1
SUPPORTING
STATEMENT
Emission
Reporting
Requirements
for
Ozone
SIP
Revisions
(
or
Associated
Federal
Implementation
Plans)
Relating
to
Statewide
Budgets
for
NOx
Emissions
to
Reduce
the
Regional
Transport
of
Ozone
EPA
ICR
#
1857.02
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
"
Emission
Reporting
Requirements
for
Ozone
State
Implementation
Plan
(
SIP)
Revisions
(
or
Associated
Federal
Implementation
Plans)
Relating
to
Statewide
Budgets
for
NOx
Emissions
to
Reduce
Regional
Transport
of
Ozone."

1(
b)
Short
Characterization/
Abstract
This
Information
Collection
Request
(
ICR)
addresses
the
labor
hour
burden
and
costs
of
State
reporting
requirements
under
§
51.122
contained
in
the
U.
S.
Environmental
Protection
Agency's
(
EPA)
rule
to
control
regional
transport
of
ozone
season
NOx
emissions
contributing
to
exceedances
of
the
ozone
National
Ambient
Air
Quality
Standard
(
NAAQS)
in
the
eastern
United
States.
The
reporting
requirements
of
this
rule
under
§
51.122
are
imposed
directly
on
the
States,
not
on
industry.
However,
in
order
to
meet
the
requirements
of
this
rule,
States
will
of
necessity
have
to
impose
requirements
on
industry
for
installation
of
continuous
emission
monitors
and
for
recordkeeping
and
reporting.
Therefore,
there
will
be
an
indirect
record
keeping
and
reporting
burden
on
industry
as
a
result
of
this
rule.
This
ICR
estimates
the
burden
hours
and
costs
incurred
by
industry
as
a
result
of
reporting
requirements
of
the
rule.
The
rule
does
not
require
an
emissions
trading
program,
but
it
strongly
encourages
such
a
trading
program,
and
it
is
anticipated
that
every
State
will
adopt
a
trading
program
for
fossil
fuel­
fired
NOx
sources
serving
electrical
generators
with
a
nameplate
capacity
greater
than
25
MW
or
boilers,
combustion
turbines
or
combined
cycle
units
with
maximum
design
heat
input
greater
than
250
mm
BTU/
hr.
For
this
ICR,
it
is
assumed
that
each
State
will
adopt
the
Federal
model
trading
program,
and
the
burden
associated
with
such
a
program
is
evaluated.
This
trading
program
burden
would
include
the
paper
work
burden
related
to
(
1)
transferring
and
tracking
allowances;
(
2)
the
allocation
of
allowances
to
affected
units;
(
3)
permitting;
(
4)
annual
year
end
compliance
certification;
and
(
5)
meeting
the
monitoring
and
reporting
requirements
of
the
program.
The
1For
the
remainder
of
this
supporting
statement,
reference
to
"
State(
s)"
includes
the
District
of
Columbia
for
a
total
of
22
"
States".

2
monitoring
and
reporting
requirements
of
a
trading
program
will
require
capital
and
labor
expenditures
by
industry,
and
these
are
evaluated.
Reporting
requirements
under
the
trading
program
can
often
be
used
to
satisfy
the
§
51.122
reporting
requirements,
but
other
requirements
of
the
trading
program
are
specific
to
the
trading
program
and
will
often
be
discussed
here
under
separate
headings.

The
options
reported
here
are
consistent
with
the
set
of
assumptions
used
to
develop
the
budgets
for
the
NOx
SIP
call.
However,
there
is
no
certainty
that
these
options
are
what
a
particular
State
will
adopt
since
States
have
flexibility
to
adopt
different
measures
to
meet
their
budget.

The
reporting
requirements
were
first
proposed
in
the
EPA's
supplemental
notice
of
proposed
rulemaking
(
SNPR),
May
11,
1998
(
63
FR
25901).
The
final
NOx
SIP
call
rule
was
issued
by
EPA
on
October
27,
1998
(
63
FR
57356).
Eight
states
challenged
the
rule
and
asked
the
U.
S.
Court
of
Appeals
for
the
D.
C.
Circuit
to
stay
the
due
date
for
the
State
plans.
As
an
interim
measure,
the
Court
issued
an
indefinite
stay
on
May
25,
1999.
On
March
3,
2000
the
Court
issued
an
opinion
largely
upholding
the
NOx
SIP
call,
however
the
Court
did
not
lift
the
stay
until
June
22,
2000.

The
original
rule
established
statewide
ozone
season
NOx
emissions
budgets
for
22
States
and
the
District
of
Columbia.
The
March
3,
2000
U.
S.
Court
of
Appeals
ruling
vacated
the
rule
for
Wisconsin,
therefore
this
analysis
is
done
for
21
States
plus
the
District
of
Columbia.
1
The
NOx
budgets
for
the
22
States
were
developed
based
in
part
on
the
recommendations
of
the
Ozone
Transport
Assessment
Group
(
OTAG).
The
22
States
were
required
to
achieve
their
NOx
emissions
budgets
by
2007.
The
EPA
is
anticipating
that
each
State
will
adopt
control
measures
and
implement
controls
on
large
stationary
NOx
emission
sources
by
2003.
Many
of
these
sources
may
need
to
install
and
operate
continuous
emissions
monitoring
systems
(
CEMS)
in
order
to
monitor
NOx
mass
emissions
if
they
are
not
already
equipped
with
these
systems.
Starting
in
2003
(
for
the
year
2002),
States
will
be
required
to
electronically
report
data
to
EPA
to
demonstrate
progress
towards
meeting
their
NOx
budgets
by
2007,
and
subsequently
maintain
compliance
with
their
budgets
after
2007.
The
EPA
will
use
the
data
reported
by
each
State
to
verify
the
State's
progress
toward
meeting
its
NOx
budget.
The
NOx
emission
reporting
requirements
are
provided
in
§
51.122
of
the
final
rule.

States
are
required
to
report
data
annually
for
those
point,
area,
nonroad
mobile,
and
highway
mobile
sources
for
which
they
adopt
control
measures
to
meet
their
NOx
emissions
budgets.
These
annual
reports
must
include
ozone
season
NOx
emission
inventories.
States
must
report
a
statewide
inventory
of
all
NOx
sources
every
3
years
starting
in
the
year
2003
for
the
2002
inventory,
and
must
also
report
in
2008
for
the
2007
compliance
demonstration
inventory.
While
the
States
are
expected
to
use
their
existing
emission
inventory
data
collection
and
electronic
reporting
mechanisms
for
submitting
the
data
to
EPA,
some
modifications
will
be
necessary
to
account
for
the
reporting
of
ozone
season
3
emissions
data.
The
data
reports
may
be
provided
using
one
of
several
procedures,
including
submittal
in
Emission
Inventory
Improvement
Program/
Electronic
Data
Interchange
(
EIIP/
EDI)
format,
or
in
proprietary
format
based
on
the
EIIP
data
model.
The
EPA
will
allow
for
the
direct
reporting
of
point
source
data
from
sources
to
EPA
if
the
sources
are
subject
to
the
monitoring
and
reporting
provisions
of
Subpart
H
of
40
CFR
Part
75.

EPA
has
proposed
Federal
implementation
plans
(
FIPs)
that
may
be
needed
if
any
State
fails
to
revise
its
State
implementation
plan
(
SIP)
to
comply
with
the
nitrogen
oxides
(
NOx)
SIP
call.
The
FIPs
would
be
applicable
to
sources
of
emissions
of
nitrogen
oxides
located
within
any
State
that
is
listed
in
40
CFR
51.121
and
for
which
EPA
has
found
that
the
State
has:

(
1)
Failed
to
submit
the
State
implementation
plan
revision
required
by
40
CFR
51.121;
(
2)
Failed
to
submit
such
a
plan
revision
meeting
the
minimum
criteria
in
40
CFR
51.103
and
Appendix
V
of
part
51;
or
(
3)
Submitted
a
plan
revision
that
EPA
has
disapproved
as
not
meeting
the
requirements
of
40
CFR
51.121.

In
these
cases,
the
FIP
will
impose
essentially
the
same
reporting
burden
on
affected
sources
as
would
be
required
by
the
NOx
SIP
call.
The
industry
burden
reported
in
this
ICR
will
be
essentially
the
same
whether
the
burden
is
a
result
of
the
NOx
SIP
call
or
of
FIPs.
The
industry
sources
will
be
required
to
comply
with
reporting
requirements
imposed
either
by
the
State
as
a
result
of
the
NOx
SIP
call
or
imposed
by
the
EPA
through
a
FIP.
Before
EPA
proposed
the
FIP
rule
(
see
"
Federal
Implementation
Plans
to
Reduce
the
Regional
Transport
of
Ozone;
Proposed
Rule,"
October
21,
1998
[
63
FR
56394]),
EPA
prepared
an
Information
Collection
Request
(
ICR)
document
(
ICR
No.
1883.01)
titled
"
Draft
Information
Collection
Request
for
a
Federal
Implementation
Plan
to
Reduce
the
Regional
Transport
of
Ozone"
which
was
submitted
to
the
Office
of
Management
and
Budget
and
was
made
available
on
the
internet
at
http://
www.
epa.
gov/
icr.
The
burden
calculated
in
that
FIP
ICR
has
been
incorporated
into
this
current
ICR,
and
this
ICR
will
serve
as
the
ICR
for
both
the
NOx
SIP
call
and
the
FIP.
This
is
appropriate
because
to
do
otherwise
could
result
in
double
counting
of
the
burden,
since
sources
will
be
subject
to
either
the
NOx
SIP
call
or
a
FIP
and
will
incur
approximately
the
same
record
keeping
and
reporting
burden
in
either
case.
If
all
States
comply
with
the
NOx
SIP
call
requirements,
there
will
be
no
FIPs,
and
all
the
burden
reported
in
this
ICR
will
result
from
the
NOx
SIP
call.

Emissions
Trading
Program
The
ability
to
buy
and
sell
(
or
transfer)
allowances
is
expected
to
provide
substantial
economic
benefits,
by
encouraging
the
greatest
emissions
reductions
where
costs
of
reductions
are
lowest.
This
concept
of
allowance
transfers
cannot
be
implemented,
however,
unless
regulations
governing
emissions
monitoring
and
permitting
of
sources
are
in
place
as
well.
To
ensure
compliance
with
the
emissions
reduction
requirements
and
to
provide
the
regionwide
consistency
needed
to
foster
the
allowance
4
market,
the
designated
representative
of
the
owners
and
operators
of
each
source
with
affected
units
will
be
required
to
obtain
an
operating
permit
for
the
affected
source
and
to
certify
that
an
approved
emissions
monitoring
system
has
been
installed
and
is
properly
operated
at
each
affected
unit's
source
of
emissions.

While
compliance
is
not
mandatory
until
2002,
the
Agency
estimates
that
one­
third
of
the
coalfired
units
subject
to
the
program
will
choose
to
come
into
compliance
before
2002.
These
early
election
units
will
record
baseline
emissions
in
2000
and
begin
the
allowance
trading
and
banking
program
in
2001.

(
i)
Allowance
Allocations
For
existing
units,
information
for
the
allocation
process
will
be
recorded
and
collected
as
part
of
the
emissions
monitoring
and
reporting
process.
The
allocation
system
is
an
input
based
system
that
uses
information
that
is
already
needed
for
purposes
of
calculating
NOx
mass.
New
units
will
have
to
submit
projected
information
to
determine
allowance
allocations.

(
ii)
Permits
Permit
applicants
are
required
to
submit
a
permit
application
for
each
affected
source.
Because
most
sources
regulated
under
the
NOx
Trading
Program
will
have
existing
permits
under
Title
V,
a
permit
revision
is
all
that
will
be
necessary.
Some
sources
will
also
need
to
obtain
permits
to
construct
necessary
facilities.

(
iii)
Capital/
Start­
up
Costs
While
many
sources
have
already
installed
necessary
emissions
monitoring
equipment
due
to
requirements
under
other
regulations,
some
sources
will
need
to
either
install
new
monitors
or
upgrade
existing
monitors.
Capital
costs
also
usually
include
the
cost
of
initial
certification
of
new
or
upgraded
monitors
is
included
as
part
of
start­
up
costs.

(
iv)
Emissions
Monitoring
Emissions
monitoring
and
reporting
is
the
foundation
upon
which
the
allowance
trading
system
is
based.
EPA
will
use
the
data
contained
in
the
reports
to
verify
actual
emissions.
Without
accurate
monitoring
and
reporting
of
emissions,
the
integrity
of
the
allowance
system
would
be
undermined,
and
there
would
be
no
assurance
that
emissions
had
been
reduced.
To
meet
the
emissions
monitoring,
recordkeeping
and
reporting
requirements,
affected
units
are
required
to
(
1)
submit
a
monitoring
plan
and
certification
reports
for
each
monitoring
system,
(
2)
record
hourly
emissions
data,
and
(
3)
submit
reports
of
their
emissions
data
to
EPA.
5
(
v)
Year­
end
Compliance
Certifications
Each
source
is
required
to
submit
an
annual
statement
providing
information
on
which
allowances
are
to
be
deducted
and
certifying
that
the
unit
is
in
compliance
with
emission
limitations
and
monitoring
and
reporting
requirements.

(
vi)
Allowance
Transfers
and
Tracking
All
participants
in
the
allowance
transfer
system
will
be
required
to
complete
and
submit
an
allowance
transfer
form
for
each
allowance
transfer.
Participants
in
the
transfer
system
that
are
not
affected
sources,
such
as
allowance
brokers,
fuel
suppliers
and
environmental
groups
will
also
be
required
to
file
a
one
time
account
information
application
to
establish
an
account
in
the
Allowance
Tracking
System
(
ATS).

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
The
State
reporting
requirements
included
in
the
final
rule
are
necessary
for
EPA
to
carry
out
properly
its
evaluation
of
each
State's
compliance
with
its
ozone
season
NOx
emissions
budget.
The
legal
authority
for
the
reporting
requirements
resides
in
Sections
110(
a)
and
301(
a)
of
the
Clean
Air
Act.
Specifically,
the
requirement
in
Section
110(
a)(
2)(
D)
that
SIPs
include
"
adequate
provisions"
to
mitigate
certain
transport
effects
on
other
States
implicitly
authorizes
emissions
inventory
reporting
to
EPA,
as
needed
and
appropriate
to
verify
that
a
State
is
in
fact
meeting
its
NOx
budget.
Section
110(
a)(
2)(
F)
provides
additional
authority
for
requiring
that
SIP
call
submissions
include
provisions
for
emissions
reporting
by
sources
to
a
State,
correlation
of
source
information
by
the
State,
and
steps
by
the
State
to
make
the
correlated
information
available
to
the
public.
Section
110(
a)(
2)(
K),
in
turn,
requires
a
State
to
submit
to
EPA
as
requested
data
related
to
modeling
the
effect
of
NOx
and
other
emissions
on
ambient
air
quality.
The
reported
emissions
inventory
data
described
in
this
section
will
be
used
by
EPA
in
air
quality
modeling
to
assess
the
effectiveness
of
the
transport
rulemaking's
regional
strategy.
Finally,
Section
301(
a)
grants
EPA
broad
authority
to
prescribe
such
regulations
as
are
necessary
to
carry
out
its
functions
under
the
Clean
Air
Act.

