United States Environmental Protection Agency


EPA
Office of Air and RadiationOffice of Air Quality Planning and Standards
Air Quality Policy Division
Geographic Strategies Group
Draft April 19, 2012


August, 2003


                                       
                        INFORMATION COLLECTION REQUEST
                           SUPPORTING STATEMENT FOR
                            EPA ICR NUMBER 1813.08,
             RENEWAL OF THE ICR FOR THE REGIONAL HAZE REGULATIONS 

                                        


	 


	














EPA # 1813.08
EPA # 1230.16

Executive Summary
Draft 05/01/06
This ICR, EPA Form 1813.08, is an update of the Office of Management and Budget (OMB) Control Number 2060-0421; EPA Form 1813.07 which expires on October 31, 2012. The current approved collection is for 859 respondents, 31,841 hours per year, and $2,563,000 per year. This renewal requests approval for 35 respondents (34 state agencies, and 1 group of Federal Land Managers (FLMs)), 4,080 hours per year, and $198,084 per year. Table E.1 summarizes the total annual respondent burden for this renewal. No tribes submitted regional haze plans, so there are no burden estimates for them.Draft 04/17/12
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 the fact that the aggregate initial regional haze state implementation plans (SIPs) and best available retrofit technology (BART) determinations will have been acted upon by the EPA by November 2012 and the states will be shifting their focus to development of interim progress reports required by the regional haze rule.  

Table E-1 Estimated State, Source, and FLM Respondent Burden to Implement Requirements
Task Element
                                    States
                                    Source
                                     FLMs

Average Annual Hours
Average Annual Cost ($)
Average Annual Hours
Average Annual Cost ($)
Average Annual  Hours
Average Annual Cost ($)
Total Burden by Respondent
3,173
154,049
0
0
907
44,035
Total for Respondent Universe
4,080 hours; $198,084	

 
                         EPA TRACKING NUMBER: 1813.08
                                       
                              E-TRACKING NUMBER:
                                 OMB-2060-0421
1	Identification of the Information Collection
1.1	Title
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 1813.08. The title of this Information Collection Request (ICR) is "Information Collection Request Supporting Statement for EPA ICR Number 1813.08, Renewal of The ICR for the Regional Haze Regulations."1.2	Description
OMD1.2	Description
Subpart P of 40 CFR 51, 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, Federal Land Managers (FLMs), and the EPA will focus on  reporting requirements in the rule to address the progress of regional haze implementation plans. 40 CFR 51.308 (g) requires states to develop periodic reports evaluating progress towards the reasonable progress goals for improving visibility in  Class I areas inside the state and in neighboring states. There are similar reporting requirements under 40 CFR 51.309, a section of the regional haze rule in which 3 states (Utah, Wyoming, and New Mexico) elected to submit their SIPs. Under section 309, these states adopted 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, the 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 per year of visibility-impairing pollution. Those facilities fall into 26 categories, including utility and industrial boilers, and large industrial 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 regulations, 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 had to develop their implementation plans by December, 2007. As part of those plans, states were required identify the facilities that will have to reduce emissions under BART and then set BART emissions limits for those facilities.

