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Assessment of Compliance Assistance Projects (Change -add hours)

1860.10 Direct Asst Region 2

Direct Assistance Survey - Region 2

OMB: 2020-0015

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REQUEST FOR FY2008 REAPPROVAL OF INFORMATION COLLECTION ACTIVITY


March 31, 2007


EPA REGION 2

COMPLIANCE ASSISTANCE SECTION

Patrick Harvey, Branch Chief, 212-637-3267

Linda Longo, Compliance Assistance Coordinator, 212-637-3565



  1. Background

Under The Government Performance and Results Act (GPRA), the region is required to report to the Office of Compliance (OC) on outcome measurements achieved from direct compliance assistance provided to regulated entities. Beginning in Fiscal Year 2006, the Region must report the percent of regulated entities that (1) increased understanding, (2) changed environmental management practices, and (3) reduced, treated or eliminated pollution as a result of EPA assistance.


The region collects compliance assistance outcome data from many programs and numerous sector initiatives. Therefore, this survey will be used by regional staff contacting sector recipients from various media and programs. The affected audience for this Information Collection Request (ICR) includes members of the regulated community and, to a lesser extent, state and local regulators and compliance assistance providers that receive EPA compliance assistance tools or services. We estimate reaching out to approximately 15,000 recipients through Fiscal Year 2008.


  1. Survey Purpose and Description

We propose to use the same survey which was approved for the FY07 reporting period for Region 2 which expires on March 31, 2008 (OMB Control # 2020-0015). The same survey was also translated into Spanish with OMB approval in February 2007 and was submitted to OMB. We will use the Spanish version for our Puerto Rico recipients.


Measurement will be collected from facility visits, facility re-visits, on-going facility specific work, response to inquiry, workshops, training courses, and presentations. Regulated entities receiving this direct assistance will be contacted several months after the event to review if knowledge of environmental requirements and best management practices was increased and acted on.


The proposed survey below does not involve fact-finding for the purposes of regulatory development or enforcement. The burden estimate in section IV below takes this into account.







U.S. Environmental Protection Agency Region 2 Compliance Assistance Survey



Fiscal Year 2008


Please check all boxes that apply. Thank you.


1. What regulatory actions as a result of the compliance assistance activity:

Did you take

Do you intend to take

File a notification

Obtain a permit or certification

Provide data to EPA, state, or local regulator

Submit reports to EPA, state, or local regulator

Comply with an environmental requirement

No regulatory actions will be taken

Other, specify:__________________________

File a notification

Obtain a permit or certification

Provide data to EPA, state, or local regulator

Submit reports to EPA, state, or local regulator

Comply with an environmental requirement

No regulatory actions will be taken

Other, specify:__________________________


2. What process changes at your facility as a result of the compliance assistance activity:

Did you make

Do you intend to make

Change the storage or handling of a waste or emission

Change a process or practice

Purchase new process equipment

Implement material or waste recycling system

Install pollution control equipment (e.g., scrubbers, control technique)

Install a waste treatment system

Switch to renewable energy

No process changes will be taken

Other, specify:__________________________

Change the storage or handling of a waste or emission

Change a process or practice

Purchase new process equipment

Implement material or waste recycling system

Install pollution control equipment (e.g., scrubbers, control technique)

Install a waste treatment system

Switch to renewable energy

No process changes will be taken

Other, specify:__________________________



  1. What management changes at your facility as a result of the compliance assistance activity:

Did you take

Do you intend to take

Conduct a self audit

Institute an environmental management policy, system or procedure

Institute training or other communication to improve awareness and/or practices

Identify pollution prevention opportunity

No management action will be taken

Other, specify:__________________________

Conduct a self audit

Institute an environmental management policy, system or procedure

Institute training or other communication to improve awareness and/or practices

Identify pollution prevention opportunity

No management action will be taken

Other, specify:__________________________



  1. Who (if anyone) have you contacted for further assistance as a result of the compliance assistance activity:

Who have you contacted

Who do you intend to contact

A vendor

A state or local regulatory agency

A non-regulatory local source for additional compliance assistance

No contacts will be made

Other, specify:________________________

A vendor

A state or local regulatory agency

A non-regulatory local source for additional compliance assistance

No contacts will be made

Other, specify:________________________



  1. Please identify any reductions or the elimination of a pollutant(s) that resulted, or will result, from the actions taken as a result of the compliance assistance activity.