2(
b)
Practical
Utility/
Users
of
the
Data
The
EPA
believes
it
is
essential
that
compliance
with
the
regional
control
strategy
be
verified.
Tracking
emissions
is
the
principal
mechanism
to
ensure
compliance
with
the
budget
and
to
assure
the
downwind
affected
States
and
EPA
that
the
ozone
transport
problem
is
being
mitigated.
6
If
tracking
and
periodic
reports
indicate
that
a
State
is
not
implementing
all
of
its
NOx
control
measures
beginning
in
2003
or
is
off
track
to
meet
its
statewide
budget
by
2007,
EPA
will
work
with
the
State
to
determine
the
reasons
for
noncompliance
and
what
course
of
remedial
action
is
needed.
The
EPA
will
expect
the
State
to
submit
a
plan
showing
what
steps
it
will
take
to
correct
the
problems.
Noncompliance
with
the
NOx
transport
SIP
may
lead
EPA
to
make
a
finding
of
failure
to
implement
the
SIP
and
potentially
to
implement
sanctions,
if
the
State
does
not
take
corrective
action
within
a
specified
time
period.

The
EPA
will
use
data
from
the
2007
inventory
and
beyond
to
assess
how
each
State's
SIP
actually
performed
in
meeting
the
statewide
ozone
season
NOx
emissions
budget.
If
emissions
exceed
the
required
budget
in
any
year
after
2006,
the
control
strategies
in
the
SIP
will
need
to
be
strengthened.
The
EPA
will
evaluate
the
circumstances
for
the
budget
failure
and
may
issue
a
call
for
States
to
revise
their
SIPs,
as
appropriate.

Emissions
Trading
Program
(
i)
Permits
Permit
applications,
including
proposed
compliance
plans,
will
be
used
by
EPA
to
issue
operating
permits
and
to
allocate
allowances.
A
permit
application
will
be
legally
binding
on
the
owners,
operators,
and
designated
representative
of
a
source
until
the
actual
permit
is
issued.
This
aspect
of
the
permit
application
reduces
significantly
the
uncertainty
imposed
on
a
source
due
to
possible
delays
at
EPA.
Affected
sources
may
rely
on
the
permit
for
information
on
the
requirements
with
which
they
must
comply.
Because
permit
applications
and
permits
will
be
public
documents,
they
may
be
used
by
the
public
to
examine
activities
undertaken
by
affected
sources.

(
ii)
Emissions
Monitoring
Data
from
emissions
monitoring
is
indispensable
to
successful
implementation
of
the
NOx
Trading
Program
for
two
reasons:

°
The
primary
purpose
of
the
NOx
Trading
Program
is
to
assist
States
in
the
attainment
of
the
ozone
national
ambient
air
quality
standards
(
NAAQS)
by
reducing
the
adverse
effects
of
the
transport
of
ozone
and
ozone
precursors
from
upwind
States
by
reducing
annual
emissions
of
nitrogen
oxides;
and
°
EPA
can
only
enforce
the
program
by
comparing,
for
each
affected
unit,
emissions
data
and
the
number
of
allowances
held.
7
(
iii)
Year­
end
Compliance
Certification
This
information
will
be
used
by
EPA
to
determine
annual
compliance
and
to
verify
that
the
monitoring
plan
for
the
unit
continues
to
be
accurate.

(
iv)
Allowance
Transfers
and
Tracking
Information
collected
on
allowance
transfers
will
be
used
by
EPA
or
its
designated
agent
to
track
allowances
for
the
purpose
of
determining
compliance
with
the
NOx
Trading
Program.
Information
on
allowance
transfers
will
also
be
used
by
participants
in
the
allowance
market
and
the
public
to
evaluate
the
activities
of
affected
sources,
and
by
EPA
for
program
evaluation.

Together,
the
allowance
trading
system,
operating
permits,
and
emissions
data
will
help
to
provide
the
accountability
to
allow
the
NOx
Trading
Program
to
function
without
more
stringent
command
and
control
approaches.

3.
NONDUPLICATION,
CONSULTATIONS
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
To
minimize
the
reporting
burden
on
State
agencies,
the
reporting
requirements
for
the
final
rule
are
based
on
existing
annual
and
periodic
emission
inventory
reporting
requirements
as
much
as
possible.
However,
since
these
requirements
are
being
established
to
support
an
ozone
season
reduction
program
and
since
existing
provisions
do
not
require
the
collection
of
ozone
season
inventories,
some
additional
reporting
will
be
required.
The
EPA
requires
that
States
report
annually
data
for
all
point
sources
that
are
part
of
a
control
measure
that
was
adopted
for
purposes
of
meeting
the
NOx
budget.
If
States
act
in
accordance
with
OTAG
recommendations
for
setting
the
emissions
budgets,
the
sources
controlled
will
all
be
point
sources
emitting
$
100
tons
per
year
(
tpy)
of
NOx.
The
100
tpy
threshold
is
consistent
with
the
NOx
reporting
threshold
for
the
existing
annual
emission
inventory.
However,
the
rule
does
allow
States
the
option
of
defining
the
NOx
point
source
threshold
to
be
less
than
100
tpy.

The
EPA
will
allow
the
direct
reporting
of
point
source
data
from
sources
to
EPA
to
satisfy
this
requirement
if
the
sources
are
subject
to
the
monitoring
and
reporting
requirements
of
Subpart
H
of
40
CFR
Part
75.
The
direct
reporting
of
data
from
sources
to
EPA
will
minimize
the
reporting
burden
on
States.
Also,
direct
reporting
will
avoid
duplication
of
effort
for
sources
subject
to
the
Part
75
requirements.
8
Currently,
there
are
no
existing
annual
reporting
requirements
for
area,
nonroad
mobile,
and
highway
mobile
source
emissions.
For
the
purposes
of
the
final
rule,
an
area
source
is
any
anthropogenic
source
that
is
not
included
in
the
point,
nonroad
mobile,
or
highway
mobile
source
inventories.
The
EPA
requires
that
the
State
report
annually
area
source
NOx
emissions
for
only
those
stationary
area
source
categories
for
which
the
State
adopts
control
measures
for
the
purpose
of
meeting
its
NOx
budget.
For
nonroad
mobile
and
highway
mobile
sources,
the
EPA
requires
that
the
State
report
annually
NOx
emissions
for
only
those
source
categories
for
which
the
State
adopts
control
measures
that
are
more
stringent
than
Federal
measures
for
the
purpose
of
meeting
its
NOx
budget.
Based
on
the
recommendations
of
OTAG,
it
is
not
expected
that
States
will
adopt
area,
nonroad
mobile,
or
highway
mobile
source
control
measures
to
meet
their
NOx
budgets.
However,
if
one
or
more
States
do
adopt
such
measures,
annual
reporting
of
emissions
will
be
necessary
to
track
the
States'
progress
toward
meeting
their
NOx
budgets.

The
rule
contains
a
requirement
for
States
to
report
statewide
point,
area,
nonroad
mobile,
and
highway
mobile
source
NOx
emissions
data
every
3
years
starting
with
the
inventory
year
2002.
The
data
reported
would
be
ozone
season
emissions
data
for
each
third
year
and
would
include
data
from
all
source
categories
in
the
State
regardless
of
whether
sources
are
being
controlled
to
meet
a
NOx
budget.
This
3­
year
cycle
reporting
requirement
coincides
with
the
schedule
for
the
existing
periodic
emission
inventory
reporting
requirement
for
the
States.

The
EPA
requires
that
in
2007,
States
submit
to
EPA
statewide
ozone
season
NOx
emissions
data
from
all
NOx
sources
(
point,
area,
nonroad
mobile,
and
highway
mobile)
within
the
State.
The
data
reporting
requirements
are
identical
to
the
reporting
requirements
for
the
3­
year
cycle
inventory,
but
would
occur
1
year
prior
to
the
next
3­
year
cycle
inventory.
This
one­
time
reporting
requirement
for
a
2007
statewide
inventory
will
allow
evaluation
of
whether
the
NOx
budgets
are
met
for
2007.
However,
EPA
will
work
with
the
States
to
minimize
the
incremental
burden
associated
with
preparing
a
2007
and
a
2008
statewide
inventory.
The
incremental
burden
is
associated
with
the
area
and
mobile
source
inventories
since
States
must
report
point
source
data
annually.
For
area,
nonroad
mobile,
and
highway
mobile
source
data,
States
may
project
incremental
changes
in
emissions
from
2007
to
2008
to
allow
the
2008
inventory
requirement
to
be
more
easily
met
and
to
reduce
the
burden
on
the
States.

Emissions
Trading
Program
Almost
all
information
requested
from
respondents
under
this
proposed
ICR
is
not
available
from
other
sources.
Where
EPA
needs
information
that
has
already
been
submitted,
EPA
is
simply
requiring
a
photocopy
of
the
prior
submittal
or
the
retransmission
of
stored
electronic
data.
In
addition,
EPA
intends
to
integrate
the
reporting
requirements
for
the
NOx
Trading
Program
into
existing
electronic
data
reporting
(
EDR)
formats.
The
EDR
formats
are
used
by
Acid
Rain
Program
units
under
Title
IV
of
the
Act
and
units
subject
to
the
NOx
Budget
Program
implemented
in
the
Ozone
Transport
Commission
(
OTC)
region
under
Title
I
of
the
Act.
Thus,
for
units
subject
to
the
Acid
Rain
or
OTC
quarterly
reporting
requirements,
only
one
submission
will
need
to
be
made
on
a
quarterly
basis.
9
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
The
NOx
SIP
call
ICR
is
for
a
rule
related
collection.
The
related
FIP
ICR
proposal,
which
has
been
incorporated
into
the
NOx
SIP
call,
is
also
for
a
rule
related
collection.
Therefore,
the
requirement
to
solicit
public
comments
for
a
60­
day
period
prior
to
submitting
the
ICR
to
OMB
does
not
apply.

For
the
NOx
SIP
call,
the
SNPR
was
signed
by
the
EPA
Administrator
on
April
28,
1998.
The
Federal
Register
notice,
announcing
the
SNPR
and
ICR,
was
published
on
May
11,
1998.
All
comments
received
on
the
reporting
rule
§
51.122
during
the
public
comment
period
were
considered
by
EPA,
and
some
revisions
were
made
to
reporting
requirements
in
the
final
rule
in
response
to
comments.
The
only
comments
received
on
the
proposal
NOx
SIP
call
ICR
were
those
from
OMB.

The
proposal
notice
for
the
FIP,
Federal
Implementation
Plans
To
Reduce
the
Regional
Transport
of
Ozone,
was
published
on
October
21,
1998
(
63
FR
56394).
This
notice
announced
the
availability
of
an
ICR
document
(
ICR
No.
1883.01).
The
availability
of
the
document
was
announced
along
with
an
internet
site
(
http://
www.
epa.
gov/
icr)
where
it
could
be
downloaded.
No
comments
were
received
on
the
proposed
FIP
ICR.

The
NOx
SIP
call
proposal
ICR
contained
only
consideration
of
the
burden
by
the
State
to
report
to
EPA
under
§
51.122.
The
proposal
did
not
include
burden
to
industry
to
collect
data
or
the
burden
of
participating
in
an
emissions
trading
program.
In
response
to
comments
by
OMB,
these
burdens
have
been
added
to
the
ICR
by
incorporating
the
burden
to
operate
an
emission
trading
program
in
the
affected
states
which
was
reported
in
the
FIP
ICR
proposal
as
discussed
in
section
1(
b).
In
addition,
burden
for
data
collection
and
reporting
for
cement
kilns
and
I.
C.
engines
were
added.

3(
c)
Consultations
On
January
13,
1998,
EPA
held
a
one­
day
pre­
proposal
workshop
with
the
States
to
discuss
tracking
issues.
The
objective
of
the
workshop
was
to
determine
what
type
and
frequency
of
inventory
reporting
is
feasible
for
the
different
source
sectors
(
power
generating
sources,
other
point
sources,
area
sources,
nonroad
mobile,
and
highway
mobile
sources),
to
identify
key
reporting
issues
related
to
each
sector,
and
to
develop
recommendations
on
reporting
requirements
to
ensure
compliance
with
the
NOx
budgets.
The
goal
was
to
share
information
and
ideas
rather
than
to
reach
consensus.
A
summary
of
the
meeting
is
contained
in
the
docket
(
docket
no.
A­
96­
56,
item
V­
B­
18)
for
this
rulemaking.

The
workshop
participants
generally
thought
that
existing
reporting
requirements
for
attainment
SIPs
should
be
used
whenever
possible
to
minimize
any
new
reporting
burden.
The
States
further
recommended
that
the
degree
of
reporting
rigor
should
be
directly
related
to
the
sectors
that
the
State
chooses
to
control
in
its
NOx
transport
strategy.
Reporting
every
3
years
was
considered
feasible
for
10
all
source
sectors.
Reporting
on
an
annual
basis
was
considered
both
achievable
and
necessary
for
all
source
sectors
that
a
State
chooses
to
regulate
specifically
for
the
purpose
of
meeting
the
SIP
call
NOx
budgets.
This
would
include
all
NOx
sources
within
the
State
which
are
subject
to
measures
included
by
the
State
in
its
transport
SIP
revision
in
response
to
the
SIP
call.
In
addition,
it
was
noted
that
sources
or
source
categories
that
would
be
participating
in
a
trading
program
would
need
to
meet
the
reporting
protocols
specific
to
that
program.
Consideration
was
also
given
to
establishing
uniform
monitoring
and
reporting
requirements
and
a
centralized
data
base
for
reporting
for
other
sources.
Several
States
indicated
support
for
this
concept
if
there
were
easy
access
to
the
data
by
all
parties.
The
reporting
requirements
included
in
the
proposed
and
final
rule
are
based,
in
part,
on
the
suggestions
of
participants
in
the
workshop.

Emissions
Trading
Program
The
requirements
for
the
NOx
Trading
Program
have
been
developed
using
both
the
methodology
found
in
existing
trading
programs
as
well
as
consultations
with
interested
parties.

