savings associated with reductions in burden , where the total cost of the burden is equal to the total 717

burden multiplied by the loaded wage rate of an RPP training provider clerical worker ($26.79 per hour, 718

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

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3

- 17 see Exhibit 7

- 3 for the derivation of the wage rate). Column 6 is equal to total cost savings of materials. 719

According to the FLPP pre

- training notification data from 2014, 91.6 percent of pre

- trainin g notifications 720

were submitted via CDX and 8.4 percent were faxed. (Less than 1 percent of pre

- training notifications 721

were mailed and less than 1 percent were hand delivered, thus both methods of delivery were assumed to 722

be 0 percent.) Each pre

- training no tification submitted by fax requires a document to be printed, which is 723

assumed to be equivalent to the cost of a photocopy ($0.10 per pre

- training notification ( U.S. EPA 724

2011 ) ) 18 

### . There is no cost of material for pre

- tr aining notification s submitted via CDX. Column 7 is equal 725

to the total annual cost savings and Column 8 and Column 9 are equal to the net present value of cost 726

savings discounted using rates of 3 and 7 percent, respectively. 727

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

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– Do Not Quote, Cite, or Release During Review ***

3

- 18 Exhibit 3

- 11 : Pre

- training N otification Cost Savings for Regulatory Options Over a Ten Year Period, 201 6 through 202 5 (2014$)

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

Option Reduction in Renovators

Choosing In

- person

Refresher Training Reduction in

P re

- 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 Cycles 1 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

P re

- 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 Cycles 1 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

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– Do Not Quote, Cite, or Release During Review ***

3

- 19 Exhibit 3

- 11 : Pre

- training N otification Cost Savings for Regulatory Options Over a Ten Year Period, 201 6 through 202 5 (2014$)

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

Option Reduction in Renovators

Choosing In

- person

Refresher Training Reduction in

P re

- 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 Cycles 1 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

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– Do Not Quote, Cite, or Release During Review ***

3

- 20 3.3.3 Post

- training N otification Amendment 

### 728

There are two changes to the rule that have competing effects on the notification burden: (1) options that 729

require mo re frequent refresher training result in more post

- training notifications, which increases post

730

training notification burden; and (2) post

- training notification burden is reduced because training 731

providers will be allowed to submit post

- training notifications for their online courses once per month. 732

Under some option/scenario combinations, these effects produce a net reduction in post

- trainin g 733

notification burden while under other option /scenario combinations , including the final rule

– Option 734

Option 4 ( c)

– these effects produce a net increase in the post

- training notification burden . Since the total 735

notification burden for pre

- and post

- train ing notifications combined is reduced

, the tables present the 736

burden changes in terms of the burden reduction. Thus, a negative burden reduction indicates an increase 737

in burden. 19 

### 738

Under the amended rule, training providers will be allowed to submit post

- t raining notification s for their 739

online course s once per month instead of after each course, although they will be required to submit them 740

via the CDX. 20 

### Allowing post

- training notifications to be submitted once per month is expected to reduce 741

training provider burden and material costs associated with preparing and submitting post

- training 742

notification s. Exhibit 3

- 12 presents the init ial burden associated with enrolling in the CDX system and the 743

recurring burden associated with employee turnover and compromised or surrendered electronic 744

signa tures. For this analysis, managerial and technical worker classes have been combined into the 745

p rofessional worker class to be consistent with economic analyses and ICRs related to the RRP rule. 746

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

Exhibit 3

- 13 presents the net present value and annualized costs of using the CDX to submit notifications. 748

Column 2 and Column 3 of Exhibit 3

- 13 are calculated by taking the product of the clerical and 749

professional burden and their wage rates , $2 6.79 and $53.66, respectively (s ee Exhibit 7

- 3 for the 750

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, tr aining 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 derivation of the wage rates) . Column 4 is equal to the product of training providers offering online 751

courses ( 400 ) and 8

. 4 percent

- the percent of training providers that currently do not submit notifications 752

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 Signature 1 $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

The number of post

- training notification s associated with in

- person recertifications is equal to the number 756

of in

- person courses, which is estimated using FLPP pre

- training notification and certification data for the 757

RRP program from 20 12 to 2014. Because the number of classes offered (and thus the number of 758

post

- training notification s) depends on the annual number of certifications , and the estimated annual 759

number of renovator re certifications varies by option, the number of post

- training notification s needs to 760

be estimated as a function of the number of renovator certifications . The first step is to calculate the rat io 761

of the number of renovator certifications to the number of course s

. The number of courses is equal to the 762

number of original pre

- training notification s minus cancelation pre

- training notification s. The average 763

number of renovator certifications per cour se from 20 12 to 2014 is 7

. That is, the average class size is 7 764

21 

### Four hundred training providers i s 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 accred itation 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 curre ntly 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 students. Thus, given 35 ,000 certifications, there would be 5

, 000 courses and therefore 5

, 000 765

post

- training notification s ( 35 ,000 / 7 = 5,000 )

. 766

The number of post

- training notification s associated with online recertifications is equal to the product of 767

the number of training providers offering online recertifications and th e number of annual submissions. 768

Four hundred training providers are assumed to offer online refresher training course s . Under the 769

amended rule they would only be required to submit post

- training notification s once a month (i.e., 12 770

times a year ) . Thus, training providers are estimated to submit 4

, 8 00 post

- training notification s per year 771

for online classes regardless of w hich regulatory option is selected (12 * 400 = 4,800 )

. 22 

### Without the 772

amendment to post

- training notification requirements, training providers would submit approximately 773

10,400 post

- training notification per year, or 5,600 additional notifications per year. This is estimated by 774

assuming that 400 training providers would submit online post

- training notifications every 14 days 23 

### : 775

Online post

- training notifications = 400 training providers * � 365 day

year

14 day

submission �

= 10,400 submission

year . 

### 776

Assuming each post

- training notification takes a clerical worker 0.6 hours to prepare and submit at a 777

loaded wage rate of $26.79 per hour, the amendment would save training providers approximately 778

$90,000 per year ($90,000 ≈ $26.79 /hr * 5,600 notifications/yr * 0.6 hours/not ification )

. 779

The rule requires training providers to include the expiration date of the renovator’s certification in the 780

post

- training notification, but the time required to do this is negligible. T he rule also clarifies the 781

requirements for post

- training notifications for in

- person training courses. Training providers are already 782

required to submit post

- training notifications for renovator training. 24 

### The correction to the regulatory text 783

clarifies that the notifications must be submitted no later than ten business days following course 784

completion. The amendment may affect the timing of when the notifications are submitted, but not the 785

cost of compliance. Thus, and b ecause this requirement is already accounted for in a previous economic 786

analyses and Informat ion Collection Requests (ICRs) for the lead program, there is no incremental 787

burden

, cost , or impact estimated

. 788

Exhibit 3

- 14 presents the cost savings of the changes to the post

- training notification requirements. 789

Column 2 is equal to the reduction in the total number of recertifications requiring hands

- on training 790

(baseline

- [ Column 2 + Column 3 of Exhibit 3

- 9 ] ). Column 3 is equal to the estimated reduction in the 791

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 regulator y 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 pro vide notification

following completion of renovator, dust sampling technician, or lead

- based paint activities courses” and

745.225(c)(14)(ii)(D)(6) requires that f or renovator or dust sampling technician courses, the notification must

include a digital pho tograph of the student

.