The majority of the states did not submit their SIPs on time, and the EPA is currently subject to several consent decrees establishing schedules for final actions on the SIPs, or promulgation of FIPs, that in the aggregate require the agency to complete all remaining unfinished actions on the initial regional haze implementation plans by November 2012. Since that date aligns closely with the expiration of the currently approved ICR (October 31, 2012) and the majority of the effort required to complete the actions on the initial SIPs will have occurred, the primary focus for estimating burden for this 3 year renewal period (October 31, 2012  -  October 30, 2015) will apply to the next program milestone which is the 5 year periodic progress report (see 40 CFR 51.308(g)). The due date for states to submit the progress reports is 5 years from their initial regional haze SIP submittals, and for an estimated 34 states, that due date falls within the date range of this ICR renewal. In the 5 year progress reports, states are required to describe the status of the implementation of measures needed to achieve reasonable progress goals, report on the emissions reductions achieved, assess visibility changes, and evaluate whether the current implementation plan is sufficient to meet all established reasonable progress goals.
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 CAA 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. 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 raze rule. During this clearance period, we anticipate that the reporting requirements under 40 CFR 51.308(g) will be the major program focus and the similar reporting requirements (see 40 CFR 51.309(d)(10)) for 3 states that submitted regional haze SIPs under 40 CFR 51.309
2	Need and Use of the Collection
2.1	Need / Authority for the Collection
  2.2	Practical Utility / Users of the Data
The data collected from respondents include revised state implementation plans. These data confirm progress in assessing visibility impairment and source contribution, and provide the foundation for the establishment of the reasonable progress goals, control strategies, and BART requirements. 	
2.3	Caveats and Considerations
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.
This information collection renewal request is related to provisions in 40 CFR 51.308(g) and 40 CFR 51.309(d)(10) which require periodic reports describing progress towards the reasonable progress goals. Each state must submit an implementation plan revision evaluating whether improvement in visibility is made towards the reasonable progress goal for each mandatory Class 1 Federal area located within the state and in each mandatory Class 1 Federal area located outside the state which may be affected by emissions from within the state. These implementation plans are due 5 years from the submittal of the initial regional haze plan. The reasonable progress implementation plans required by the regional haze rule are unique and do not duplicate other implementation plan requirements.
3.1	Non-Duplication
3	Non-Duplication, Consultation, and Other Collection Criteria
3.2	Public Notice Requirements
In compliance with the PRA, this draft ICR must solicit public comments for a 60-day period prior to submission to OMB.  

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 August 2009. 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 August 26, 2009 (74 FR 43118). No significant comments were received. 

3.3	Consultations
The EPA consulted with the EPA Region 5 Office for comment, review, and suggestions on this ICR renewal. The point of contact for the regional office is John Summerhays, regional haze coordinator for EPA Region 5, (312)886-6067. Mr. Summerhays had no comments.  

We also contacted the state of Virginia Department of Environmental Quality (DEQ), explained the requirements of the ICR renewal, and solicited comment. The point of contact is Mr. Michael Kiss, Director, Office of Air Quality Assessments, Richmond, VA, (804) 698-4460. Mr. Kiss had no comments. 

3.4	Less Frequent
	Collection
The information collection requested under this ICR is necessary to ensure implementation of the 40 CFR 51.308 and 40 CFR 51.309 requirements.  3.5	General
	Guidelines
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 every 5 years.
   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.
   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 CAA.
3.6	Confidentiality
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 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).

3.7	Sensitive 
	Questions
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 does not include personal data on any owner or operator.
3.8	Environmental Justice Considerations
Because the regional haze program operates nation-wide and across numerous industry classifications, the Agency does not believe there is a disproportionate EJ effect in the regional haze program.  4	The Respondents and the Information Requested
4.1	Respondents/ 
The major categories of respondents directly affected during this ICR period of October 31, 2012 through October 15, 2015 include the states and FLMs. The states are developing implementation plans under 40 CFR 51.308(g) and 40 CFR 51.309(d)(10) evaluating progress towards the reasonable progress goal for each mandatory Class I Federal area located within the state and in each mandatory Class I Federal area located outside the state which may be affected by emissions from within the state.  
The FLMs will evaluate the SIP revisions and provide comments to the states. The states are required to consult with the FLMs and explain how they address the FLMs comments in their final SIPs.

4.2	Information
	Requested
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 are revising their SIPs to report on progress made towards reaching their long term visibility goals. For 34 states, the progress reports will be due during the October 31, 2012 to October 30, 2015 ICR period.
The information that is requested under this renewal period under the regional haze rule requirements includes:

Submittal of Requirements for Periodic Reports Describing Progress Towards the Reasonable Progress Goals

   * Description of status of control measures
   * Summary of emission reductions
   * Calculation of visibility conditions and changes
   * Calculation of 5 year progress
   * Assessment of contributing emissions 
   * Assessment of reasonable progress goals 
   * Review monitoring strategy and note changes
   * Submit 5 year progress report
   * Determine degree of visibility improvement
   * Consult with FLMs

The first progress reports must be in the form of implementation plan revisions that comply with procedural requirements of 40 CFR 51.102 and 40 CFR 51.103. The reports are due 5 years after the initial regional haze plan submission.


