EPA Paperwork:

Burden Estimate Increasing Despite Reduction Claims

GGD-00-59: Published: Mar 16, 2000. Publicly Released: Mar 23, 2000.

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Carlotta C. Joyner
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Pursuant to a congressional request, GAO provided information on the Environmental Protection Agency's (EPA) paperwork burden, focusing on: (1) the general dimensions of EPA's paperwork requirements and the agency's progress toward reducing the burden that those requirements impose; (2) the process that EPA used to develop paperwork burden-hour estimates for its largest information collections as of September 30, 1998, and gauge the credibility of those estimates; (3) EPA's largest paperwork burden-hour reductions between September 30, 1995, and September 30, 1998, and gauge the credibility of those reductions; and (4) EPA's Reinventing Environmental Information initiative and the agency's new Office of Environmental Information.

GAO noted that: (1) EPA's estimate of the paperwork burden that it imposed on the public increased from about 109 million burden hours as of September 30, 1995, to about 119 million burden hours as of September 30, 1998; (2) this 10 million burden-hour increase in paperwork would have been even greater if EPA had not eliminated about 24 million burden hours from its estimate during this period; (3) as of September 30, 1998, more than two-thirds of EPA's estimated 119 million burden hours were imposed on businesses, nearly three-quarters were related to information collections intended to determine compliance with regulatory requirements, and about 80 percent were associated with collections in which responses were mandatory; (4) EPA used a systematic process to develop annual burden-hour estimates for each of its 14 largest information collections; (5) that process involved breaking each collection into specific tasks and subtasks and developing estimates of the amount of time required for the activity, the number of respondents, and the frequency with which the activity must be performed each year; (6) the assumptions that EPA used to develop those estimates were based on a combination of existing information, past programmatic experience, information and comments provided by the public, and, to a certain extent, best guesses; (7) the organizations that provided comments on EPA estimates said that five of the seven EPA burden-hour estimates they reviewed were generally accurate but that two of the estimates were too low; (8) EPA eliminated 24 million burden hours from its estimated paperwork burden during fiscal years 1995 and 1998; (9) GAO examined 13 information collections that accounted for more than 70 percent of these burden hours; (10) most of the reductions were because of: (a) revisions of previous agency estimates that had no impact on the burden borne by the public; (b) changes in the economy or respondents' technology for which EPA should not claim credit; or (c) the planned maturation of the program requirements over time; (11) in contrast, in EPA's annual report for 1998, the agency said that it had reduced its paperwork burden on the public by streamlining processes, eliminating outdated provisions, and consolidating duplicative requirements, and that the reductions had saved businesses and communities hundreds of millions of dollars; and (12) GAO could not gauge the credibility of all of EPA's burden-hour reductions because most of the organizations representing respondents that GAO contacted did not provide comments.

Recommendation for Executive Action

  1. Status: Closed - Implemented

    Comments: EPA officials provided documentary evidence that they have corrected the agency's burden-hour estimate for the national pretreatment program. They also indicated that future editions of the burden estimate for the National Pretreatment Program were revised back to hours. Those changes were made final at the end of September, 2000.

    Recommendation: The Administrator, EPA, should correct the agency's burden-hour estimate for the national pretreatment program in the Regulatory Information Service Center database and future editions of the Information Collection Budget by including in its estimate the nearly 600,000 burden hours that were converted to dollars.

    Agency Affected: Environmental Protection Agency


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