Supporting Statement

for

Information Collection Request

Clean Air Interstate Rule to Reduce Interstate Transport of Fine
Particle Matter and Ozone (Renewal)

EPA ICR Number 2152.03; OMB Control Number 2060-0570

40 CFR Part 51

40 CFR Part 96

Clean Air Markets Division

Office of Air and Radiation

U.S. Environmental Protection Agency

1.	IDENTIFICATION OF THE INFORMATION COLLECTION

1(a)  Title of the Information Collection

Clean Air Interstate Rule to Reduce Interstate Transport of Fine
Particle Matter and Ozone, ICR Number 2152.03, OMB Number 2060-0570.

1(b)  Short Characterization/Abstract

In 2005, the United States (U.S.) Environmental Protection Agency (EPA)
promulgated a the Clean Air Interstate Rule (CAIR) to Reduce Interstate
Transport of Fine Particle Matter and Ozone.  CAIR combined its
reporting requirements with existing requirements from the Consolidated
Emissions Reporting Rule (CERR), the Emission Reporting Requirements for
Ozone State Implementation Plan (SIP) Revisions Relating to Statewide
Budgets for NOx Emissions to Reduce Regional Transport of Ozone (NOx SIP
Call) and the Acid Rain Program (ARP) under Title IV of the CAA
Amendments of 1990.  These other requirements have approved ICRs in
place.  CERR  is covered under OMB Control Number 2060-0088, and the ARP
is covered under OMB Control Number 2060-0258.  The ICR Emission
Reporting Requirements for Ozone State Implementation Plan (SIP)
Revisions Relating to Statewide Budgets for NOx Emissions to Reduce
Regional Transport of Ozone (NOx SIP Call), OMB Control Number
2060-0445) expires at the end of 2008.  Sources previously subject to
the NOx SIP Call requirements are now covered under CAIR.

This supporting Statement and ICR is being submitted to account for the
incremental burden associated with CAIR.  As such, this supporting
Statement references the burden analysis included in the ICRs for CERR
(2060-0088) and ARP (2060-0258) and estimates the change in burden
resulting from CAIR beyond the scope of these ICRs.  

This ICR details the additions and changes to reporting requirements
associated with CAIR.  These changes can be logically divided into two
categories:  1) changes to existing requirements for emission reporting
under the CERR; and 2) the addition of reporting requirements to support
emissions trading in States using the CAIR model cap and trade rules. 
Throughout this Supporting Statement, the burden analysis associated
with these two categories will be discussed sequentially as "Emission
Reporting Requirements" and "Emission Trading Requirements."  

Emission Reporting Requirements

The existing emissions reporting requirements under the CERR are already
rather comprehensive.  First, in Arkansas, Florida, Iowa, Louisiana,
Mississippi, and Wisconsin, which we have determined make significant
contributions to ozone nonattainment in another State but are not among
the 21 States subject to the NOx SIP Call, the required emissions
reporting will be expanded to match those of the NOx SIP Call States. 
The change requires that those States report NOx emissions during the
five-month ozone season, in addition to the existing requirement for
reporting emissions for the full year.  This new requirement begins with
the triennial inventory year prior to the CAIR implementation date. 
This will be the 2008 inventory year, the report for which will be due
to EPA by June 1, 2010.  By combining the SIP Call and CAIR emission
reporting, this ICR now accounts for the ozone season emissions
reporting by all 28 States and the District of Columbia.

Second, under the existing CERR, yearly reporting is required only for
sources whose emissions exceed specified amounts.  Under CAIR, the 23
States and the District of Columbia subject to CAIR for reasons of PM2.5
must report to EPA each year a set of specified data elements for all
sources subject to new controls adopted specifically to meet the CAIR
requirements related to PM2.5, unless the sources participate in an
EPA-administered emissions trading program.  This is like the every-year
reporting requirement for controlled sources under the NOx SIP Call, but
covering SO2 in addition to NOx and covering the whole year - since the
PM2.5 NAAQS at issue is the annual NAAQS - rather than only the ozone
season.  This rule could increase the number of sources for which States
must submit reports each year rather than only every third year, if a
State chooses to control non-EGU sources under CAIR or if the State does
not join the EPA trading programs for EGUs.  This new requirement will
begin with the 2009 inventory year, the report for which will be due to
EPA by June 1, 2011.  After the 2009 reporting year, this new
requirement will have no effect on States that fully comply with CAIR by
requiring their EGUs to participate in the EPA model cap-and-trade
programs.

Emission Trading Requirements

For this ICR, it is assumed that each State will adopt the relevant CAIR
SO2, annual NOx and ozone season NOx model trading rules, and the burden
associated with these programs is evaluated.  The trading programs
include paperwork burden related to:  1) transferring and tracking
allowances; 2) allocation of allowances to affected units; 3)
permitting; 4) annual year end compliance certification; and 5)
monitoring and reporting.  The monitoring and reporting requirements of
the trading programs will require capital and labor expenditures by
industry, and these are evaluated.

As with the Acid Rain Program and the NOx SIP Call, the ability to buy
and sell (or transfer) allowances is expected to provide substantial
economic benefits by encouraging the greatest emissions reductions where
costs of reductions are lowest.  Allowance trading cannot be
implemented, however, unless regulations governing emissions monitoring
and permitting of sources are in place as well.  To ensure compliance
with the emissions reduction requirements and to provide the region wide
consistency needed to foster the allowance market, the designated
representative of the owners and operators of each source with affected
units are required to have CAIR requirements integrated into their Title
V permits for the affected source and to certify that an approved SO2
and NOx emissions monitoring system has been installed and is properly
operated at each affected unit.

For affected units currently required to monitor using Part 75
provisions, information for the allocation methodology will be recorded
and collected as part of the emissions monitoring and reporting process.
 While many sources have already installed necessary emissions
monitoring equipment due to requirements under other regulations, some
sources will need to install new monitors or upgrade existing monitors. 
Capital costs also usually include the cost of initial certification of
new or upgraded monitors is included as part of start-up costs.

Emissions monitoring and reporting by sources in the cap and trade
program is fundamental to the allowance trading system.  EPA will use
the data contained in the reports to verify actual emissions.  Without
accurate monitoring and reporting of emissions, the integrity of the
allowance system would be undermined, and there would be no assurance
that the cap is achieved and emissions had been reduced.  To meet the
emissions monitoring, recordkeeping and reporting requirements, affected
units are required to:  1) submit a monitoring plan and certification
reports for each monitoring system; 2) record hourly emissions data; and
3) submit reports of their emissions and operating data to EPA.  Sources
with monitors already certified under Part 75 may be exempt from initial
certification requirements.  

Note that EPA recently revised 40 CFR Part 75 (see 73 FR 4312, January
24, 2008).  A separate ICR addresses the specific burdens associated
with meeting those revised Part 75 requirements.  In large part, these
revisions support EPA's modernization of electronic reporting under Part
75, through the new Emission Collection and Monitoring Plan System
(ECMPS).  While the ICR estimates a one-time burden of understanding and
implementing the new rules, in the longer term, EPA believes the new
system will streamline the reporting process.  EPA has not yet accounted
for any reduced burden in this ICR, but intends to use the 2009 through
2011 implementation period to evaluate whether the reporting burden
estimates in this ICR (and the Acid Rain Program ICR) should be modified
based on reporting through ECMPS.

All participants in the allowance transfer system are required either to
complete and submit an allowance transfer form for each allowance
transfer or to perform the transfer on-line.  Participants in the
transfer system that are not affected sources, such as allowance
brokers, fuel suppliers and environmental groups are also required to
file a onetime account information application to establish accounts in
the allowance tracking systems.  For sources affected by CAIR, allowance
transfers currently conducted under the Acid Rain and NOx SIP Call
Programs will occur in the context of the CAIR Trading Program starting
in 2009 for the ozone season NOx programs and 2010 for the SO2 annual
program.  The only additional transfers as a result of CAIR will occur
under the annual NOx trading program.

2.	NEED FOR AND USE OF THE COLLECTION

2(a)  Need/Authority for the Collection

One of the goals of this rulemaking is to consolidate the emission
inventory reporting requirements found in several existing regulations
and streamline the activities involved in submitting the emissions data
to EPA.  This will enable the EPA to achieve uniformity and completeness
in emission inventories used to support national, regional, and local
air quality planning and attainment. 

While the CAA does not provide a specific authorization for a national
emissions data base, the CAA provides the EPA ample legislative
authority for acquiring such data.  Emissions data are of vital
importance to the EPA for fulfilling a host of monitoring,
standard-setting, rulemaking, reviewing, and reporting duties.  Section
110 and 301(a) of the CAA provide a primary authority for a national
emissions data base.  Section 110 requires each State to prepare a plan
which provides for implementation, maintenance, and enforcement of the
primary standard for each pollutant for which air quality criteria have
been issued.  This plan must include provisions for periodic reports
identifying sources and listing amounts of emissions.  Section 301(a)
authorizes the Administrator to promulgate necessary regulations.

