EPA estimates high costs for NPDES pesticide permitEPA estimates high costs for NPDES pesticide permit
EPA has estimated that permittees and permitting authorities will spend more than a million hours and more than $50 million a year to collect, report and evaluate information related to NPDES permits for pesticide applications to or over, including near, waters of the United States.
November 5, 2010
EPA has estimated that permittees and permitting authorities will spend more than a million hours and more than $50 million a year to collect, report and evaluate information related to National Pollutant Discharge Elimination System (NPDES) permits for pesticide applications to or over, including near, waters of the United States.
The estimates come in a proposed information collection request (ICR). A notice announcing that EPA plans to submit the ICR to the Office of Management and Budget (OMB) for approval and will seek public comment is due to be published in the Federal Register.
The ICR includes the following estimates:
· Total number of potential respondents: 365,000 permittees, 45 permitting authorities (44 states and Virgin Islands)
· Frequency of response: varies from once every five years to occasionally as needed
· Total average number of responses for each respondent: 3.6
· Average number of hours per response: 0.8
· Total annual burden in hours: 1,033,713 (987,904 hours for permittees and 45,809 hours for permitting authorities)
· Total annual costs: $51,850,723 ($50,109,969 for permittees and $1,740,754 for permitting authorities - all for labor costs and none for capital investment or operations and maintenance costs)
The estimates are based on EPA's proposed NPDES Pesticide General Permit, which was released in June and contains a number of reporting and recordkeeping requirements. The estimates will be revised based on the final permit, which EPA expects to release in early 2011.
Among other things, EPA is seeking public input that will allow it to evaluate the accuracy of its estimates. According to the notice, the agency, in particular, is "requesting comments from very small businesses (those that employ less than 25) on examples of specific additional efforts that EPA could make to reduce the paperwork burden for very small businesses affected by this collection."
Based on the comments received, EPA says it will revise the ICR as appropriate and submit a final ICR package to OMB for approval. Stakeholders will be able to submit additional comments to OMB.
Comments on the proposed ICR are due 60 days after publication in the Federal Register.
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