### *** EO 12866 Review Draft

– Deliberative

– Do Not Quote, Cite, or Release During Review ***

3

- 23 number of post

- training notification s. For example, Option 4(c) , Scenario I, is associated with a reduction 792

of 14,789 renovators taking the in

- person refr esher training course with the hands

- on training component : 793

14,789 = 70,000 (baseline)

- [35,000 + 20,211 from Exhibit 3

- 9 ]. 794

This equates to a reduction of 2,113 po st

- training notifications associated with the in

- person refresher 795

training course : 796

2,113 post

- training notifications or courses

= 14,789 renovators / 7 students per course. 797

However, there are 4,800 additional post

- training notifications associated with re fresher training courses 798

taught online. Thus, the net reduction in post

- training notifications is equal to

- 2,687 ( i.e., there is a net 799

increase of 2,687 post

- training notifications compared to the baseline ) . As illustrated in Exhibit 3

- 14

, 800

some options result in additional post

- training notifications (e.g., Option 4 ( c ) , Scenario I) while other 801

options result in a reduction in post

- training notifications (e.g., Option 1, Scenar io I) relative to the 802

number of post

- training notifications represented in the baseline

. Column 4 equal s the reduction in post

803

training notification burden. Note that the burden and associated costs of enrollment into the CDX are 804

only included in the last four columns. It takes a clerical worker an average of 0

. 6 hours to prepare and 805

submit a post

- training notification ( U.S. EPA 2011 )

. Thus, Option 4(c), Scenario I, is associated with a 806

reduction in burden equal to

- 1,61 2 hours (i.e., an increase in burden) : 807

- 1

, 61 2 tot. reduction in burden

=

- 2,687 post

- training notifications * 0

. 6 hours of burden. 808

Column 5 is equal to the total cost savings of the reductions in burden, where the total cost of the burden 809

is equal to the total reduction in burden multiplied by the loaded wage rate of an RPP training provider 810

clerical worker ($26.79 per hour, see Exhibit 7

- 3 for the derivation of the wage rate). Column 6 is equal to 811

total cost savings of materials. According to the FLPP pre

- training notification data from 2014, 91.6 812

percent of pre

- training notifications were submitted via CDX a nd 8.4 percent were faxed. (Less than 1 813

percent of pre

- training notifications were mailed and less than 1 percent were hand delivered, so the 814

analysis makes the simplifying assumption that pre

- training notifications are either submitted via CDX or 815

faxed. E ach post

- training notification submitted by fax requires a document to be printed, which is 816

assumed to be equivalent to the cost of a photocopy ($0.10 per post

- training notification ( U.S. EPA 817

2011 ) ). There is no cost of material for post

- training notification s submitted via CDX. Thus, Option 4(c), 818

Scenario I, is associated with a reduction in the cost of materials equal to $18: 819

$18

= 2,113 reduction in in

- person post

- training notifications * 8.4 percent of 820

post

- training notifications faxed * $0.10 cost per post

- training notification faxed. 821

Column 7 and Column 8 are equal to the annual ized cost savings

, which account for CDX costs, 822

discounted using rate s of 3 and 7 percent, respectively. Column 9 and Column 10 are equal to the net 823

present value of savings, including CDX costs, discounted using rate s of 3 and 7 percent, respectively. 824

When training providers submit notifications via CDX, it also reduces the time and expense needed for 825

EPA to enter the information into the FLPP database

. 826

827

### *** EO 12866 Review Draft

– Deliberative

– Do Not Quote, Cite, or Release During Review ***

3

- 24 Exhibit 3

- 14 : Post

- training N otification 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 Cycles 1 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 Cycles 1 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 N otification 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 Cycles 1 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 3.3.4 Summary of Notification Cost Savings 

### 828

Exhibit 3

- 15 presents a summary of pre

- and post

- training notification cost savings associated with the 829

amendment s to the training provider notification requirements. Depending on the option and scenario, the 830

effect of these changes is estimated to range from an increase in costs of $36,355 to a cost savings of 831

$1 60,388 ( annualized using a rate of 3 percent ; s ee Exhibit 3

- 15 ). For the final rule, Option 4(c), the result 832

is estimated to range from an increase in costs of $21,793 per year to a cost savings of $22,908 per year

. 833

### *** 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 Cycles 1 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 Cycles 1 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 Cycles 1 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 

## 3.4 Total Industry Cost Savings 835

The net present value and annualized industry cost savings for the amended rule are summarized in 836

Exhibit 3

- 16

. These savings reflect a 1 0 yea r period from 201 6 through 20 25 , and are discounted using 837

rate s of 3 and 7 percent

. 838

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 Cycles 1 $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 Cycles 1 $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 Cycles 1 $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 

## 3.5 Other Industry Costs 841

3.5.1 Abatement Multi

- jurisdiction Registration Fee Amendment 

### 842

EPA does not anticipate other direct or indirect impacts resulting from the final rule that would cause 843

entities regulated under the abatement program to experience increases or reductions in their costs

. 844

3.5.2 Renovator Refresher Trai ning Course Amendment 

### 845

Individual t raining providers offering RRP training courses could be negatively impacted by the final rule 846

if (1) their profit margins are lower for the online course , or ( 2 ) they lose market share with the 847

introduction of the online course

. 848

Under the regulatory options , a much larger portion of renovators are expected to enroll in the online 849

refresher training course t han the online component of the initial training course . This is because 850

renovators would not have to travel or travel as frequently to a training facility if the hands

- on refresher 851

training requirement were amended

. (By contrast, renovators taking the initial training course will still 852

have to travel to take the hands

- on portion.) If training providers do not de velop their own online course

, 853

they must contract a third

- party firm to offer the course online. In this scenario, training providers will 854

incur costs in the form of fees paid to the third

- party firm s to develop and administer the online course s

. 855

At the sa me time

, offering refresher courses without a hands

- on training component reduces the training 856

providers’ costs, since they may be able to teach classes with a larger student

- to

- teacher ratio , they do not 857

have to purchase hands

- on training course supplies (such as EPA

- recognized test kits, disposable plastic 858

drop cloths, tape, electrostatically charged cleaning cloths, disposable wet cleaning wipes, garbage bags, 859

and so on) for each student in every class, and there may be savings in travel and facility ren tal costs for 860

traveling training

. T raining providers will not choose to offer online training unless the savings from 861

doing so exceed the costs or if they can recover their costs through tuition charges or other means. 862