Congressional support for collecting and reporting emissions data is
demonstrated in three sections of the CAA.  Section 110(a)(2)(F)
requires that each State provide for periodic reports on the nature and
amounts of emissions of criteria pollutants from stationary sources. 
Sections 182(a)(3)(A) and 187(a)(5) of the CAA specify periodic
inventory requirements for ozone and CO nonattainment areas,
respectively.  Section 182(a)(3)(A) requires States with ozone
nonattainment areas to submit a current inventory of actual emissions of
VOC, NOx, and CO every three years.  Section 187(a)(5) requires a
similar inventory of actual CO emissions for CO nonattainment areas. 
Periodic inventories include emission estimates for all point, nonpoint,
onroad mobile, nonroad mobile, and biogenic sources.  Section 172(c)(3)
also provides the Administrator with discretionary authority to require
other emissions data as deemed necessary for State Implementation Plan
(SIP) development in nonattainment areas to meet the NAAQS.  In 1998,
EPA promulgated the NOx SIP Call which required the affected States and
the District of Columbia to submit SIP revisions providing for NOx
reductions to reduce their adverse impact on downwind ozone
nonattainment areas.  (63 FR 57356, October 27, 1998).  As part of that
rule, codified in 40 CFR 51.122, EPA established emissions reporting
requirements to be included in the SIP revisions required under that
action.  The CERR emissions reporting requirements were promulgated by
EPA in 2002, and are codified at 40 CFR part 51 subpart A (67 FR 39602,
June 10, 2002).  These requirements replaced the requirements previously
contained in subpart Q, expanding their geographic and pollutant
coverages while simplifying them in other ways.

The CAIR rulemaking consolidated two sections of title 40 of the CFR
that contain emissions reporting requirements applicable to States
(subpart A of part 51 (the CERR) and section 51.122 in subpart G of part
51 (the NOx SIP Call reporting requirements)) and incorporated some
modifications.  The emissions reporting requirements for CAIR are
included in 40 CFR 51.125.  The requirements in section 51.125 are
intended to achieve the reporting needed to verify the reductions
required by CAIR. 

Under the CAIR requirements in section 51.125, every year States must
report to EPA, both the annual emissions of NOx and SO2 and the ozone
season (May 1 through September 30) emissions of NOx from sources that
the State has determined to be subject to the emissions control
requirements of CAIR.  The affected States are also required to report
ozone season emissions and typical summer daily emissions of NOx from
all sources every third year (2011 is the next reporting year).  The
reports are due to EPA on December 31 of the calendar year following the
inventory year.  The emissions reporting requirements affect the
District of Columbia and the 28 States affected by CAIR.

2(b)  Practical Utility/Users of the Data

Emission Reporting Requirements

Emissions data and related information on stationary point and nonpoint
sources, as well as non-road and on-road mobile sources, are routinely
used by OAQPS and EPA Regional Offices in carrying out a variety of
activities.  These activities support regulatory functions as well as
functions that are more programmatic in nature such as trends analyses. 
Such projects include:

●	Evaluation of existing control strategies, such as CAIR, for States
and larger areas;

●	Evaluation of proposed control strategies for States and larger
areas, including applications of regional scale models;

●	Development of national control strategies and preparation of
Regulatory Impact Analyses (RIA);

●	Preparation and publication of national summaries of emissions
including trend analyses;

●	As a data base to assist in the identification of important source
categories for future regulation; and

●	Preparation of the stationary source portion of a report to Congress
on SO2 emissions.  This report is required by Section 406 of the CAA and
is due on a five-year cycle that began on January 1, 1995.  The report
must contain an inventory of national annual SO2 emissions from
industrial sources (as defined in Title IV of the CAA).

EPA's Office of Research and Development (ORD) uses emissions source
data in determining priorities for control technology research and as a
key data component in the application of regional scale models.  EPA's
Regional Offices use emissions and other source parameters to support
source inspections and in the analyses of the impact of new or modified
sources within an area.  EPA's Emission Factor and Inventory Group
(EFIG) use the data to assess and analyze trends in criteria pollutant
emissions over time.

In addition to supporting projects and initiatives internal to EPA, both
OAQPS and EPA's Regional Offices respond to numerous requests for
reports on emission sources.  Typically this is done under the Freedom
of Information Act.  Most requests come from contractors and consultants
involved in special studies; a smaller number come from the press and
universities and others involved in research.

The collection of emissions data specific to nonattainment areas for
certain criteria air pollutants is necessary to comply with requirements
specified in Title I of the CAA.  States with nonattainment areas rely
on current information for point, nonpoint, and mobile sources to revise
their SIPs and to plan for emission reductions mandated by the CAA.  In
addition, a Statewide inventory compiled at least every three years for
all point, nonpoint, and mobile sources is considered to be a key tool
to assist States in meeting CAA requirements that address emissions
tracking, compliance issues, and mid-course adjustments.  Statewide
emission inventories can be used by States affected by pollution
transport from upwind areas to develop more efficient control strategies
to meet the NAAQS.  Statewide emission inventories that were developed
by EPA (the NEI) are being used by the Regional Planning Organizations
(RPOs) as the starting point for the development of Statewide emission
inventories used in the regional haze program to define control
strategies.

Emission Trading Requirements

Permit applications, including proposed compliance plans, will be used
by States and EPA to issue operating permits and to allocate allowances.
 A permit application is legally binding on the owners, operators, and
designated representative of a source until the actual permit is issued.
 Affected sources may rely on the permit for information on the
requirements with which they must comply.  Because permit applications
and permits are public documents, they may be used by the public to
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●	The primary purpose of the trading programs is to assist States in
the attainment of the ozone and fine particulate matter national ambient
air quality standards (NAAQS) by reducing the adverse effects of the
transport of ozone, ozone precursors and fine particles from upwind
States by reducing annual emissions of sulfur dioxide and nitrogen
oxides; and

●	EPA can only enforce the program by comparing, for each affected
unit, emissions data and the number of allowances held.

Information collected on allowance transfers is used by EPA or its
designated agent to track allowances for the purpose of determining
compliance with the NOx and SO2 Trading Programs.  Information on
allowance transfers is also used by participants in the allowance market
and the public to evaluate the activities of affected sources, and by
EPA for program evaluation.

Together, the allowance trading system, operating permits, and emissions
data helps to provide the accountability needed so that the NOx and SO2
Trading Programs can function without more stringent command and control
approaches.

3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a)  Nonduplication

Emission Reporting Requirements

EPA will allow the direct reporting of point source data from sources to
EPA to satisfy this requirement if the sources are subject to the
monitoring and reporting requirements of 40 CFR Part 75.  The direct
reporting of data from sources to EPA will minimize the reporting burden
on States.  Also, direct reporting will avoid duplication of effort for
sources subject to the Part 75 requirements.

Emission Trading Requirements

Reporting requirements for affected sources for the CAIR NOx and SO2
Trading Programs are integrated with existing Part 75 reporting formats.
 The reporting formats are currently used by Acid Rain Program units
under Title IV of the Act and through 2008 are being used by units
subject to the NOx SIP Call Trading Program implemented under Title I of
the Act.  Thus, for units subject to Acid Rain or the CAIR quarterly
reporting requirements, or both, only one submission will need to be
made on a quarterly basis.  Starting in 2009, CAIR reporting replaces
NOx SIP Call trading program reporting.

3(b)  Public Notice Required Prior to ICR Submission to OMB

An announcement of the public comment period for this ICR renewal was
published in the Federal Register (73 FR 24973) on May 6, 2008.  In
addition, all documents associated with this ICR renewal are accessible
on   HYPERLINK "http://www.regulations.gov"  www.regulations.gov , under
Docket # EPA-HQ-OAR-2006-0947 and Docket # EPA-HQ-OAR-2008-0317.  No
comments were received in response to this ICR renewal. 

  

3(c)  Consultations  

Emission Reporting Requirements

During the development of emission reporting requirements for CAIR
discussions were held with STAPPA/ALAPCO to clarify EPA's logic in
developing the rule and to answer questions.  The Agency has provided
seven implementation workshops for state personnel and five additional
workshops for sources, both of which were well attended with up to 200
participants.  Average attendance at these workshops has been about 110
stakeholders.  In addition, EPA holds bimonthly consultations with
STAPPA as well as monthly monitoring conference calls with states, and
the CAIR rule and related issues are an important component of those
consultations and meetings.  

