United
States
Environmental
Protection
Agency
Office
of
Air
and
Radiation
Office
of
Air
Quality
Planning
and
Standards
Air
Quality
Policy
Division
Geographic
Strategies
Group
INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
FOR
EPA
ICR
NUMBER
1813.06,
RENEWAL
OF
THE
ICR
FOR
THE
REGIONAL
HAZE
RULE
EPA
May,
2006
EPA
#
1813.06
INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
FOR
EPA
ICR
NUMBER
1813.06,
RENEWAL
OF
THE
ICR
FOR
THE
REGIONAL
HAZE
RULE
Page
2
This
ICR,
EPA
Form
1813.06,
is
an
update
of
the
Office
of
Management
and
Budget
(
OMB)
Control
Number
2060­
0421;
EPA
Form
1813.04
which
expires
on
July
31,
2006.
The
current
approved
collection
is
for
205
respondents,
56,605
hours
per
year,
and
$
2,515,383
per
year.
This
renewal
requests
approval
for
860
respondents
(
50
State
agencies,
1
Tribe,
1
group
of
FLMs,
and
808
industrial
sources),
32,551
hours
per
year,
and
$
1,856,000
per
year.
Tables
E.
1summarizes
the
total
annual
respondent
burden
for
this
renewal.

The
previous
annual
burden
estimate
was
56,605
hours
and
$
2,513,383.
The
current
estimate
represents
a
decrease
in
the
hour
burden
estimate
of
24,054
hours
and
in
the
cost
burden
of
$
657,383.
The
change
in
burden
is
a
program
adjustment,
reflecting
changes
in
labor
rates,
changes
in
the
activities
conducted
due
to
the
normal
progression
of
the
program,
and
better
information
regarding
the
numbers
of
respondents
and
the
fact
that
the
role
of
industrial
respondents
is
increasing
as
the
program
moves
from
the
planning
stages
to
the
implementation
stages.

Table
E­
1
Estimated
State,
Tribal,
Source,
and
FLM
Respondent
Burden
to
Implement
Requirements
States
Tribes
Source
FLMs
Task
Element
Average
Annual
Hours
Average
Annual
Cost
($
1000)
Average
Annual
Hours
Average
Annual
Cost
($
1000)
Average
Annual
Hours
Average
Annual
Cost
($
1000)
Average
Annual
Hours
Average
Annual
Cost
($
1000)

Total
Burden
by
Respondent
17,132
765
710
32
13,975
1,026
734
33
Total
for
Respondent
Universe
32,551
hours;
$
1,856,000
Executive
Summary
Draft
05/
24/
06
INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
FOR
EPA
ICR
NUMBER
1813.06,
RENEWAL
OF
THE
ICR
FOR
THE
REGIONAL
HAZE
RULE
Page
3
This
document
fulfills
the
Agency's
requirements
under
the
Paperwork
Reduction
Act
(
PRA)
with
regards
to
determining
the
regulatory
burden
associated
with
the
implementation
of
the
Regional
Haze
program
(
40
CFR
51.308)
and
requirements
related
to
the
Grand
Canyon
Visibility
Transport
Commission
(
40
CFR
51.309).
It
has
been
assigned
EPA
tracking
number
1813.06.
The
title
of
this
Information
Collection
Request
(
ICR)
is
"
Information
Collection
Request
Supporting
Statement
for
EPA
ICR
Number
1813.06,
Renewal
of
The
ICR
for
the
Regional
Haze
Rule."

Subpart
P,
Protection
of
Visibility,
also
known
as
the
Regional
Haze
Rule,
is
the
subject
of
this
clearance
request.
In
the
next
3
years,
activities
conducted
by
the
States,
Tribes,
industry,
Federal
Land
Managers
(
FLMs),
Regional
Planning
Organizations
(
RPOs),
and
EPA
will
focus
on
the
two
major
paths
identified
in
the
rule
to
address
regional
haze.
One
path
is
40
CFR
51.
308,
which
requires
States
and
Tribes
to
develop
long­
term
strategies
up
to
and
including
the
year
2064.
These
strategies
must
be
shown
to
make
reasonable
progress
in
improving
visibility
in
Class
I
areas
inside
the
State
and
in
neighboring
jurisdictions.
The
second
path,
40
CFR
51.309,
is
an
option
for
nine
States,
and
the
185
Tribes
located
within
those
States,
to
adopt
Regional
Haze
strategies
for
the
period
from
2003
to
2018
for
sulfur
dioxide
emissions.
These
strategies
are
based
on
recommendations
from
the
Grand
Canyon
Visibility
Transport
Commission
(
GCVTC)
for
protecting
the
16
Class
I
areas
on
the
Colorado
Plateau
area.

On
June
15,
2005,
EPA
finalized
amendments
to
the
July
1999
Regional
Haze
Rule.
These
amendments
apply
to
the
provisions
of
the
Regional
Haze
Rule
that
require
emission
controls
known
as
best
available
retrofit
technology,
or
BART,
for
industrial
facilities
emitting
air
pollutants
that
reduce
visibility
by
causing
or
contributing
to
regional
haze.
The
pollutants
that
reduce
visibility
include
fine
particulate
matter
(
PM2.5),
and
compounds
which
contribute
to
PM2.5
formation,
such
as
nitrogen
oxides
(
NOx),
sulfur
dioxides
(
SO2),
and
under
certain
conditions
volatile
organic
compounds
(
VOC),
and
ammonia.

The
BART
requirements
of
the
Regional
Haze
Rule
apply
to
facilities
built
between
1962
and
1977
that
have
the
potential
to
emit
more
than
250
tons
a
year
of
visibility­
impairing
pollution.
Those
facilities
fall
into
26
categories,
including
utility
and
industrial
boilers,
and
large
industrial
1
Identification
of
the
Information
Collection
1.1
Title
OMD1.2
Description
EPA
TRACKING
NUMBER:
1813.06
E­
TRACKING
NUMBER:
OMB­
2060­
0421
1.2
Description
INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
FOR
EPA
ICR
NUMBER
1813.06,
RENEWAL
OF
THE
ICR
FOR
THE
REGIONAL
HAZE
RULE
Page
4
plants
such
as
pulp
mills,
refineries
and
smelters.
Many
of
these
facilities
have
not
been
previously
subject
to
Federal
pollution
control
requirements
for
these
pollutants.

Under
the
1999
Regional
Haze
Rule,
States
are
required
to
set
periodic
goals
for
improving
visibility
in
the
156
Federal
Class
I
areas.
As
States
work
to
reach
these
goals,
they
must
develop
regional
haze
implementation
plans
that
contain
enforceable
measures
and
strategies
for
reducing
visibility­
impairing
pollution.
The
2005
amendments
include
guidelines,
known
as
BART
guidelines,
for
States
to
use
in
determining
which
facilities
must
install
controls
and
the
type
of
controls
the
facilities
must
use.
States
must
develop
their
implementation
plans
by
December,
2007.
As
part
of
those
plans,
States
will
identify
the
facilities
that
will
have
to
reduce
emissions
under
BART
and
then
set
BART
emissions
limits
for
those
facilities.
INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
FOR
EPA
ICR
NUMBER
1813.06,
RENEWAL
OF
THE
ICR
FOR
THE
REGIONAL
HAZE
RULE
Page
3
Section
169A
of
the
Clean
Air
Act
(
CAA)
sets
forth
a
national
goal
for
visibility.
The
goal
is
the
"
prevention
of
any
future,
and
the
remedying
of
any
existing,
impairment
in
visibility
in
mandatory
Class
I
Federal
areas
which
impairment
results
from
man­
made
air
pollution."
This
section
of
the
Act
also
calls
for
EPA
regulations
to
assure
that
States
provide
for
reasonable
progress
toward
meeting
the
national
goal.
The
original
regulations
on
protection
of
visibility
in
mandatory
Class
I
Federal
areas,
developed
in
1980,
addressed
visibility
that
is
"
reasonably
attributable"
to
a
single
source
or
small
group
of
sources.
Actions
under
those
regulations
are
triggered
by
a
FLM.
The
Regional
Haze
Rule,
promulgated
in
1999,
added
new
sections
to
the
code
of
federal
environmental
regulations.
These
included
sections
40
CFR
51.308
and
40
CFR
51.309.
This
ICR
renewal
request
provides
for
continued
implementation
of
the
Regional
Haze
Rule.
During
this
clearance
period,
we
anticipate
that
the
40
CFR
51.308
and
51.309
will
be
the
major
program
focus.

