      2013 Information Collection Request Update for the 40 CFR Part 64 
                  Compliance Assurance Monitoring (CAM) Rule

Overview
Every three years we are required to renew the CAM rule ICR. In this current evaluation we reviewed and updated, where necessary, labor rates; estimates of labor hours needed for recordkeeping; the number of permits, facilities and pollutant specific emissions units (PSEUs); and the formulas used to calculate burden.
Changes in Burden Estimates from 2010 to 2013 
   * The total annualized cost for all units and permitting authorities decreased from $264 to $14.2 million. 
   * The total annual hour burden decreased from 7,453,581 to 343,187 hours.
   * The estimated number of facilities subject to the CAM rule increased from 3,174 to 3,290. This increase is based on assumptions for growth outlined in 2010 ICR. The estimated number of facilities with newly-issued permits continues to be 112.
Rationale for Changes in Burden
   * The decrease in burden is a result of:
         o Most facilities now using electronic, not manual, monitoring to record data, thus resulting in a decrease of labor hours.
         o All existing facilities have permits with approved CAM, therefore significantly reducing the costs for new monitoring development. 
         o Updates to the formulas used to calculate burden to better reflect projected trends for the next three years. 
Background 
   * Owners and operators of title V sources whose pollutant specific emissions units (PESUs) have active control devices and have a pre-control potential to emit major amounts of regulated air pollutants are required to submit monitoring, compliance certification, periodic reporting and record keeping information to their permitting authorities as part 64 of the Code of Federal Regulations (also known as the CAM rule).
   * Owners or operators are required to submit monitoring reports on no less than a semi-annual basis, and permitting authorities are required to store and maintain these data for at least five years.