Resulted

Will result

Reduced or eliminated waste (solid/hazardous)

Reduced or eliminated air emissions (air, fugitive)

Reduced or eliminated pollution emissions (e.g. wastewater)

None

Don’t know

Other, specify:__________________________


Reduced or eliminated waste (solid/hazardous)

Reduced or eliminated air emissions (air, fugitive)

Reduced or eliminated pollution emissions (e.g. wastewater)

None

Don’t know

Other, specify:__________________________




OMB Control # 2020-0015 OMB Control # 2020

6. Have you realized, or expect to realize, a cost savings from actions taken as a result of the compliance assistance activity.

__ Yes

__ No


The contact information below is OPTIONAL. We will contact you if we need clarification

on the survey. Your contact information will not be included in any aggregated reports.


Respondent Name:___ ____________________________________________________


Facility Name: ____________________________________________________________


Facility Address:___________________________________________________________


Contact Phone Number: _____________________________________________________


E-Mail Address: ___________________________________________________________


Thank you very much for your time and support in helping us better serve environmental assistance to the regulated community.


Questions on the survey, please contact Linda Longo, 212-637-3565, longo.linda@epa.gov


Thank you for your input!


Patrick Harvey, Branch Chief

Compliance Assistance & Program Support Branch

Division of Enforcement and Compliance Assistance, Region 2


Public reporting burden for this collection is estimated to average 10 minutes per response, including time for

reviewing instructions, gathering information, and completing and reviewing the information. Send comments on

the Agency=s need for this information, the accuracy of the provided burden estimate, and any suggestions for

reducing the burden, including the use of automated collection techniques, to the Director, Office of Environmental

Information, Collection Strategies Division, United States Environmental Protection Agency (mail Code 2822),

1200 Pennsylvania Ave, NW Washington, D.C. 20460; and to the Office of Information & Regulatory Affairs,

Office of Management & Budget, 725 17th Street, NW, Washington D.C. 20503, Attention: Desk Officer for EPA.

Include the EPA ICR 1860.03 and the OMB control number 2020-0015 in any correspondence. Approval expires 9-

30-08 Do not send completed survey to the Washington, D.C address.


Send competed surveys to the following address:

Linda Longo

Environmental Assistance Coordinator

U.S. Environmental Protection Agency, Region 2

290 Broadway, 21st floor

New York, NY 10007




III. Survey Methodology and Use of Results

The region will normally notify the regulated entity at the time of compliance assistance delivery that EPA plans to follow up with them to assess the quality of the assistance. At this time regional staff will indicate the assessment method to be used (e.g., phone, letter, email). The method of survey delivery will primarily be through mailed surveys or phone conversations conducted several months after the direct assistance to determine if actual changes were made.

Results will be recorded in the Compliance Assistance Module of the Integrated Compliance Information System (ICIS) and reported to regional managers for certification to Office of Compliance at mid-year and end-of-year.


The use of these results will be accompanied by the following qualifying language:


"These performance measures are not calculated from a representative sample of the regulated entity universe. The percentages are based on the number of regulated entities that answer affirmatively to these questions on our voluntary surveys. The percentages do not account for the number of regulated entities who chose not answer these questions or the majority of entities who chose not to answer the survey."



  1. Respondents Burden

To minimize the respondent burden, the simple and clear six (6) generic survey questions approved by Office of Management and Budget (OMB) will be used.


a) How many respondents do you anticipate will respond to the survey?

15,000

b) How long will it take to complete the survey?

10 minutes

c) Calculate the cost per hour for the respondent. The ICR calculates $68.63/hour


Total Burden Hours:

15,000 x 10 min. / 60 min. = 2,500 hours over a three year period

2,500 / 3 = 833 hours for one year


Total Respondents Cost:

2,500 x $68.63 = $171,575 over a three year period

$171,575 / 3 = $57,192 for one year


  1. Agency Burden

Time it will take staff to review the responses and conduct analysis. The ICR calculates $41.25/hour.


Total Agency Burden (EPA staff time in hours multiplied by cost per hour):

2,500 hours x $41.25 = $103,125 over a three year period

$103,125 / 3 = $34,375 for one year


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File TitleREQUEST FOR APPROVAL OF INFORMATION COLLECTION ACTIVITY
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