The
data
collected
from
respondents
include
State
and
Tribal
implementation
plans.
These
data
confirm
progress
in
assessing
visibility
impairment
and
source
contribution.
The
data
provide
the
foundation
for
the
identification
of
progress
goals,
control
strategies,
and
BART
requirements.
Those
goals,
strategies,
and
requirements
will
be
developed
during
the
course
of
this
period
(
August
1,
2006
 
July
31,
2009.)

The
information
in
this
ICR
is
based
upon
the
best
data
available
to
the
Agency
at
this
time.
However,
incomplete
data,
and
sampling
limitations
imposed
necessitated
a
certain
amount
of
extrapolation
and
"
best­
guess"
estimations.
Consequently,
the
reader
should
not
consider
the
conclusions
to
be
an
exact
representation
of
the
level
of
burden
or
cost
that
will
occur.
Instead,
this
ICR
should
be
considered
a
directionally
correct
assessment
of
the
impact
the
programmatic
changes
included
in
this
rulemaking
may
have
over
the
next
3
years.

Throughout
this
ICR,
the
reader
will
observe
estimated
values
that
show
accuracy
to
the
single
hour
or
dollar.
However,
reporting
values
at
the
single
unit
level
can
be
misleading.
In
most
situations,
the
proper
way
to
present
estimated
data
would
be
to
determine
an
appropriate
level
of
precision
and
truncate
values
accordingly,
usually
in
terms
of
thousands
or
millions
of
units.
For
instance,
a
spreadsheet
generated
estimation
of
$
5,456,295
could
be
presented
in
the
text
as
$
5.5
(
millions)
or
$
5,456
(
thousands).
One
problem
with
such
an
approach
is
the
loss
of
data
richness
when
the
report
contains
a
mixture
of
very
large
and
very
small
numbers.
Consequently,
to
avoid
the
loss
of
information
through
rounding,
this
ICR
reports
all
values
at
the
single
unit
level
and
reminds
the
reader
that
there
is
no
implied
precision
inherent
in
this
style
of
reporting.
2
Need
and
Use
of
the
Collection
2.1
Need
/
Authority
for
the
Collection
2.2
Practical
Utility
/
Users
of
the
Data
2.3
Caveats
and
Considerations
INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
FOR
EPA
ICR
NUMBER
1813.06,
RENEWAL
OF
THE
ICR
FOR
THE
REGIONAL
HAZE
RULE
Page
4
There
are
two
parts
of
the
information
collection
for
this
renewal
request.
One
is
related
to
the
40
CFR
51.308
provisions.
This
includes
State
submittal
of
an
implementation
plan,
draft
BART
regulations,
and
assessment
of
alternative
progress
goals
and
regional
strategies.
The
other
part
is
related
to
the
SO2
provisions
of
40
CFR
51.309
which
allow
the
nine
western
States
and
Tribes
in
those
States
to
adopt
Regional
Haze
strategies
to
implement
the
GCVTC
recommendations.
These
States
and
Tribes
may
submit
separate
SO2
implementation
plans.
The
implementation
plans
required
by
the
Regional
Haze
Rule
are
unique
and
do
not
duplicate
other
implementation
plan
requirements.
In
the
case
of
the
40
CFR
51.309
plans,
they
will
build
upon
information
gathered
in
the
process
of
developing
the
report
of
the
GCVTC,
the
Annex
to
that
report
prepared
by
the
Western
Regional
Air
Partnership
(
WRAP),
and
the
initial
2003
submittals.

For
any
existing
rule,
§
3507(
g)
of
the
PRA
limits
how
long
a
Director
may
take
to
approve
a
collection
of
information
to
3
years.
The
ICR
for
the
Regional
Haze
Rule
was
revised
last
in
July
2003.
We
solicited
public
comments
on
this
ICR
prior
to
submitting
it
to
OMB.
We
issued
a
Federal
Register
notice
requesting
comments
on
the
ICR
renewal
on
March
13,
2006
(
71
FR
12696).
No
significant
comments
were
received.

The
EPA
consulted
with
non­
EPA
persons
on
the
anticipated
policy,
organization,
and
technical
responsibilities
while
developing
the
Regional
Haze
Rule,
most
recently
in
developing
the
2005
final
amendments.
These
persons
included
representatives
of
RPOs,
FLMs,
and
stakeholders.
These
consultations
facilitate
implementation
of
the
Regional
Haze
Rule.

More
specifically,
we
consulted
with
the
EPA
Regional
Offices,
and
through
them,
the
RPOs
in
developing
the
list
of
activities
expected
to
occur
during
this
ICR
clearance
period.

The
information
collection
requested
under
this
ICR
is
necessary
to
ensure
implementation
of
the
40
CFR
51.308
and
40
CFR
51.309
requirements.

OMB's
general
guidelines
for
information
collections
must
be
adhered
to
by
all
Federal
Agencies
for
approval
of
any
rulemaking's
collection
methodology.
In
accordance
with
the
requirements
of
5
CFR
1320.5,
the
Agency
believes:

1.
The
Regional
Haze
regulations
do
not
require
periodic
reporting
more
frequently
than
annually.
2.
The
Regional
Haze
regulations
do
not
require
respondents
to
participate
in
any
statistical
survey.
3.
Written
responses
to
Agency
inquiries
are
not
required
to
be
submitted
in
less
than
30
days.
3
Non­
Duplication,
Consultation,
and
Other
Collection
Criteria
3.1
Non­
Duplication
3.2
Public
Notice
Requirements
3.3
Consultations
3.4
Less
Frequent
Collection
3.5
General
Guidelines
INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
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EPA
ICR
NUMBER
1813.06,
RENEWAL
OF
THE
ICR
FOR
THE
REGIONAL
HAZE
RULE
Page
5
4.
Respondents
do
not
receive
remuneration
for
the
preparation
of
reports
required
by
the
Act
or
part
51.
5.
To
the
greatest
extent
possible,
the
Agency
has
taken
advantage
of
automated
methods
of
reporting.

The
recordkeeping
and
reporting
requirements
contained
in
the
current
Regional
Haze
program
and
the
changes
proposed
in
this
rulemaking
do
not
exceed
any
of
the
Paperwork
Reduction
Act
guidelines
contained
in
5
CFR
1320.5,
except
for
the
guideline
which
limits
retention
of
records
by
respondents
to
3
years.
The
Act
requires
both
respondents
and
State
or
local
agencies
to
retain
records
for
a
period
of
5
years.
The
justification
for
this
exception
is
found
in
28
U.
S.
C.
2462,
which
specifies
5
years
as
the
general
statute
of
limitations
for
Federal
claims
in
response
to
violations
by
regulated
entities.
The
decision
in
U.
S.
v.
Conoco,
Inc.,
No.
83­
1916­
E
(
W.
D.
Okla.,
January
23,
1984)
found
that
the
5­
year
general
statute
of
limitations
applied
to
the
Clean
Air
Act.