Emission Trading Requirements

The requirements for the CAIR Trading Programs have been developed using
both the methodology found in existing trading programs as well as
consultations with interested parties.  EPA built on the cap and trade
strategy used in the Acid Rain Program, Ozone Transport Commission's NOx
Budget Program, and the NOx SIP Call.

EPA held two workshops with States in the NOx SIP Call or OTC programs
to discuss lessons learned in those programs.  Additionally, EPA has had
frequent interaction with affected sources and States in the course of
implementing the Acid Rain and NOx SIP Call Trading Programs.  EPA has
received comments following the workshops and through these less formal
interactions and considered and incorporated those comments into the
final CAIR rule package.  Recently, EPA has held numerous consultations
with stakeholders as EPA implements the new data system (ECMPS) that
will support Part 75 reporting as of January 1, 2009.  EPA has also held
stakeholder workshops on CAIR implementation.  EPA has considered and
accounted for those interactions in preparing this renewal ICR.

Finally, as part of updating the previous ICR for the Acid Rain Program
(Part 75) monitoring requirements, EPA contacted various affected
parties to gather information on CEM capital costs, CEM operation and
maintenance costs, fuel meter capital costs, and CEM/fuelmeter testing
costs.  That information has been used in this ICR where appropriate.

3(d)  Effects of Less Frequent Collection

Emission Reporting Requirements	

The submittal dates required for reporting of emissions data to EPA have
been established to minimize the burden on State and local agencies, but
also to ensure that State and local agencies are collecting timely and
sufficient emissions inventory data to support their air pollution
control efforts.  A Statewide inventory compiled at least every three
years for all point, nonpoint, and mobile sources is considered
important to assist States in meeting various CAA requirements.

If the information collection were not carried out every three years for
all sources and annually for major point sources, the EPA would not be
able to maintain a central, national repository of emissions data from
which to extract updated information needed to fulfill EPA mandates.

If this information collection were not carried out annually for sources
being controlled to meet the SO2 and NOx budgets, EPA would not be able
to verify that emission reductions necessary to meet each State's SO2
and NOx emission budgets were being achieved.

In addition, a triennial report of all NOx sources Statewide is vital in
enabling EPA to track States' progress towards meeting the NOx budgets. 
Because the SO2 and NOx budgets prescribed have been deemed essential in
order for downwind States to attain the NAAQS in a timely manner, data
collected less frequently would be of little or no use.

Emission Trading Requirements

Submittal of allowance trading information and emissions information on
an annual basis provides necessary feedback on the requirements of the
program, especially whether the program caps have been maintained.  If
this information collection were not carried out annually for sources
being controlled to meet the SO2 and NOx budgets, EPA would not be able
to verify that emission reductions necessary to meet each State's SO2
and NOx emission budgets were being achieved.  Because the SO2 and NOx
budgets prescribed have been deemed essential in order to aid downwind
States in attaining the NAAQS in a timely manner, data collected less
frequently would be of little or no use.

Quarterly collections of emissions data allows the opportunity to check
data for errors and provide rapid feedback on needed adjustments to data
collection systems, and thereby promotes accurate and reliable emissions
data.  For this same reason, existing federal and State emission
monitoring programs often require quarterly reporting, or in some cases,
monthly.  Less frequent collection, such as semi-annually or annually,
would increase the amount of preparation and review time at the end of
the reporting period both for regulated sources and for EPA.  This would
slow down the process for the verification of compliance.

3(e)  General Guidelines

This ICR does not violate any of OMB's guidelines for information
collections.

3(f)  Confidentiality

Any data that is submitted to EPA under this rule will be considered in
the public domain and cannot be treated as confidential. 

As required by Section 114 of the Clean Air Act, estimates or
measurements of emissions must be treated as non-confidential.  Under
Agency procedures, data items relating to the computation of emissions
may be identified as sensitive by a State and are then treated as
"State-sensitive" by EPA.  The potentially State-sensitive items include
the following:  Process rate, boiler design capacity, emission
estimation codes, percent space heat, operating rate, and maximum
operation rate/hour.  Where Federal and State requirements are
inconsistent, EPA Regional Office should be consulted for final
reconciliation.

3(g)  Sensitive Questions

This information collection does not ask any questions concerning sexual
behavior or attitudes, religious beliefs, or other matters usually
considered private.

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a)  Respondents/Standard Industrial Classification (SIC) Codes

Emission Reporting Requirements	

The emissions data required by the rule will generally be submitted by
State air pollution control agencies.  Under the CERR, there are 55
State and territorial air pollution control agencies, as well as 49
local air agencies that will be subject to the national reporting
requirements and will be required to compile and report emissions
information for large stationary point sources on an annual basis, and
for smaller point sources, stationary nonpoint and mobile sources on a
three-year basis.  CAIR requires 28 States and the District of Columbia
to report NOx and SO2 emission related data on an annual and triennial
basis.  Those States subject to CAIR for reasons of PM2.5 and/or ozone
must report to EPA each year a set of specified data elements for all
sources subject to new controls adopted specifically to meet the CAIR
requirements related to PM2.5 and/or ozone, unless the sources
participate in an EPA-administered emissions trading program.  The
affected SIC code would be 9511 - Air and Water Resource and Solid Waste
Management, which includes governmental environmental protection and
control agencies, and pollution control agencies.  Because all 28 States
and Washington D.C. intend to use the trading program, no burden is
associated with this requirement.  

Emission Trading Requirements

This ICR also estimates a burden for affected industry sources to
monitor SO2 and NOx mass emissions and demonstrate compliance with SO2
and NOx control measures.  Sources may report data directly to EPA if a
source is required to meet the monitoring and reporting requirements of
Part 75.  All affected States and Washington D.C. have chosen to control
large electric utility sources to comply with their SO2 and NOx
emissions budgets.  Electric utility combustion sources are generally
classified as either SIC 4911 - Electric Services, or 4931 - Electric
and Other Services Combined [NAICS 221112 Electric Power Distribution]. 
In addition, the NOx SIP Call trading program affected combustion
sources across many industrial sectors.  States previously subject to
that trading program have the option to keep those sources in the CAIR
ozone season NOx program, and many States have elected to do so.  Those
sources include a wide range of SIC [NAICS] codes, including cement
kilns, which fall primarily under SIC 327 - Concrete, Gypsum, and
Plaster Products) [NAICS 3273 Cement Manufacturing and 3274 Gypsum
Product Manufacturing] and large industrial combustion sources (e.g.,
boilers, turbines, and internal combustion engines), which are expected
to fall under SIC codes for the manufacturing sector, i.e., SIC Major
Groups 29-40 [NAICS 31-33 Manufacturing].

4(b)  Information Requested

Emission Reporting Requirements

The CERR and NOx SIP Call established the basic emission reporting
requirements.  CAIR changes some of these requirements such that the
previously accounted for reporting burden also changes.  Only the
changes to the CERR and NOx SIP Call reporting requirements that would
change reporting burden are discussed here.

Respondent activities

For the emission inventory reporting requirements of CAIR, respondent
activities are very similar to what has been required to satisfy
reporting under CERR and the NOx SIP Call.  The specific State
respondent activities associated with CAIR that are changes from the
existing CERR requirements include a triennial State reporting burden. 
This ICR includes estimates for the incremental burden across all CAIR
affected States and Washington D.C., including those previously subject
to the NOx SIP Call reporting requirements.

	The one-time State burden items include reading the reporting
requirements of the rule and the Triennial State burden item.

Emission Trading Requirements

This section describes the data items requested from affected sources
for the collections described in this ICR.  This section also defines
the activities in which respondents must engage to assemble, submit, or
store these data items.

(i)  Data Items, Including Recordkeeping Requirements

(a)  Allowance Tracking

There are several data items required for allowance tracking activities.
 First, the affected source must submit account certificates of
representation for the CAIR designated representative and (if desired)
alternate CAIR designated representative.  This documentation, the
requirement for which is found in 40 CFR 96.113, .213 and .313, must
include:

●	Identification of the source and unit;

●	Dates on which the unit commenced operation and commenced commercial
operation;

●	Name and contact information for the CAIR designated representative
and alternate;

●	A list of the owners and operators of each source and unit; and

●	A certification Statement and signature of the CAIR designated
representative and alternate.

Certification applications are to be kept for a period of five years
pursuant to the general requirements imposed for Title V permitted
facilities.