EPA
considered
the
strategy
taken
in
the
OTC's
NOx
Budget
Program,
a
trading
program
developed
for
use
in
eleven
States
and
the
District
of
Columbia.
EPA
also
considered
the
results
of
the
findings
of
the
Ozone
Transport
Assessment
Group
(
OTAG),
especially
OTAG's
Trading
and
Incentives
Workgroup.
Members
of
OTAG
include
37
States,
the
District
of
Columbia,
EPA,
and
industry
and
environmental
group
participants.
OTAG
conducted
meetings
in
1995
and
issued
final
recommendations
in
1997
concerning
ozone
transport.
EPA
also
considered
the
work
of
the
RECLAIM
program,
another
cap­
and­
trade
market
based
system.

Prior
to
proposing
the
ICR
for
the
FIP
rule,
EPA
also
held
two
public
workshops
in
1997,
lasting
two
days
each.
Over
150
people
participated
in
each
of
these
workshops,
including
States
and
industry
representatives.
EPA
received
comments
following
the
workshops
and
considered
and
incorporated
those
comments
into
the
proposed
ICR
along
with
comments
received
during
the
meetings.

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

3(
d)
Effects
of
Less
Frequent
Collection
If
this
information
collection
were
not
carried
out
annually
for
sources
being
controlled
to
meet
the
NOx
budgets,
EPA
would
not
be
able
to
verify
that
NOx
emission
reductions
necessary
to
meet
each
State's
NOx
emission
budget
were
being
achieved.
In
addition,
a
triennial
report
of
all
NOx
sources
11
statewide
is
vital
in
enabling
EPA
to
track
States'
progress
towards
meeting
the
NOx
budgets.
Because
the
NOx
budgets
prescribed
have
been
deemed
essential
in
order
for
downwind
States
to
attain
the
NAAQS
in
a
timely
manner,
data
collected
less
frequently
would
be
of
little
or
no
use.

Emissions
Trading
Program
Submittal
of
allowance
trading
information
and
compliance
information
on
an
annual
basis
provides
necessary
feedback
on
the
allocation
of
allowances.
If
this
information
collection
were
not
carried
out
annually
for
sources
being
controlled
to
meet
the
NOx
budgets,
EPA
would
not
be
able
to
verify
that
NOx
emission
reductions
necessary
to
meet
each
State's
NOx
emission
budget
were
being
achieved.
Because
the
NOx
budgets
prescribed
have
been
deemed
essential
in
order
for
downwind
States
to
attain
the
NAAQS
in
a
timely
manner,
data
collected
less
frequently
would
be
of
little
or
no
use.

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

As
an
option
for
this
program,
EPA
will
allow
for
ozone
season
reporting
instead
of
quarterly
reports
for
the
entire
calendar
year.
Under
this
option,
units
would
only
be
required
to
submit
two
reports
per
year
(
covering
the
second
and
third
calendar
quarters).
However,
because
the
Agency
believes
that
full­
year
quarterly
reporting
will
be
beneficial
for
both
the
source
and
the
Agency,
this
ICR
assumes
all
units
will
elect
to
comply
with
the
standard
quarterly
reporting
requirement.

3(
e)
General
Guidelines
This
ICR
does
not
violate
any
of
OMB's
guidelines
for
information
collections.

3(
f)
Confidentiality
As
required
by
Section
114
of
the
Clean
Air
Act,
estimates
or
measurements
of
emissions
must
be
treated
as
nonconfidential.
Under
Agency
procedures,
data
items
relating
to
the
computation
of
emissions
may
be
identified
as
sensitive
by
a
State
and
are
then
treated
as
"
State­
sensitive"
by
EPA.
The
potentially
State­
sensitive
items
include
the
following:
Process
rate,
boiler
design
capacity,
emission
estimation
codes,
percent
space
heat,
operating
rate,
and
maximum
operation
rate/
hour.
Where
Federal
and
State
requirements
are
inconsistent,
EPA
Regional
Office
should
be
consulted
for
final
reconciliation.
2
The
U.
S.
Court
of
Appeals
decision
of
March
3,
2000
vacated
the
rule
for
Wisconsin.

12
3(
g)
Sensitive
Questions
Not
applicable.
This
information
collection
does
not
ask
any
questions
concerning
sexual
behavior
or
attitudes,
religious
beliefs,
or
other
matters
usually
considered
private.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
SIC
Codes
The
reports
submitted
under
this
ICR
will
be
submitted
by
the
State
air
pollution
control
agencies
for
which
NOx
budgets
will
be
established,
which
include
the
following
21
States
and
the
District
of
Columbia:
Alabama,
Connecticut,
Delaware,
Georgia,
Illinois,
Indiana,
Kentucky,
Massachusetts,
Maryland,
Michigan,
Missouri,
North
Carolina,
New
Jersey,
New
York,
Ohio,
Pennsylvania,
Rhode
Island,
South
Carolina,
Tennessee,
Virginia,
and
West
Virginia.
2
The
affected
SIC
would
be
9511
­
Air
and
Water
Resource
and
Solid
Waste
Management,
which
includes
government
environmental
protection
and
control
agencies,
as
well
as
pollution
control
agencies.

This
ICR
also
estimates
a
burden
for
affected
industry
sources
to
monitor
NOx
mass
emissions
and
demonstrate
compliance
with
NOx
control
measures.
Sources
may
report
data
directly
to
EPA
if
a
source
is
required
to
meet
the
monitoring
and
reporting
requirements
of
Subpart
H
of
Part
75.
If
the
OTAG
recommendations
are
followed,
States
will
control
larger
electric
utility
and
industrial
combustion
point
sources
to
comply
with
their
NOx
emissions
budgets
for
2007.
Electric
utility
combustion
sources
are
generally
classified
as
either
SIC
4911
­
Electric
Services,
or
4931
­
Electric
and
Other
Services
Combined.
States
must
decide
which
sources
to
control
for
the
purpose
of
meeting
their
NOx
budgets.
Thus,
at
this
time,
it
is
not
possible
to
determine
the
SIC
codes
for
the
industrial
combustion
sources
that
will
potentially
be
controlled
by
the
States.
Large
industrial
combustion
sources
(
e.
g.,
boilers,
turbines,
and
internal
combustion
engines)
are
expected
to
fall
under
SIC
codes
for
the
manufacturing
sector,
i.
e.,
SIC
Major
Groups
29­
40.
In
addition,
States
have
the
option
of
controlling
area,
nonroad
mobile,
and
highway
mobile
NOx
sources
for
meeting
their
NOx
budgets.
However,
based
on
OTAG's
recommendations,
it
is
unlikely
that
States
will
adopt
area,
nonroad
mobile,
or
highway
mobile
source
control
measures
to
meet
their
NOx
budgets.
The
Agency's
action
eventually
will
also
impose
additional,
non­
trading
program
requirements
on
internal
combustion
engines
(
potentially
applicable
in
a
variety
of
industries,
with
significant
number
in
SIC
492
­
Gas
Production
and
Distribution)
and
cement
kilns
(
primarily
SIC
327
­
Concrete,
Gypsum,
and
Plaster
Products).
13
4(
b)
Information
Requested
This
section
describes
State
reporting
and
recordkeeping
requirements
and
the
activities
(
i.
e.,
burden
items)
associated
with
the
requirements
in
§
51.122.
States
must
report
NOx
emissions
data
as
specified
in
§
51.122
of
the
final
rule.
States
are
required
to
submit
the
appropriate
emissions
data
within
12
months
of
the
end
of
the
inventory
year
(
e.
g.,
a
statewide
NOx
emissions
inventory
for
the
year
2005
would
be
required
by
December
of
2006).
The
activities
that
an
affected
source
would
have
to
conduct
are
also
listed.

(
i)
Data
items,
including
recordkeeping
requirements
Reporting
requirements
Many
of
the
required
emissions
data
elements
are
already
being
provided
to
the
EPA
under
existing
annual
point
source
reporting
requirements,
as
well
as
periodic
SIP
inventory
reporting
provisions
for
point,
area
and
nonroad
mobile,
and
highway
mobile
sources.
The
following
lists
the
data
items
required
for
point,
area,
nonroad
mobile,
and
highway
mobile
sources,
and
identifies
new
data
items
not
required
to
be
included
in
emission
inventories
currently
reported
to
EPA.

Point
sources
For
NOx
point
sources
controlled
for
purposes
of
meeting
the
NOx
budgets,
States
must
annually
report
the
following
data
items,
unless
the
point
sources
are
reporting
directly
to
EPA
under
Subpart
H
of
40
CFR
Part
75.
The
new
data
items
are
identified
with
an
asterisk
(*).

Inventory
year
State
Federal
Information
Processing
System
(
FIPS)
code
County
FIPS
code
Federal
ID
code
(
plant)
Federal
ID
code
(
point)
Federal
ID
code
(
process)
Federal
ID
code
(
stack)
Site
name
Physical
address
Source
Classification
Code
(
SCC)
Pollutant
code
Work
weekday
emissions
Fuel
heat
content
(
annual)
Activity
throughput
(
annual)
Emission
factor
14
Spring/
Summer/
Fall
throughput
(%)
Hour/
day
in
operation
Operations
start
time
(
hour)
Day/
week
in
operation
Week/
year
in
operation
Area
designation*
Ozone
season
emissions*
Fuel
heat
content
(
seasonal)*
Source
of
fuel
heat
content
data*
Activity
throughput
(
seasonal)*
Source
of
activity
throughput*
Source
of
emission
factor*

Additional
reporting
requirements
apply
every
3
years
(
triennially),
starting
for
the
inventory
year
2002,
and
for
the
year
2007.
For
these
years,
States
must
submit
a
statewide
NOx
point
source
inventory
for
all
controlled
and
uncontrolled
sources.
In
addition
to
the
data
items
required
for
annual
reporting,
the
following
elements
must
be
reported
to
EPA
triennially
and
for
2007:

Latitude/
longitude
Stack
height
Stack
diameter
Exit
gas
temperature
Exit
gas
velocity
Exit
gas
flow
rate
Standard
Industrial
Classification
(
SIC)
Boiler/
process
throughput
design
capacity
Maximum
design
rate
Maximum
capacity
Primary
control
efficiency
Secondary
control
efficiency
Control
device
type
Area
sources
The
following
lists
the
data
elements
States
must
report
annually
for
area
sources
controlled
for
the
purpose
of
meeting
the
NOx
budgets.
States
must
report
these
same
data
elements
for
all
area
sources
in
their
statewide
triennial
inventory,
starting
in
2002,
and
for
2007.
The
new
data
items
are
identified
with
an
asterisk
(*).

Inventory
year
State
FIPS
code
3For
highway
mobile
sources,
the
activity
is
expressed
as
VMT
by
roadway
class.

15
County
FIPS
code
SCC
Pollutant
code
Emission
factor
Activity
throughput
level
(
annual)
Control
efficiency
(%)
Spring/
Summer/
Fall
throughput
(%)
Hour/
day
in
operation
Day/
week
in
operation
Week/
year
in
operation
Ozone
season
emissions*
Source
of
emission
factor*
Activity
throughput
level
(
seasonal)*
Source
of
activity
throughput
data*
Source
of
emissions
data*

Highway
and
nonroad
mobile
sources
The
following
lists
the
data
elements
States
must
report
annually
for
highway
mobile
and
nonroad
mobile
sources
controlled
for
purposes
of
meeting
the
NOx
budgets.
States
are
required
to
report
annually
for
those
highway
and
nonroad
mobile
sources
covered
by
State­
adopted
regulations
that
are
more
stringent
than
Federal
standards.
States
must
report
these
same
data
elements
for
all
highway
and
nonroad
mobile
sources
in
their
statewide
triennial
inventory
starting
in
2002,
and
for
2007.
The
new
data
items
are
identified
with
an
asterisk
(*).

Inventory
Year
State
FIPS
Code
County
FIPS
Code
SCC
Pollutant
code
Summer
work
weekday
emissions
Emission
factor
Activity3
Ozone
season
emissions*
Source
of
emission
factor*
Source
of
activity
data*
Source
of
emissions
data*
16
Justification
for
additional
data
items
Ozone
season
emissions
are
emissions
for
the
period
May
1
through
September
30
of
a
year.
Emission
estimates
representing
this
period
are
required
in
order
to
demonstrate
that
the
reductions
required
by
the
final
rule
are
made
during
this
same
period.
The
EPA
is
also
requiring
States
to
provide
an
example
ozone
season
calculation,
along
with
sufficient
information
for
EPA
to
verify
the
calculated
value
of
ozone
season
emissions.
This
calculation,
as
well
as
two
additional
seasonal
data
elements
(
i.
e.,
fuel
heat
content
for
point
sources,
activity/
throughput
level),
will
facilitate
quality
assurance
review
of
the
seasonal
emissions
data.
Other
data
fields
for
providing
the
source
of
fuel
heat
content
data,
source
of
emissions
data,
source
of
emission
factor,
and
source
of
activity
throughput
data
will
also
assist
EPA
in
their
NOx
budget
verification
procedures.

The
EPA
is
also
requiring
the
"
Area
Designation"
element
so
that
States
that
establish
an
offset
pool
composed
of
actual
emission
reductions
achieved
through
compliance
with
the
SIP
call
NOx
budgets
can
track
whether
they
are
obtaining
creditable
offsets
as
specified
in
Section
173(
c)
of
the
Act
(
which
requires
that
major
sources
obtain
offsets
from
areas
with
equal
or
higher
nonattainment
classification).

Recordkeeping
requirements
The
final
rule
specifies
that
States
are
to
comply
with
existing
SIP
recordkeeping
and
data
availability
requirements
as
outlined
in
40
CFR
Part
51.116.
As
such,
there
are
no
recordkeeping
burden
items
that
are
incremental
to
existing
recordkeeping
requirements.

(
ii)
Respondent
activities
The
one­
time
State
burden
items
associated
with
this
ICR
include:

°
Prepare
SIP
revision
for
submission
to
EPA
in
response
to
the
NOx
SIP
call.

°
Read
the
reporting
requirements
of
the
rule;

°
Submit
example
ozone
season
emissions
calculations
to
EPA
[
§
51.122(
g)];

°
Create
7
additional
data
fields
in
electronic
point
source
data
base
file,
5
additional
data
fields
in
the
area
source
data
base
file,
and
4
additional
data
fields
in
each
of
the
nonroad
mobile
and
highway
mobile
source
electronic
data
base
files
for
new
data
items
[
§
51.122(
c),
(
d),
(
e)];

°
Develop
procedures
by
which
to
estimate
stationary
area
source
NOx
emissions
for
triennial
statewide
reporting
requirements
[
to
comply
with
§
51.122(
b)(
2),
(
3)];
4Typically,
the
initial
CEMS
certification
testing,
as
well
as
annual
relative
accuracy
testing,
are
performed
as
part
of
a
fixed
price
contract.
However,
for
the
purposes
of
this
analysis,
the
costs
to
perform
these
activities
are
presented
in
terms
of
labor
rates
applied
to
burden
hours.