Confidentiality
is
not
an
issue
for
this
rulemaking.
In
accordance
with
the
Clean
Air
Act
Amendments
of
1990,
any
monitoring
information
to
be
submitted
by
sources
as
a
part
of
their
BART
determination
is
a
matter
of
public
record.
To
the
extent
that
the
information
required
is
proprietary,
confidential,
or
of
a
nature
that
could
impair
the
ability
of
the
source
to
maintain
its
market
position,
that
information
is
collected
and
handled
subject
to
the
requirements
of
§
503(
e)
and
§
114(
c)
of
the
Act.
Information
received
and
identified
by
owners
or
operators
as
confidential
business
information
(
CBI)
and
approved
as
CBI
by
EPA,
in
accordance
with
Title
40,
Chapter
1,
Part
2,
Subpart
B,
shall
be
maintained
appropriately
(
see
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
39999,
September
8,
1978;
43
FR
42251,
September
28,
1978;
44
FR
17674,
March
23,
1979).

The
consideration
of
sensitive
questions,
(
i.
e.,
sexual,
religious,
personal
or
other
private
matters),
is
not
applicable
to
this
rulemaking.
The
information
gathered
to
develop
an
implementation
plan
and
make
BART
determinations
does
not
include
personal
data
on
any
owner
or
operator.

The
President's
priorities
in
promoting
environmental
justice
(
EJ)
are
contained
in
Executive
Order
#
12898.
Because
the
Regional
Haze
program
operates
nation­
wide
and
across
26
different
industry
classifications,
the
Agency
does
not
believe
there
is
a
disproportionate
EJ
effect
in
the
Regional
Haze
program.
3.6
Confidentiality
3.7
Sensitive
Questions
3.8
Environmental
Justice
Considerations
INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
FOR
EPA
ICR
NUMBER
1813.06,
RENEWAL
OF
THE
ICR
FOR
THE
REGIONAL
HAZE
RULE
Page
6
The
major
categories
of
respondents
directly
affected
include
the
States,
Tribes,
and
FLMs.
The
States
and,
if
they
so
choose,
the
Tribes
will
develop
an
implementation
plan
under
40
CFR
51.308.
In
addition
Western
States
have
the
option
of
developing
Regional
Haze
strategies
for
SO2
emissions
under
40
CFR
51.309.

In
addition,
during
this
ICR
renewal
period,
other
entities,
at
the
discretion
of
the
States
and
Tribes,
may
respond
to
a
request
of
the
States
or
Tribes
to
fulfill
obligations
of
the
1999
Regional
Haze
Rule.
For
example,
there
may
be
private
sector
respondents
in
particular
Standard
Industrial
Classification
(
SIC)
and
North
American
Industrial
Classification
System
(
NAICS)
Codes
and
production
process
categories
that
are
asked
to
assess
and
determine
if
they
are
BART
eligible
sources
and
make
a
preliminary
BART
determination.
1
These
source
categories
and
their
corresponding
SIC
and
NAICS
codes
are
listed
in
Table
4.1.

The
FLMs
will
work
as
partners
with
the
RPOs
from
the
perspective
of
Class
I
area
land
managers.
Their
policy
focus
will
be
on
prescribed
fire
policy,
and
quantification
of
reasonable
progress
goals.
On
the
technical
side,
they
will
assess
air
quality
monitoring
data
and
work
with
the
RPOs
and
EPA
to
determine
impacts
on
visibility
in
their
Class
I
areas
and
natural
background
conditions.

1
Sources
that
are
part
of
categories
listed
in
the
Clean
Air
Act
(
Section
169A)
and
emitting
more
than
250
tons
per
year
and
constructed
during
the
August
1962
to
August
1977
time
period
are
BART
eligible.
4
The
Respondents
and
the
Information
Requested
4.1
Respondents/
SIC
and
NAICS
Codes
INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
FOR
EPA
ICR
NUMBER
1813.06,
RENEWAL
OF
THE
ICR
FOR
THE
REGIONAL
HAZE
RULE
Page
7
Table
4.1
Categories
and
Corresponding
SIC/
NAICS
Codes
for
Potentially
Affected
Respondents
Industry
Group
SIC
NAICS
Fossil
Fuel
Steam
Electric
Plants
>
250
million
BTUs
4911
221112
Coal
Clean
Plants
Thermal
Dryers
(
assumed
to
be
part
of
the
coal
mining
industry)
1221,
1222,
1231
21211
Kraft
Pulp
Mills
(
assumed
part
of
pulp,
paper,
and
paperboard
mills)
2611
32211
Portland
Cement
Plants
3241
327310
Primary
Zinc
Smelters
3339
331419
Iron
&
Steel
Plants
3312
331111
Primary
Aluminum
Ore
Reduction
Plants
3334
331312
Primary
Copper
Smelter
3331
331411
Municipal
Incinerators
Capable
of
Charging
>
50tpd
refuse
4953
562219
Hydrofluoric
Acid
Plants
2819
325188
Sulfuric
Acid
Plants
2819
325199
Nitric
Acid
Plants
2819
325199
Petroleum
Refineries
2911
324110
Lime
Plants
3274
327410
Phosphate
Rock
Processing
Plants
1475
212392
Coke
Oven
Batteries
3312
324199
Sulfur
Recovery
Plant
(
assumed
to
be
part
of
natural
gas
processing
operations)
2819
211112
Carbon
Black
Plants
Furnace
Process
2816
325182
Primary
Lead
Smelters
3339
331419
Fuel
Conversion
Plants
(
none
are
known
to
exist)
n.
a.
n.
a.

Sintering
Plants
3312
331314,
331423,
331492
Chemical
Process
Plants
(
this
is
a
2
digit
SIC)
28
Fossil
Fuel
Boilers
of
>
250
BTUs/
hour
heat
input
(
industrial
boilers;
this
encompasses
many
SICs
&
NAICS)

Petroleum
Storage
and
Transfer
Facilities
cap.>
300,000
bbls
5150
422710
Taconite
Ore
Processing
Facilities
1011
21210
Glass
Fiber
Processing
Plants
(
assumed
to
not
include
container
plants)
3229
327212
Charcoal
Production
Facilities
(
assumed
to
not
include
activated
charcoal
manufacture)
2861
325191
The
information
required
under
this
ICR
renewal
provides
for
a
continuation
of
the
process
initiated
with
previous
ICRs
for
the
Regional
Haze
Rule.
In
this
stage
of
the
process,
the
States
and
Tribes
are
working
toward
establishment
of
progress
goals
and
strategies
that
will
be
part
of
the
August
1,
2006
to
July
31,
2009
reporting
period.
4.2
Information
Requested
INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
FOR
EPA
ICR
NUMBER
1813.06,
RENEWAL
OF
THE
ICR
FOR
THE
REGIONAL
HAZE
RULE
Page
8
The
information
that
is
requested
under
this
renewal
period
under
the
40
CFR
51.308
provisions
includes:

Develop
and
Submit
Regional
Haze
Implementation
Plan
 
Develop
RH
implementation
plan
template
 
Conduct
2002
Baseline
Visibility
Modeling
 
Calculate
natural
visibility
conditions
 
Conduct
2018
baseline
modeling
 
Prepare
attribution
of
haze
report
 
Identify
reasonable
progress
goals
 
Develop
long
term
strategies
 
Submit
monitoring
strategy
Most
of
this
information
has
been
largely
completed
by
the
RPOs
and
States.
The
States
are
working
to
prepare
and
submit
implementation
plans
by
the
December
2007
deadline.

Make
BART
Determinations
 
Identify
BART­
eligible
sources
 
Identify
BART­
exempt
sources
 
Make
BART
determinations
 
Consult
with
FLMs
 
Identify
BART
controls
 
Determine
degree
of
visibility
improvement
Activities
required
to
make
the
source­
specific
BART
determinations
are
well
underway
as
well.
The
States
may
request
sources
to
provide
information
to
help
make
these
determinations
and
identify
BART
controls.