(b)  Permitting

The basic requirement for permitting is an application for a permit
revision to a source's operating permit issued under Title V of the Act.
 Although there is some possibility that a non-Title V source could be
affected under the CAIR Trading Program, all affected sources are
assumed to be Title V sources for purposes of this ICR.  Except for the
permit revision application, all of the other monitoring, reporting or
recordkeeping requirements associated with Title V permitting are either
part of the baseline Title V requirements or are covered separately
under section 4(c).  Title V permit applications must be kept for five
years pursuant to Title V recordkeeping requirements.  In addition, some
coal-fired units that are not part of the Acid Rain Program may have to
apply for a permit to construct under Title I of the Act as part of a
CAIR compliance strategy.  For this ICR, most of this burden was
expected to occur prior to the end of 2008.  During the 2009-2011
period, this ICR estimates that only a small percentage of sources will
still have to go through the permitting process as a result of CAIR. 

(c)  Monitoring and Reporting

Affected trading program sources are required to monitor SO2 and NOx
mass emissions, and record and report emissions data using the
requirements of 40 CFR Part 75.  The emissions monitoring requirements
specify that affected sources must:  1) submit a monitoring plan for
each affected unit at a source; 2) submit data for certification of each
monitor; and 3) record hourly operational, pollutant monitor, and flow
monitor data for each affected unit and submit quarterly reports of
their emissions data to EPA.

Respondents are required by 40 CFR 75.64 to submit the quarterly SO2 and
NOx mass emissions data electronically, by direct electronic submission
to EPA, and must also include a certification Statement by the
designated representative of the unit.  All monitoring records are to be
kept for three years, with one possible exception under a voluntary
option for fuel flowmeter calibration testing.

(ii)  Respondent Activities

The primary tasks that will be performed by trading program respondents
to meet the emissions monitoring requirements are:  1) completing and
submitting appropriate monitoring plan forms for each affected source
and each affected unit at a source; 2) conducting tests to certify the
operation of monitors, and submitting test results to EPA; 3) recording
hourly emissions data (this activity generally is performed
electronically); 4) operation and maintenance activities associated with
the monitoring, including quality assurance activities; 5) assuring data
quality, preparing quarterly reports of emissions data and submitting
these reports to EPA; and 6) responding to error messages generated by
EPA.  In addition, some respondents will have to purchase the necessary
monitoring hardware and purchase the electronic data reporting software
(or software upgrades).  Most of these purchases are expected to occur
prior to 2009 but this ICR continues to include annualized costs for
sources that are likely to have incurred these expenditures through
2008.

5.	THE INFORMATION COLLECTED(AGENCY ACTIVITIES, COLLECTION METHODS, AND
INFORMATION MANAGEMENT

5(a) 
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●	Receiving, reviewing, and storing emission inventory data submitted
by each State;

●	Processing and updating data submitted by States, including
performing quality assurance of data, and coordination of efforts to
resolve errors and anomalies; and

●	Fulfilling information requests.

Emission Trading Requirements

The major EPA activities related to the CAIR Trading Program include: 
(1) maintenance and administration of the SO2 and NOx allowance tracking
systems, (2) reviewing permit applications, (3) reviewing monitoring
plans and certification applications, (4) processing, reviewing and
evaluating reports of quarterly emissions data from affected units, (5)
calculating/reviewing annual emissions from affected sources, and (6)
reviewing total annual emissions data submitted to track each State's
progress toward meeting its budgets and creating a summary report of
emissions.  EPA will use a computer system to track and maintain
monitoring and emissions information.  EPA will also answer respondent
questions and conduct audits of data submissions.

5(b)  Collection Methodology and Management

Emission Reporting Requirements

The EPA has established a central repository of inventory data for all
States termed the National Emissions Inventory (NEI) database. 
Emissions inventory data reported electronically will be stored in the
NEI database and used by the EPA and by other States for air modeling,
tracking progress in meeting CAA requirements, setting policy, and
answering questions from the public.

The EPA has created and maintains the NEI database as a central
repository of inventory data for all States, but the data must be
supplied by the States in electronic form.  The EPA currently requires
that States use the NEI Input Format (NIF) for electronic data reporting
(EDR).  EPA is in the process of reengineering the NEI in order to
improve the process for State agency submittals.

Emission Trading Requirements

To ensure consistency region wide and to expedite data entry, EPA
requires that standard formats used for Part 75 reporting be used to
submit the information collected for the CAIR Trading Programs.

Several computer systems and associated databases have been developed to
(1) track allowances, (2) record quarterly emissions monitoring data,
and (3) calculate the number of allowances to be deducted each year. 
The systems and databases are designed to coordinate the information for
easy access and use by the Agency, States, regulated community, and the
public.  Beginning with the first quarter of 2009, all industry sources
must use the Emissions Collection and Monitoring Plan System (ECMPS) to
submit monitoring plan, quality assurance, certification test, and
emissions data to EPA for the Acid Rain and CAIR programs.

The EPA also has established a Clean Air Markets Page on the Internet,
which includes detailed information collected from emissions reports. 
Those without access to the Internet may use the Clean Air Markets
Hotline to request information, including summary reports.  The Agency
expects to rely on these electronic means to disseminate information
about the CAIR Trading Programs as the programs are implemented.

5(c)  Small Entity Flexibility

Emission Reporting Requirements

State and territorial control agencies are not considered to be small
entities.  OMB's definition for a small entity includes small
governmental jurisdictions with populations of less than 50,000. 
According to 1999 population data from the U.S. Census Bureau, no State
or Territory has a population below this threshold.  However, certain
local air pollution agencies may be in charge of individual counties or
multi-county areas whose population is less than 50,000.

These local agencies have had experience compiling their 2002 and 2005
inventories that were submitted to EPA in June 2004 and June 2007,
respectively, as required by the CERR.  

Emission Trading Requirements

The CAIR Trading Program includes fossil fuel-fired units (stationary
boilers, combustion turbines, and combined cycle systems) that serve an
electrical generator of capacity greater than 25 MWe.  Units with a
lower capacity are not included because of the high cost of monitoring
emissions from these sources and the de minimis nature of their
emissions.

There is one small unit provision applicable to the CAIR Trading
Programs which provides for reduced monitoring.  The low mass emissions
provisions (40 CFR 75.19) allows optional reduced monitoring, quality
assurance, and reporting requirements for units that combust natural gas
and/or fuel oil and that emit no more than 100 tons of NOx annually
provided that no more than 50 tons of NOx is emitted in the ozone season
(May 1 - September 30) and no more than 25 tons of SO2 annually and that
calculate no more than the same amount based on specified procedures for
calculating and reporting emissions.  Utilities that qualify are not
required to keep monitoring equipment installed on (or conduct fuel
sampling for) low mass emissions units, nor are they required to perform
quality assurance or quality control tests.  Moreover, emissions
reporting requirements are significantly simplified for these units.

Even if a gas- or oil-fired unit does not qualify for the "low mass
emissions unit" provisions, the monitoring provisions of Part 75 do
allow for the use of alternative methods to determine emissions.  As
discussed in the Regulatory Impact Analysis (RIA) of the final Acid Rain
Implementation Regulations (October 19, 1992), smaller utilities are
more likely to be dependent on these oil- and gas-fired units,
especially very small utilities (see p. 5-14 of that RIA document). 
This analysis remains relevant under CAIR.

5(d)  Collection Schedule

Collection frequency under CAIR will be on a quarterly, annual, and
triennial basis.  All affected industry sources will use ECMPS to submit
monitoring plan, quality assurance, certification test, and emissions
data to EPA on a quarterly basis.  In addition, CAIR requires the
collection of allowance trading and emissions information on an annual
basis and the collection of a Statewide inventory of NOx sources every
three years.  

6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a)  Estimating Respondent Burden

Emission Reporting Requirements

The respondent burden for complying with the reporting requirements of
the rule is estimated incremental to the burden associated with existing
annual inventory and periodic inventory reporting requirements. 

In general, States already have mechanisms in place for reporting
emissions data to EPA under the existing CERR and NOx SIP Call inventory
requirements, particularly for those States previously subject to the
NOx SIP Call (the requirements of which are covered by CAIR starting in
2009).  The changes to the existing reporting requirements are specified
in Section 4(b)(i) of this supporting Statement. 

Other ongoing State activities that support existing inventory reporting
requirements include:

●	Collecting emissions data and other associated information;

●	Training staff in coding and submissions techniques;

●	Quality-assuring emissions data and resolution of errors and
anomalies identified by EPA;

●	Maintaining records associated with data submitted by sources; and

●	Preparing and submitting required inventory data items in approvable
format.