M any uncertainties and data gaps exist about the extent to which individual training provider profit 863

margins might change

. Some training providers may exit the market, others may add market share, and 864

new entrants might also seek training provider accredita tion. While there would not be a net loss to the 865

economy if market shares shift , training providers unable to compete in the online market might 866

experience reduced profits. Alternatively, if many renovators choose to take refresher training from the 867

provid er of their initial training, there may be little change in market shares. 868

869

870

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- 1 

# 4. Agency Costs 871

EPA will incur costs resulting from the new rule associated with reviewing the expedited online course 872

applications submitted by training pro viders to attain accreditation. It is estimated to take an average of 4 873

hours apiece for an Agency employee to review each of the 400 applications

. The base wage rate of the 874

federal government employee reviewing applications is taken from the 2014 General Schedule (GS) 875

Locality Pay Table for Washington

- Baltimore

- Northern Virginia , published by the Office of Personnel 876

Management (OPM) . A loaded wage rate of $78.13 is then derived by applying a 1.6 fringe benefits and 877

overhead multiplier to the base wage rate of a GS

- 13 Step 5 government employee ( see Exhibit 4

- 1 ) 878

( OPM 2014 )

. The 1.6 fringe benefits and overhead multiplier is taken from the ICR Handbook

- EPA’s 879

Guide to Writing Information Collection Requests , published in 2009 ( U.S. EPA 2009 )

. 880

Exhibit 4

- 1 : EPA Wage Rate

Labor

Category Date Base

Wage 1 Fringe Benefits and

Overhead Multiplier 2 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

- VA

WV

- PA. SALARY TABLE 2014

- DCB

.

2 U.S. EPA (2009). "ICR Handbook

- EPA’s Guide to Writing Information Collection

Requests."



### 881

Exhibit 4

- 2 presents net present value and annualized cost accrued by EPA over a ten year period from 882

201 6 through 20 25

, under the final rule. C osts are discounted using rates of 3 and 7 percent. It is not 883

known how many training providers will only offer refresher training online and how many will maintain 884

dual accreditations (one for in

- person train ing and one for online training). Therefore, it is unknown 885

whether there will be a change in the number of reaccreditation applications after 201 6

. If most training 886

providers begin offering refresher training only onl ine

, EPA’ s work load for reviewing accreditation 887

applications would not change much in future years since the training providers would be substituting an 888

online accreditation for one that is in

- person

. Conversely, if most training providers begin offering 889

refresher train ing online in addition to the in

- person course, EPA’s work load for reviewing accreditation 890

applications would increase and remain higher in future years. To produce more conservative cost 891

estimates, it is assumed that training providers maintain accredita tion for both the online and in

- person 892

refresher training courses. As a result, the analysis considers EPA’s costs for reviewing additional 893

accreditation applications through 2025. Course accreditation is valid for four years, thus it is assumed 894

that each of the 400 training providers will apply for reaccreditation of their online refresher training 895

course in 2020 and 2024. 896

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- 2 Exhibit 4

- 2 : Ten Year Net Present Value and Annualized Cost to EPA Under the Final Rul e (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

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- 1 

# 5. Social Cost Savings 898

The estimated total social cost savings is equal to the sum of industry cost savings less A gency costs. 899

Exhibit 5

- 1 presents the net present value and annualized equivalent value of expected cost savings to 900

society over a ten year period ranging from 201 6 to 20 25

. Estimates are discounted using rates of 3 and 7 901

percent

. 902

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 Cycles 1 $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 Cycles 1 $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 Cycles 1 $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

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- 1 

# 6. Small Entity Impact Analysis 904

The Regulatory Flexibility Act (RFA) of 1980, amended by the Small Business Regulatory Enforcement 905

Fairness Act (SBREFA) of 1996, requires regulators to assess the effects of regulations on small entities 906

i ncluding businesses, nonprofit organizations, and gov ernments. In some instances, agencies are also 907

required to examine regulatory alternatives that may reduce adverse economic effects on significantly 908

impacted small entities. The RFA requires agencies to prepare an initial and final regulatory flexibility 909

analysis for each rule unless the Agency certifies that the rule will not have a significant economic impact 910

on a substantial number of small entities. 911

The rule allows training providers (many of which a re small businesses) additional flexibility in how they 912

offer training. Online training is already allowed for the classroom component of both initial and refresher 913

training, and training providers can choose whether or not to offer it. The amended rule st ill allows 914

training providers to choose what type of training to offer because they can continue to offer refresher 915

training with a hands

- on component, begin offering online training without the hands

- on component, or 916

offer both types of training. 917

Trainin g providers that voluntarily choose to start offering online refresher training without a hands

- on 918

component would incur costs for some activities (e.g., applying for a new accreditation) but they would 919

reduce other expenses (e.g., supplies for the hands

- o n training). Because there is no requirement 920

mandating that training providers offer an online refresher course, training providers will not choose to 921

offer online training unless the savings from doing so exceed the costs, or if they can recover their cos ts 922

through tuition charges, increased volum e of business, or other means. Although some accredited training 923

providers may lose market share to other training providers that are more competitive in the online 924

training market, this would be an indirect impac t not a direct cost of complying with the rule

. 925

Eliminating multi

- jurisdiction registration fees saves money for entities that wish to perform LBP 926

activities in multiple jurisdictions. The rule requires training providers to include the expiration date of 927

the renovator’s certification in the post

- training notification, but the time req uired to do this is negligible. 928

The clarification in the rule that post

- training notifications must be submitted no later than ten business 929

days following course completion ma y affect the timing of when the notifications are submitted, but not 930

the cost of completing and submitting them. The changes in this action to the regulatory language on the 931

training provider applications is a clarification of the existing requirement , not a new requirement. 932

933

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- 1 

# 7. Other Impact Analyses 934

Several statutes and executive orders (EOs) pertain to the final rule

. This chapter presents 935

statements discussing unfunded mandates, environmental justice, children’s health, and 936

paperwork burden, among others. 937



## 7.1 Paperwork Reduction Act 938

The Paperwork Reduction Act of 1995 (PRA) (superseding the PRA of 1980), as implemented by 939

the Office of Management and Budget (OMB), requires that agencies submit a supporting 940

statement to OMB for any information collection that solicits the same data from more than nine 941

parties. The PRA seeks to ensure that Federal agencies balance their need to collect information 942

with the paperwork burden imposed on the public by the collecti on. The definition of 943