5	The Information Collected - Agency Activities, Collection Methodologies, and Information Management
5.1	Agency Activities
EPA. Each EPA regional office is responsible for reviewing and approving the SIPs and promulgating FIPs when necessary. For this ICR renewal period, the EPA will primarily be reviewing the SIP revisions required under 308(g) and 309(d)(10), which are the periodic progress reports. The 10 EPA regional offices as well as the EPA headquarters offices will provide direction and facilitate resolution of major issues, and deliver data, tools, and training to the states as needed. Each regional office must address public comments before approving the SIPs or promulgating FIPs.

FLMs. The FLMs will be reviewing the SIP revisions and offering comments as part of the public comment process.

5.2	Collection 
	Methodology
	and
	Management
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 11/05), 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. For example, 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 hours. 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.
   * While this ICR renewal estimates burden to federal and state agencies, it does not include costs estimates to the industrial sources. This is because the effort for this ICR renewal period, October 31, 2012 through October 31, 2015 mainly involves preparation and review of the progress reports required under 308(g) and 309(d)(10) of the regional haze rule. Sources, for the most part, will not be involved in preparation of these reports.

The implementation plans prepared by the states are periodic progress reports which are due five years after the state submits its comprehensive regional haze SIP. The plans must at a minimum include the following elements:

   * A description of the status of all measures included in the regional haze implementation plan for achieving reasonable progress.
   * A summary of the emissions reductions achieved throughout the state through implementation of the measures.
   * An assessment of the following visibility conditions and changes for each mandatory Class 1 Federal area within the state with values for most impaired and least impaired days expressed in terms of 5-year averages of the annual values: current visibility conditions for the most impaired and least impaired days; the difference between current visibility conditions for the most impaired and least impaired days and baseline visibility conditions; and the change in visibility impairment for the most impaired and least impaired days over the past 5 years.
   * An analysis tracking the change over the past 5 years in emissions of pollutants contributing to visibility impairment from all sources and activities within the state.
   * An assessment of any significant changes in anthropogenic emissions within or outside the state that have occurred over the past 5 years that have limited or impeded progress in reducing pollutant emissions and improving visibility.
   * An assessment of whether the current regional haze implementation plan elements and strategies are sufficient to enable the state, or other states with mandatory Class 1 Federal areas affected by emissions from the state, to meet all established reasonable progress goals.
   * A review of the state's visibility monitoring strategy and any modifications to the strategy as necessary.
   * Other elements, including reporting, record keeping, and other measures, necessary to assess and report on visibility.

5.3	Small Entity
	Flexibility
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 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. 

The EPA determined that it was not necessary to prepare a regulatory flexibility analysis in connection with the regional haze rule (July 6, 2005, 70 FR 39104) because the rule did not have a significant economic impact on a substantial number of small entities. Similarly, this ICR renewal will not impose any direct requirements on small entities and will apply primarily to states which are developing the SIP revisions. 

5.4	Collection
	Schedule
States are required to submit their periodic progress reports, in the form of a SIP revision, 5 years after the initial regional haze plan submission. Table 5.1 shows when these reports are due for each of the states. Note that some states have reports which are due outside of this renewal period, beyond October 31, 2012. Accordingly, we have estimated burden only for the 34 states with due dates that fall in 2015 or earlier.
Table 5.1	Due Dates for the 5 Year Progress Reports
Initial Regional Haze Submittal Year
5 Year Progress Report Due Date
State
2007
2012
NC, SC
2008
2013
AL, AR, DE, KY, LA, MS, MO, TN, UT, Albuquerque/Bernalillo County NM
2009
2014
CA, CT, KS, MN, NV, NJ, RI, TX, VT
2010
2015
District of Columbia, FL, GA, ID, ME, MI, NH, NY, ND, OK, OR, PA, VA
2011
2016
AK, AZ, CO, IN, NE, NM, OH, SD, WA, WY
2012
2017
MA, MD


6	Estimating the Burden and Cost of the Collection
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 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) the total capital and start-up cost component annualized over its useful life; (2) the 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.