Report
Annual
Emissions.
By
the
third
year
of
the
clearance
period,
sources
with
BART
determinations
will
be
required
to
report
annual
emissions
to
the
States
in
order
to
track
progress.
The
States
will
then
prepare
an
annual
emissions
report
for
EPA.

The
information
that
is
requested
under
this
renewal
period
under
40
CFR
51.309
provisions
includes:

Prepare
Revised
SIP
for
SO2
Western
Backstop
Trading
Program.
Under
Section
309
of
the
federal
Regional
Haze
Rule,
nine
western
States
and
Tribes
within
those
States
have
the
option
of
submitting
plans
to
reduce
regional
haze
emissions
that
impair
visibility
at
16
Class
I
national
parks
and
wilderness
areas
on
the
Colorado
Plateau.
Five
states
 
Arizona,
New
Mexico,
Oregon,
Utah
and
Wyoming
 
have
previously
submitted
INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
FOR
EPA
ICR
NUMBER
1813.06,
RENEWAL
OF
THE
ICR
FOR
THE
REGIONAL
HAZE
RULE
Page
9
plans
to
EPA,
but
due
to
a
recent
Court
decisions,
these
plans
must
be
resubmitted
by
December
2007.
We
believe
the
five
States
will
resubmit,
making
minor
revisions
to
their
existing
plans.

Report
Annual
SO2
Emissions.
In
each
year
of
the
clearance
period,
sources
with
BART
determinations
will
be
required
to
report
annual
SO2
emissions
to
the
States
in
order
to
track
progress.
The
States
will
then
prepare
an
annual
emissions
report
for
EPA.

Section
51.309
contains
a
number
of
provisions
related
to
the
backstop
trading
program
that
States
must
have
in
place
in
case
a
regional
SO2
milestone
is
exceeded.
The
Agency
does
not
provide
any
burden
estimates
for
implementing
the
backstop
trading
program.
This
omission
is
appropriate
because
there
is
no
indication
that
the
milestone
will
be
exceeded
during
the
clearance
period.
INFORMATION
COLLECTION
REQUEST
SUPPORTING
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RENEWAL
OF
THE
ICR
FOR
THE
REGIONAL
HAZE
RULE
Page
10
EPA.
EPA
will
work
in
the
policy
and
technical
area.
With
respect
to
policy,
the
EPA's
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS)
will
provide
direction
and
facilitate
resolution
of
major
issues.
The
lead
EPA
region
will
work
with
the
RPOs
to
identify
issues
and
provide
recommendations.
In
the
technical
area,
OAQPS
will
deliver
data,
tools,
and
training
to
the
RPOs.
EPA
will
review
the
implementation
plans
submitted
by
participating
State
and
Tribal
governments.

This
section
discusses
the
development
of
burden
estimates
and
their
conversion
into
costs,
which
are
separated
into
burden
costs
and
capital
and
O&
M
costs.
According
to
the
latest
guidance
for
ICRs
(
EPA
2/
99),
capital
and
O&
M
costs
display
the
cost
of
any
new
capital
equipment
the
respondent
may
have
to
purchase
solely
for
information
collection,
assimilation,
and
storage
purposes.
For
example,
if
a
source
had
to
purchase
a
new
mini­
computer
to
store
and
manipulate
data,
that
computer
would
be
a
cost
of
administration
subject
to
reporting
in
the
ICR.
In
addition,
the
latest
guidance
instructs
the
Agency
to
differentiate
the
burden
associated
with
a
source's
labor
and
that
which
it
hires
through
outside
contractors.
To
the
extent
a
source
contracts
out
for
administrative
purposes
(
e.
g.,
employing
consultants
to
perform
visibility
modeling),
the
burden
associated
with
those
contracted
tasks
are
not
a
burden
to
the
source
­
but
they
still
remain
a
cost.
The
reader
should
read
this
section
with
the
following
considerations
in
mind:

 
The
Agency
believes
the
time
necessary
to
perform
a
task
is
independent
of
the
origins
of
its
labor.
In
other
words,
if
a
source
would
employ
20
hours
of
burden
to
fully
perform
a
function,
then
a
contractor
hired
by
the
source
would
also
take
20
hours
to
perform
that
same
task.
Furthermore,
the
Agency
assumes
no
economies
or
diseconomies
of
scale.
The
linear
combination
of
any
amount
of
contractor
and
source
effort
will
also
sum
to
20.
Therefore,
the
burden
estimates
in
this
ICR
act
as
an
accurate
assessment
of
the
total
burden
to
respondents.
 
For
some
burden
categories,
the
Agency
believes
the
hours
assigned
to
them
will
be
divided
between
the
source
and
outside
contractors.
For
these
categories,
the
Agency
established
a
composite
cost
per
hour
by
developing
a
weighted
average
of
the
source
and
contractor
wages,
with
the
weight
defined
by
the
percentage
of
total
effort
each
burden
source
applied.
Consequently,
the
cost
developed
in
this
ICR
should
be
interpreted
as
an
upper
bound
on
the
actual
cost
of
administration
by
the
source.
The
methodology
for
determining
cost
per
hour
can
be
found
in
greater
detail
in
section
6.2,
below.
5
The
Information
Collected
­
Agency
Activities,
Collection
Methodologies,
and
Information
Management
5.2
Collection
Methodology
and
Management
5.1
Agency
Activities
INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
FOR
EPA
ICR
NUMBER
1813.06,
RENEWAL
OF
THE
ICR
FOR
THE
REGIONAL
HAZE
RULE
Page
11
The
section
308
implementation
plans
prepared
by
participating
States
and
Tribes
will
set
forth
the
specifics
regarding
the
actual
methodology
and
management.
The
plans
must
include
the
following
elements:

 
Procedures
by
which
monitoring
data
and
other
information
are
used
in
determining
the
contribution
of
emissions
from
within
the
State
to
regional
haze
visibility
impairment
at
mandatory
Class
I
Federal
areas
both
within
and
outside
the
State.
 
For
a
State
with
no
mandatory
Class
I
Federal
areas,
procedures
by
which
monitoring
data
and
other
information
are
used
in
determining
the
contribution
of
emissions
from
within
the
State
to
regional
haze
visibility
impairment
at
mandatory
Class
I
Federal
areas
in
other
States.
 
Reporting
of
all
visibility
monitoring
data
to
the
Administrator
at
least
annually
for
each
mandatory
Class
I
Federal
area
in
the
State.
To
the
extent
possible,
the
State
should
report
visibility
monitoring
data
electronically.
 
A
statewide
inventory
of
emissions
of
pollutants
that
are
reasonably
anticipated
to
cause
or
contribute
to
visibility
impairment
in
any
mandatory
Class
I
Federal
area.
The
inventory
must
include
emissions
for
a
baseline
year,
emissions
for
the
most
recent
year
for
which
data
are
available,
and
estimates
of
future
projected
emissions.
The
State
must
also
include
a
commitment
to
update
the
inventory
periodically.

Other
elements,
including
reporting,
recordkeeping,
and
other
measures,
necessary
to
assess
and
report
on
visibility.

In
addition,
for
State
and
Tribes
submitting
under
40
CFR
51.309,
provisions
are
made
for
adjustments
in
view
of
changes
in
emissions
monitoring
or
calculation
methods,
flow
rate
measurement
methods,
adjustments
for
illegal
emissions,
adjustment
based
upon
program
audits,
adjustments
for
sources
opting
into
the
program,
documentation
of
emission
calculation
methods,
record
keeping,
completion
and
submission
of
emissions
reports,
exceptions
reports,
and
annual
comparison
of
emissions
to
milestones.

