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View ICR - OIRA Conclusion



2040-0090 199708-2040-001
Historical Active 199603-2040-001
EPA/OW
Public Water Systems Supervision Program
Extension without change of a currently approved collection   No
Regular
Approved without change 09/29/1998
Retrieve Notice of Action (NOA) 08/07/1997
EPA is to be commended for its efforts to update and refine its estimate of the burden associated with this information collection. However, when significant changes to burden estimates are made that do not reflect underlying program changes, both the basis and the quantitative effect of each changed assumption or calculation needs to be documented. The documentation provided with this ICR did not allow an itemization of changed assumptions and their effects. Instead, detailed qualitative documentation of the revised methodology was provided. Some of the revisions (eg, use of current information on the number of affected systems) were clearly appropriate, while others (eg, monetization of contractor burden previously expressed in hours, elimination of burden that was previously amortized over 18 years because the actual burden has already been incurred) were not. Still others may have been appropriate (eg, reduction of burden associated with sanitary surveys because initial round of sanitary surveys had been completed) but it was impossible to tell if the magnitude of burden reduction associated with the reviision was appropriate or not (eg, becuase there is still an on-going requirement to conduct sanitary surveys at least once every 5 years). The revised estimates suggest that there may be significant areas where burden has previously been either overstated or understated. When this information collection is submitted for renewal in 3 years, EPA should reassess whether it is appropriate to recalculate burden, and if so, provide the appropriate documentation with the revised estimates. In the mean time, however, this ICR is being approved with no change in burden. Since there has been no change in the underlying program requirements, this is an appropriate way to account for the burden until a reassessment, including adequate documentation of any changes, has been completed.
  Inventory as of this Action Requested Previously Approved
09/30/2001 09/30/2001 09/30/1998
4,157,056 0 17,621,954
12,386,280 0 12,386,280
204,700,000 0 0