This supporting Statement estimates burden using methods similar to the
ones used for the CERR and the NOx SIP Call.  As Stated in 40 CFR
§51.125(b)(2), each State must provide triennial reports of SO2 and NOx
emissions data from all affected sources within the State.  The CAIR
reporting requirements necessitate the estimation and reporting of
annual NOx and SO2 emissions in 2011 for all States subject to CAIR for
purposes of ozone and PM2.5.  For States subject to CAIR for purposes of
ozone nonattainment, respondents must also submit ozone season and daily
NOx emissions data from all affected sources.  For these States, EPA
estimates that each respondent would spend 24 hours of technical staff
time and one hour of managerial staff time.  The following sections
discuss the assumptions used to develop burden hour estimates for
one-time only activities and triennial activities.  Table 6-1 lists the
burden items included under these categories, and presents their
associated burden hours for one year.  In general, managerial time was
estimated to be five percent of technical staff time.  Burden hours and
associated costs were estimated for the 2009-2011 period.  Table 6-2
shows the required activities that a State must perform each year,
during these years.  Table 6-3 presents the State and local respondent
annual burden hours and costs by activity. 

The time for States, territorial, and local agencies to read and
interpret the reporting requirements of the rule was estimated to be one
hour for technical staff and one hour for managerial staff.  

Emission Trading Requirements

This section estimates the paperwork burden and cost of submitting
permit applications, allowance tracking and transfer materials
(including applications for early reduction credits), year-end
compliance certifications, submittal of monitoring plans, obtaining
certification of each monitoring system, conducting monitor quality
assurance activities, and recording and reporting data from CEM systems
(or approved alternatives).

To estimate the burden and/or cost of each incidence of the various rule
revisions, EPA had available prior estimates of the costs of various
activities, estimates provided by affected utilities in comments to the
Agency, and estimates based on the Agency's experience in implementing
the trading programs under the NOx SIP Call and the Acid Rain Program. 

For the purposes of this analysis, the trading sources are grouped into
the following categories:

●	Acid Rain Program units located in any CAIR-affected State;

●	Trading units (non-Acid Rain) located in a PM/O3 State (AL, FL, IA,
IL, IN, KY, LA, MD, MI, MO, MS, NY, NC, OH, PA, SC, TN, VA, WI, WV, and
DC) or a PM-only State (GA, MN and TX); and

●	Trading units (non-Acid Rain) located in an O3-only State (AR, CT,
DE, MA, and NJ).

Note that for certain collection activities, the burden is calculated
separately for sources located in the NOx SIP Call region in order to
account for the fact that these sources are already familiar with the
reporting requirements.  The NOx SIP Call Program, a region wide
cap-and-trade program that phases out at the end of 2008, targeted
utility and large industrial combustion sources to facilitate NOx
emissions reductions in the NOx SIP Call region.  As such, the burden
for the information collection activities associated with reviewing
instructions and requirements and debugging computer software will be
lower for sources located in this region.  The NOx SIP Call States in
the CAIR region include Alabama, Connecticut, Delaware, Illinois,
Indiana, Kentucky, Maryland, Massachusetts, Michigan, Missouri, New
Jersey, New York, North Carolina, Ohio, Pennsylvania, South Carolina,
Tennessee, Virginia, and West Virginia, as well as the District of
Columbia.

The CAIR Trading Program requires all affected sources to monitor NOx
and SO2 emissions, SO2 emission rate, and heat input in order to
determine NOx mass emissions and SO2 mass emissions.  Coal-fired units
use an SO2, NOx, and flow CEMS to meet those requirements.  Oil and gas
units have some alternatives.  For SO2, these units can use fuel
sampling and analysis (or an SO2 default factor for pipeline natural
gas) combined with a fuel flowmeter.  In addition, peaking units that
burn natural gas and/or fuel oil may use an alternative method for
calculating NOx emission rates.  EPA will also allow certain low mass
emissions units to use assumed emissions factors together with
operational data to calculate NOx and SO2 emissions.

For purposes of this ICR, it is important that the burdens and costs be
calculated only in terms of incremental impacts for units subject to the
Acid Rain Program.  As such, the labor hour and cost estimates per unit
or facility, as identified in this document, represent the weighted
average burden and cost for all units and do not represent the actual
burden and cost for a particular unit or facility.  For sources
previously subject to the trading program under the NOx SIP Call, this
ICR incorporates the burdens previously accounted for in the ICR under
that program.  In addition, this ICR does not attempt to take into
account the potential for sources to use monitoring equipment required
under another program (such as a 40 CFR Part 60 New Source Performance
Standard).  As such, the weighting is a conservative estimate.

The following discussion highlights some of the basic differences for
the categories of units.  Included in this discussion is the
consideration of monitoring and reporting activities that are currently
completed by many of these sources under the Acid Rain Program.

Trading units subject to the Acid Rain Program that are located in a
CAIR State will have the smallest overall impact with regard to
monitoring and reporting.  Aside from a small burden associated with
DAHS upgrades (for those not previously subject to the NOx SIP Call),
Acid Rain Program-affected units already monitor and report both SO2
mass emissions and NOx emission rates on a year round basis and will not
incur additional burdens (or capital and operating and maintenance
costs) as a result of CAIR since they have already installed and are
operating a CEMS (or approved alternative).  

Trading units not subject to the Acid Rain Program that are located in a
CAIR State will incur the largest impact with regard to monitoring.  For
the CAIR ozone season program, this ICR incorporates the monitoring
burdens previously accounted for under the NOx SIP Call ICR (ICR Number
1857.03).  For the CAIR annual NOx and SO2 programs (in States not
previously covered by the SIP Call or in the CAIR ozone season program),
sources are currently not required to monitor according to Part 75. 
These sources will need to monitor and report NOx emissions during the
O3 season and on an annual basis as well as SO2 on an annual basis.  The
burdens will be less in States that are subject only to the CAIR ozone
season NOx program.  These units will also have additional burden
associated with permit applications and certain allowance transactions. 
Monitoring will depend on the type of fuel and the amount of time the
unit is operated.  Therefore, the costs will vary depending on the
appropriate monitoring alternative and the monitoring requirements that
previously applied to the unit under the NOx SIP Call.

Sources are subject to the CAIR Trading Programs NOx monitoring and
reporting requirements in 2008 and the SO2 monitoring and reporting
requirements in 2009.  Compliance with the emissions caps, along with
allowance holding requirements, begins in 2009 for NOx and 2010 for SO2.
 Table 6-4 shows the burden associated with monitoring SO2 and NOx under
the CAIR trading programs at the various types of sources.

The primary tasks performed by owners and operators of affected units
are:  1) permitting; 2) monitoring, recording, and reporting emissions
data; 3) allowance trading activities; and 4) submittal of the year end
compliance certification.

(i)  Permitting

Each affected entity will have to submit a permit revision application
to include in the source's Title V permit the necessary conditions
related to compliance with the CAIR Trading Programs.  The Agency
included the burden for this application process in the 2006-2008 time
period.  For this renewal ICR, covering 2009 through 2011, EPA estimates
that approximately ten percent of the sources may still need to complete
some permit application steps (such as to correct issues/problems).  EPA
believes that this application should be relatively routine, and that a
standard method of incorporating the requirements by reference or a
standard set of permit conditions will be available.  The Agency
estimates that, on a per unit basis, about four managerial hours will be
required to revise the Title V permit.

Some sources will also be required to construct additional facilities,
and therefore will need to complete a permit to construct application. 
The Agency estimates that this requirement will be necessary for all
coal-fired units that are not in the Acid Rain Program and that the task
will take 20 hours of managerial and 20 hours of technician time, per
permit.  This action was previously accounted for in the 2006 through
2008 time period, and EPA estimates that in 2009 through 2011, only ten
percent of the sources will need to undertake further steps in this
process.

(ii)  Monitoring.

For monitoring, the burdens differ greatly based on the amount and type
of monitoring the unit is already subject to and the particular subtask
of monitoring being conducted.  The specific elements of burden are:

Start-up Activities.  A large part of start-up activities involves
capital and test contractor costs.  However, the owner or operator will
incur some labor burden for these activities, as applicable.  For Acid
Rain units that were also previously affected by the NOx SIP Call, CAIR
imposes no start-up burdens beyond existing programs.  There will be a
small burden associated with DAHS upgrades for those ARP units not
previously affected by the NOx SIP Call.  For the non-Acid Rain units,
the burdens reflect arranging for SO2 and NOx CEMS purchase (as
required) and oversight of the certification process.  The non-Acid Rain
units in O3-only States would need to purchase and certify only NOx
monitoring systems.  In the 2009 through 2011 time period, EPA
anticipates that purchase and certification has already occurred for all
NOx and SO2 systems.  During this period, only new units will need to go
through this process.  Some units will also have to recertify their
systems.  Because capital costs are annualized in prior ICRs (see ICR
Numbers 2152.01 and 2152.02), those annualized capital costs continue to
occur in the 2009 through 2011 period.  Owners and operators of Acid
Rain units, non-Acid Rain units, and non-Acid Rain units in O3-only
States, will incur an insignificant certification cost increase due to
the air emission test body competency requirements affecting RATAs,
site-specific NOx LME tests, and Appendix E tests.