The
Regulatory
Flexibility
Act
(
RFA)
requires
regulatory
agencies,
upon
regulatory
action,
to
assess
that
action's
potential
impact
on
small
entities
(
businesses,
governments,
and
small
non­
governmental
organizations)
and
report
the
results
of
the
assessments
in
(
1)
an
Initial
Regulatory
Flexibility
Analysis
(
IRFA),
(
2)
a
Final
Regulatory
Flexibility
Analysis
(
FRFA),
and
(
3)
a
Certification.
For
ICR
approval,
the
Agency
must
demonstrate
that
it
"
has
taken
all
practicable
steps
to
develop
separate
and
simplified
requirements
for
small
businesses
and
other
small
entities"
(
5
CFR
5.3
Small
Entity
Flexibility
INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
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EPA
ICR
NUMBER
1813.06,
RENEWAL
OF
THE
ICR
FOR
THE
REGIONAL
HAZE
RULE
Page
12
1320.6(
h)).
In
addition,
the
agencies
must
assure
through
various
mechanisms
that
small
entities
are
given
an
opportunity
to
participate
in
the
rulemaking
process.

EPA
has
determined
that
it
is
not
necessary
to
prepare
a
regulatory
flexibility
analysis
in
connection
with
the
Regional
Haze
rule
(
July
6,
2005,
70
FR
39104).
After
considering
the
economic
impacts
of
the
final
rule
on
small
entities,
EPA
has
concluded
that
this
action
will
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities.
This
final
rule
will
not
impose
any
direct
requirements
on
small
entities.
The
rule
would
apply
to
States,
not
to
small
entities.

BART
requirements
in
the
Regional
Haze
Rule
require
BART
determinations
for
a
select
list
of
major
stationary
sources
defined
by
section
169A(
g)(
7)
of
the
CAA.
However,
as
noted
in
the
proposed
and
final
Regional
Haze
Rules,
the
State's
determination
of
BART
for
regional
haze
involves
some
State
discretion
in
considering
a
number
of
factors
set
forth
in
section
169A(
g)(
2),
including
the
costs
of
compliance.
Further,
the
Regional
Haze
Rule
allows
States
to
adopt
alternative
measures
in
lieu
of
requiring
the
installation
and
operation
of
BART
at
these
major
stationary
sources.
As
a
result,
the
potential
consequences
of
the
BART
provisions
of
the
regional
haze
rule
at
specific
sources
are
speculative.
Any
requirements
for
BART
will
be
established
by
State
rulemakings.
The
States
would
accordingly
exercise
substantial
intervening
discretion
in
implementing
the
BART
requirements
of
the
Regional
Haze
Rule
and
BART
guidelines.

States
and
Tribes
are
required
to
submit
their
implementation
plans
by
December
2007.
In
addition,
the
Western
States
have
the
option
of
submitting
their
SO2
Regional
Haze
Strategies
by
this
date.
Sources
in
these
States
must
report
their
annual
emissions
and
the
RPO
will
submit
annual
emissions
reports.
5.4
Collection
Schedule
INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
FOR
EPA
ICR
NUMBER
1813.06,
RENEWAL
OF
THE
ICR
FOR
THE
REGIONAL
HAZE
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Page
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Burden
means
the
total
time,
effort,
of
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
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
The
burden
estimate
should
be
composed
of
(
1)
a
total
capital
and
start­
up
cost
component
annualized
over
its
useful
life;
(
2)
a
total
operation,
maintenance
and
purchases
of
services
component.
Each
component
should
be
divided
into
burden
borne
directly
by
the
respondent
and
any
services
that
are
contracted
out.

Although
there
have
been
regulatory
changes
to
the
Regional
Haze
program
since
the
2003
renewal,
these
changes
were
largely
clarification
and
do
not
significantly
change
the
burden
associated
with
developing
an
implementation
plan.
Most
of
the
activities
associated
with
making
BART
determinations
have
been
conducted
under
the
previous
collection
periods.
Table
6.1
summarizes
the
results
for
each
of
the
major
categories
of
respondents.

Develop
and
Submit
Regional
Haze
Implementation
Plan.
Based
on
a
review
of
the
previous
ICR
we
believe
that
an
estimate
of
400
hours
per
State
to
complete
the
Regional
Haze
SIP
is
reasonable.
Based
on
discussion
with
EPA
and
RPO
staff,
we
believe
that
the
majority
of
the
SIP
development
effort
will
be
complete
by
the
time
this
clearance
period
takes
effect.
We
have
also
assumed
that
one
Tribe
will
accept
delegation
of
the
40
CFR
51.308
program
and
will
prepare
and
submit
a
Regional
Haze
SIP
for
an
estimated
burden
of
400
hours.

Make
BART
Determinations.
We
believe
80
hours
per
BART­
eligible
category
is
a
reasonable
estimate
of
State
agency
burden
to
make
a
BART
determination.
Once
again,
a
lot
of
this
work
has
been
done
previously
in
the
form
of
control
guidance,
emissions
analysis
for
inventory
projections,
etc.
Based
on
information
found
in
the
draft
list
of
BART
eligible
sources
for
two
RPOs
(
Midwest
RPO
and
WRAP),
there
are
on
average
7.42
BART
categories
represented
in
each
State.
Therefore
we
have
assumed
an
average
of
594
hours
per
State
to
make
BART
determinations.
For
the
single
Tribe
we
have
assumed
that
will
take
delegation
of
the
40
CFR
51.309
program,
we
have
assumed
there
are
two
BART
categories
represented,
for
a
total
of
160
hours.
Because
some
States
may
request
6
Estimating
the
Burden
and
Cost
of
the
Collection
6.1
Estimating
Respondent
Burden
INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
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EPA
ICR
NUMBER
1813.06,
RENEWAL
OF
THE
ICR
FOR
THE
REGIONAL
HAZE
RULE
Page
14
sources
to
conduct
visibility
modeling
or
provide
other
information,
we
have
included
an
estimate
for
40
hours
per
source.

Report
Calendar
Year
Emissions.
In
the
third
year
of
this
clearance
period,
we
estimate
that
sources
with
BART
determinations
will
be
reporting
their
calendar
year
emissions.
Most
States
currently
require
reporting
of
sources
that
are
100
tons/
year
or
greater.
However,
the
recently
signed
consolidated
and
emissions
and
reporting
rule
relaxes
Federal
requirements
for
those
sources
to
2500
tons/
year.
Whether
the
States
will
adjust
their
reporting
accordingly
is
unknown;
we
assume
they
do.
Hence,
there
is
an
estimate
of
incremental
reporting
burden
for
those
sources
that
emit
>
100
and
<
2500
tons/
year.
Examples
of
non­
complex
sources
include
industrial
boilers,
lime
kilns,
cement
plants,
and
natural
gas
plants.
The
complex
sources
include
refineries,
smelters
and
other
metallurgical
operations,
and
Kraft
pulp
mills.
At
these
sources,
there
may
be
a
variety
of
operations
emitting
sulfur
dioxide.
Hence,
the
higher
estimate
of
burden
hours.
We
estimate
non­
complex
sources
will
spend
4
hours/
year
generating
their
emission
reports
and
complex
sources
will
spend
16
hours/
year.
We
believe
that
these
sources
will
already
have
much
if
not
all
of
the
needed
information
available
to
them
because
of
other
reporting
requirements,
including
Title
V
permits.

Using
the
list
of
BART
eligible
sources,
an
assumption
that
90
percent
of
the
sources
will
ultimately
be
determined
to
be
BART
eligible,
and
the
percentages
of
emissions
categories
represented
by
the
WRAP
States
as
indicative
of
the
nation
as
a
whole,
we
estimate
there
will
be
326
"
complex"
sources
and
422
"
noncomplex"
sources
reporting
emissions
in
2008.
As
described
in
Table
6.1,
the
States
also
will
be
required
to
prepare
and
submit
annual
emissions
reports
to
EPA.
We
believe
the
States
will
have
an
automated
system
in
place
to
generate
these
reports
and
the
estimated
burden
for
this
activity
is
20
hours/
State/
year.