17
°
Develop
allocation
for
estimating
county­
level
vehicle
miles
traveled
(
VMT)
from
Statelevel
VMT
data
[
to
comply
with
§
51.122(
b)(
2),
(
3)];

°
Project
2007
area,
nonroad
mobile,
and
highway
mobile
inventories
to
2008
to
satisfy
3­
year
cycle
requirement
[
§
51.122(
b)(
2),
(
3)];
and
°
Review
Title
V
permit
revisions
from
controlled
sources
[
§
51.121(
h)(
1)].

The
one­
time
industry
burden
items
associated
with
this
ICR
include:

°
Read
the
reporting
requirements
of
the
rule;

°
Revise
Title
V
permit
to
incorporate
NOx
monitoring
[
§
51.121(
h)(
1)];
and
°
Install
and
perform
testing
to
certify
NOx
CEMS
or
other
approved
monitoring
system
[
§
51.121(
h)(
1)].
4
Annual
State
burden
items
associated
with
this
ICR
include:

°
Determine
ozone
season
emissions
for
controlled
sources
[
§
51.122(
c)(
1),
(
2)];

°
Notify
the
appropriate
EPA
Regional
Office
when
submitting
an
annual,
triennial,
and
2007
NOx
inventory
[
§
51.122(
h)];
and
°
Submit
electronic
NOx
budget
emissions
report
[
§
51.122(
b)(
1)].

The
annual
burden
items
for
industry
associated
with
this
ICR
include:

°
For
units
subject
to
Title
IV
monitoring
requirements,
reporting
compliance
information
to
a
State
or
EPA
[
§
51.121(
h)(
1)].

°
For
units
not
already
subject
to
Title
IV
monitoring
requirements:

°
Perform
general
operations
and
maintenance
activities
(
e.
g.,
quality
assurance
testing,
calibrations,
cylinder
gas
audits)[
§
51.121(
h)(
1)];
and
18
°
Prepare
and
submit
reports
to
demonstrate
compliance,
including
update
of
monitoring
plan
[
§
51.121(
h)(
1)].

Triennial
State
burden
items
associated
with
this
ICR
include:

°
Prepare
statewide
inventory
for
area,
nonroad
mobile,
and
highway
mobile
sources,
including
a
determination
of
ozone
season
emissions
for
all
sources
[
§
51.122(
b)(
2)];
and
°
Compile
summary
report
of
statewide
NOx
emissions
for
submittal
to
EPA
[
§
51.122(
b)(
2),
(
h)].

There
are
no
triennial
industry
burden
items
associated
with
this
collection
in
addition
to
the
burdens
listed
above..

Emissions
Trading
Program
This
section
describes
the
data
items
requested
from
affected
sources
for
the
collections
described
in
this
ICR.
This
section
also
defines
the
activities
in
which
respondents
must
engage
to
assemble,
submit,
or
store
these
data
items.
Except
where
explicitly
noted
below,
these
requirements
apply
only
apply
to
the
trading
program
units,
not
the
non­
trading
units
(
internal
combustion
engines
and
cement
kilns).

(
i)
Data
Items,
Including
Recordkeeping
Requirements
(
a)
Allowance
Tracking
There
are
several
data
items
required
for
allowance
tracking
activities.
First,
the
utility
must
submit
account
certificates
of
representation
for
the
NOx
authorized
account
representative
and
(
if
desired)
alternate
NOx
authorized
account
representative.
This
documentation,
found
in
40
CFR
§
96.13,
must
include:

C
Identification
of
the
source
and
unit,
C
Name
and
contact
information
for
the
NOx
authorized
account
representative
and
alternate,
C
A
list
of
the
owners
and
operators
of
each
source
and
unit,
and
C
A
certification
statement
and
signature
of
the
NOx
authorized
account
representative
and
alternate.

Certification
applications
are
to
be
kept
for
a
period
of
5
years
pursuant
to
the
general
requirements
imposed
for
Title
V
permitted
facilities.
19
(
b)
Permitting
The
basic
requirement
for
permitting
will
be
an
application
for
a
permit
revision
to
a
source's
operating
permit
issued
under
Title
V
of
the
Act.
This
requirement
will
apply
to
both
trading
and
nontrading
sources.
Although
there
is
some
possibility
that
a
non­
Title
V
source
could
be
affected
under
the
NOx
Trading
Program,
all
affected
sources
are
assumed
to
be
Title
V
sources
for
purposes
of
this
ICR.
Except
for
the
permit
revision
application,
all
of
the
other
monitoring,
reporting
or
recordkeeping
requirements
associated
with
Title
V
permitting
are
either
part
of
the
baseline
Title
V
requirements
or
are
covered
separately
under
sections
4(
c)
and
4(
d),
below.
Title
V
permit
applications
must
be
kept
for
5
years
pursuant
to
Title
V
recordkeeping
requirements.
In
addition,
coal­
fired
units
that
are
not
part
of
the
Acid
Rain
Program
and
are
located
outside
the
OTC
region
are
expected
to
have
to
apply
for
a
permit
to
construct
under
Title
I
of
the
Act.

(
c)
Year­
end
Compliance
Certifications
On
or
before
November
30
of
each
year,
the
NOx
authorized
account
representative
for
each
source
must
submit
a
compliance
certification
report
covering
all
units
at
the
source.
Under
40
CFR
§
96.30,
the
report
must
include
the
following:

C
Identification
of
each
unit,
C
Serial
numbers
of
each
NOx
allowance
to
be
deducted
from
the
unit's
compliance
account,
C
For
units
sharing
a
common
stack,
the
percentage
of
allowances
to
be
deducted
from
the
unit's
compliance
account,
and
C
Compliance
certification,
including
certification
that
the
unit
was
operated
in
accordance
with
the
emission
limitation,
verification
that
the
monitoring
plan
is
complete
and
accurate,
a
statement
that
all
NOx
emissions
have
been
monitored
and
reported
appropriately,
and
whether
the
basis
for
certification
has
changed
(
and,
if
so,
details
of
the
change).

(
d)
Monitoring
and
Reporting
Affected
trading
program
sources
would
be
required
to
monitor
NOx
mass
emissions,
and
record
and
report
emissions
data
using
the
requirements
of
40
CFR
Part
75.
The
emissions
monitoring
requirements
specify
that
affected
sources
must
(
1)
submit
a
monitoring
plan
for
each
affected
unit
at
a
source,
(
2)
submit
data
for
certification
of
each
monitor,
and
(
3)
record
hourly
operational,
pollutant
monitor,
and
flow
monitor
data
for
each
affected
unit
and
submit
quarterly
reports
of
their
emissions
data
to
EPA.
Appendices
A
and
B
to
this
ICR
contain
a
list
of
the
data
items
required
by
the
recordkeeping
and
reporting
provisions
of
Part
75.

Respondents
are
required
by
40
CFR
75.64
to
submit
the
quarterly
NOx
mass
emissions
data
electronically,
by
direct
electronic
submission
to
EPA,
and
must
also
include
a
certification
statement
by
the
designated
representative
of
the
unit.
All
monitoring
records
are
to
be
kept
for
three
years,
with
20
one
possible
exception
under
a
voluntary
option
for
fuel
flowmeter
calibration
testing.
For
purposes
of
the
NOx
Trading
Program,
EPA
currently
is
not
requiring
electronic
submission
of
reports,
but
intends
to
do
so
after
finalizing
proposed
revisions
to
Part
75.
For
purposes
of
this
ICR,
the
labor
burdens
and
other
costs
are
calculated
on
the
assumption
that
such
a
requirement
will
be
in
effect
at
the
time
reporting
is
required
under
this
program.

(
ii)
Respondent
Activities
The
primary
tasks
that
will
be
performed
by
trading
program
respondents
to
meet
the
emissions
monitoring
requirements
are
(
1)
completing
and
submitting
appropriate
monitoring
plan
forms
for
each
affected
source
and
each
affected
unit
at
a
source;
(
2)
conducting
tests
to
certify
the
operation
of
monitors,
and
submitting
test
results
to
EPA;
(
3)
recording
hourly
emissions
data
(
this
activity
generally
is
performed
electronically);
(
4)
operation
and
maintenance
activities
associated
with
the
monitoring,
including
quality
assurance
activities;
(
5)
assuring
data
quality,
preparing
quarterly
reports
of
emissions
data
and
submitting
these
reports
to
EPA;
and
(
6)
responding
to
error
messages
generated
by
EPA.
In
addition,
respondents
will
have
to
purchase
the
necessary
monitoring
hardware
and
purchase
the
electronic
data
reporting
software
(
or
software
upgrades).

5.
THE
INFORMATION
COLLECTED
 
AGENCY
ACTIVITIES,
COLLECTION
METHODS,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
The
EPA
activities
associated
with
§
51.122
of
the
final
rule
are
as
follows:

°
Review/
verify
ozone
season
emissions
calculation
submitted
by
each
State;
°
Receive
and
store
emission
inventory
data
submitted
by
each
State
and
by
point
sources;
°
Review
emissions
data
submitted
annually
by
each
State
to
track
each
State's
progress
toward
meeting
its
NOx
budget;
°
Review
summary
report
of
statewide
NOx
emissions
submitted
by
each
State
every
3
years;
and
°
Respond
to
questions
from
States
and
point
sources
concerning
electronic
submittal
of
emissions
data.

Emissions
Trading
Program
The
major
EPA
activities
related
to
the
NOx
Trading
Program
include
(
1)
maintenance
and
administration
of
the
allowance
tracking
system
(
NATS),
(
2)
reviewing
permit
applications,
(
3)
21
reviewing
monitoring
plans
and
certification
applications,
(
4)
processing,
reviewing
and
evaluating
reports
of
quarterly
emissions
data
from
affected
units,
(
5)
calculating/
reviewing
ozone
season
emissions,
and
(
6)
reviewing
emissions
data
submitted
annually
to
track
each
State's
progress
toward
meeting
its
NOx
budget
and
creating
a
summary
report
of
statewide
NOx
emissions
every
three
years.
EPA
will
use
a
computer
system
called
the
Emissions
Tracking
System
(
ETS)
to
track
and
maintain
monitoring
and
emissions
information.
EPA
will
also
answer
respondent
questions
and
conduct
audits
of
data
submissions.

5(
b)
Collection
Methodology
and
Management
Several
options
are
currently
available
for
data
reporting.
One
option
is
for
an
agency
to
convert
its
emissions
data
into
the
EIIP/
EDI
format.
Through
the
EIIP,
EPA
is
participating
in
a
joint
effort
with
State
and
local
air
pollution
control
agencies
to
establish
a
common
format
for
exchanging
data
from
one
agency
to
another
(
example:
State
to
State,
State
to
EPA).
The
need
for
such
a
format
has
increased
with
the
increase
in
regional
air
quality
modeling
efforts
that
require
data
sharing
by
multiple
States.
This
file
can
then
be
made
available
to
any
requestor,
either
using
E­
mail,
floppy
disk,
or
value
added
network
(
VAN),
or
can
be
placed
on
a
file
transfer
protocol
(
FTP)
site.
As
a
second
option,
an
agency
may
submit
its
emissions
data
in
a
proprietary
format
based
on
the
EIIP
data
model.
For
the
last
two
options,
the
terms
submitting
and
reporting
data
are
defined
as
either
providing
the
data
in
the
EIIP/
EDI
format
or
the
EIIP
based
data
model
proprietary
format
to
EPA,
Office
of
Air
Quality
Planning
and
Standards,
Emission
Factors
and
Inventory
Group
directly
or
notifying
this
group
that
the
data
are
available
in
the
specified
format
and
at
a
specific
electronic
location
(
e.
g.,
FTP
site).

Another
option
for
annual
reporting
(
not
for
third
year
reports)
is
to
have
sources
submit
the
data
directly
to
EPA.
This
option
will
be
available
to
any
source
in
a
State
that
is
both
participating
in
a
trading
program
meeting
the
requirements
of
Part
96
and
that
has
agreed
to
submit
data
in
this
format.
The
EPA
will
make
both
the
raw
data
submitted
in
this
format
and
summary
data
available
to
any
State
that
chooses
this
option.

Emissions
Trading
Program
To
ensure
consistency
nationwide
and
to
expedite
data
entry,
EPA
will
require
that
standard
electronic
data
reporting
(
EDR)
formats
used
for
Part
75
reporting
be
used
to
submit
the
information
collected
for
the
NOx
Trading
Program.
The
revised
draft
EDR
formats
(
version
2.1)
that
correspond
to
the
proposed
revisions
to
Part
75
are
included
as
Appendix
A
to
this
document.
As
discussed
in
Section
4(
b),
above,
upon
promulgation
of
currently
proposed
Part
75
revisions,
EPA
intends
to
require
that
data
be
sent
via
direct
electronic
submission
to
EPA
using
the
revised
EDR
format.
Nontrading
program
sources
will
have
to
report
results
of
performance
tests
or
excess
emissions,
as
applicable
consistent
with
the
reporting
required
under
40
CFR
Part
60.
22
Several
computer
systems
and
associated
databases
have
been
developed
to
(
1)
track
allowances,
(
2)
record
quarterly
emissions
monitoring
data,
and
(
3)
calculate
the
number
of
allowances
to
be
deducted
each
year.
The
systems
and
databases
are
designed
to
coordinate
the
information
for
easy
access
and
use
by
the
Agency,
states,
regulated
community,
and
the
public.

The
EPA
also
has
established
an
Acid
Rain
Home
Page
on
the
Internet,
which
includes
detailed
information
collected
from
emissions
reports.
Those
without
access
to
the
Internet
may
use
the
Acid
Rain
Hotline
to
request
information,
including
the
Acid
Rain
Program
Updates
or
other
summary
reports.
The
Agency
expects
to
rely
on
these
electronic
means
to
disseminate
information
about
the
NOx
Trading
Program
as
the
program
is
developed.

5(
c)
Small
Entity
Flexibility
The
State
control
agencies
affected
by
this
rulemaking
are
not
considered
to
be
small
entities.
To
support
States
with
fewer
sophisticated
processing
capabilities,
the
EPA
has
developed
mainframe
and
PC
software
to
facilitate
State
efforts
in
storing,
maintaining,
and
reporting
source
data.
A
number
of
Territories
and
smaller
States
have
adopted
these
and
use
them
to
make
their
submissions.
By
providing
a
number
of
means
whereby
the
respondents
can
make
their
submissions,
respondents
are
able
to
select
those
which
minimize
their
efforts
and
costs
and
still
use
some
type
of
electronic
technology.

The
rulemaking,
which
EPA
published
by
notice
in
63
FR
57356
(
October
8,
1998),
would
simply
require
States
to
develop,
adopt,
and
submit
SIP
revisions.
Pursuant
to
5
U.
S.
C.
605(
b),
in
the
rulemaking,
the
Administrator
certified
that
the
rule
will
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities.