This ICR renewal will apply primarily to 34 states which are developing 5-year progress reports in the form of SIP revisions6.1	Estimating Respondent Burden
 to satisfy the requirements of the regional haze rule. 5.4	Collection
	Schedule
Table 5.1 above shows when these reports are due for each of the states and the estimated due date for the SIPs. The FLMs will review and comment on those plans. For this renewal period, the burden for industrial sources will be negligible as the reports are required from the states.

For three states (Utah, Wyoming, and New Mexico) which submitted their regional haze SIPs under section 309 of the regional haze rule, there are also 5-year periodic reporting requirements that are essentially the same as the requirements under section 308(g). Table 6.1 summarizes the results for each of the major categories of respondents with details discussed in the narrative below.

Develop and Submit 5-Year Progress Reports as required under the Regional Haze Rule.  Based on the elements that are required for the report, which are described in section 5.2 above, we believe that an estimate of 280 hours per state to complete the report is reasonable.  Much of the analysis for the report will entail the states assessing changes in their emission inventories for the reporting period and reporting on changes in visibility based on available monitoring data. This burden estimate does not include any hours for preparation and finalization of the emission inventories because it is assumed that the EPA will provide an approved inventory, with appropriate forward projections of future visibility conditions, which the states may use for their analyses. For each individual state, we believe that approximately 160 hours on average is needed to analyze, evaluate, and summarize changes in the inventory and monitoring data over the reporting period, and another 80 hours is sufficient to prepare the report in the form of a SIP revision. These estimates are based on informal conversations with state and the EPA's technical staff. Finally, we assumed that states would need approximately 40 additional hours to address and respond to any public comments received on its SIP revision.

We assumed the FLMs would spend 80 hours, on average, reviewing and formally commenting on each of the SIP revisions.


Table 6.1. Estimated Respondent Burden to Implement Requirements
Task Element
Hours/State
Hours/Source
FLM  -  hours/state SIP
Year Incurred
Develop and submit §308(g) or 309(d)(10) Implementation Plan  -  5-year periodic reports
240
0
80
2012 - 2015


6.2	Estimating Respondent Costs
This ICR uses the most recently available wage values with the wage rate methods established in the New Source Review (NSR) ICRs. For this renewal period, the burden for industrial sources will be negligible as the reports are required from the states with review being done by the EPA and the FLMs. 
Consistent with methodologies for previous NSR ICRs, the labor rate used to calculate federal, state, and local respondents' labor costs is approximated from the 2012 federal government pay schedule. Managerial rates are accounted for by multiplying the hourly rate by 9%; the clerical support rates are multiplied by 13%. The hourly rate is $48.55, and the calculation is shown in Table 6.3


Table 6.3 Determination of Federal, State, and Local Wage Rates
Annual Salary of Technical Staff, GS 11 Step 3 (FY 12 Schedule)*

                                                                     $53,639.00
Annual Cost of Supervisory Staff, GS 13 Step 3 (FY 12 Schedule)*
                                                                     $76,452.00

   Factor (1/11)
                                                                           0.09
                                                                               


                                                                      $6,880.68
Annual Cost of Support Staff, GS 6 Step 6 (FY 12 Schedule)*
   Factor (1/8)
                                                                     $35,672.00


                                                                           0.13
                                                                               


                                                                      $4,637.36
Annual Applicable Salary of Technical Staff

                                                                     $65,157.04
Benefits (at 16%)

                                                                     $10,425.13
Sick Leave / Vacation (at 10%)

                                                                      $6,515.70
General Overhead (at 29%)

                                                                     $18,895.54
Total Cost Per FTE

                                                                    $100,993.41
Total Hourly Cost (Total Per FTE divided by 2,080 hours per year)

                                                                         $48.55
* http://www.opm.gov/oca/12tables/html/gs.asp  February 2012

Since the purchase of capital equipment is believed to be an insignificant factor in meeting the requirements associated with this ICR renewal, the EPA assumes the operation, maintenance, or services are negligible Most of the data and other guidance for estimating emissions and visibility impacts are available in electronic form and any equipment needed to respond to requests will be part of the respondent's operating inventory.