Regulatory Review.  The ICR includes an allocation of time for the
managerial and technical staff to review the regulatory requirements and
the reporting formats and instructions.  Units not in the Acid Rain
Program that were also not previously affected under the NOx SIP Call,
will have a burden similar to that estimated for Acid Rain Program units
in the Acid Rain Program ICR -- 24 hours of managerial time and 24 hours
of technician time in year one of the program and four hours each for
managerial and technician time, per year, after year one.  The burden
estimates for all Acid Rain units and units previously affected under
the NOx SIP Call is reduced because of the similar Acid Rain and NOx SIP
Call requirements.  The estimates for these units are five hours of
managerial time and five hours of technician time in year one and one
hour each per year after year one. 

Response to Error Messages.  The Agency provides feedback to affected
sources for errors that are found in monitoring plans or other reports. 
The Agency estimates that for each unit not affected by the Acid Rain
Program, an owner or operator will spend approximately four hours of
managerial time and eight hours of technician time responding to these
error messages each year.  (The time for the other sources is accounted
for in other ICRs.)

DAHS Debugging.  Based on experience with the Acid Rain Program, some
effort will be involved to fix problems with the DAHS software used to
report in the Part 75 formats.  This burden is assumed to fall primarily
on units that are not affected under the Acid Rain Program or previously
affected under the NOx SIP Call.  Consistent with the existing Part 75
ICR, the Agency estimates that about 16 managerial and 88 technician
hours will be spent on this task in the first year of implementation,
and then one managerial and four technician hours will be required in
the second and subsequent years of implementation. 

Monitoring Plans.  The regulations require submittal of monitoring
plans.  Because most of the monitoring plan elements are now part of the
EDR format, the effort involved in developing and maintaining the plans
are incorporated into the overall reporting burden estimate.

Monitor Certification/Recertification.  Initial certification burdens
and costs for new monitoring equipment are addressed above under
start-up activities since these costs are often part of the overall
purchase expense for the equipment.  For some non Acid Rain units,
however, there will be burdens associated with certifying existing
monitors used under other programs for this program, as well as burdens
for recertification to the extent a change in a monitoring system
requires recertification.  EPA estimates that approximately ten percent
of all units will have to recertify each year following the year in
which the initial certification occurs.  The ICR incorporates a labor
burden estimate generally consistent with existing Agency models for the
labor burdens associated with certification.  However, note that the ICR
reduces the labor hours for this activity to avoid double counting hours
that are already accounted for in the quality assurance activity area
(see the following subsection).  The double counting would occur because
a portion of the labor incurred for the certification or recertification
event replaces the labor burden that is generally allocated to the
annual relative accuracy test audit (RATA) in the year in which the
certification event occurs. Owners and operators of Acid Rain units,
non-Acid Rain units, and non-Acid Rain units in O3-only States, will
incur an insignificant certification cost increase due to the air
emission test body competency requirements affecting RATAs,
site-specific NOx LME tests, and Appendix E tests.

Quality Assurance.  Quality assurance (QA) activities and other routine
maintenance for monitoring systems is the largest burden item under the
CAIR Trading Programs.  These requirements generally include daily,
quarterly, and annual QA requirements, depending on the monitoring
approach being used.  For reporting units that use a CEMS, the Agency
has assumed a per unit labor burden based on a variety of sources,
including the existing Acid Rain Program ICR, the NOx SIP Call ICR that
expires at the end of 2008, information provided by Acid Rain Program
sources, a CEM cost model developed by EPA, and comments submitted in
response to the section 110 SIP Call for ozone transport.  For units
that rely on alternative methodologies, reduced labor burden estimates
apply because the quality assurance activities for the excepted methods
are less than for a CEMS.  Consistent with the existing Acid Rain
Program ICR, the labor burden is expected to be almost entirely
technician labor.  Owners and operators of Acid Rain units, non-Acid
Rain units, and non-Acid Rain units in O3-only States, will incur an
insignificant certification cost increase due to the air emission test
body competency requirements affecting RATAs, site-specific NOx LME
tests, and Appendix E tests.

Quarterly Reports.  Tasks performed by utilities in preparing quarterly
reports include: (1) assuring the quality of the data, (2) preparing the
quarterly report, (3) revising the monitoring plan, if necessary, (4)
preparation of hard copy documentation accompanying the quarterly
reports, and managerial review.  The existing Acid Rain program ICR was
used as the basis for these estimates.

Fuel Sampling.  To calculate heat input where the source is using the
fuel flowmeter option for an oil or gas-fired unit, the source must
obtain gross calorific value data from sampling in accordance with
Appendix D of Part 75.  For purposes of this ICR, it is assumed that the
GCV data would be collected as part of standard business operating
procedures to assure compliance with contractual specifications.  Thus
no additional fuel sampling burdens or costs should be incurred.

(iii)  Allowance transaction activities

The Agency anticipates the average number of additional allowance
transactions will be approximately 7,500 per year beginning in 2009. 
Since this ICR now covers the units and activities associated with the
NOx SIP Call, this estimated number of transactions reflects the
incremental number of transactions previously estimated for units
subject to CAIR (approximately 2,500) along with the number of
transactions previously accounted for under the NOx SIP Call trading
program (approximately 5,000 based on 2007 allowance transaction data). 
A portion of all units will likely conduct transactions in each year
solely as a result of this program.  The Agency believes that each
transaction will involve about one hour each of managerial and
technician time. 

6(b)  Estimating Respondent Costs

Table 6-3 presents State and local respondent annualized hours and costs
for each information collection activity.  To estimate annualized hours
and costs for one-time and triennial activities, the burden estimate is
divided by three to estimate the burden over a three-year period.  Table
6-4 summarizes the annual industry respondent costs.  The following
discussion describes how the costs were derived.

(i)  Estimating Labor Costs

For this ICR, the labor rate used for technical staff at State agencies
is $37.73 per hour, and the labor rate for managerial employees at State
agencies is $46.21.  These labor rates include benefits and overhead. 
These labor rates are derived from data shown on the U. S. Department of
Labor, Bureau of Labor Statistics, website at   HYPERLINK
"http://stats.bls.gov/news.release/ecec.toc.htm" 
http://stats.bls.gov/news.release/ecec.toc.htm .  Wage and salary rates
are given in Employee Costs for Employee Compensation "Table 3.  State
and local government, by major occupation and industry group (December
2007)."  The wage and salary rates from this table account for benefits
provided to workers.  When considering both technical and managerial
hours, labor costs for State and Territorial agencies are estimated to
be $46,000 per year per respondent, and labor costs for local agencies
are estimated to be $30,000 per year per respondent for the emissions
reporting requirements.

In estimating labor costs for industry respondents, EPA used the
following amounts: $83.43 per hour for managers and $58.00 per hour for
technicians.  These rates reflect the rates used in the existing NOx
Budget Program ICR, adjusted for inflation using the Bureau of Labor
Statistics Employment Cost Index.

Federal Agency labor rates were assumed to be $47.39 per hour.  This
labor rate was derived from the federal government's General Schedule
dated January 2008 published by the U.S. Office of Personnel Management
(see:    HYPERLINK "http://www.opm.gov/oca/08tables/pdf/gs.pdf" 
http://www.opm.gov/oca/08tables/pdf/gs.pdf ) using the factors in the
following table.

Determination of Federal Wage Rates

Annual Salary of Technical Staff, GS 11 Step 3

$51,358

Annual Cost of Supervisory Staff, GS 13, step 3	$73,201

	Factor (1/11)	0.09



	$6,588

Annual Cost of Support Staff, GS 6, step 6	$34,156

	Factor (1/8)	0.13



	$4,440

Annual Applicable Salary of Permit Staff

$62,386

Benefits (at 16%)

$9,982

Sick Leave/ Vacation (at 10%)

$6,239

General Overhead (at 32%)

$19,964

Total Cost per FTE

$98,571

Total Hourly Cost (total per FTE dividend divided by 2,080 hours per
year)

$47.39



(ii)  Estimating Capital and Operations and Maintenance Costs

Emission Reporting Requirements

EPA has concluded that the Capital and Operations and Maintenance Costs
estimated under the CERR are sufficient to accommodate the modest
changes in reporting burden for CAIR.  Therefore, no estimate of Capital
and Operations and Maintenance Costs were made for this ICR.

Emission Trading Requirements

Capital/start-up costs include the cost of installing required CEMS or
alternatives.  Operation and maintenance costs (exclusive of labor
costs) reflect ongoing costs to a unit and include both contractor costs
for the required recertification, diagnostic, and quality assurance (QA)
testing, and other direct maintenance-related expenses (e.g., spare
parts and calibration gases).  These cost estimates have been derived
from EPA CEM cost models, existing ICRs, Agency staff experience under
the Acid Rain and NOx SIP Call programs, and supplemental estimates
provided by affected utilities and others related to the various cost
items.