“information collection” includes activities required by regulations such as permit development, 944

monitoring, recordkeeping, and reporting. The term “burden” refers to the “time, effort, or 945

financial resources” the public expends to pr ovide information to or for a Federal agency, or to 946

otherwise fulfill statutory or regulatory requirements. PRA paperwork burden is measured in 947

terms of annual time and financial resources the public devotes to meet one

- time and recurring 948

information reque sts (44 U.S.C. 3502(2); 5 C.F.R. 1320.3(b)). Information collection activities 949

may include: 950

• reviewing rule requirements; 951

• using technology to collect, process, and disclose information; 952

• adjusting existing practices to comply with requirements; 953

• searching dat a sources; 954

• completing and reviewing the response; and 955

• transmitting or disclosing information. 956

Agencies must provide information to OMB on the parties affected, the annual reporting burden, 957

and the annual cost of responding to the information collection. 958

7.1.1 Industry Burden 

### 959

RPP Training Provider Burden 

### 960

Currently accredited training providers that wish to add an already reviewed and accepted RRP 961

online course from another training provider to their training curriculum are eligible for an 962

expedited online course approval

. All requests to add an already

- reviewed online course 963

curriculum to an already

- accredited training providers' record must include a cover letter; a 964

training provider application to amend their accreditation; and an online course quality control 965

(QC) plan

. The QC plan must address issues such as how the trainer will ensure that students 966

successfully complete the online modules and the online course module final assessment

. 967

Training providers that are already accredited are not charged a fee when a dding an 968

already reviewed online course curriculum. 969

Training providers currently accredited for the renovator refresher training course are assumed to 970

apply for an online refresher training course accreditation if the hands

- on requirement is removed 971

or ame nded in accordance with the proposed regulatory options

. T herefore

, they would incur an 972

incremental paperwork burden. Training providers applying for accreditation incur a one

- time 973

burden associated with becoming familiar with the new rule’s requirements, as well as the burden 974

of completing the accreditation application. Training providers would also incur an incremental 975

burden associated with training course notifications. They would incur a recurring burden 976

### *** EO 12866 Review Draft

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- 2 associated with pre

- training notifications, pre

- training re

- notifications, and post

- training 977

notifications. (Note that the recurring burden associated with the changes to the pre

- training 978

notification and pre

- training re

- notification requirement s is always negative, indicating a 979

reduction in annual burden.) Training providers who do not currently submit notifications via the 980

CDX would incur the initial and recurring burden associated with registration and ongoing 981

administrative activities. 982

The rule requires training providers to include the expiratio n date of the renovator’s certification 983

in the post

- training notification, but the time required to do this is negligible. T he rule also 984

clarifies the requirements for post

- training notifications for in

- person training courses. Training 985

providers are alrea dy required to submit post

- training notifications for renovator training. The 986

rule’s correction to the regulatory text (clarifying that the notifications must be submitted no later 987

than ten business days following course completion) may affect the timing o f when the 988

notifications are submitted, but not the cost of compliance. Furthermore, the burden and cost of 989

this requirement was already accounted for in previous Information Collection Requests (ICRs) 990

for the lead program

. 991

There are assumed to be 400 tr aining providers with accredited renovator refresher training 992

programs. It is estimated that renovation training providers will spend half as long on becoming 993

accredited for an online refresher training course as on initial accreditation for an initial tra ining 994

course

. (L ess information needs to be provided for an expedited online course application, given 995

that the training provider has already been accredited for an in

- person course. ) Burden for the 996

initial accreditation of an initial renovation training c ourse is taken from the previously approved 997

ICR (EPA No. 1715.13)

. Burden h our estimates were rounded to one decimal place for this ICR. 998

The resulting burden is estimated to be 4 hours for training providers to familiarize themselves 999

with the rule requirements ; 4.8 hours to complete the accreditation statement; and 5 hours to 1000

complete the Quality Control Plan (see Exhibit 7

- 1 )

. Exhibit 7

- 2 presents estimates of total 1001

burden for each activity for the first three years of the final rule. These estimates are based on 1002

Scenario I (50% of the active stock of renovators chooses on line refresher training), which yields 1003

a conservative estimate of reporting and recordkeeping burden. 1004

Wage rates for each category of personnel are derived with methods and from sources either 1005

identical or very similar to those used in previous ICRs and ec onomic analyses

. Loaded wage 1006

rates of $53.66 and $26.79 represent training provider wages for professional and clerical 1007

workers, respectively

. Wage and fringe benefit s data are taken from the Employer Cost for 1008

Employee Compensation data series published by the Bureau of Labor Statistics ( BLS 2013 )

. 1009

Both the professional and clerical base wage rates are inflated to 2014 dollars by applying the CPI 1010

for All Urban Consumers published by the Bureau of Labor Statistics ( BLS 2014 )

. The overhead 1011

data is taken from Wage Rate s for Economic Analyses of The Toxics Release Inventory Program 1012

( U.S. EPA 2002 )

. Th e overhead loading factor is added to the benefits loading factor, and the 1013

total is then applied to the base wage to derive the fully loaded wage. See Exhibit 7

- 3 for a 1014

detailed derivation of the training provider loaded wage rates. 1015

1016

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- 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

Accreditation 1 ,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

1 Burden hour esti mates 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

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- 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

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- 5 Exhibit 7

- 3 : Loaded RRP Training Provider Wage Rates

Labor

Category Occupation

Category (BLS) 1 Date Base

Wage 1 Fringe

Benefit s Benefit s

(% of

Wage) 1 Overhead

(% of

Wage) 2 Wage

Multiplier Loaded

Wages 3

(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

As shown in Exhibit 7

- 2

, training providers would incur an incremental burden of 6,36 6 hours in 1018

Year 1 an d an incremental burden of 801 hours in Year 2 and Year 3

. Exhibit 7

- 4 presents the 1019

incremental costs to training providers associated with training program accreditation. T raining 1020

providers would incur incremental costs of $298,677 in Year 1 and incremental costs of $21,574 1021

in Year 2 and Year 3

. 25 

### Wage rates of $53.66 and $26.79 are applied to the professional and 1022

clerical hour burdens, respectively , to calculate costs

. Exhibit 7

- 5 presents bottom line burden and 1023

cost estimates. The average annual aggregate burden for training providers over three ye ars is 1024

2,656 hours. The average annual aggregate cost for training providers over three years is 1025

$113,9 4 2. 1026

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 t he activity involves disclosing information, it is accounted for separately as part of the

paperwork burden analysis.

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- 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

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7

- 7 Exhibit 7

- 5 : Annual Respondent Burden and Cost Summary

Activity Number of

Respondents Number of Small

Respondents 1 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.

