Attachment B -Consultation Qs

Sample Consultation Questions for ICR Renewals
EPA Questions asked in Consultation
(1)

(2)

Publicly Available Data
$

Is the data that the Agency seeks available from any public source, or already
collected by another office at EPA or by another agency?

$

If yes, where can you find the data? (Does your answer indicate a true
duplication, or does the input indicate that certain data elements are available, but
that they don=t meet our data needs very well?)

Frequency of Collection
$

(3)

(4)

Can the Agency collect the information less frequently and still produce the same
outcome?

Clarity of Instructions
$

The ICR is intended to require that respondents provide certain data so that the
Agency can utilize them.

$

Based on the instructions (regulations, PR Notices, etc.), is it clear what you are
required to do and how to submit such data? If not, what suggestions do you have
to clarify the instructions?

$

Do you understand that you are required to maintain records?

$

Considering that there is no required submission format, is it difficult to submit
information in ways that are clear, logical and easy to complete?

$

Are there forms associated with this process? Do you use them? Are they clear,
logical, and easy to complete?

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.
$
$

(5)

What do you think about electronic submissions, such as the Agency’s Central
Data Exchange (CDX)?
Are you keeping your records electronically? If yes, in what format?

Burden and Costs
$
$

Are the labor rates accurate?
The Agency assumes there is no capital cost associated with this activity. Is that
correct?
1

$

$

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.
Are there other costs that should be accounted for that may have been missed?

2