Prepare
Revised
SIP
for
SO2
Western
Backstop
Trading
Program.
The
Section
309
burdens
are
based
on
the
previous
renewal,
except
that
the
burden
associated
with
developing
a
Regional
Haze
Strategy
is
reduced
because
the
States
are
expected
only
to
update
their
previous
submittals.

Report
Calendar
Year
SO2
Emissions.
As
described
in
Table
6.1,
sources
will
also
be
required
to
report
calendar
year
emissions
in
the
ICR
clearance
period.
Based
on
the
emissions
information
provided
on
the
WRAP's
list
of
BART
eligible
sources
and
our
assumption
that
90
percent
of
these
will
actually
be
determined
to
be
BART­
eligible
in
the
final
analysis,
we
estimate
that
there
will
be
127
"
complex"
sources
and
167
"
noncomplex"
sources
emitting
less
than
2,500
tons/
year.
As
described
above,
we
estimate
non­
complex
sources
will
spend
4
hours/
year
INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
FOR
EPA
ICR
NUMBER
1813.06,
RENEWAL
OF
THE
ICR
FOR
THE
REGIONAL
HAZE
RULE
Page
15
generating
their
emission
reports
and
complex
sources
will
spend
16
hours/
year.
We
believe
that
these
sources
will
already
have
much
if
not
all
of
the
needed
information
available
to
them
because
of
other
reporting
requirements,
including
Title
V
permits.
Also
the
four
WRAP
States
will
generate
annual
SO2
emissions
report
for
an
estimated
burden
of
20/
hours/
State/
year.

Table
6.1.
Estimated
Respondent
Burden
to
Implement
Requirements
Task
Element
Hours/
State
Hours/
Tribe
Hours/
Source
Total
Hours
for
FLMs
Year
Incurred
40
CFR
51.308
Requirements
Develop
and
submit
§
308
Implementation
Plan
400
400
0
2000
2006
­
2007
Make
BART
determinations
594
160
40
0
2006
­
2007
Report
calendar
year
emissions
n/
a
n/
a
0
for
>
2500
tons/
year
sources;
4
for
non­
complex
sources,
16
for
complex
sources
n/
a
2008
Prepare
and
submit
emissions
reports
20
20
0
0
2008
40
CFR
51.309
Requirements
Develop
and
submit
§
309
Regional
Haze
strategies
80
0
0
200
2006
­
2007
Report
calendar
year
emissions
n/
a
n/
a
0
for
>
2500
tons/
year
sources;
4
for
non­
complex
sources,
16
for
complex
sources
n/
a
2006
­
2008
Prepare
and
submit
annual
emissions
reports
60
0
0
0
2006
­
2008
This
ICR
uses
the
most
recently
available
wage
values
with
the
wage
rate
methods
established
in
the
New
Source
Review
(
NSR)
ICRs,
which
use
standard
methods
based
in
the
Federal
Operating
Permit
Programs
ICRs.

We
estimated
industry
labor
costs
using
a
two­
step
process.
First,
we
calculated
an
estimated
in­
house
labor
rate
using
the
latest
data
from
the
Bureau
of
Labor
Statistics
(
BLS).
We
then
calculated
an
industrial
respondent's
labor
rate
reflecting
a
division
between
in­
house
technical
staff
and
contractor
staff.

The
labor
rate
used
to
calculate
the
industrial
respondent's
labor
cost
is
$
73.40/
hr
and
reflects
a
division
of
labor
between
in­
house
technical
staff
6.2
Estimating
Respondent
Costs
6.2.1
Estimating
Labor
Costs
6.2.1.1
Industrial
Labor
Rates
INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
FOR
EPA
ICR
NUMBER
1813.06,
RENEWAL
OF
THE
ICR
FOR
THE
REGIONAL
HAZE
RULE
Page
16
and
managerial
staff,
and
the
involvement
of
outside
consultants.
The
following
steps
detail
the
estimated
industrial
respondent
labor
rates:

1.
To
calculate
the
in­
house
labor
rate,
$
62.20/
hr,
we
have
used
a
graded
approach
in
calculating
labor
cost
as
recommended
in
the
ICR
handbook.
We
used
wage
rates
for
industry
respondents
retrieved
from
the
BLS.
Because
of
the
breadth
of
industry
categories
that
could
be
affected,
we
used
average
industry
rates
for
Engineering
Mangers
(
management),
Environmental
Engineers
(
technical),
and
Correspondence
Clerks
(
clerical).
Based
on
current
BLS
data
for
private
sector
benefits
compensation,
we
used
28.8
percent
of
the
total
compensation
to
estimate
benefits.
2
We
calculated
the
overhead
rate
as
50
percent
of
the
total
compensation
rate
(
i.
e.
salary
plus
benefits).
The
addition
of
benefits
and
overhead
to
the
hourly
rate
produces
a
pay
rate
that
reflects
the
true
cost
to
employ
an
industry
sector
worker.
Table
6.2
summarizes
this
result.

Table
6.2
Calculated
In­
house
Weighted
Hourly
Labor
Rates
Labor
Type
Base
Salary,
Hourly
Rate
Benefit
Hourly
Rate
a
Overhead
Hourly
Rate
b
Adjusted
Hourly
Rate
In­
house
Weighting
(%)
In­
house
Weighted
Hourly
Rate
Management
50.10
c
14.43
32.26
96.79
5%
4.84
Technical
33.27
d
9.58
21.43
64.28
85%
54.64
Clerical
14.10
e
4.06
9.08
27.24
10%
2.72
Total
100%
$
62.20
a
Benefits
are
28.8%
of
Base
Salary
Hourly
Rate
based
on
Nov
2004
data
from
the
Dept
of
Labor:
Bureau
of
Labor
and
Statistics
http://
data.
bls.
gov/
cgi­
bin/
dsrv
b
Overhead
rate
is
50%
of
Base
Salary
Hourly
Rate
plus
Benefit
Hourly
Rate.

c
Dept
of
Labor:
Bureau
of
Labor
and
Statistics
http://
www.
bls.
gov/
oes/
current/
oes119041.
htm,
November
2004
d
Dept
of
Labor:
Bureau
of
Labor
and
Statistics
http://
www.
bls.
gov/
oes/
current/
oes172081.
htm,
November
2004
e
Dept
of
Labor:
Bureau
of
Labor
and
Statistics
http://
www.
bls.
gov/
oes/
current/
oes434021.
htm,
November
2004
2.
The
fully
loaded
weighted
consultant
rate
was
calculated
using
the
1997
NSR
ICR
which
was
estimated
to
be
60
percent
higher
than
the
loaded
in­
house
rate.
Therefore,
we
have
estimated
the
current
fully
loaded
weighted
consultant
rate
to
be
$
99.52
($
62.20
×
1.60
=
$
99.52).
3.
The
industrial
respondent's
labor
rate
is
calculated
by
taking
70%
of
the
2006
in­
house
rate
($
62.20
×
0.70
=
$
43.54).
This
is
derived
using
fully
loaded
weighted
technical,
clerical,
and
managerial
staff
wages.

2
U.
S.
Department
of
Labor:
Bureau
of
Labor
Statistics:
Bureau
of
Labor
Statistics
Data.
http://
data.
bls.
gov/
cgi­
bin/
drsv
Accessed
April
2006.
INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
FOR
EPA
ICR
NUMBER
1813.06,
RENEWAL
OF
THE
ICR
FOR
THE
REGIONAL
HAZE
RULE
Page
17
4.
This
number
is
added
to
30%
of
the
2006
fully
loaded
weighted
consultant
rate
for
technical,
clerical,
and
managerial
staff
($
99.52
×
0.30
=
$
29.86).
5.
The
resultant
industrial
respondent's
labor
rate
equals
$
73.40/
hr
($
43.54
+
$
29.52
=
$
73.40).