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7

- 8 

## 7.2 Unfunded Mandates Reform Act 1027

Title II of the Unfunded Mandates Reform Act of 1995 (UMRA), 2 U.S.C. 1531

- 1538, directs agencies to 1028

assess the effects of significant regulatory actions that impose Federal mandates on State, local, and tribal 1029

governments, and the private sector

. This action does not contain an unfunded mandate of $100 million or 1030

more as descri bed in UMRA, 2 U.S.C. 1531

– 1538. Therefore, this action is not subject to the 1031

require ment s of UMRA sections 202 or 205. 1032

This action is also not subject to the requirements of UMRA section 203 because it contains no regulatory 1033

requirements that might significantly or uniquely affect small governments. The rule amendments do not 1034

preempt reg ulations by states, territories, or tribal governments that have their own authorized lead 1035

programs, so those jurisdictions are not required to change their programs. Those training providers (both 1036

those in the private sector

, as well as State, local or tr ibal governments) that choose to offer online 1037

refresher renovator training would incur costs for some activities ( e.g., applying for a new accreditation) 1038

but they would reduce other expenses ( e.g., supplies for the hands

- on training). However, there is no 1039

requirement mandating that training providers offer an online refresher course. So training providers will 1040

not choose to offer online training unless the savings of doing so exceed the costs

, or if they can recover 1041

their costs through tuition charges or ot her means. 1042



## 7.3 Executive Order 13132

– Federalism 1043

Executive Order 13132 (64 FR 43255, August 10, 1999) applies to policies that have substantial direct 1044

effects on the States, on the relationship between the national government and the States, or on the 1045

distrib ution of power and responsibilities among the various levels of government. This final rule does 1046

not have substantial direct effects on the States, on the relationship between the national government and 1047

the States, or on the distribution of power and resp onsibilities among the various levels of government

. 1048

The rule amendments do not preempt regulations by states, territories, or tribal governments that have 1049

their own authorized lead programs, so those jurisdictions are not required to change their programs

. 1050

Government entities can serve as training providers, and those training providers that choose to offer 1051

online refresher renovator training would incur costs for some activities ( e.g., applying for a new 1052

accreditation) but they would reduce other expenses ( e.g., supplies for the hands

- on training). However, 1053

there is no requirement mandating that training providers offer an online refresher course. So training 1054

providers will not choose t o offer online training unless the savings of doing so exceed the costs, or if 1055

they can recover their costs through tuition charges or other means. 1056



## 7.4 Executive Order 13175

– Consultation and Coordination with Indian Tribal 1057



## Governments 1058

Executive Order 13175 ( 65 FR 67249, November 9, 2000) directs agencies to consult and collaborate 1059

with tribal officials in Federal policy decisions that have tribal implications

. This final rule does not have 1060

tribal implications

. The rule amendments do not preempt regulations by tribal governments that have their 1061

own authorized lead programs, so those jurisdictions are not required to adopt these amendments. Tribal 1062

governments can serve as training providers, and those training providers that choose to offer online 1063

refresher reno vator training would incur costs for some activities ( e.g., applying for a new accreditation) 1064

but they would reduce other expenses ( e.g., supplies for the hands

- on training). However, there is no 1065

requirement mandating that training providers offer an onlin e refresher course. So training providers will 1066

### *** EO 12866 Review Draft

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7

- 9 not choose to offer online training unless the savings of doing so exceed the costs, or if they can recover 1067

their costs through tuition charges or other means. 1068



## 7.5 Executive Order 13045

- Children’s Health 1069

Execut ive Order 13045 (62 FR 19885, April 23, 1997) applies to rules that are economically significant 1070

and that concern health or safety risks that EPA has reason to believe may disproportionately affect 1071

children. This final rule is not an economically significa nt regulatory action as defined by Executive 1072

Order 12866 . Furthermore, EPA interprets Executive Order 13045 as applying only to those regulatory 1073

actions that concern health or safety risks, such that the analysis required under section 5

- 501 of the 1074

Executi ve Order has the potential to influence the regulation. This final rule does not establish an 1075

environmental standard intended to mitigate health or safety risks. Therefore, t his action is not subject to 1076

the requirements of Executive Orde r 13045. 1077



## 7.6 Executive Order 13211

– Energy Supply, Distribution, or Use 1078

Executive Order 13211 (66 FR 28355, May 22, 2001) addresses actions that effect the supply, 1079

distribution, or use of energy. This final rule is not likely to have any adverse effect on the supply, 1080

distribution, or use of energy. 1081



## 7.7 National Technology Transfer and Advancement Act 1082

Section 12(d) of NTTAA, 15 U.S.C. 272 note, directs agencies to use voluntary consensus standards in 1083

their regula tory activities unless to do so would be inconsistent with applicable law or otherwise 1084

impractical. Voluntary consensus standards are technical standards ( e.g. , materials specifications, test 1085

methods, sampling procedures, and business practices) that are developed or adopted by voluntary 1086

consensus standards bodies

. This final rule does not involve technical standards. 1087



## 7.8 Executive Order 12898

– Environmental Justice 1088

Executive Order 12898 (59 FR 7629, February 16, 1994) establishes federal executive policy on 1089

environmental justice

. Its main provision directs federal agencies, to the greatest extent practicable and 1090

permitted by law, to make environmental justice part of their mission by identifying and addressing, as 1091

appropriate, disproportionately high and adv erse human health or environmental effects of their programs, 1092

policies, and activities on minority populations and low

- income populations in the United States

. 1093

This action does not directly affect the level of protection provided to human healt h or the environment. 1094

The rule removes multi

- jurisdiction fees for the LBP Activities program, revises the hands

- on 1095

requirement for refresher renovator training, and changes the notification requirements for training 1096

providers . However, renovators will sti ll be required to take an 8 hour initial training that includes a 1097

hands

- on component; they will still have to take regular refresher training; the refresher training will have 1098

to include a hands

- on component every other training cycle; refresher training w ithout a hands

- on 1099

component will only be valid for three years; and renovators will still have to comply with the work 1100

practice requirements for renovation, repair or painting activities that disturb lead

- based paint. 1101

### *** EO 12866 Review Draft

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8

- 1 

# 8. References 1102

Bureau o f Labor Statistics (BLS). (2012, Mar. 29, 2013). "Occupational Employment Statistics

- 1103

Occupational Employment and Wages, May 2012, 47

- 1011 First

- Line Supervisors of 1104

Construction Trades and Extraction Workers." Retrieved Jan. 30, 2014, 1105

from http://www.bls.gov/oes/current/oes471011.htm#(2)

. 1106

Bureau of Labor Statistics (BLS). (2013, Dec. 11). "Employer Costs for Employee Compensation

- 1107

September 2013." Retrieved Jan. 30, 2014, 1108

from http://www.bls.gov/news.release/archives/ecec_12112013.pdf

. 1109

Bureau of Labor Statistics (BLS). (2014). "Consumer Price Index

- All Urban Consumers, U.S. City 1110

Average (2004 to 2014)." CUSR0000SA0 Retrieved Mar. 21, 2014. 1111

Environmental Systems Resource Institute (ESRI) (2005). StreetMap North America (ESRI Data). 1112

Redlands, CA. 1113

Environmental Systems Resource Institute (ESRI) (2013). ArcMap 10.2.1. Redlands, CA, ESRI. 1114