Most Acid Rain affected units are not expected to incur any non-labor
costs associated with this program.  The total non-labor cost for
capital/start-up items is estimated at $4,000 per unit for most Acid
Rain units that are not in the NOx SIP Call region (to account for a
DAHS upgrade to provide NOx mass reporting under Part 75, Subpart H). 
Most non Acid Rain units will require some combination of a NOx,
diluent, SO2 and/or flow CEMS depending on the fuel type, whether the
unit is an LME or peaking unit, and whether the source is subject to
CAIR for PM2.5 and/or ozone.  The costs for these units range from
$15,000 to $192,000.  The cost for an SO2 analyzer has been estimated at
$42,525.  The variance in unit cost is due to the monitoring methodology
used and what monitoring equipment may already be in place at the unit. 


Note that testing contractor costs for certification, recertification,
and annual relative accuracy test audits (RATAs) are presented as other
direct costs and are not converted to equivalent source labor hours. 
This approach is consistent with the common business practice for
obtaining outside contractors to conduct certification/recertification
tests and annual RATAs.  For initial certification, the certification
test costs are commonly bundled with equipment purchase contracts,
according to information provided by a range of CEMS equipment vendors. 
For RATAs that are conducted either as part of the annual quality
assurance requirements or as part of recertification, industry contacts
have indicated that RATA testing is usually performed under a fixed
price contract basis, except for travel costs that may be billed on an
hourly basis beyond the basic contract cost.

The Agency also notes that this ICR does not include a cost for the
purchase of monitoring equipment for units.  Many sources covered by the
CAIR Trading Programs are already required to have CEMS under that
program.  Therefore, to the extent that no new equipment is needed by
these sources, capital costs are not included because those costs were
included in the Acid Rain Program ICR.  Thus, the capital and other
costs included in Table 6-4 represent weighted average costs for each
respondent, not the total individual cost for any particular respondent.

(iii)  Capital/Start-up vs. Operating and Maintenance (O & M) Costs

Capital costs for emissions trading reflect one-time costs for purchase
of equipment which will be used over a period of years.  Conversely,
operating and maintenance costs are those costs which are incurred on an
annual or other scheduled basis.  For instance, costs associated with
quality assurance activities, such as spare parts or contractor costs
for work, will be incurred on an annual basis.

(iv)  Annualizing Capital Costs

The relevant capital costs for the emissions trading portion of this ICR
were annualized at a rate of seven percent (i.e., the annualized capital
cost was calculated assuming money to purchase the capital equipment was
borrowed at a seven percent annual interest rate).  The cost of the loan
was amortized over the life of the loan to repay original borrowed
amount plus interest.  The result is the annualized capital cost
reported.  The annualized cost of the necessary capital purchases varies
from $2,250 to $22,500, per year, per unit, depending on the type of
monitoring methodology.  Table 6-4 contains a breakdown of annual costs
by monitoring methodology.  

6(d)  Estimating the Respondent Universe and Total Burden and Costs

Emission Reporting Requirements

The number of respondents is estimated to be 29 States (including DC). 
See Table 6-1 for the total number of hours and costs estimated for each
respondent.  

Emission Trading Requirements

The number of industry respondents varies depending on the activity in
question.  Activities such as processing allowance transfers can involve
over one thousand sources.  The number of units that will be required to
install a particular type of monitoring equipment will be less since
many already have monitoring equipment under the Acid Rain Program. 
Table 6-1 provides estimates for the State burden associated with the
trading program requirements.  Table 6-2 provides estimates of industry
burden for 2009 through 2011.  The total number of respondents and the
total labor and cost for all respondents are summarized in the following
tables in Section 6(e) below.  This burden includes monitoring,
reporting, and other activities involved in participating in the CAIR
emissions trading programs.  The total number of State and industry
respondents is estimated to be 29 and 1,161, respectively.  

6(e)  Bottom Line Burden Hours and Cost Tables 

Emission Reporting Requirements

Total Estimated Respondent Burden and Cost Summary

	Number of Respondents	Total Hours Per Year (All Respondents)	Total
Costs Per Year (All Respondents)

State Respondents	29	3,480	$132,776



Emission Trading Requirements

Total Estimated Respondent Burden and Cost Summary

	Number of Respondents	Total Hours Per Year (All Respondents)	Total
Costs Per Year 

(All Respondents)

State Respondents	29	12,760	$491,272

Industry Respondents	1,161	388,465	$50,845,155



6(f)  Reasons for Change in Burden

	The burden and cost is higher than the previous CAIR ICR (2152.02)
because this ICR incorporates the burden associated with all
CAIR-affected sources, including those located in NOx SIP Call States. 
The NOx SIP Call ICR (OMB Control Number 2060-0445) expires at the end
of 2008.  As such, starting in 2009, the burden associated with the NOx
trading program requirements under the NOx SIP Call are now covered in
this ICR.  Without incorporating those burdens and costs, the overall
labor burden in this ICR would be less than the estimate in the prior
version (2006-2008) of this ICR.

Emission Reporting Requirements

The net change in emission reporting burden as compared with the
approved ICRs for the CERR is an increase of 120 hours (per respondent
per year), which were included to account for the preparation and
submittal of the 2011 triennial report.  The overall burden is higher
than the previous ICR since all CAIR-affected States are now covered
under this ICR.  

Emission Trading Requirements

The large burden associated with this rule is a result of the costs of
monitoring, certifying, quality assuring and reporting emissions data
from large electric generating units regulated under CAIR.  The burden
is significantly higher than the previous ICR since the NOx Budget
Program will phase-out at the end of 2008 and the affected sources in
all CAIR-affected States will be covered under CAIR starting in 2009. 
Affected sources for which the burden was previously included in the NOx
SIP Call ICR are now included in the burden estimate for this ICR. 
However, this burden is tempered by the integration of these monitoring
and reporting requirements with those already required under the Acid
Rain Program and those previously required under the NOx SIP Call
trading program.  Otherwise, the burden would be higher.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 87 hours per response.  Burden
means the total time, effort, or financial resources expended by persons
to generate, maintain, retain, or disclose or provide information to or
for a Federal agency.  This includes the time needed to review
instructions; develop, acquire, install, and utilize technology and
systems for the purposes of collecting, validating, and verifying
information, processing and maintaining information, and disclosing and
providing information; adjust the existing ways to comply with any
previously applicable instructions and requirements; train personnel to
be able to respond to a collection of information; search data sources;
complete and review the collection of information; and transmit or
otherwise disclose the information.  An agency may not conduct or
sponsor, and a person is not required to respond to, a collection of
information unless it displays a currently valid OMB control number. 
The OMB control numbers for EPA's regulations are listed in 40 CFR Part
9 and 48 CFR Chapter 15.

Send comments on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondents burden, including through the use of automated collection
techniques, to the Director, OPPE Regulatory Information Division, U.S.
Environmental Protection Agency (2137), 401 M St., S.W., Washington, DC
20460; and to Paperwork Reduction Project (OMB# 2060-0570), Office of
Information and Regulatory Affairs, Office of Management and Budget,
Washington, DC 20503, Attention:  Desk Officer for EPA.  Please include
the EPA ICR number (2152.03), the EPA Docket ID Number
(EPA-HQ-OAR-2006-0947 and EPA-HQ-OAR-2008-0317) and the OMB Control
Number (2060-0570) in any correspondence.

Table 6-1 

Annual State Respondent Burden and Cost by Activity, 2009 and Subsequent
Years

 	Hours and Costs Per Respondent	Total Hours and Costs

Information Collection or Trading Rule Activity	Manager $46.21 per hour
Technical $37.73 per hour	Respondent Hours/

Year	Labor Cost 	Number of Respondents	Total Hours/

Year	Total Cost/

Year

Annual Trading Program-related activities (e.g., monitoring
certifications, audits) 	40	400	440	$16,940	29	12,760	$491,272

Submit triennial report in 2011	6	114	120	$4,578	29	3,480	$132,776

Total	46	514	560	$21,518	29	16,240	$624,048



Table 6-2 

Annual Industry Respondent Burden and Cost by Activity, 2009 and
subsequent years

Information Collection Activity



Respondent

Labor Cost/Year

2009	Annual Capital





Manager $83.43

Per Hour (2009)	Technical $58.00

Per Hour (2009)	Respondent Hours/Year

2009

Startup Costs

2009	O&M Cost

2009	Number of Respondents

2009	Total Hours/Year

2009	Total Cost/Year

2009

Title V permit application (facilities)	4	0	4	$333.72 	 	 	116	464
$38,711.52 

Permit to Construct (units)	20	20	40	$2,828.60 	 	 	7	280	$19,800.20 

Startup/ Capital Items

~ ARP Sources in PM and O3 States 

a.  DAHS modification (facilities)	2	4	6	$398.86 	$600.00 	 	410	2,460
$409,532.60 

~ Non-ARP  Sources in PM/O3 and PM Only States

a.  Solid Fuel:  SO2, NOx, and Flow CEMS (units)	34	23	57	$4,170.62 
$28,900	 	102	5,814	$3,373,203.24 

b.  Gas-Oil:  NOx CEMS and Appendix D fuel monitoring (units)	64	10	74
$5,919.52 	$18,750.00 	 	493	36,482	$12,162,073.36 

c.  Gas-Oil Peaking Units:  Appendix D fuel sampling, Appendix E, or LME
methods (units)	20	10	30	$2,248.60 	$2,250.00 	 	150	4,500	$674,790.00 

(cont.)