Emissions
Trading
Program
The
NOx
Trading
Program
only
includes
fossil
fuel­
fired
units
(
stationary
boilers,
combustion
turbines,
and
combined
cycle
systems)
that
serve
an
electrical
generator
of
capacity
greater
than
25
MWe,
and
any
other
fossil
fuel­
fired
units
that
have
a
heat
input
capacity
greater
than
250
mmBtu/
hr.
Units
with
a
lower
capacity
are
not
included
because
of
the
high
cost
of
monitoring
emissions
from
these
sources
and
the
de
minimis
nature
of
their
emissions.

There
are
two
small
unit
exceptions
that
are
applicable
to
the
NOx
Trading
Program.
The
first
provides
for
reduced
monitoring
and
the
second
provides
for
an
exemption
from
participation
in
the
program.
The
low
mass
emitter
exception
(
40
CFR
75.19),
allows
optional
reduced
monitoring,
quality
assurance,
and
reporting
requirements
for
units
that
combust
natural
gas
and/
or
fuel
oil
and
that
emit
no
more
than
50
tons
of
NOx
annually
(
or,
at
the
source's
election,
25
tons
per
ozone
season)
and
that
calculate
no
more
than
the
same
amount
based
on
specified
procedures
for
calculating
and
reporting
emissions.
Qualifying
utilities
are
not
required
to
keep
monitoring
equipment
installed
on
(
or
conduct
23
fuel
sampling
for)
low
mass
emissions
units,
nor
are
they
required
to
perform
quality
assurance
or
quality
control
tests.
Moreover,
emissions
reporting
requirements
are
significantly
simplified
for
these
units.

The
second
exception
provides
an
exemption
for
units
that
restrict
NOx
mass
emissions
to
less
than
25
tons
during
the
ozone
season.
To
be
eligible,
the
unit
must
accept
a
federally­
enforceable
operating
hour
permit
limit.
The
unit
would
calculate
the
operating
hour
restriction
by
dividing
25
tons
by
the
unit's
maximum
potential
hourly
NOx
mass
emissions.

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

5(
d)
Collection
Schedule
Beginning
for
the
inventory
year
2003,
the
EPA
is
requiring
States
to
annually
submit
ozone
season
inventories
for
all
NOx
sources
for
which
States
adopt
control
measures
to
meet
their
NOx
budget.
Every
3
years,
starting
for
the
inventory
year
2002,
statewide
NOx
inventories
of
all
controlled
and
uncontrolled
sources
are
required.
This
statewide
inventory
requirement
also
applies
to
the
year
2007.

For
all
of
the
above
reporting
activities,
the
final
rule
specifies
that
States
submit
the
appropriate
emissions
data
within
12
months
of
the
end
of
the
inventory
year
(
e.
g.,
a
statewide
NOx
emissions
inventory
for
the
year
2005
would
be
required
by
December
of
2006).

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
The
State
burden
for
complying
with
the
reporting
requirements
under
§
51.122
is
estimated
incremental
to
the
burden
associated
with
existing
annual
inventory
and
periodic
inventory
reporting
requirements.

In
general,
States
already
have
mechanisms
in
place
for
reporting
emissions
data
to
EPA.
Under
the
existing
annual
point
source
inventory
requirements,
States
are
required
to
submit
the
emissions
data
specified
in
Section
4(
b)(
i)
of
this
supporting
statement
(
excluding
the
incremental
data
elements
identified).
Since
most
of
the
data
which
the
States
are
required
to
update
for
point
sources
(
area
codes,
addresses,
or
other
physical
parameters)
do
not
change
often,
the
updating
of
more
than
24
90
percent
of
all
source
records
is
minimal
and
typically
involves
only
changes
in
emissions
and
closely
related
information
(
fuel
usage,
process
rates,
seasonal
throughput,
etc.).

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

°
Collecting
emissions
data
and
other
associated
information;
°
Quality
assuring
emissions
data;
°
Training
staff
in
coding
and
submissions
techniques;
°
Creating
information
(
e.
g.,
assigning
EPA
codes
to
State
point
source
records);
°
Resolution
of
errors
and
anomalies
identified
by
EPA;
°
Maintaining
records
associated
with
data
submitted
by
sources;
and
°
Preparing
and
submitting
required
inventory
data
items
in
approvable
format.

Under
the
existing
periodic
inventory,
States
with
ozone
nonattainment
areas
(
or
in
the
ozone
transport
region)
must
report
triennially
to
EPA
area,
nonroad
mobile,
and
highway
mobile
source
emissions
for
the
nonattainment
areas.
For
the
final
rule,
EPA
is
requiring
that
States
report
statewide
area,
nonroad
mobile,
and
highway
mobile
source
ozone
season
emissions
every
year
if
the
State
adopts
control
measures
for
these
sources
specifically
for
the
purpose
of
meeting
the
NOx
budget.
This
could
be
an
incremental
burden
to
States
each
year.
However,
no
burden
was
estimated
for
States
to
annually
report
area,
nonroad
mobile,
or
highway
mobile
source
emissions
to
EPA
for
years
that
do
not
coincide
with
the
existing
3­
year
cycle
inventory.
This
is
because
OTAG
modeling
results
indicate
that
States
will
most
likely
control
large
stationary
NOx
emission
sources
rather
than
area,
nonroad
mobile,
or
highway
mobile
emission
sources
to
meet
their
NOx
budgets.

One­
time
activities
The
time
for
States
to
read
and
interpret
the
reporting
requirements
of
the
§
51.122
rule
was
estimated
to
be
1
hour
for
technical
staff
and
1
hour
for
managerial
staff.
The
time
required
for
preparing
and
submitting
example
ozone
season
emissions
calculations
to
EPA
would
vary,
depending
on
the
complexity
of
the
calculations.
States
that
estimate
seasonal
emissions
by
applying
a
factor
of
5/
12'
s
to
their
annual
emissions
inventory
can
complete
this
task
in
minimal
time.
States
that
account
for
factors
such
as
changes
in
activity
levels
or
fuels
would
require
more
time.
On
average,
it
was
estimated
to
take
10
hours
for
technical
staff
and
0.5
hour
for
managerial
staff.
Another
one­
time
activity
involves
a
State
modifying
its
emissions
data
bases
to
incorporate
7
additional
data
items
for
point
sources,
5
additional
data
items
for
area
sources,
and
4
additional
data
items
for
highway
and
nonroad
mobile
sources.
Technical
staff
time
to
perform
this
activity
was
estimated
to
be
60
hours,
and
managerial
staff
time
was
estimated
to
be
3
hours.

A
one­
time
effort
is
expected
for
the
States
to
establish
procedures
to
estimate
statewide
ozone
season
NOx
emissions
from
stationary
area
sources.
Area
source
NOx
emissions
in
the
OTAG
25
inventory
are
due
to
stationary
fuel
combustion,
incineration
and
open
burning,
and
wildfires
and
prescribed
burning.
It
is
assumed
that
States
would
develop
a
spreadsheet
or
data
base
containing
county­
level
activity
indicators
(
e.
g.,
population,
employment,
forest
acreage)
to
allocate
activity
data
typically
available
at
the
State
level
to
the
county
level.
It
will
also
be
necessary
to
account
for
any
controls
or
seasonal
restrictions
that
would
impact
NOx
emissions.
The
average
respondent
time
to
develop
the
procedures
to
predict
county­
level
area
source
NOx
emissions
for
an
entire
State
was
estimated
to
be
80
hours
of
technical
staff
time
and
4
hours
of
managerial
staff
time.

For
highway
mobile
sources,
it
will
be
necessary
for
States
to
prepare
a
procedure
for
estimating
county­
level
VMT
as
input
to
EPA's
MOBILE
model.
It
was
assumed
that
States
will
distribute
statewide
VMT
available
from
the
Federal
Highway
Administration's
(
FHWA)
Highway
Performance
Monitoring
System
(
HPMS)
to
the
county
level
using
a
surrogate
activity
indicator
such
as
population.
In
addition,
any
highway
mobile
source
controls
applicable
to
a
county
must
be
identified
and
accounted
for
in
the
emission
estimates
for
a
county.
The
one­
time
burden
for
performing
these
activities
was
estimated
to
take
40
technical
hours
and
2
managerial
hours.

States
must
prepare
and
submit
a
statewide
ozone
season
NOx
emissions
inventory
of
all
controlled
and
uncontrolled
sources
for
the
year
2007.
A
2007
statewide
ozone
season
NOx
emissions
inventory
for
all
point,
area,
nonroad
mobile,
and
highway
mobile
sources
is
required
to
allow
evaluation
of
whether
the
NOx
budgets
are
met
for
the
year
2007.
This
one­
time
special
inventory
is
necessary
because
the
scheduled
3­
year
reporting
cycle
does
not
fall
in
the
year
2007.
States
which
must
submit
the
2007
inventory
may
project
incremental
changes
in
emissions
from
2007
to
2008
to
allow
the
2008
inventory
requirement
to
be
more
easily
met
and
to
reduce
the
burden
on
States
which
must
submit
full
NOx
inventories
in
consecutive
years
(
i.
e.,
2007
and
2008).
The
burden
associated
with
projecting
the
area,
nonroad
mobile,
and
highway
mobile
source
2007
inventories
to
2008
is
accounted
for
in
this
ICR
and
is
estimated
to
be
8
hours
of
technical
staff
time,
and
0.4
hour
of
managerial
staff
time
per
State.
No
burden
is
estimated
for
point
source
inventory
preparation
since
it
is
already
collected
annually.

Lastly,
the
burden
for
a
State
to
review
a
Title
V
permit
revision
submitted
by
controlled
sources
was
estimated
to
be
0.8
hours
of
technical
staff
(
i.
e.,
4
hours
annualized
over
the
5­
year
permit
cycle).

Annual
Activities
Annual
State
burden
items
associated
with
this
ICR
are
as
follows.
States
must
notify
the
appropriate
EPA
Regional
Office
when
submitting
an
annual,
triennial,
and
2007
NOx
inventory.
This
activity
was
estimated
to
take
0.5
hour
per
year
for
managerial
staff.
An
additional
0.5
hour
per
year
was
estimated
for
technical
staff
to
prepare
and
submit
an
electronic
NOx
emissions
budget
report.
Most
of
the
data
collection
activities
associated
with
the
annual
inventory
are
already
being
done
to
meet
existing
inventory
requirements.
However,
there
is
additional
burden
associated
with
compiling
5EPA's
NONROAD
model
is
currently
under
development
by
EPA's
Office
of
Mobile
Sources
(
OMS).
A
final
version
of
the
model
is
expected
to
be
in
use
by
States
by
2003.

6These
estimates
are
based
on
a
State
using
MOBILE6,
which
will
be
the
next
version
of
EPA's
MOBILE
model.

26
and
quality­
assuring
the
ozone
season
inventory.
The
additional
annual
burden
for
this
activity
was
estimated
to
be
16
hours
per
year
for
technical
staff
and
0.8
hours
per
year
for
managerial
staff.

Triennial
Activities
Every
3
years,
States
are
required
to
submit
ozone
season
emissions
data
for
all
point,
area,
nonroad
mobile,
and
highway
mobile
sources
of
NOx
within
the
State.
States
are
already
submitting
a
statewide
emissions
inventory
of
all
point
sources
under
the
existing
annual
inventory
requirements.
However,
a
burden
is
expected
for
States
to
develop
statewide
NOx
stationary
area
source,
nonroad
mobile
source,
and
highway
mobile
source
inventories
every
3
years.
Under
the
existing
periodic
SIP
inventory
requirements,
emissions
from
these
sectors
were
only
determined
for
ozone
nonattainment
area
counties.
The
incremental
burden
for
developing
statewide
ozone
season
inventories
for
all
controlled
and
uncontrolled
sources
consists
of
the
following
activities:

C
For
stationary
area
sources,
collecting
activity
data
needed
to
allocate
State­
level
activity
data
to
the
county­
level
and
estimating
area
source
emissions;
(
160
technical
hours;
8
managerial
hours);

C
For
nonroad
mobile
sources,
estimating
emissions
according
to
EPA's
NONROAD
emission
inventory
model5
(
240
technical
hours;
12
managerial
hours);
and
C
For
highway
mobile
sources,
estimating
emissions
using
EPA's
MOBILE
model6
(
120
technical
hours;
10
managerial
hours).

The
above
hour
estimates
also
account
for
generating
and
quality­
assuring
ozone
season
emissions.
For
the
highway
mobile
source
inventory,
beginning
in
the
year
2003,
the
recurrent
burden
hours
every
3
years
will
include
40
hours
of
technical
staff
time
to
perform
the
VMT
calculations.
Thus,
the
burden
for
performing
all
the
necessary
steps
to
generate
the
2002
highway
mobile
source
inventory
in
2003
is
assumed
to
be
120
hours
(
i.
e.,
40
+
80
hours).

States
must
compile
a
summary
report
of
statewide
NOx
emissions
for
submittal
to
EPA.
A
small
burden
was
estimated
for
States
to
account
for
sources
that
have
been
reporting
directly
to
EPA
annually
using
a
different
reporting
format
(
e.
g.,
EDR
format
for
Part
75).
An
additional
3
hours
(
1
for
managerial,
2
for
technical
staff)
was
estimated
to
be
the
time
needed
for
a
State
to
request
source­
27
submitted
data
from
EPA
and
merge
these
emissions
data
into
a
consistent
format
for
the
required
triennial
report.

Burden
calculations
Burden
hours
and
associated
costs
were
estimated
for
the
first
period
that
the
affected
States
may
start
reporting
emissions
data
to
EPA.
In
this
case,
that
period
corresponds
to
the
year
2002
(
States
would
have
to
begin
reporting
data
for
the
year
2002
within
12
months
of
the
end
of
2002,
however
it
is
possible,
if
not
likely,
that
a
State
could
report
by
the
end
of
year
2002..)
Tables
6­
1,
6­
2,
and
6­
3
presents
the
annual
State
burden
hours
and
costs
by
activity
for
the
2000­
2002
time
period.
Tables
6­
4,
6­
5
and
6­
6
present
the
annual
industry
burden
hours
and
costs
by
activity
for
the
2000­
2002
time
period.

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

To
estimate
the
burden
and/
or
cost
of
each
incidence
of
the
various
proposed
rule
revisions,
EPA
had
available
prior
estimates
of
the
costs
of
various
activities,
estimates
provided
by
affected
utilities
in
comments
to
the
Agency,
and
estimates
based
on
the
Agency's
experience
in
implementing
the
existing
trading
programs.
In
addition,
the
hourly
labor
rates
for
managerial,
technical
and
clerical
staff
reflect
the
labor
rates
used
in
the
existing
Acid
Rain
program
ICR
but
updated
to
1998
dollars
using
the
Employment
Cost
Index,
consistent
with
Agency
ICR
guidance.

