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OAQPS Economic Analysis Resource Document

6.3 The Paperwork Reduction Act (PRA)

In many rulemakings, various recordkeeping, reporting, labeling, testing, and other requirements are included to help EPA verify compliance with the rule after it has been promulgated. Under the PRA, the Agency is required to estimate the “burden hours” associated with the recordkeeping and reporting requirements and to weigh this burden against the “practical utility” of the information collection. This analysis must be presented to OMB for review in a standardized document known as an ICR.

In general, an ICR is composed of the following elements:

  • a summary of the collection of information;
  • a description of the need for, and proposed use of, the information;
  • a description of the likely respondents, including the number of respondents and the frequency of response; and
  • an estimate of the total annual reporting and recordkeeping burden that will result from the information collection.

An outline for a typical ICR is presented in Table 6-3.

The ISEG analyst may play a role in or be primarily responsible for preparing estimates of burden associated with recordkeeping and reporting requirements presented in Section 6 of the ICR. The workgroup chair for the rulemaking is usually responsible for preparing the remainder of the ICR. Cost and burden estimates should reflect any reporting and recordkeeping costs estimated in the cost section of the EIA. It is important to note, however, that the reporting and recordkeeping costs included in the ICR are estimated over a period of 3 years. In contrast, the reporting and recordkeeping costs estimated in the cost section of the EIA span the entire period of analysis considered in the EIA. These estimates should include the total time and resources needed to


6 Impact Analyses

 6.0 Intro

 6.1 The Unfunded
   Mandates Reform
   Act (UMRA)

 6.2 Regulatory
   Flexibility Act
   (RFA) and Small
   Business Regul-
   atory Enforce-
   ment Fairness
   Act (SBREFA)

 6.3 The Paperwork
   Reduction Act

 6.4 Distributional

 6.5 Structural
Table 6-3
  • review instructions;
  • develop systems for the purpose of collecting, validating, and verifying information; processing and maintaining information; and disclosing or providing information;
  • adjust current practice to comply with the recordkeeping and reporting requirements;
  • train personnel to respond to an information collection;
  • search data sources;
  • complete and review the information collection; and
  • transmit or disclose the information.
Analysts should consult the Office of Policy (OP) ICR Handbook ( EPA, 1998e) when preparing recordkeeping and reporting cost estimates to be included in an ICR.

As part of the statement of need for the proposed action, the ICR should also describe the practical utility of the information to be collected, maintained, or disclosed. 5 CFR 1320 defines practical utility as “the actual...usefulness of the information to or for an agency, taking into account its accuracy, validity, adequacy, and reliability, and the agency’s ability to process the information it collects...in a timely fashion.” Practical utility is typically established by qualitatively describing the use of the information. The discussion of practical utility is usually left to the workgroup.

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