Internal Revenue Ser vice (IRS). (2013, Dec. 6). "2014 Standard Mileage Rates." Retrieved Mar. 19, 1115

2014, from http://www.irs.gov/2014

- Standard

- Mileage

- Rates

- for

- Business

, - Medical

- and

1116

Moving

- Announced

. 1117

NAHB Business Management & Information Technology (2012). Cost of Doing Business Study, 2012 1118

Edition , NAHB BuilderBooks.com®. 1119

Office of Personal Management (OPM) (2014). 2014 General Schedule (GS) Locality Pay Tables: 1120

WASHIN GTON

- BALTIMORE

- NORTHERN VIRGINIA, DC

- MD

- VA

- WV

- PA. SALARY 1121

TABLE 2014

- DCB 1122

SAS Institute Inc. (2015). SAS Software 9.4. Cary, NC, SAS Institute Inc., 2002

- 2012. 1123

U.S. EPA (2002). Wage Rates for Economic Analyses of The Toxics Release Inventory Program, U.S. 1124

E nvironmental Protection Agency, Office of Environmental Information, Environmental Analysis 1125

Division, Analytical Support Branch. 1126

U.S. EPA (2009). "ICR Handbook

- EPA’s Guide to Writing Information Collection Requests." 1127

U.S. EPA (2011). ICR 1715.13: TSCA Sec tions 402 and Section 404 Training, Certification, 1128

Accreditation and Standards for Lead

- Based Paint Activities and Renovation, Repair, and 1129

Painting. Washington, DC. 1130

U.S. EPA (2014a). "Federal Lead

- Based Paint Program (FLPP) Database." 1131

U.S. EPA. (2014b, Jan . 15). "Lead

- Based Paint Activities Professionals." Retrieved Mar. 7, 2014, 1132

from http://www2.epa.gov/lead/lead

- based

- paint

- activities

- professionals#map

. 1133

U.S. Gene ral Services Administration (GSA). (2014, Jan. 14). "Meals and Incidental Expenses (M&IE) 1134

Breakdown." Retrieved Jan. 30, 2014, from www.gsa.gov/mie

. 1135

1136

### *** EO 12866 Review Draft

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A

- 1 

## Training Courses Tuition Data 1137

Exhibit A

- 1 : Sample of Renovation (Re)certification Training Courses

Company 1, 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 Harbor 3 $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

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A

- 2 Exhibit A

- 1 : Sample of Renovation (Re)certification Training Courses

Company 1, 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

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A

- 3 Exhibit A

- 1 : Sample of Renovation (Re)certification Training Courses

Company 1, 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

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A

- 4 Exhibit A

- 1 : Sample of Renovation (Re)certification Training Courses

Company 1, 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 Tenn es see $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 t raining providers offer price reductions, such as

coupon codes or specials, discounts for students taking multiple different classes, discounts for multiple students from a fi rm 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 ad dition, some training providers include lunch in the price of the tuition they

charge for a training class.

2 Some t raining providers are listed more than once because they offer training in multiple locations and the tuition differs by loca tion.

3 Initial hands

- on training course tuition is derived by taking the tuition for the initial online classroom and hands

- on traini ng 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

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B

- 1 

## Rule Amendment Options

- Derivation of Estimates for the 1139



## Number of Individuals Seeking Recertification 1140

Because the regulatory options have different training intervals and cycle requirements for 1141

hands

- on training, the methodology to calculate the number of renovators taking the in

- person 1142

course (either by choice or as part of the periodic hands

- on training requirement stipulated in the 1143

option) and the online course differs by option. The annual number of renovators that are required 1144

to take a course with a hands

- on training compone nt depends on the length of time and number of 1145

training cycles for which the course without a hands

- on training component is valid. A series of 1146

equations are solved to estimate the steady state number of renovators taking the refresher 1147

training course for the rule amendment options. These equations are presented in this appendix. 1148

(i) Renovator Always Chooses In

- person Refresher Training 1149

Option 1

- 4: Refresher training course with hands

- on training valid for 5 years 1150

For Options 1 through 4, the following eq uation is used to estimate the steady state number of 1151

renovators taking the refresher training course with hands

- on training every 5

- year training cycle: 1152

InP = (S / 5) * PREC 5Y * (100%

- EPCT) 1153

where, 1154

InP = The number renovators taking the refresher traini ng course with hands

- on training 1155

in the steady state, 1156

S = The active stock of certified renovators (500,000), 1157

PREC5Y = The percent of renovators with expiring certifications that become recertified 1158

given a 5

- year training cycle (70%), and 1159

EPCT = The online refresher training course scenario percentage (50%, 75%, or 90%). 1160

Thus, for Scenario I (50% of the active stock of renovators choose online refresher training), 1161

InP = (500,000 / 5) * 70% * (100%

- 50%) = 35,000

. 1162

Note that under Option 1, ren ovators take the refresher training course without the hands

- on 1163

training component whether they travel to the training facility or take the course online because it 1164

is assumed that the refresher hands

- on training component is not offered by training provid ers. 1165

For the other options, the in

- person course is assumed to always include the hands

- on component. 1166

(ii) Renovator Chooses Online Refresher Training 1167

Option 1: Refresher training course without hands

- on training valid for 5 years 1168

Under Option 1, the number of renovators taking the refresher training course online to become 1169

recertified is estimated according to the following equation: 1170

E = (S / 5) * PREC 5Y * (EPCT) 1171

where, 1172

E = The number of renovators taking the refresher training course online, 1173

S = Th e active stock of certified renovators (500,000), 1174

### *** EO 12866 Review Draft

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B

- 2 PREC5Y = The percent of renovators with expiring certifications that become recertified 1175

given a 5

- year training cycle (70%), and 1176

EPCT = The online refresher training course scenario percentage (50%, 75%, o r 90%). 1177

Option 2: Refresher training without hands

- on valid for 5 years; Hands

- on required every 2 1178

cycles 1179

The following equation is used to estimate the steady state number of renovators taking the 1180

refresher training course in person among those individuals taking the online training course 1181

every other training cycle under option 2: 1182

InP = ( PREC 2nd 

### * EPCT * I) / (1 00%

- PREC 2nd 

### )

, 1183

where, 1184

InP = The number of renovators taking the refresher training course in person (hands

- on 1185

cycle) among those indiv iduals taking the online training course every other 1186

training cycle, 1187

PREC 2nd 

### =The percent of renovators with expiring certifications that become recertified 1188

for the second time given two 5

- year recertifications periods 1189

(( PREC 2nd 

### = 70 % * 70%

= 49%), 1190

EPCT = The online refresher training course scenario percentage (50%, 75%, or 90%), 1191

and 1192

I = The number of initial certifications each year (30,000). 1193

Thus, for Scenario I (50 percent of the active stock of renovators choose online refresher training) 1194

under Option 2, 1195

InP = (49% * 50% * 30,000 ) / (1 00%

– 49% ) = 14,412

. 1196

The following equation is used to estimate the number of renovators taking the refresher training 1197

course online: 1198

E = ((PREC5Y * EPCT * I) + (PREC5Y * InP)