The
labor
rate
used
to
calculate
the
State
and
local
respondents'
and
FLMs'
labor
cost
is
$
44.63/
hr.
This
rate
is
the
result
of
inserting
2006
Federal
government
pay
schedule
wage
rates
for
clerical,
technical,
and
managerial
staff
into
the
weighting
system
developed
in
the
1997
renewal
ICR
and
described
in
the
November
2002
parts
51
&
52
ICR
update.
3
For
this
ICR,
the
Agency
employed
the
same
methodology
to
determine
2006
Federal
burden
costs.
Table
6.3
summarizes
this
result.

Table
6.3
Determination
of
Federal
and
State
Wage
Rates
Annual
Salary
of
Permit
Staff,
GS
11
Step
3
(
FY
06
Schedule)*
$
49,269.00
Annual
Cost
of
Supervisory
Staff,
GS
13
Step
3
(
FY
06
Schedule)*
$
70,220.00
Factor
(
1/
11)
0.09
$
6,319.80
$
32,765.00
Annual
Cost
of
Support
Staff,
GS
6
Step
6
(
FY
06
Schedule)*
Factor
(
1/
8)
0.13
$
4,259.45
Annual
Applicable
Salary
of
Permit
Staff
$
59,848.25
Benefits
(
at
16%)
$
9,575.72
Sick
Leave
/
Vacation
(
at
10%)
$
5,984.83
General
Overhead
$
17,413.37
Total
Cost
Per
FTE
$
92,822.17
Total
Hourly
Cost
(
Total
Per
FTE
divided
by
2,080
hours
per
year)
$
44.63
a
http://
www.
opm.
gov/
oca/
06tables/
html/
gs.
asp
April
2006
All
of
the
sources
subject
to
these
requirements
are
existing
and
should
have
most,
and
perhaps
all,
of
the
equipment
needed
to
respond
to
State
requests
(
for
example,
the
computers
and
basic
software)
will
be
part
of
the
source's
business
operation
inventory.
Furthermore,
much
of
the
data
and
regulatory
and
policy
information
for
estimating
emissions
and
visibility
impact
are
available
in
electronic
form
from
several
different
EPA
bulletin
boards
for
just
the
communication
charges,
which
are
typically
absorbed
in
routine
business
overhead
expenses.

3
U.
S.,
Environmental
Protection
Agency,
Office
of
Air
Quality
Planning
and
Standards,
DRAFT
INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PART
51
AND
52
PREVENTION
OF
SIGNIFICANT
DETERIORATION
AND
NEW
SOURCE
REVIEW
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES,
November,
2002,
p.
29.
6.2.2
Estimating
Capital
and
Operations
and
Maintenance
Costs
including
Purchase
of
Services
6.2.1.2
State
and
Local
Respondent
Labor
Rates
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STATEMENT
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EPA
ICR
NUMBER
1813.06,
RENEWAL
OF
THE
ICR
FOR
THE
REGIONAL
HAZE
RULE
Page
18
Since
the
purchase
of
capital
equipment
is
believed
to
be
an
insignificant
factor
in
responding
to
State
requests,
EPA
assumes
the
operation,
maintenance,
or
services
for
same
are
negligible.

Typically
annualized
capital
cost
would
be
derived
from
a
discounted
net
present
value
of
the
stream
of
costs
that
would
occur
over
the
life
of
the
activity,
or
the
ICR,
whichever
is
shorter.
We
anticipate
there
may
be
monitoring
costs
associated
with
the
final
BART
determinations
as
sources
take
steps
to
ensure
they
will
be
in
compliance
with
the
BART
requirements.
However
we
do
not
anticipate
these
expenses
will
be
incurred
during
this
clearance
period.

The
Agency
Burden
is
divided
between
the
EPA
Regional
Offices,
who
perform
the
primary
review
of
State
submittals,
and
EPA
Headquarters
staff,
who
provide
oversight.
In
addition,
EPA
funds
five
RPOs,
who
address
regional
haze
and
related
issues.
These
organizations
have
provided
key
support
in
evaluating
technical
information
to
better
understand
how
their
States
and
Tribes
impact
national
park
and
wilderness
areas
(
Class
I
areas)
across
the
country.
They
also
have
developed
key
implementation
tools
that
they
and
the
States
and
Tribes
are
using
to
develop
the
pending
implementation
plans
to
reduce
emissions
of
particulate
matter
and
other
pollutants
leading
to
regional
haze.
In
the
previous
ICR
(
1813.04),
the
burden
associated
with
RPO
activities
was
excluded
because
their
activities
were
funded
by
EPA
grants.
However,
for
this
ICR,
we
have
decided
that
it
is
appropriate
to
include
some
burden
for
their
activities
as
part
of
the
overall
Agency
burden.
We
recognize
that
the
States
also
contribute
substantial
RPO
support,
in
terms
of
staff
hours.
We
assume
this
support
is
reflected
in
the
overall
State
burden
estimates
presented
earlier
in
this
ICR.

For
this
ICR,
we
have
assumed
the
following
number
of
offices
will
be
involved
in
implementing
the
Regional
Haze
requirements.

EPA
Regional
Offices.
We
assume
that
all
10
EPA
Regional
Offices
will
be
responsible
for
reviewing
implementation
plans
from
the
States
in
their
jurisdiction.
We
assume
that
4
Regional
Offices
(
6,
8,
9,
10)
will
review
40
CFR
51.309
submittals
from
5
States
(
Arizona,
New
Mexico,
Oregon,
Utah,
and
Wyoming).

EPA
Headquarters.
The
EPA
Headquarters
staff
will
provide
oversight
and
review
for
Regional
Haze
submittals.

RPOs.
All
5
RPOs
will
be
involved
in
developing
Regional
Haze
rule
submittals.
In
addition,
the
WRAP
will
be
involved
in
helping
the
5
western
States
develop
40
CFR
51.309
submittals.
6.2.3
Annualized
Capital
Costs
6.3
Estimating
Agency
Burden
and
Cost
INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
FOR
EPA
ICR
NUMBER
1813.06,
RENEWAL
OF
THE
ICR
FOR
THE
REGIONAL
HAZE
RULE
Page
19
Table
6.4
presents
our
estimate
of
the
Agency
burden
in
the
ICR
clearance
period.
In
developing
these
estimates,
we
considered
previous
estimates
for
similar
activities
as
well
as
the
fact
that
much
of
the
development
work
has
already
been
performed
(
e.
g.,
inventories,
monitoring
strategy,
control
option
assessments,
etc.).

Table
6.5
summarizes
the
total
annual
average
burden
to
the
Agency,
which
is
2,443
hours
and
$
111,000
during
the
3­
year
clearance
period.
This
annual
burden
is
calculated
by
taking
the
total
burden
from
Table
6.4
(
years
1
 
3,
combined),
dividing
it
by
three
and
multiplying
by
the
number
of
respondents.
As
described
in
section
6.2.1.3,
we
calculated
Federal
labor
rates
using
the
weighting
developed
in
the
1997
NSR
ICR
renewal
and
subsequent
updates.
The
estimated
labor
rate
is
$
44.63/
hr.