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

C
Trading
units
subject
to
Title
IV
Acid
Rain
monitoring
requirements
(
40
CFR
Part
75)
that
are
located
in
the
Ozone
Transport
Commission
(
OTC)
region
("
AR­
OTC");
C
Trading
units
subject
to
Title
IV
monitoring
requirements
that
are
not
located
in
the
OTC
region
("
AR­
NOTC");
C
Trading
units
not
subject
to
Title
IV
monitoring
requirements
that
are
located
in
the
OTC
region
("
NAR­
OTC");
and
C
Trading
units
not
subject
to
Title
IV
monitoring
requirements
that
are
not
located
in
the
OTC
region
("
NAR­
NOTC")

The
NOx
Trading
Program
requires
all
affected
sources
to
install
a
NOx
emission
rate
(
or
concentration)
CEM
and
a
flow
CEM
(
or
approved
alternative).
Affected
gas­
and
oil­
fired
units
may
28
elect
to
use
a
NOx
emissions
rate
CEM
and
a
fuel
flowmeter.
In
addition,
peaking
units
that
burn
natural
gas
and/
or
fuel
oil
may
use
an
alternative
method
for
calculating
NOx
emission
rates.
EPA
will
also
allow
certain
low
mass
emissions
units
to
use
assumed
emissions
factors
together
with
operational
data
to
calculate
emissions.

The
OTC
NOx
Budget
Program
is
a
regionwide
cap­
and­
trade
program
that
targets
utility
and
large
industrial
combustion
sources
to
facilitate
NOx
emissions
reductions
in
the
OTC
region.
The
OTC
States
include
Maine,
New
Hampshire,
Vermont,
Massachusetts,
Connecticut,
Rhode
Island,
New
York,
New
Jersey,
Pennsylvania,
Maryland,
Delaware,
and
DC.
For
purposes
of
this
ICR,
it
is
important
that
the
burdens
and
costs
be
calculated
only
in
terms
of
incremental
impacts
for
units
located
in
these
states.
Similarly,
non­
OTC
states
have
existing
requirements
for
CEMS
in
some
cases
that
a
unit
will
already
be
subject
to.
Thus,
it
should
be
noted
that
the
labor
hour
and
cost
estimates
per
unit
identified
in
this
document,
represent
the
weighted
average
burden
and
cost
for
all
units
and
do
not
represent
the
actual
burden
and
cost
for
a
particular
unit.

The
following
discussion
highlights
some
of
the
basic
differences
for
the
four
basic
categories
of
units:

For
AR­
OTC
units,
EPA
believes
that
the
only
labor
burdens
will
be
associated
with
permit
applications,
certain
allowance
transactions,
and
applications
for
early
election
credits.
These
units
will
not
incur
additional
burdens
(
or
capital
and
operating
and
maintenance
costs)
as
a
result
of
the
NOx
SIP
call
rule
since
they
have
already
installed
and
are
operating
a
CEMS
(
or
approved
alternative)
meeting
Part
75
Subpart
H
specifications.
However,
AR­
NOTC
units
will
likely
require
minor
upgrades
to
their
data
acquisition
and
handling
system
(
DAHS).
In
addition,
a
few
AR­
NOTC
units
with
complex
stack
situations
may
need
to
reconfigure
their
Title
IV
approved
monitoring
systems
under
Part
75.
Therefore,
this
ICR
reflects
some
incremental
monitoring
costs
for
these
sources.

For
NAR­
OTC
units,
EPA
believes
that
each
unit
will
incur
labor
burdens
associated
with
permit
applications,
certain
allowance
transactions,
and
applications
for
early
election
credits.
In
addition,
some
NAR­
OTC
units
are
expected
to
have
to
install
new
flow
CEMS
to
meet
Part
75
Subpart
H
requirements.
As
a
result,
these
units
will
incur
additional
capital
and
other
operating
costs.
The
additional
labor
burdens
associated
with
flow
CEMS
quality
assurance
activities
are
offset
by
the
fact
that
the
unit
will
not
be
required
to
conduct
the
quality
assurance
activities
for
the
flow
monitoring
alternative
used
under
the
OTC
program.
Finally,
a
large
number
of
NAR­
OTC
units
are
expected
to
incur
some
costs
associated
with
upgrading
the
DAHS.

For
NAR­
NOTC
units,
the
respondents
will
incur
the
labor
burdens
and
other
costs
for
all
of
the
activities
associated
with
the
NOx
Trading
Program.
The
costs
will
vary
depending
on
what
monitoring
alternative
is
appropriate
for
the
unit
and
what
monitoring
requirements
apply
to
the
unit
under
other
regulatory
programs.
29
Also,
as
discussed
in
section
(
1),
the
Agency
anticipates
a
split
in
compliance
dates,
with
435
sources
opting
to
be
in
the
early
election
program
(
beginning
in
2000),
and
the
remaining
sources
becoming
subject
to
the
trading
rule
in
2002.
Note
that
some
early
election
units
are
in
the
Acid
Rain
Program
or
OTC
region,
and
will
therefore
incur
additional
costs
under
the
trading
rule
only
for
permit
applications,
certain
allowance
transactions,
and
applications
for
early
election
credits.
This
ICR
reflects
the
varying
number
of
respondents
through
the
2000­
2002
period.

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

(
i)
Permitting.

Each
affected
entity
will
have
to
submit
a
permit
revision
application
to
include
in
the
source's
Title
V
permit
the
necessary
conditions
related
to
compliance
with
the
NOx
Trading
Program.
The
Agency
believes
that
this
application
should
be
relatively
routine,
and
that
a
standard
method
of
incorporating
the
requirements
by
reference
or
a
standard
set
of
permit
conditions
will
be
available.
The
Agency
estimates
that,
on
a
per
unit
basis,
about
4
managerial
hours
will
be
required
to
revise
the
Title
V
permit,
and
that
half
of
the
revisions
will
occur
in
2001,
and
half
in
2002.

Some
sources
will
also
be
required
to
construct
additional
facilities,
and
therefore
will
need
to
complete
a
permit
to
construct
application.
The
Agency
estimates
that
this
requirement
will
be
necessary
for
all
coal­
fired
units
that
are
not
in
the
Acid
Rain
Program
or
in
the
OTC
and
that
the
task
will
take
20
hours
of
managerial
and
20
hours
of
technician
time,
per
permit.
These
burden
estimates
are
consistent
with
the
average
burden
for
a
minor
New
Source
Review
permit
application
used
in
the
ICR
for
the
New
Source
Review
program
under
Title
1
of
the
Act
(
EPA
ICR
No.
1230.09).

(
ii)
Monitoring.

For
monitoring,
the
burdens
differ
greatly
based
on
the
amount
and
type
of
monitoring
the
unit
is
already
subject
to
and
the
particular
subtask
of
monitoring
being
conducted.
Note
that
in
most
cases,
burdens
will
not
be
incurred
until
2002.
The
exception
is
early
election
units,
which
will
generally
begin
incurring
burdens
in
2000.
The
specific
elements
of
burden
are:

Start­
up
Activities.
A
large
part
of
start­
up
activities
involves
capital
and
test
contractor
costs.
However,
the
owner
or
operator
will
incur
some
labor
burden
for
these
activities,
as
applicable.
For
AR­
OTC
units,
the
program
imposes
no
start­
up
burdens
beyond
existing
programs.
For
ARNOTC
units,
the
owner
or
operator
will
incur
some
small
amount
of
burden
associated
with
DAHS
or
(
in
a
small
percent
of
circumstances)
CEMS
upgrade
activities.
For
NAR­
OTC
units,
EPA
estimates
that
a
number
of
units
will
have
to
install
a
flow
CEMS
and
that
all
of
the
units
will
have
to
arrange
for
a
30
DAHS
upgrade.
For
the
NAR­
NOTC
units,
the
burdens
reflect
burdens
for
arranging
for
CEMS
purchase
(
as
required)
and
oversight
of
the
certification
process.

Regulatory
Review.
The
ICR
includes
an
allocation
of
time
for
the
managerial
and
technical
staff
to
review
the
regulatory
requirements
and
the
EDR
formats
and
instructions.
The
NAR­
NOTC
units
will
have
a
burden
similar
to
that
estimated
for
Acid
Rain
Program
units
in
the
Acid
Rain
Program
ICR
­­
24
hours
of
managerial
time
and
24
hours
of
technician
time
in
year
one
of
the
program
and
4
hours
each
for
managerial
and
technician
time,
per
year,
after
year
one.
The
burden
estimates
for
NAR­
OTC
units
is
reduced
because
of
the
similar
OTC
requirements.
The
estimates
for
these
units
are
5
hours
of
managerial
time
and
5
hours
of
technician
time
in
year
one
and
1
hour
each
per
year
after
year
one.

Response
to
Error
Messages.
The
Agency
provides
feedback
to
affected
sources
for
errors
that
are
found
in
monitoring
plans
or
other
reports.
The
Agency
estimates
that
for
each
NARNOTC
unit,
an
owner
or
operator
will
spend
approximately
4
hours
of
managerial
time
and
8
hours
of
technician
time
responding
to
these
error
messages
each
year.

DAHS
Debugging.
Based
on
experience
with
the
Acid
Rain
Program,
some
effort
will
be
involved
to
fix
problems
with
the
DAHS
software
used
to
report
in
the
EDR
formats.
This
burden
is
assumed
to
fall
primarily
on
units
that
are
not
affected
under
either
the
Acid
Rain
or
OTC
programs.
Consistent
with
the
existing
Part
75
ICR,
the
Agency
estimates
that
about
16
managerial
and
88
technician
hours
will
be
spent
on
this
task
in
the
first
year
of
implementation,
and
then
4
managerial
and
12
technician
hours
will
be
required
in
the
second
and
subsequent
years
of
implementation.

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

Monitor
Certification/
Recertification.
Initial
certification
burdens
and
costs
for
new
monitoring
equipment
are
addressed
above
under
start­
up
activities
since
these
costs
are
often
part
of
the
overall
purchase
expense
for
the
equipment.
For
some
NAR­
NOTC
units,
however,
there
will
be
burdens
associated
with
certifying
existing
monitors
used
under
other
programs
for
this
program,
as
well
as
burdens
for
recertification
to
the
extent
a
change
in
a
monitoring
system
requires
recertification.
EPA
estimates
that
approximately
10%
of
all
units
will
have
to
recertify
each
year
following
the
year
in
which
the
initial
certification
occurs.
For
this
initial
ICR,
the
only
units
that
will
incur
recertification
costs
are
a
portion
of
the
early
election
units.
The
ICR
incorporates
a
labor
burden
estimate
generally
consistent
with
existing
Agency
models
for
the
labor
burdens
associated
with
certification.
However,
note
that
the
ICR
reduces
the
labor
hours
for
this
activity
to
avoid
double
counting
hours
that
are
already
accounted
for
in
the
quality
assurance
activity
area
(
see
the
following
subsection
below).
The
double
counting
would
occur
because
a
portion
of
the
labor
incurred
for
the
certification
or
recertification
event
replaces
31
the
labor
burden
that
is
generally
allocated
to
the
annual
relative
accuracy
test
audit
(
RATA)
in
the
year
in
which
the
certification
event
occurs.

Quality
Assurance.
Quality
assurance
(
QA)
activities
and
other
routine
maintenance
for
monitoring
systems
is
the
largest
burden
item
under
the
NOx
Trading
Program.
These
requirements
generally
include
daily,
quarterly
and
annual
QA
requirements,
depending
on
the
monitoring
approach
being
used.
For
reporting
units
that
use
a
CEMS,
the
Agency
has
assumed
a
per
unit
labor
burden
based
on
a
variety
of
sources,
including
the
existing
Acid
Rain
Program
ICR,
information
provided
by
Acid
Rain
Program
sources,
a
CEM
cost
model
developed
by
EPA,
and
comments
submitted
in
response
to
the
section
110
SIP
Call
for
ozone
transport.
For
units
that
rely
on
alternative
methodologies,
reduced
labor
burden
estimates
apply
because
the
quality
assurance
activities
for
the
excepted
methods
are
less
than
for
a
CEMS.
The
labor
burdens
for
these
excepted
methods
were
derived
primarily
from
cost
estimates
provided
by
a
group
of
affected
utilities
(
see
Docket
A­
97­
35,
Item
II­
D­
48).
Consistent
with
the
existing
Acid
Rain
Program
ICR,
the
labor
burden
is
expected
to
be
almost
entirely
technician
labor.

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

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

(
iii)
Year­
end
compliance
certification.

Each
owner
or
operator
will
have
to
submit
an
annual
compliance
certification
report.
The
compliance
certification
is
anticipated
to
take
about
two
managerial
hours
per
unit.

(
iv)
Allowance
transaction
activities.

The
Agency
anticipates
the
total
number
of
allowance
transactions
will
be
2,602,
2,651,
and
2,910
for
the
years
2000­
2002,
respectively.
Those
numbers
are
based
first
on
the
assumption
that
there
will
be
an
allowance
allocation
transaction
for
each
unit
in
each
year.
Second,
each
early
election
unit
will
have
an
additional
allocation
transaction
in
2001
and
2002.
Finally,
some
percentage
of
all
NAR­
NOTC
units
will
likely
conduct
transactions
in
each
year
solely
as
a
result
of
this
program.
The
32
Agency
has
estimated
that
12.5%
of
these
units
will
do
so
in
2000
and
2001,
and
25%
of
these
units
will
do
so
in
2002.

The
Agency
believes
that
each
transaction
will
involve
about
1
hour
each
of
managerial
and
technician
time.

(
v)
Application
for
Early
Reduction
Credits
Sources
that
opted
into
the
early
election
program
will
be
eligible
to
receive
early
election
credits
beginning
in
2001.
The
Agency
estimates
that
completion
of
the
annual
application
to
receive
the
credits
will
take
8
labor
hours
per
year,
split
between
managerial
and
technician
time.
This
burden
will
be
incurred
by
all
435
early
election
units,
and
only
in
2001
and
2002.

6(
b)
Estimating
Respondent
Costs
Tables
6­
4,
6­
5,
and
6­
6
summarize
the
annual
respondent
costs.
The
following
discussion
describes
how
those
costs
were
derived.

