EPA Paperwork

Burden Estimate Increasing Despite Reduction Claims Gao ID: GGD-00-59 March 16, 2000

The Environmental Protection Agency (EPA), like other federal agencies, collects information from the public. EPA uses this information to help ensure compliance with the agency's regulations, to evaluate the effectiveness of its programs, and to determine eligibility for program benefits. However, EPA's information collection efforts impose a substantial burden on the public, and small businesses contend that they are particularly affected by government paperwork. This report (1) describes the general dimensions of EPA's paperwork requirements and the agency's progress toward reducing the burden that those requirements impose, (2) describes EPA's process for developing paperwork burden-hour estimates for its largest information collections as of September 1998 and gauges the credibility of those estimates, and (3) describes EPA's largest paperwork burden-hour reductions between September 1995 and September 1998 and gauges the credibility of those reductions. GAO also provides information on EPA's Reinventing Environmental Information Initiatives 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.


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