The Environmental Protection Agency Needs To Better Control Its Growing Paperwork Burden on the Public

GGD-81-40: Published: May 15, 1981. Publicly Released: May 22, 1981.

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GAO was requested to examine the effectiveness of the Environmental Protection Agency's (EPA) paperwork management program and policies. Because of recent environmental legislation and program changes, the EPA requirements for information from the public are expected to increase dramatically. Until the Paperwork Reduction Act of 1980, the Federal Reports Act of 1942 provided the foundation for controlling the federal government's paperwork burden on the public. The Office of Management and Budget (OMB) must clear the reporting requirements proposed by most agencies including EPA.

EPA management has not supported its own paperwork control system. EPA interpreted the Federal Reports Act as exempting some reporting requirements mandated by law from OMB control. As a result, EPA was constrained by organizational and operational weaknesses and was only marginally effective. Ultimately, businesses were subject to numerous reporting requirements that OMB had never approved. Every business or other facility with an EPA permit for discharging wastewater is required periodically to submit a discharge monitoring report to EPA. EPA was to use this report to check whether the permit holder stayed within approved pollutant limits. However, some of the regional offices did not review or use the monitoring reports of minor dischargers because the EPA policy was to emphasize enforcement of major dischargers' permits and because the offices lacked sufficient staff. Under the Clear Air Act regulations, importers of motor vehicles or motor vehicle engines must file an EPA declaration form on which they declare whether or not the import meets federal emission requirements or is exempt. The U.S. Customs Service investigated only 30 cases of alleged falsified information involving 62 vehicles. Burden hour estimates are an essential element in the OMB system for controlling paperwork. OMB uses the estimates to gauge the impact of a proposed requirement and, conversely, to measure progress in reducing paperwork. However, most of the EPA estimates are based on judgment, particularly those for complex requirements.

Recommendations for Executive Action

  1. Status: Closed

    Comments: Please call 202/512-6100 for additional information.

    Recommendation: The Administrator of EPA should change the requirements for the declaration form for imported motor vehicles and engines so that the form would apply only in those cases where the import is not in compliance with the applicable emission requirements, or when a Customs Service inspection reveals a possible violation of the requirements.

    Agency Affected: Environmental Protection Agency

  2. Status: Closed

    Comments: Please call 202/512-6100 for additional information.

    Recommendation: The Administrator of EPA should change wastewater discharge permits for minor dischargers so that reporting schedules are consistent with EPA capability to use the information.

    Agency Affected: Environmental Protection Agency

  3. Status: Closed

    Comments: Please call 202/512-6100 for additional information.

    Recommendation: The Administrator of EPA should direct the Office of the Inspector General to make periodic management audits of the efficacy of paperwork controls throughout the agency.

    Agency Affected: Environmental Protection Agency

  4. Status: Closed

    Comments: Please call 202/512-6100 for additional information.

    Recommendation: The Administrator of EPA should direct the clearance officer to periodically evaluate the practical utility of EPA reporting requirements.

    Agency Affected: Environmental Protection Agency

  5. Status: Closed

    Comments: Please call 202/512-6100 for additional information.

    Recommendation: The Director of OMB should revise OMB Circular A-40 to encourage use of pretests, especially for complex reporting requirements.

    Agency Affected: Executive Office of the President: Office of Management and Budget

  6. Status: Closed

    Comments: Please call 202/512-6100 for additional information.

    Recommendation: The Administrator of EPA should provide the support necessary for those responsible for implementing the Paperwork Reduction Act to: (1) maintain centralized control over the reporting requirements imposed by the agency; (2) oversee the preparation and submission of clearance requests for all requirements that meet the clearance criteria; and (3) evaluate the technical quality of all proposed information collection plans and related questionnaires.

    Agency Affected: Environmental Protection Agency

 

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