(
i)
Estimating
Labor
Costs
For
this
ICR,
the
labor
rate
for
technical
staff
at
State
agencies
was
assumed
to
be
$
25.73
per
hour.
This
is
consistent
with
the
technical
labor
rate
used
for
the
ICR
for
the
annual
inventory
(
OMB
#
2060­
0088).
Hours
assumed
for
managerial
staff
were
multiplied
by
$
40.00
per
hour.
This
labor
rate
was
derived
from
the
federal
government's
1998
General
Schedule
published
by
the
U.
S.
Office
of
Personnel
Management.
The
rate
corresponds
to
a
GS­
13,
Step
1
labor
rate
($
25.00
per
hour)
multiplied
by
a
factor
of
1.6
to
account
for
benefits
provided
to
workers.

In
estimation
of
industry
labor
costs,
EPA
used
the
following
amounts:
$
66.05
per
hour
for
managers
and
$
45.44
per
hour
for
technicians.
These
rates
were
derived
by
updating
the
labor
rates
used
in
the
existing
Acid
Rain
Program
ICR
to
1998
dollars.

Federal
Agency
labor
rates
were
assumed
to
be
$
40.00
per
hour.
This
labor
rate
was
derived
from
the
federal
government's
1998
General
Schedule
published
by
the
U.
S.
Office
of
Personnel
Management.
The
rate
corresponds
to
a
GS­
13,
Step
1
labor
rate
($
25.00
per
hour)
multiplied
by
a
factor
of
1.6
to
account
for
benefits
provided
to
workers.

(
ii)
Estimating
Total
Capital
and
Annual
Operations
and
Maintenance
Costs
Capital/
start­
up
costs
include
the
cost
of
installing
required
CEMS
or
alternatives.
Operation
and
maintenance
costs
(
exclusive
of
labor
costs)
reflect
ongoing
costs
to
a
unit
and
include
both
contractor
costs
for
the
required
recertification,
diagnostic,
and
quality
assurance
(
QA)
testing,
and
other
direct
33
maintenance­
related
expenses
(
e.
g.,
spare
parts
and
calibration
gases).
These
cost
estimates
have
been
derived
from
EPA
CEM
cost
models,
existing
ICRs,
Agency
staff
experience
under
the
Acid
Rain
program,
and
supplemental
estimates
provided
by
affected
utilities
and
others
related
to
the
various
cost
items
(
see,
e.
g.,
EPA
Air
Dockets
A­
96­
56­
V­
H­
93
and
A­
97­
35,
Item
II­
D­
48).

The
AR­
OTC
units
are
not
expected
to
incur
any
non­
labor
costs
associated
with
this
program.
The
total
non­
labor
cost
for
capital/
start­
up
items
is
estimated
at
$
2,500
to
$
5,000
per
unit
for
most
AR­
NOTC
units
(
to
account
for
a
DAHS
upgrade),
although
approximately
1
percent
of
the
units
are
also
expected
to
need
a
CEMS
upgrade
of
approximately
$
50,000.
For
NAR­
OTC
units,
most
units
will
require
only
a
DAHS
upgrade,
estimated
at
$
5,000­$
10,000
per
unit.
However,
EPA
estimates
that
approximately
one­
half
of
the
coal­
fired
NAR­
OTC
units
will
also
need
to
install
a
new
flow
CEMS
at
an
estimated
cost
of
$
73,000
(
inclusive
of
DAHS
upgrade).
For
NAR­
NOTC
units,
the
Appendix
E/
fuel
flowmeter
units
are
expected
to
incur
only
DAHS
costs,
while
the
other
units
will
require
some
combination
of
a
NOx,
diluent
and/
or
flow
CEMS.
The
costs
for
these
units
ranges
from
$
25,000
to
$
270,000.
The
variance
is
due
to
the
monitoring
methodology
used
and
what
monitoring
equipment
may
already
be
in
place
at
the
unit.

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

The
Agency
also
notes
that
this
ICR
does
not
include
a
cost
for
the
purchase
of
monitoring
equipment
for
all
affected
units.
Many
sources
covered
by
the
NOx
Trading
Program
are
already
required
to
have
CEMS
under
other
regulatory
programs.
Therefore,
to
the
extent
that
no
new
equipment
is
needed
by
these
sources,
capital
costs
are
not
included
because
those
costs
were
included
in
the
ICRs
of
those
other
programs.
Thus,
the
capital
and
other
costs
included
in
Table
6­
1,
above,
represent
weighted
average
costs
for
each
respondent,
not
the
total
individual
cost
for
any
particular
respondent.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O
&
M)
Costs
Capital
costs
reflect
one­
time
costs
for
purchase
of
equipment
which
will
be
used
over
a
period
of
years.
Conversely,
operating
and
maintenance
costs
are
those
costs
which
are
incurred
on
an
annual
or
34
other
scheduled
basis.
For
instance,
costs
associated
with
quality
assurance
activities,
such
as
spare
parts
or
contractor
costs
for
work,
will
be
incurred
on
an
annual
basis.

(
iv)
Annualizing
Capital
Costs
The
relevant
capital
costs
for
this
ICR
were
annualized
at
a
rate
of
7%.
The
annualized
cost
of
the
necessary
capital
purchases
varies
from
$
400
to
$
29,600,
per
year,
per
source,
depending
on
the
type
of
monitoring
methodology.
Tables
6­
5,
6­
6,
and
6­
7
contains
a
breakdown
of
annual
costs
by
monitoring
methodology.

6(
c)
Estimating
Agency
Burden
and
Cost
The
Agency
activities
associated
with
the
final
rule
§
51.122
will
only
slightly
increase
the
burden
of
the
activities
that
EPA
is
already
performing
to
manage
emissions
data
to
evaluate
compliance
of
States
with
their
ozone
SIPs,
and
to
evaluate
compliance
of
emission
sources
already
reporting
to
EPA
under
the
acid
rain
provisions
of
40
CFR
Part
75.
The
EPA
will
use
its
existing
emission
inventory
reporting
mechanisms
and
staff
to
handle
the
emissions
data
submitted
to
comply
with
the
reporting
requirements
of
the
final
rule.
For
example,
EPA
assisted
OTAG
in
compiling
emissions
inventory
data
for
all
37
OTAG
States
and
the
District
of
Columbia
in
preparing
the
base
year
and
projection
year
emission
inventories
that
were
used
to
establish
the
NOx
emission
budgets
for
the
22
States
that
will
be
subject
to
the
rule.
In
so
doing,
EPA
already
has
experience
in
interacting
with
the
22
States
to
transfer
emission
inventory
data
bases
and
has
resolved
difficulties
associated
with
electronic
submittals
of
emission
inventory
data.
Finally,
EPA
is
already
providing
States
with
data
reported
directly
by
point
sources
to
EPA.
Thus,
EPA
does
not
anticipate
any
additional
burden
associated
with
providing
States
with
directly
reported
point
source
emissions
data
which
States
will
need
to
prepare
their
summary
report
of
statewide
NOx
emissions
every
3
years.

Emissions
Trading
Program
The
primary
burdens
for
EPA
associated
with
the
implementation
of
the
trading
program
are
related
to
reviewing
permits,
certifying
monitors,
tracking
allowances
and
emissions
and
certifying
end
of
year
compliance.
Table
6­
8
summarizes
the
Agency
burden
and
costs
associated
with
administering
the
emission
trading
program
for
the
NOx
SIP
call
States,
as
well
as
for
processing
emissions
reported
under
§
51.122.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
number
of
State
respondents
is
estimated
to
be
22
jurisdictions,
including
21
States
and
the
District
of
Columbia..
The
number
of
industry
respondents
varies
depending
on
the
activity
in
question.
Activities
such
as
title
V
permit
application
or
precessing
allowance
transfers
can
involve
over
two
thousand
sources.
The
number
of
sources
which
will
be
required
to
install
a
particular
type
of
35
monitoring
equipment
will
be
less
since
many
sources
already
have
monitoring
equipment
especially
if
they
are
in
the
Ozone
Transport
Commission
region.
Tables
6­
2,
6­
3,
and
6­
4
give
estimates
of
State
burden.
These
burdens
include
preparation
of
the
SIP
revision
in
response
to
the
NOx
SIP
call,
activities
associated
with
participating
in
an
emissions
trading
program,
and
reporting
information
to
EPA
under
§
51.122
.
Tables
6­
5,
6­
6,
and
6­
7
give
estimates
of
industry
burden.
This
burden
includes
monitoring,
reporting
and
other
activities
involved
in
participating
in
an
emissions
trading
program.
The
total
average
number
of
respondents
is
estimated
to
be
2,831.

6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
(
i)
Respondent
Tally
Table
6­
1
summarizes
the
aggregate
burden
and
cost
estimates
to
respondents
from
2000
through
2002
for
collections
associated
with
implementation
of
the
NOx
SIP
call.
This
burden
includes
burden
on
States
and
industry
to
comply
with
requirements
imposed
by
the
SIP
call.
The
total
burden
for
2000,
2001,
and
2002
is
106,141
hours,
84,252
hours,
and
663,846
hours
respectively.
This
gives
an
average
burden
for
the
three
years
of
284,746
hours.
Since
the
burden
varies
by
year
during
the
startup
period,
the
burden
reported
on
the
form
OMB
83­
I
(
item
13)
is
the
average
of
the
burden
estimates
for
each
of
the
years
2000,
2001,
and
2002.

The
total
annualized
capital/
start­
up
cost
for
2000,
2001
and
2002
is
$
3,657,090,
$
4,158,
712
and
$
19,234,700
respectively.
This
gives
an
average
capital/
start
up
cost
for
the
three
years
of
$
9,016,834.
The
total
annual
O&
M
cost
for
2000,
2001
and
2002
is
$
2,486,400,
$
2,360,400,
and
$
15,164,200
respectively.
This
gives
an
average
O&
M
cost
for
the
three
years
of
$
6,670,333.

(
ii)
The
Agency
Tally
Table
6­
8
summarizes
the
aggregate
burden
and
cost
estimates
to
EPA
for
monitoring
certifications,
audits,
allowance
tracking
and
collection,
analysis,
and
storage
of
the
emissions
data
under
an
emissions
trading
program.
This
table
also
estimates
Agency
burden
for
processing
data
reported
by
States
under
§
51.122.
A
burden
estimate
is
made
for
the
Agency
review
of
the
NOx
SIP
revision
submissions
from
States
in
response
to
the
NOx
SIP
call.

(
iii)
Variations
in
the
Annual
Bottom
Line
There
is
a
substantial
amount
of
variation
in
the
years
2000­
2002
because
of
the
delayed
compliance
date
and
the
early
election
program.
Because
only
a
small
perentage
of
total
units
will
be
incurring
burdens
and
costs
in
2000
and
2001
for
most
required
activities,
the
total
cost/
burden
rises
steeply
in
2002.
After
the
program
is
fully
implemented,
annual
burdens
and
costs
are
expected
to
have
reduced
variation.
For
the
core
units
in
the
NOx
Trading
Program,
the
costs
and
burdens
in
2002
are
expected
to
see
the
highest
burdens
and
costs
because
of
several
one­
time
activities
required
near
36
the
start
of
the
program.
After
2002,
the
burdens
associated
with
permit
applications
and
start­
up
for
new
monitoring
or
DAHS
equipment
will
cease,
and
the
burdens
associated
with
reviewing
regulatory
requirements
and
debugging
computer
software
should
drop
sharply.
The
expected
reduction
in
burden
in
2003
from
these
activities
will
be
approximately
140,000
hours,
or
over
20%
of
the
total
burden
in
2002.

6(
f)
Reasons
for
Change
in
Burden
Not
applicable
since
this
is
a
new
ICR.

6(
g)
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;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
time
required
to
comply
with
this
information
collection
is
estimated
to
average
284,746
hours
per
year
over
the
next
three
years.
Table
6­
1.
Total
Estimated
Respondent
Burden
and
Cost
Summary,
2000
­
2002
Number
of
Respondents
Number
of
Activities
Total
Hours
per
Year
Total
Labor
Costs
per
Year
Total
Annual
Capital
Costs
Total
Annual
O&
M
Costs
Total
Annual
Costs
2000
State
Respondents
22
110
4,158
$
115,148
$
11,990
$
0
$
127,138
Industry
Respondents
2,415
3,558
101,983
$
5,213,475
$
3,645,100
$
2,486,400
$
11,344,975
Total
2,437
3,668
106,141
$
5,328,623
$
3,657,090
$
2,486,400
$
11,472,113
2001
State
Respondents
22
44
2,090
$
55,659
$
513,612
$
0
$
569,271
Industry
Respondents
2,850
5,539
82,162
$
4,171,507
$
3,645,100
$
2,360,400
$
10,177,007
Total
2,872
5,583
84,252
$
4,227,166
$
4,158,712
$
2,360,400
$
10,746,278
2002
State
Respondents
22
418
38,830
$
1,026,292
$
0
$
0
$
1,028,292
Industry
Respondents
3,163
14,553
625,016
$
31,109,025
$
19,234,700
$
15,164,200
$
65,509,925
Total
3,185
14,971
663,846
$
32,137,317
$
19,234,700
$
15,164,200
$
66,538,217
The
burden
calculated
in
this
table
is
for
NOx
SIP
call
as
published
in
the
final
rule
October
27,
1998
minus
the
State
of
Wisconsin
.
Table
6­
2
Annual
State
Respondent
Burden
and
Cost
by
Activity
for
Trading
Program,
2000
Annualized
Mgr.
Tech.
Capital/
Total
Total
Total
$
40.00
$
25.73
Respondent
Labor
Startup
Number
Labor
Labor
Capital
Total
/
Hour
/
Hour
Hours/
Year
Cost/
Year
Costs
of
hrs/
yr
cost/
yr
cost/
year
Cost/
Year
Information
Collection
Activity
2000
2000
2000
2000
2000
Respondents
2000
2000
2000
2000
State
Trading
Program
Activities
Read
regulations
16
16
32
$
1,052
$
0
22
704
$
23,137
$
0
$
23,137
Monitoring
certifications
AR­
OTC
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
AR­
NOTC
1
10
11
$
297
$
0
22
242
$
6,541
$
0
$
6,541
NAR­
OTC
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
NAR­
NOTC
3
48
51
$
1,355
$
0
22
1,122
$
29,811
$
0
$
29,811
Annual
auditing
costs
5
88
93
$
2,464
$
545
22
2,046
$
54,213
$
11,990
$
66,203
Subtotal
4,114
$
113,702
$
11,990
$
125,692
Information
Collection
Activities
for
§
51.122
One­
time
Read
the
reporting
requirements
of
the
rule
1
1
2
$
66
$
0
22
44
$
1,446
$
0
$
1,446
Submit
example
ozone
season
emissions
calculations
to
EPA
[
§
51.122(
g)]
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Modify
point,
area,
nonroad
mobile,
and
highway
mobile
source
data
bases
to
add
data
fields
for
additional
data
items
[
§
51/
122(
c).
(
d),
(
e)]
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Develop
procedures
by
which
to
estimate
area
source
NOx
emissions
for
triennial
statewide
reporting
requirements
[
§
51.122(
b)(
2),(
3)]
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Develop
procedure
for
generating
county
level
vehicle
miles
traveled
(
VMT)
[
§
51.