- InP) / (100%

- PREC5Y), 1199

where, 1200

E

= 

### The number of renovators taking the refresher training course online (no hands

- on 1201

cycle), 1202

InP = The number of renovators taking the refresher training course in person (hands

- on 1203

cycle) among those individuals taking the online training course every other 1204

train ing cycle, 1205

PREC5Y = The percent of renovators with expiring certifications that become recertified 1206

given a 5

- year training cycle (70%), 1207

EPCT = The online refresher training course scenario percentage (50%, 75%, or 90%), 1208

and 1209

I = The number of initial certifications each year (30,000) 1210

### *** EO 12866 Review Draft

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B

- 3 Thus, for Scenario I (50 percent of the active stock of renovators choose online refresher training) 1211

under Option 2, 1212

E = ((70% * 50% * 30,000) + (70% * 14,412)

- 14,412) / (100%

- 70%)) = 1213

20,588. 1214

Therefore, in the steady state under Option 2

, Scenario I: 1215

 One fifth of the active stock of 500,000 renovators (100,000 renovators) will have an 1216

expiring recertification in a given year. Seventy percent of them (70,000 per year) are 1217

estimated to seek recer tification and the balance of 30,000 per year are assumed to exit 1218

the industry and be replaced by newly certified renovators who take initial training. Of 1219

the 70,000 renovators per year estimated to seek recertification, 50 percent (35,000 per 1220

year) are as sumed to always choose the in

- person refresher training course under this 1221

scenario. 1222

 The other fifty percent (35,000) choose the online refresher training course. However, as 1223

shown in Exhibit B

- 1 , within that group of 35,000, more renovators take the online 1224

training without hands

- on training (20,588) than take the in

- person training with hands

1225

on training (14,412) in an average year because renovators drop out of the ac tive stock 1226

over time. For example, more renovators will have dropped out of the active stock 10 1227

years after their initial training compared to 5 years after their initial training (and they 1228

would take the online course without hands

- on training 5 years aft er their initial training 1229

and the hands

- on in

- person course 10 years after their initial training). 1230

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

Option 3: Refresher training without hands

- on valid for 2 or 3 years 1232

Under Option 3(a) (online course recertification valid for 2 years ), the number of renovators 1233

taking the online refresher training course to become recertified is estimated according to the 1234

following equation: 1235

E = (S * EPCT * PREC 5Y) / 2, 1236

Where, 1237

E = The number renovators taking the refresher training course online, 1238

S = The active stock of certified renovators (500,000) 1239

PREC5Y = The percent of renovators with expiring certifications that become recertified 1240

given a 5

- year training cycle (70%), and 1241

EPCT = The online refresher training course scenario percentage (50%, 75%, or 90%). 1242

### *** EO 12866 Review Draft

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B

- 4 Under Option 3(b) (online course recertification valid for 3 years ), the annual number of 1243

renovators taking the online refresher training course to become recertified is estimated according 1244

to the following equation: 1245

E = (S * EPCT * PREC 5Y) / 3, 1246

where, 1247

E = The number renovators taking refresher training course online, 1248

S = The active stock of certified renovators (500,000) 1249

PREC5Y = The percent of renovators with expiring certifications that become recertified 1250

given a 5

- year training cycle (70%), and 1251

EPCT = Online refresher training course scenario percentage scenario percentage (50%, 1252

75%, or 90%). 1253

Option 4: Cyclical hands

- on requirement; online course train ing valid for 2 or 3 years 1254

The methodology for estimating the steady state number of recertifications for Options 4(a) 1255

through 4(d) is similar to that of Option 2. Because the methodology is essentially the same for 1256

Option 4(a) through Option 4(d), only th e methodology for Option 4(a) will be described in 1257

detail; however the equations for Options 4(b) through 4(d) are provided following Exhibit B

- 2

. 1258

The following equati on is used to estimate the steady state number of renovators taking the 1259

refresher training course in person (hands

- on cycle) among those individuals taking the online 1260

training course every other training cycle: 1261

InP = ( PREC 2nd 

### * EPCT * I) / (100%

- PREC 2nd 

### )

, 1262

where, 1263

InP = The number of renovators taking the refresher training course in person (hands

- on 1264

cycle) among those individuals taking the online training course every other 1265

training cycle, 1266

PREC 2nd 

### = The percent of renovators with expiring certifications that become recertified 1267

for the second time given one 5

- year recertification period ( PREC 5Y

= 7 0% ) 1268

and one 2

- year recertification period 1269

( PREC 2Y

= [100%

- (((100%

- PREC 5Y) / 5) * 2)]) 1270

( PREC 2nd 

### = PREC 5Y * PREC 2Y = 61.6%), 1271

EPCT = Online refresher training course scenario percentage (50%, 75%, or 90%), and 1272

I = The number of initial certifications each year (30,000). 1273

Thus, for Scenario I (50 percent of the active stock of renovators choose online refr esher training) 1274

under Option 4(a), 1275

InP = (61.6% * 50% * 30,000 ) / (1 00%

- 61.6% ) = 24,063

. 1276

The following equation is used to estimate the number of renovators taking the refresher training 1277

course online under Option 4(a): 1278

E = ((PREC5Y * EPCT * I) + (PREC5Y * InP)

- InP) / (100%

- PREC2Y), 1279

### *** EO 12866 Review Draft

– Deliberative

– Do Not Quote, Cite, or Release During Review ***

B

- 5 where, 1280

E

= 

### The number of renovators taking the refresher training course online (no hands

- on 1281

cycle), 1282

InP = The number of renovators taking the refresher training course in person (hands

- on 1283

cycle) among those individuals t aking the online training course every other 1284

training cycle, 1285

PREC5Y = The percent of renovators with expiring certifications that become recertified 1286

given a 5

- year training cycle (70%), 1287

PREC2Y = The percent of renovators with expiring certifications becomi ng recertified 1288

given a two year recertification period 1289

( PREC2Y

= [100%

- (((100%

- PREC5Y ) / 5) * 2]

= 88%), 1290

EPCT = Online refresher training course scenario percentage (50%, 75%, or 90%), and 1291

I = The number of initial certifications each year (30,000). 1292

Thus, for Scenario I (50 percent of the active stock of renovators choose online refresher training) 1293

under Option 4(a), 1294

E = ((70% * 50% * 30,000) + (70% * 24,063)

- 24,063) / (100%

- 88%)) = 1295

27,343. 1296

In the steady state under Option 4(a) and what is termed the 50 percent scenario, the total number 1297

of renovators choosing online refresher training each year (51,406) is greater than 50 percent of 1298

the total number of renovators taking refresher training each year (86,406). This is because 1299

renovato rs choosing online refresher training must be recertified more frequently. For example, a 1300

renovator choosing online refresher training must take the training course twice every seven 1301

years, whereas a renovator always choosing the in

- person refresher traini ng course must only take 1302

the training course once every five years. However, 50 percent of the active stock of recertified 1303

renovators is recertified by taking the refresher training course online every other training cycle. 1304

