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View ICR - OIRA Conclusion



2040-0042 200501-2040-005
Historical Active 200109-2040-005
EPA/OW
Underground Injection Control Program (Renewal)
Extension without change of a currently approved collection   No
Regular
Approved without change 10/25/2005
Retrieve Notice of Action (NOA) 01/27/2005
This ICR is approved for 18 months. OMB does not believe that concerns raised in the previous terms of clearance have been adequately addressed. BEFORE beginning preparation of the next renewal of this ICR, EPA shall orally brief OMB on its progress to date on addressing the issues outlined below in these terms of clearance. The next renewal of this ICR shall also include a written update on progress in this area. The previous terms of clearance noted the temporary suspension of EPA's consultations on modifying the 7520 Forms in favor of the National Source Water Contamination Prevention Strategy, which was designed to focus reporting within the UIC program on more meaningful measures of program progress. Following completion of this progress, modification of the 7520 Reporting Forms was to be completed. EPA was to report to OMB on its progress in this area during the current renewal of this ICR. A brief report accompanying the current ICR indicates that the Strategy has now evolved into two national guidances plus several EPA program activity measures. These guidances are not described, other than to indicate that they instruct states and Federal programs on how to report crucial data that is largely required by regulations with the same focus. Measures are to focus specifically on meaningful data element collections to Headquarters that will give a national picture. Somewhere along the way in this evolving process, the focus on on ensuring that all data have practical utility and that burden is reduced to the extent practical and appropriate (both of which are required by 5 CFR 1320.9) seems to have gotten lost. There has been no modification to the 7520 Forms, and no other actions to reduce burden since FY 1996, when EPA reduced the frequency of some reporting requirements. There appears to have been no followup on recommended changes by the Federal Reporting Forms workgroup. While a new Excell Spreadsheet reporting process has been added to track four new Performance Activity Measures (PAMs), none of the existing reporting requirements have been eliminated or reduced. The annual burden of this report has increased by 22%. While the agency has characterized this increase as an adjustment, OMB notes that 127,843 hours reflects new permitting and closure requirements for operators of certain Class V wells, and has reclassified this burden. During the next year, prior to beginning the renewal process for this ICR, EPA needs to review the recommendations of the Federal Reporting Forms workgroup and determine whether these or other changes to the Forms, with the specific goal of reducing unnecessary burden, are appropriate._EPA needs to provide OMB a full report on how it has addressed each of the specific recommendations of the Federal Reporting Forms workgroup.
  Inventory as of this Action Requested Previously Approved
04/30/2007 04/30/2007 10/31/2005
478,189 0 422,287
1,334,054 0 1,091,945
89,415,000 0 31,828,000