Table 6-2 

Annual Industry Respondent Burden and Cost by Activity, 2009 and
subsequent years (cont.)



Information Collection Activity



Respondent

Labor Cost/Year

2009	Annual Capital





Manager $83.43

Per Hour (2009)	Technical $58.00

Per Hour (2009)	Respondent Hours/Year

2009

Startup Costs

2009	O&M Cost

2009	Number of Respondents

2009	Total Hours/Year

2009	Total Cost/Year

2009

~ Non-ARP Sources in O3 Only States

a.  Solid Fuel:  NOx, and Flow CEMS (units)	24	3	27	$2,176.32 
$22,500.00 	 	4	108	$98,705.28 

b.  Gas-Oil:  NOx CEMS and Appendix D fuel monitoring (units)	64	10	74
$5,919.52 	$18,750.00 	 	28	2,072	$690,746.56 

c.  Gas-Oil Peaking Units:  Appendix D fuel sampling, Appendix E, or LME
methods (units)	20	10	30	$2,248.60 	$2,250.00 	 	0	0	$0.00 

Review Instructions and Requirements

~ ARP PM and O3 Sources (facilities)	1	1	2	$141.43 	 	 	908	1,816
$128,418.44 

~ Non-ARP NBP Sources in PM/O3 and PM Only States (facilities)	1	1	2
$141.43 	 	 	138	276	$19,517.34 

~ Non-ARP non-NBP Sources in PM/O3 and PM Only States (facilities)	24	24
48	$3,394.32 	 	 	104	4,992	$353,009.28 

(cont.)

Table 6-2 

Annual Industry Respondent Burden and Cost by Activity, 2009 and
subsequent years (cont.)



Information Collection Activity



Respondent

Labor Cost/Year

2009	Annual Capital





Manager $83.43

Per Hour (2009)	Technical $58.00

Per Hour (2009)	Respondent Hours/Year

2009

Startup Costs

2009	O&M Cost

2009	Number of Respondents

2009	Total Hours/Year

2009	Total Cost/Year

2009

Review Instructions and Requirements (cont.)

~ Non-ARP NBP Sources in O3 Only States (facilities)	1	1	2	$141.43 	 
 	10	20	$1,414.30 

~ Non-ARP non-NBP Sources in O3 Only States (facilities)	24	24	48
$3,394.32 	 	 	1	48	$3,394.32 

Respond to EPA Generated Error Messages

~ Non-ARP Sources in PM/O3 and PM Only States (facilities)	4	8	12
$797.72 	 	 	242	2,904	$193,048.24 

~ Non-ARP Sources in O3 Only States (facilities)	4	8	12	$797.72 	 	 
11	132	$8,774.92 

Debug Computer Software

~ Non-ARP non-NBP Sources in PM/O3 and PM Only States (facilities)	16	88
104	$6,438.88 	 	 	104	10,816	$669,643.52 

~ Non-ARP non-NBP Sources in O3 Only States (facilities)	16	88	104
$6,438.88 	 	 	1	104	$6,438.88 

(cont.)

Table 6-2 

Annual Industry Respondent Burden and Cost by Activity, 2009 and
subsequent years (cont.)



Information Collection Activity



Respondent

Labor Cost/Year

2009	Annual Capital





Manager $83.43

Per Hour (2009)	Technical $58.00

Per Hour (2009)	Respondent Hours/Year

2009

Startup Costs

2009	O&M Cost

2009	Number of Respondents

2009	Total Hours/Year

2009	Total Cost/Year

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Annual Industry Respondent Burden and Cost by Activity, 2009 and
subsequent years (cont.)



Information Collection Activity



Respondent

Labor Cost/Year

2009	Annual Capital





Manager $83.43

Per Hour (2009)	Technical $58.00

Per Hour (2009)	Respondent Hours/Year

2009

Startup Costs

2009	O&M Cost

2009	Number of Respondents

2009	Total Hours/Year

2009	Total Cost/Year

2009

Certify Monitors (cont.)

~ Non-ARP Sources in O3 Only States

a.  Solid Fuel:  NOx, and Flow CEMS (units)	10	32	42	$2,690.30 	 
$2,800	1	42	$5,490.30 

b.  Gas-Oil:  NOx CEMS and Appendix D fuel monitoring (units)	10	32	42
$2,690.30 	 	10	3	126	$8,100.90 

c.  Gas-Oil Peaking Units:  Appendix D fuel sampling, Appendix E, or LME
methods (units)	8	24	32	$2,059.44 	 	8	0	0	$0.00 

Perform QA Testing and Maintenance

~ Non-ARP Sources in PM/O3 and PM Only States

a.  Solid Fuel:  SO2, NOx, and Flow CEMS (units)	50	600	650	$38,971.50 
 	31,200	102	66,300	$7,157,493.00 

b.  Gas-Oil:  NOx CEMS and Appendix D fuel monitoring (units)	20	375	395
$23,418.60 	 	$17,400	493	194,735	$20,123,569.80 

(cont.)

Table 6-2 

Annual Industry Respondent Burden and Cost by Activity, 2009 and
subsequent years (cont.)



Information Collection Activity



Respondent

Labor Cost/Year

2009	Annual Capital





Manager $83.43

Per Hour (2009)	Technical $58.00

Per Hour (2009)	Respondent Hours/Year

2009

Startup Costs

2009	O&M Cost

2009	Number of Respondents

2009	Total Hours/Year

2009	Total Cost/Year

2009

Perform QA Testing and Maintenance (cont.)

c.  Gas-Oil Peaking Units:  Appendix D fuel sampling, Appendix E, or LME
methods (units)	5	30	35	$2,157.15 	 	$1,800	150	5,250	$593,572.50 

~ Non-ARP Sources in O3 Only States

a.  Solid Fuel:  NOx, and Flow CEMS (units)	40	400	440	$26,537.20 	 
$20,800	4	1,760	$189,348.80 

b.  Gas-Oil:  NOx CEMS and Appendix D fuel monitoring (units)	20	375	395
$23,418.60 	 	$17,400	28	11,060	$1,142,920.80 

c.  Gas-Oil Peaking Units:  Appendix D fuel sampling, Appendix E, or LME
methods (units)	5	30	35	$2,157.15 	 	$1,800	0	0	$0.00 

Assure Data Quality, Prepare Reports, Submit Reports

~ Non-ARP Sources in PM/O3 and PM Only States (facilities)	16	42	58
$3,770.88 	 	 	242	14,036	$912,552.96 

(cont.)

Table 6-2 

Annual Industry Respondent Burden and Cost by Activity, 2009 and
subsequent years (cont.)



Information Collection Activity



Respondent

Labor Cost/Year

2009	Annual Capital





Manager $83.43

Per Hour (2009)	Technical $58.00

Per Hour (2009)	Respondent Hours/Year

2009

Startup Costs

2009	O&M Cost

2009	Number of Respondents

2009	Total Hours/Year

2009	Total Cost/Year

2009

Assure Data Quality, Prepare Reports, Submit Reports (cont.)

~ Non-ARP Sources in O3 Only States (facilities)	16	42	58	$3,770.88 	 
 	11	638	$41,479.68

~ Year end compliance activities (facilities)	2	0	2	$166.86 	 	 	1,161
2,322	$193,724.46

~ Allowance Transfers	1	1	2	$141.43 	 	 	7,500	15,000	$1,060,725.00

TOTAL	 	 	 	 	 	 	 	388,465	$50,845,155



 PAGE   2 

May 14, 2008	DRAFT ICR Renewal Supporting Statement

 PAGE   

	DRAFT Supporting Statement ICR

	June 30, 2008

	Page   PAGE  33 

	