• The total number of recertified renovators that become recertified by taking online 1305

refresher training is equal to 120,315 (24,063 renovators per year taking the in

- person 1306

training course, which is valid for five years) plus 54,686 (27,343 renovators per year 1307

taking the online training, which is valid for two years), which equals 175,000 when 1308

rounded to the ten thousand digit. The active stock of recertified renovators is equal to 1309

350,000 (70 percent recertification rate for the 500,000 active stock of renovators). Thus, 1310

50 percent of the recertified renovators take the online refresher training course 1311

((175,000 / 350,000)*100 = 50%). 1312

• Under Option 4(a) Scenario I, approximately 23 percent or 116,406 renovators out of the 1313

active stock of 500,000 renovators will have an expiring recertificat ion in a given year. 1314

Approximately 74 percent or 86,406 of them are estimated to seek recertification and the 1315

balance of 30,000 are assumed to leave the industry and be replaced by newly certified 1316

renovators. 1317

o While 50 percent of the active stock chooses on line refresher training, the 1318

number of renovators in this group accounts for a higher percentage of the total 1319

number of renovators seeking refresher training in a given year because 1320

### *** EO 12866 Review Draft

– Deliberative

– Do Not Quote, Cite, or Release During Review ***

B

- 6 renovators choosing online refresher training must be recertified more fre quently 1321

compared to renovators always choosing in

- person refresher training. Of the 1322

86,406 renovators estimated to seek recertification in a given year: 1323

 Approximately 41 percent (35,000) are assumed to always choose the 1324

in

- person refresher training course and 1325

 Approximately 59 percent (51,406) choose the online refresher training 1326

course training cycle. However, as shown in Exhibit B

- 2

, in an average 1327

year, more renovators take the online training course without hands

- on 1328

training (27,343) than take the in

- person training with hands

- on training 1329

(24,063) because renovators drop out of the active stock over time. For 1330

example, more renovators will have dropped out of the active stock 7 1331

years after their initial training compared to 5 years after their initial 1332

training (and they would take the online course without hands

- on training 1333

5 years after their initial training and the hands

- on in

- person course 7 1334

years after their initial training). 1335

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

• Option 4(b) Equations (2 year interval and 3 cycles): 1337

InP = (PREC 3rd 

### * EPCT * I) / (100%

- PREC 3rd 

### ) 1338

E = ((PREC5Y * EPCT * I) + (PREC5Y * InP)

- InP) / (100%

- PREC2Y) 1339

PREC 3rd 

### = The percent of renovators becoming recertified for the third time 1340

given one 5

- year recertification period and two 2

- year recertification 1341

periods 1342

( PREC 3rd 

### = PREC 5Y * PREC 2Y * PREC 2Y = 54.2%) 1343

• Option 4(c) Equations (3 year interval and 2 cycles): 1344

InP = ( PREC 2nd 

### * EPCT * I) / (100%

- PREC 2nd 

### ) 1345

E = ((PREC5Y * EPCT * I ) + (PREC5Y * InP)

- InP) / (100%

- PREC3Y) 1346

PREC3Y = The percent of renovators becoming recertified given a 3

- year 1347

recertification period (100

- (((100

- PR EC5Y) / 5) * 3)) 1348

PREC 2nd 

### = The percent of renovators becoming recertified for the second time 1349

given one 5

- year recertification period and one 3

- year recertification 1350

period 1351

( PREC 2nd 

### = PREC 5Y * PREC 3Y = 57.4%) 1352

• Option 4(d) Equations (3 year interval and 3 cy cles): 1353

InP = (PREC 3rd 

### * EPCT * I) / (100%

- PREC 3rd 

### ) 1354

### *** EO 12866 Review Draft

– Deliberative

– Do Not Quote, Cite, or Release During Review ***

B

- 7 E = ((PREC5Y * EPCT * I) + (PREC5Y * InP)

- InP) / (100%

- PREC3Y) 1355

PREC 3rd 

### = The percent of renovators becoming recertified for the third time 1356

given one 5

- year recertification period and two 3

- year recertification 1357

periods 1358

( PREC 3rd 

### = PREC 5Y * PREC 3Y * PREC 3Y = 47.1%) 1359

### *** EO 12866 Review Draft

– Deliberative

– Do Not Quote, Cite, or Release During Review ***

C

- 1 

## Detailed Exhibits of Total Renovator Training Costs 1360

Exhibit C

- 1 prese nt s the net present value and annualized costs under the baseline (refresher 1361

training with the hands

- on component valid for 5 years) , over a ten year period from 201 6 1362

through 2025. The costs are discounted using rates of 3 and 7 percent. The estimates in Exhibit 1363

C

- 1 are used to estimate cost savings for Options 1 through 4, presented in Exhibit 3

- 10

. Exhibit 1364

C

- 2 through Exhibit C

- 9 present the net present value and annualized costs for Options 1 through 1365

4. 1366

Exhibit C

- 1 : Baseline

- Ten Year Net Present Value and Annualized

Costs for Renovators Seeking Recertif ication (2014$)

Baseline 1 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

Exhibit C

- 2 present s the net present value and annualized costs under Option 1 (refresher training 1368

course without the hands

- on compon ent valid for 5 years) , over a ten year period from 201 6 1369

through 2025 , for in

- person and online training

. The costs are discounted using rates of 3 and 7 1370

percent. 1371

### *** 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

Exhibit C

- 3 present s the net present value and annualized costs under Option 2 (refresher training 1373

course without the hands

- on component valid for 5 years; refresher training course with the 1374

hands

- on com ponent required every other training cycle) , over a ten year period from 201 6 1375

through 2025 , for in

- person and online training. The costs are discounted using rates of 3 and 7 1376

percent. 1377

### *** 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

Exhibit C

- 4 and Exhibit C

- 5 present the net present value and annualized costs under Option 3(a) 1379

and 3(b) (refresher training course without the hands

- on component valid for 2 or 3 years) , over a 1380

ten year period from 20 1 6 through 2025 , for in

- person and online training. The costs are 1381

discounted using rates of 3 and 7 percent. 1382

### *** 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 S eeking 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

Exhibit C

- 6

, Exhibit C

- 7

, Exhibit C

- 7 , and Exhibit C

- 7 present the net present value and 1385

annualized costs under Option 4 (cyclical hands

- on training requirement; refresher training course 1386

without the hands

- on component valid for 2 or 3 years) , over a ten year period from 201 6 through 1387

2025 , for in

- person and online training. The costs are discounted using rates of 3 and 7 percent. 1388

### *** 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