This ICR is not
approved according to 5 CFR 1320. In the pro- posed rule associated
with this ICR EPA solicits comment on many questions associated
with the new forms 2A/2S and the associated testing and
data-gathering requirements. Respondents could have different
information collection burdens depending on the com- ments received
and what changes EPA makes in response to these comments. EPA has
not calculated the burdens associated with some of the possible
variations which may arise from the public comment process and has
therefore not demonstrated that the pro- posed option is the least
burdensome alternative. In addition, there is an unexplained drop
in burden hours from 622,628 hours under the old regime to 71,413
hours under the new forms. Lastly EPA needs to justify more fully
the inclusion of testing require- ments for contaminants even in
cases where there is no reason to expect that they may be present.
All of these issues should be addressed when EPA resubmits this
ICR.
Inventory as of this Action
Requested
Previously Approved
08/31/1998
08/31/1998
03/31/1999
1
0
1
622,628
0
0
0
0
0
The purpose of this action is to
revise the NPDES permit application requirements and develop new
permit application forms, forms 2A and 2S, to streamline the permit
application process for publicly owned treatment works and
treatment works treating domestic sewage and to improve the quality
of permits issued to these facilities. State and local governments
are affected.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.