2415.03 Attachment C

Docket ID: EPA-HQ-OPP-2016-0078

ATTACHMENT C

OMB Control No.: 2070-0188
EPA ICR No. 2415.03

Consultation Questions
1. Publicly Available Data
a) Is the data that the Agency seeks available from any public source or already collected by
another office at EPA or by another agency?
b) If yes, where can you find the data?
2. Frequency of Collection
Can the Agency collect the information less frequently and still produce the same outcome?
3. Clarity of Instructions
a) The ICR is intended to require that respondents provide certain data so that the Agency
can utilize them.
(a) Based on the instructions (regulations, PR Notices, etc.), is it clear what you are
required to do and how to submit the data?
(b) If not, what suggestions do you have to clarify the instructions?
b) Do you understand that you are required to maintain records?
c) Considering that there is no required submission format, is it difficult to submit
information in ways that are clear, logical and easy to complete?
d) Regarding the any [specific program] forms, do you use them? Are they clear, logical,
and easy to complete?
4. Electronic Reporting and Record keeping
The Government Paperwork Elimination Act requires agencies make available to the public
electronic reporting alternatives to paper-based submissions by 2003, unless there is a strong
reason for not doing so. One such reason is that, at the present time, the Agency is unable to
ensure the security of CBI that might be transmitted over the Internet.
a) What do you think about electronic alternatives to paper-based records and data
submissions? Current electronic reporting alternatives include the use of “web
forms”/XML based submissions via the Agency’s Internet site and magnetic media-based
submissions, e.g., diskette, CD-ROM, etc. Would you be interested in pursuing electronic
reporting? Are you keeping your records electronically? If yes, in what format?
b) Although the Agency does not offer an electronic reporting option for CBI-related data at
this time, would you be more inclined to submit CBI on diskette than on paper?

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Docket ID: EPA-HQ-OPP-2016-0078

ATTACHMENT C

OMB Control No.: 2070-0188
EPA ICR No. 2415.03

c) What benefits would electronic submission bring you in terms of burden reduction or
greater efficiency in compiling the information?
5. Burden and Costs
a) Are the labor rates accurate?
b) The Agency assumes there is no capital cost associated with this activity. Is that correct?
c) Bearing in mind that the burden and cost estimates include only burden hours and costs
associated with the paperwork involved with this ICR, e.g., the ICR does not include
estimated burden hours and costs for conducting studies, are the estimated burden hours
and labor rates accurate? If you provide burden and cost estimates that are substantially
different from EPA’s, please provide an explanation of how you arrived at your
estimates.
d) Are there other costs that should be accounted for that may have been missed?

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