Table
6.4.
Estimated
Agency
Burden
to
Implement
Requirements
Task
Element
Hours/
EPA
Regional
Office
Hours/
Headquarters
Hours/
RPO
Year
Incurred
40
CFR
51.308
Requirements
Develop,
submit,
and/
or
review
§
308
Implementation
Plan
200
80
160
2006
­
2007
Make
or
Review
BART
determinations
240
40
240
2006
­
2007
Report
or
review
calendar
year
emissions
report
8
0
8
2008
40
CFR
51.309
Requirements
Develop,
submit,
and
/
or
review
§
309
Regional
Haze
strategies
20
10
160
2006
­
2007
Report
or
review
calendar
year
emissions
report
24
0
24
2006
 
2008
TOTAL
484
130
584
INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
FOR
EPA
ICR
NUMBER
1813.06,
RENEWAL
OF
THE
ICR
FOR
THE
REGIONAL
HAZE
RULE
Page
20
Table
6.5
Estimated
Total
Annual
Burden
to
Agency
EPA
Regional
Office
Headquarters
RPOs
Task
Average
Annual
Hours
Average
Annual
Cost
($
1000)
Average
Annual
Hours
Average
Annual
Cost
($
1000)
Average
Annual
Hours
Average
Annual
Cost
($
1000)

40
CFR
51.308
Requirements
Develop,
submit,
and/
or
review
§
308
Implementation
Plan
(
200*
10)/
3
=
667
30
80/
3
=
27
1
(
160*
5)/
3
=
267
12
Make
or
review
BART
determinations
(
240*
10)/
3
=
800
36
40/
3
=
13
1
(
240*
5)/
3
=
400
18
Report
or
review
calendar
year
emissions
report
(
8*
50)/
3
=
133
6
0
0
(
8*
5)/
3
=
13
1
40
CFR
51.309
Requirements
Develop,
submit,
and
/
or
review
§
309
Regional
Haze
strategies
(
20*
4)/
3
=
27
1
10/
3
=
3
0.1
160/
3
=
53
2
Report
or
review
calendar
year
emissions
report
(
24*
4)/
3
=
32
1
0
0
24/
3
=
8
0.3
Total
Annual
Burden
by
Agency
1,659
76
43
2
741
33
Total
for
Agency
2,443
hours;
$
111,000
For
the
purpose
of
estimating
burden
in
this
ICR,
the
respondent
universe
is
determined
as
follows.

States.
We
assume
that
all
50
States
will
be
affected
by
the
40
CFR
51.308
requirements.
Five
States
will
submit
40
CFR
51.309
strategies
(
Arizona,
New
Mexico,
Oregon,
Utah,
and
Wyoming).

Tribes.
We
assume
that
1
Tribe
will
opt
to
develop
implement
the
40
CFR
a
Regional
Haze
plan.

Industry.
Using
the
lists
of
potential
BART
eligible
sources
developed
by
the
RPOs,
we
compiled
a
list
of
1,107
potential
sources.
Sixty­
three
percent
of
these
facilities
(
698)
are
located
in
States
subject
to
the
Clean
Air
Interstate
Rule
(
CAIR).
The
CAIR
requires
reductions
in
emissions
of
SO2
and
NOx
from
electricity
generating
units
(
EGUs)
in
28
eastern
States
and
the
District
of
Columbia.
When
fully
implemented,
CAIR
will
reduce
SO2
emissions
in
these
states
by
over
70
percent
and
NOx
emissions
by
over
60
percent
from
2003
levels.
The
CAIR
establishes
an
EPAadministered
cap
and
trade
program
for
EGUs
in
which
States
may
participate
as
a
means
to
meet
these
requirements.
In
the
BART
rule,
EPA
6.4
Estimating
the
Respondent
Universe
INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
FOR
EPA
ICR
NUMBER
1813.06,
RENEWAL
OF
THE
ICR
FOR
THE
REGIONAL
HAZE
RULE
Page
21
presents
the
results
of
an
analysis
showing
that
controls
for
EGUs
subject
to
CAIR
will
result
in
more
visibility
improvement
in
natural
areas
than
BART
would
have
provided.
States
that
adopt
the
CAIR
cap
and
trade
program
for
SO2
and
NOx
are
allowed
to
apply
CAIR
controls
as
a
substitute
for
controls
required
under
BART
because
our
analysis
concluded
that
CAIR
controls
are
"
better
than
BART"
for
EGUs
in
the
states
subject
to
CAIR.

Using
the
list
of
BART
eligible
sources,
we
determined
that
approximately
30
percent
of
them
(
209)
are
EGUs
or
fossil
fuel­
fired
steam
electric
plants
that
are
potentially
subject
to
the
CAIR.
For
purposes
of
this
ICR,
we
have
assumed
that
90
percent
of
the
remaining
sources
in
the
CAIR
States
(
440)
and
90
percent
of
the
sources
in
the
non­
CAIR
States
(
368)
sources
will
be
subject
to
the
BART
determination
process
for
a
total
of
808
sources.
We
applied
the
90
percent
factor
to
account
for
the
fact
that
the
lists
of
BART
eligible
sources
is
not
final
in
all
cases
and
we
expect
that
the
final
totals
will
be
somewhat
less
as
the
States
and
sources
review
the
draft
lists..

FLMs.
The
burden
hours
for
FLMs
are
estimated
for
the
group
as
a
whole.

Tables
6.6
summarizes
the
total
annual
respondent
burden,
which
is
32,551
hours
per
year
and
$
1,856,000
per
year.
As
described
in
section
6.2.2
and
6.2.3,
there
are
no
operation
and
maintenance
costs
or
capital
costs
associated
with
activities
to
be
conducted
during
this
3­
year
clearance
period.
The
total
number
of
respondents
is
860
(
50
State
agencies,
1
Tribe,
1
group
of
FLMs,
and
808
industrial
sources.)
6.5
Bottom
Line
Burden
and
Cost
INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
FOR
EPA
ICR
NUMBER
1813.06,
RENEWAL
OF
THE
ICR
FOR
THE
REGIONAL
HAZE
RULE
Page
22
Table
6.6
Estimated
Annual
Respondent
Burden
to
Implement
Requirements
States
Tribes
Source
FLMs
Task
Element
Average
Annual
Hours
Average
Annual
Cost
($
1000)
Average
Annual
Hours
Average
Annual
Cost
($
1000)
Average
Annual
Hours
Average
Annual
Cost
($
1000)
Average
Annual
Hours
Average
Annual
Cost
($
1000)

40
CFR
51.308
Requirements
Develop
and
submit
§
308
Implementation
Plan
(
400*
50)/
3=
6,666
298
400/
3
=
133
6
0
0
2000/
3=
667
30
Make
BART
determinations
(
594*
50)/
3=
9,900
442
1600/
3
=
533
24
(
40*
808)/
3
=
10,773
791
0
0
Report
calendar
year
emissions
0
0
0
0
(
4*
422)/
3
=
563
(
16*
326)/
3
=
1,739
169
0
0
Prepare
and
submit
emissions
reports
(
20*
50)/
3
=
333
15
20/
3
=
7
0.3
0
0
0
0
40
CFR
51.309
Requirements
Develop
and
submit
§
309
Regional
Haze
strategies
(
80*
5)/
3=
133
6
0
0
0
0
200/
3
=
67
3
Report
Calendar
Year
Emissions
0
0
0
0
(
4*
167)/
3
=
223
(
16*
127)/
3
=
677
66
0
0
Prepare
and
submit
annual
emissions
reports
(
60*
5)/
3=
100
4
110/
3=
37
2
0
0
0
0
Total
Burden
by
Respondent
17,132
765
710
32
13,975
1,026
734
33
Total
for
Respondent
Universe
32,551
hours;
$
1,856,000
The
burden
estimates
for
this
ICR
renewal
period
cover
different
task
elements
than
those
for
the
previous
renewal
(
1813.04).
These
differences
reflect
the
requirements
of
the
final
Regional
Haze
Rule
with
respect
to
the
scheduled
events
and
activities
in
the
implementation
process.
6.6
Reasons
for
Change
in
Burden
INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
FOR
EPA
ICR
NUMBER
1813.06,
RENEWAL
OF
THE
ICR
FOR
THE
REGIONAL
HAZE
RULE
Page
23
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.
The
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.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OAR­
2003­
0162,
that
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center,
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Air
Docket
is
(
202)
566­
1742.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
N.
W.,
Washington
D.
C.
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
OAR­
2003­
0162)
in
any
correspondence.
6.7
Burden
Statement