6.2.3	Annualized Capital Costs
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. However we do not anticipate these types of expenses will be incurred during this clearance period.  
6.3	Estimating Agency Burden and Cost
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, responding to public comments, and preparing federal register notices in taking final action on the SIPs.  

EPA Headquarters.  The EPA Headquarters staff will provide oversight and review of the submittals.

Table 6.4 presents our estimate of the Agency burden in the ICR clearance period which is the average to review one state plan. In developing these estimates, we considered previous estimates for similar activities, particularly related to the time necessary to review SIPs and prepare federal register notices and respond to public comments. The SIP revisions for this renewal period are anticipated to be much abbreviated compared to the comprehensive regional haze SIP submittals which are required to be submitted every 10 years. This results in a reduced burden relative to the previous ICR renewals as there are no modeling, emission inventory, or control strategy analyses due during the 2012  -  2015 collection period.  

Summing the total hours from Table 6.4 (400 hours) and multiplying by 34 total plans yields a total estimate of 13,600 hours. Using the calculated labor rate of $48.55/hr, from Table 6.3, multiplied by the 13,600 hours gives an estimated cost of $660,280, which when averaged over the 3 year collection period is $220,093 per year as the Agency's burden estimate.  

Table 6.4.  Estimated Agency Burden to Implement Requirements
Task Element
Hours/EPA Regional Office
Hours/EPA Headquarters
Year Incurred
Review Periodic Progress Reports from States 
160
80
2012 - 2015
Respond to Public Comments and Prepare Federal Register Notices
120
40
2012  -  2015
TOTAL
280
120



6.4	Estimating the Respondent Universe
For the purpose of estimating burden in this ICR, the respondent universe is determined as follows.
States. We assume that 34 states, including Bernalillo County in New Mexico, will be affected by the regional haze rule reporting requirements.  

Tribes. No tribes have elected to develop and implement the regional haze plan.

Industry. The sole regional haze requirement for this reporting period is for the states to submit periodic progress reports, and thus there is no anticipated burden for industrial sources.

FLMs. The burden hours for FLMs are estimated for the group as a whole, and are estimated to be 80 hours for each SIP revision. For 34 total SIPs, the total hours would be 2,720. Multiplying by the labor rate of $48.55/hr equates to a cost of $132,056, or $44,019 per year for each of the 3 years.

6.5	Bottom Line Burden and Cost
Tables 6.6 summarizes the total annual respondent burden which is 4,080 hours per year and $198,000 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 35 (34 state agencies and 1 group of FLMs.)

Table 6.6  Estimated Annual Respondent Burden to Implement Requirements
Task Element
                                    States
                                     FLMs

Average Annual Hours
Average Annual Cost ($)
Average Annual  Hours
Average Annual Cost ($)
Develop and submit §308(g) or 309(d)(10) Implementation Plan  -  5-year periodic reports
3,173

Calculation:
(280 hours per plan x 34 plans)/3 years=
3,173 hr/yr
154,049

Calculation:
(3,173 hrs per yr x labor rate of $48.55)
0
0
Review and Comment on Reports
0
0
907

Calculation:
(80 hours per plan x 34 plans)/3 years=
907 hr/yr
44,035

Calculation:
(907 hrs per yr x labor rate of $48.55) 
Total Burden by Respondent
3,173
154,049
907
44,035
Total for Respondent Universe
4,080 hours; $198,084
 

6.6	Reasons for Change in Burden
The burden estimates for this ICR renewal period cover different task elements than those for the previous renewal (1813.07). These differences reflect the requirements of the final regional haze rule with respect to the scheduled events and activities in the implementation process.
6.7	Burden Statement
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; adjusting the existing ways to comply with any previously applicable instructions and requirements; training personnel to be able to respond to a collection of information; searching data sources; completing and reviewing the collection of information; and transmitting or otherwise disclosing 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 the 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, the 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.
 
