EPA Collecting Information on NPDES Program Burden and Cost; Member Input Requested

Jun 9, 2021

EPA will soon embark on a renewal of its National Pollutant Discharge Elimination System (NPDES) Program Information Collection Request (ICRs), which set to expire next year.

This specific ICR, updated triennially, calculates the total burden and costs associated with the Clean Water Act’s NPDES program, essentially cataloging the incremental changes from previous NPDES program ICRs. Following a public comment period and consideration of comments received, EPA will submit the ICR package to the Office of Management and Budget (OMB) for review.

While NACWA usually does not wade into ICRs, this draft ICR from the Water Permits Division includes increased burden estimates and NACWA may want to respond to the Agency in public comments. EPA is estimating the total burden to be 32,635,866 hours at a cost of $1,824,927,998 each year. Notably, this estimate is 3,974,967 hours more (a 14% increase) than the currently approved NPDES Program ICR that estimated a time burden of 28,660,899 hours annually.

EPA is seeking input to confirm the accuracy of its assumptions on time burden and cost burden. Specifically, the Agency is looking for responses on:

  1. Has EPA adequately and reasonably described recordkeeping requirements?
  2. Are the burden hours, as described, accurate and true to experience?
  3. Are the burden costs, as described, accurate and true to experience?

EPA is also planning to consolidate several separate ICRs into this NPDES ICR including Public Notification Requirements for CSOs in the Great Lakes Basin, Effluent Limitation Guidelines and Standards for the Dental Category, and the 2020 NPDES Multi-Sector General Permit for Industrial Stormwater Discharges. Pesticides and Water Quality Standards ICRs may also be considered for consolidation.

NACWA is considering weighing in on EPA’s draft ICR by June 23. If members have feedback, please reach out to Emily Remmel by June 18.

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