122(
b)(
2),(
3)]
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Project
2007area
nonroad
mobile,
and
highway
mobile
source
inventories
to
2008
to
satisfy
3­
year
cycle
requirement
[
§
51.122(
b)(
2),(
3)]
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Review
Title
V
permit
revisions
from
controlled
sources
[
§
51/
121(
h)(
1)]
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Annual
Determine
ozone
season
emissions
for
controlled
sources
[
§
51.122(
c)(
1).(
2)]
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Notify
the
apppropriate
EPA
Regional
Office
when
submitting
annual,
triennial,

and
2007
NOx
inventory
[
§
51/
122(
h)]
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Submit
electronic
NOx
budget
emissions
report
[
§
51.122(
b)(
1)]
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Triennial
Prepare
statewide
ozone
season
inventory
for
area
nonroad
mobile,
and
highway
mobile
sources,
including
a
determination
of
ozone
season
emissions
for
all
sources
[
§
51.122(
b)(
2)]
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Prepare
statewide
ozone
season
inventory
for
nonroad
mobile
sources,
including
a
determination
of
ozone
season
emissions
for
all
sources
[
§
51.122(
b)(
2)]
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Prepare
statewide
ozone
season
inventory
for
highway
mobile
sources,
including
a
determination
of
ozone
season
emissions
for
all
sources
[
§
51.122(
b)(
2)]
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Compile
summary
report
of
statewide
ozone
season
NOx
emissions
and
account
for
sources
that
have
been
reporting
directly
to
EPA
[
§
51.122(
b)(
2),(
h)]
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Subtotal
44
$
1,446
$
0
$
1,446
TOTAL
4,158
$
115,148
$
11,990
$
127,138
Table
6­
3.
Annual
State
Respondent
Burden
and
Cost
by
Activity
,
2001
Annualized
Mgr.
Tech.
Capital/
Total
Total
Total
$
40.00
$
25.73
Respondent
Labor
Startup
Number
Labor
Labor
Capital
Total
/
Hour
/
Hour
Hours/
Year
Cost/
Year
Costs
of
hrs/
yr
cost/
yr
cost/
year
Cost/
Year
Information
Collection
Activity
2001
2001
2001
2001
2001
Respondents
2001
2001
2001
2001
State
Trading
Program
Activities
Read
regulations
1
1
2
$
66
$
0
22
44
$
1,446
$
0
$
1,446
Monitoring
certifications
AR­
OTC
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
AR­
NOTC
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
NAR­
OTC
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
NAR­
NOTC
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Annual
auditing
costs
5
88
93
$
2,464
$
23,346
22
2,046
$
54,213
$
513,612
$
567,825
Subtotal
2,090
$
55,659
$
513,612
$
569,271
Information
Collection
Activities
for
§
51.122
One­
time
Read
the
reporting
requirements
of
the
rule
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Submit
example
ozone
season
emissions
calculations
to
EPA
[
§
51.122(
g)]
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Modify
point,
area,
nonroad
mobile,
and
highway
mobile
source
data
bases
to
add
data
fields
for
additional
data
items
[
§
51/
122(
c).
(
d),
(
e)]
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Develop
procedures
by
which
to
estimate
area
source
NOx
emissions
for
triennial
statewide
reporting
requirements
[
§
51.122(
b)(
2),(
3)]
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Develop
procedure
for
generating
county
level
vehicle
miles
traveled
(
VMT)
[
§
51.

122(
b)(
2),(
3)]
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Project
2007area
nonroad
mobile,
and
highway
mobile
source
inventories
to
2008
to
satisfy
3­
year
cycle
requirement
[
§
51.122(
b)(
2),(
3)]
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Review
Title
V
permit
revisions
from
controlled
sources
[
§
51/
121(
h)(
1)]
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Annual
Determine
ozone
season
emissions
for
controlled
sources
[
§
51.122(
c)(
1).(
2)]
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Notify
the
apppropriate
EPA
Regional
Office
when
submitting
annual,
triennial,
and
2007
NOx
inventory
[
§
51/
122(
h)]
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Submit
electronic
NOx
budget
emissions
report
[
§
51.122(
b)(
1)]
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Triennial
Prepare
statewide
ozone
season
inventory
for
area
nonroad
mobile,
and
highway
mobile
sources,
including
a
determination
of
ozone
season
emissions
for
all
sources
[
§
51.122(
b)(
2)]
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Prepare
statewide
ozone
season
inventory
for
nonroad
mobile
sources,
including
a
determination
of
ozone
season
emissions
for
all
sources
[
§
51.122(
b)(
2)]
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Prepare
statewide
ozone
season
inventory
for
highway
mobile
sources,
including
a
determination
of
ozone
season
emissions
for
all
sources
[
§
51.122(
b)(
2)]
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Compile
summary
report
of
statewide
ozone
season
NOx
emissions
and
account
for
sources
that
have
been
reporting
directly
to
EPA
[
§
51.122(
b)(
2),(
h)]
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Subtotal
0
$
0
$
0
$
0
TOTAL
2,090
$
55,659
$
513,612
$
569,271
Table
6­
4.
Annual
State
Respondent
Burden
and
Cost
by
Activity
,
2002
Annualized
Mgr.
Tech.
Capital/
Total
Total
Total
$
40.00
$
25.73
Respondent
Labor
Startup
Number
Labor
Labor
Capital
Total
/
Hour
/
Hour
Hours/
Year
Cost/
Year
Costs
of
hrs/
yr
cost/
yr
cost/
year
Cost/
Year
Information
Collection
Activity
2002
2002
2002
2002
2002
Respondents
2002
2002
2002
2002
State
Trading
Program
Activities
Read
regulations
1
1
2
$
66
$
0
22
44
$
1,446
$
0
$
1,446
Monitoring
certifications
AR­
OTC
1
13
14
$
374
$
0
22
308
$
8,239
$
0
$
8,239
AR­
NOTC
2
25
27
$
723
$
0
22
594
$
15,912
$
0
$
15,912
NAR­
OTC
1
18
19
$
503
$
0
22
418
$
11,069
$
0
$
11,069
NAR­
NOTC
14
269
283
$
7,481
$
0
22
6,226
$
164,590
$
0
$
164,590
Annual
auditing
costs
32
599
631
$
16,692
$
0
22
13,882
$
367,230
$
0
$
367,230
Subtotal
21,472
$
568,486
$
0
$
568,486
Information
Collection
Activities
for
§
51.122
One­
time
Read
the
reporting
requirements
of
the
rule
0
0
0
$
0
$
0
22
0
$
0
$
0
$
0
Submit
example
ozone
season
emissions
calculations
to
EPA
[
§
51.122(
g)]
1
10
11
$
297
$
0
22
242
$
6,541
$
0
$
6,541
Modify
point,
area,
nonroad
mobile,
and
highway
mobile
source
data
bases
to
add
data
fields
for
additional
data
items
[
§
51/
122(
c).
(
d),
(
e)]
3
60
63
$
1,664
$
0
22
1,386
$
36,604
$
0
$
36,604
Develop
procedures
by
which
to
estimate
area
source
NOx
emissions
for
triennial
statewide
reporting
requirements
[
§
51.122(
b)(
2),(
3)]
4
89
93
$
2,450
$
0
22
2,046
$
53,899
$
0
$
53,899
Develop
procedure
for
generating
county
level
vehicle
miles
traveled
(
VMT)
[
§
51.

122(
b)(
2),(
3)]
2
40
42
$
1,109
$
0
22
924
$
24,402
$
0
$
24,402
Project
2007area
nonroad
mobile,
and
highway
mobile
source
inventories
to
2008
to
satisfy
3­
year
cycle
requirement
[
§
51.122(
b)(
2),(
3)]
1
8
9
$
246
$
0
22
198
$
5,408
$
0
$
5,408
Review
Title
V
permit
revisions
from
controlled
sources
[
§
51/
121(
h)(
1)]
0
1
1
$
26
$
0
22
22
$
566
$
0
$
566
Annual
Determine
ozone
season
emissions
for
controlled
sources
[
§
51.122(
c)(
1).(
2)]
1
16
17
$
452
$
0
22
374
$
9,937
$
0
$
9,937
Notify
the
apppropriate
EPA
Regional
Office
when
submitting
annual,
triennial,
and
2007
NOx
inventory
[
§
51/
122(
h)]
1
0
1
$
40
$
0
22
22
$
880
$
0
$
880
Submit
electronic
NOx
budget
emissions
report
[
§
51.122(
b)(
1)]
0
1
1
$
26
$
0
22
22
$
566
$
0
$
566
Triennial
Prepare
statewide
ozone
season
inventory
for
area
nonroad
mobile,
and
highway
mobile
sources,
including
a
determination
of
ozone
season
emissions
for
all
sources
[
§
51.122(
b)(
2)]
8
160
168
$
4,437
$
0
22
3,696
$
97,610
$
0
$
97,610
Prepare
statewide
ozone
season
inventory
for
nonroad
mobile
sources,
including
a
determination
of
ozone
season
emissions
for
all
sources
[
§
51.122(
b)(
2)]
12
240
252
$
6,655
$
0
22
5,544
$
146,414
$
0
$
146,414
Prepare
statewide
ozone
season
inventory
for
highway
mobile
sources,
including
a
determination
of
ozone
season
emissions
for
all
sources
[
§
51.122(
b)(
2)]
8
120
128
$
3,408
$
0
22
2,816
$
74,967
$
0
$
74,967
Compile
summary
report
of
statewide
ozone
season
NOx
emissions
and
account
for
sources
that
have
been
reporting
directly
to
EPA
[
§
51.122(
b)(
2),(
h)]
1
2
3
$
91
$
0
22
66
$
2,012
$
0
$
2,012
Subtotal
17,358
$
459,807
$
0
$
459,807
TOTAL
38,830
$
1,028,292
$
0
$
1,028,292
Table
6­
5.
Annual
Industry
Respondent
Burden
and
Cost
by
Activity,
2000
Annualized
Mgr.
Tech.
Capital/
Total
$
66.05
$
45.44
Respondent
Labor
Startup
O
&
M
Number
of
Hours/
Total
/
Hour
/
Hour
Hours/
Year
Cost/
Year
Costs
Cost
Respondents
Year
Cost/
Year
Information
Collection
Activity
2000
2000
2000
2000
2000
2000
2000
2000
2000
Trading
units
Title
V
pemit
application
0
0
0
$
0
$
0
$
0
0
0
$
0
Permit
to
Construct
Application
20
20
40
$
2,230
$
0
$
0
112
4,480
$
249,738
Startup/
Capital
Items
(
Inc.
initial
cert.
for
new
equip.)

1.
AR­
NOTC
a.
NOx
and
Flow
CEMS
3
6
9
$
471
$
800
$
0
228
2,052
$
289,740
b.
NOx
CEMS
&
Fuelmeter
0
0
0
$
0
$
700
$
0
0
0
$
0
c.
App.
E
&
Fuelmeter
0
0
0
$
0
$
400
$
0
0
0
$
0
2.
NAR­
OTC
a.
NOx
and
Flow
CEMS
38
8
46
$
2,873
$
5,900
$
0
25
1,150
$
219,336
b.
NOx
CEMS
&
Fuelmeter
0
0
0
$
0
$
1,400
$
0
0
0
$
0
c.
App.
E
&
Fuelmeter
0
0
0
$
0
$
700
$
0
0
0
$
0
3.
NAR­
NOTC
a.
NOx
and
Flow
CEMS
72
10
82
$
5,210
$
29,600
$
0
112
9,184
$
3,898,720
b.
NOx
CEMS
&
Fuelmeter
0
0
0
$
0
$
23,400
$
0
0
0
$
0
c.
App.
E
&
Fuelmeter
0
0
0
$
0
$
3,600
$
0
0
0
$
0
EMISSIONS
MONITORING
Review
Instructions
and
Requirements
1.
NAR­
OTC
5
5
10
$
557
$
0
$
0
25
250
$
13,936
2.
NAR­
NOTC
0
0
0
$
0
$
0
$
0
0
0
$
0
3.
NAR­
NOTC
(
Early
Elec.
Units)
24
24
48
$
2,676
$
0
$
0
112
5,376
$
299,685
Respond
to
EPA
Generated
Error
Messages
1.
NAR­
NOTC
0
9
9
$
409
$
0
$
0
0
0
$
0
2.
NAR­
NOTC
(
Early
Elec.
Units)
4
8
12
$
628
$
0
$
0
112
1,344
$
70,305
Debug
Computer
Software
1.
NAR­
OTC
1
4
5
$
248
$
0
$
0
25
125
$
6,195
2.
NAR­
NOTC
0
0
0
$
0
$
0
$
0
0
0
$
0
3.
NAR­
NOTC
(
Early
Elec.
Units)
16
88
104
$
5,056
$
0
$
0
112
11,648
$
566,218
Certify
Existing
monitors
and
App.
E
Methods/
Recertify
Early
Elec.
Monitors
1.
NAR­
NOTC
a.
NOx
and
Flow
CEMS
0
0
0
$
0
$
0
$
2,800
0
0
$
0
b.
NOx
CEMS
&
Fuelmeter
0
0
0
$
0
$
0
$
2,800
0
0
$
0
c.
App.
E
0
0
0
$
0
$
0
$
10,000
0
0
$
0
2.
NAR­
NOTC
(
Early
Elec.
Units)
35
40
75
$
4,129
$
0
$
2,800
56
4,200
$
388,044
Peform
QA
Testing
and
Maintenance
1.
NAR­
NOTC
a.
NOx
and
Flow
CEMS
0
0
0
$
0
$
0
$
20,800
0
0
$
0
b.
NOx
CEMS
&
Fuelmeter
0
0
0
$
0
$
0
$
17,400
0
0
$
0
c.
App.
E
&
Fuelmeter
0
0
0
$
0
$
0
$
1,800
0
0
$
0
2.
NAR­
NOTC
(
Early
Elec.
Units)
40
400
440
$
20,818
$
0
$
20,800
112
49,280
$
4,661,216
Assure
Data
Quality,
Prepare
Reports
(
Inc.
monitor
plan
update),
Submit
Reports
1.
NAR­
NOTC
0
0
0
$
0
$
0
$
0
0
0
$
0
2.
NAR­
NOTC
(
Early
Election
Units)
20
52
72
$
3,684
$
0
$
0
112
8,064
$
412,595
Year
End
Compliance
Certification
0
0
0
$
0
$
0
$
0
0
0
$
0
Table
6­
5.
Annual
Industry
Respondent
Burden
and
Cost
by
Activity,
2000
Annualized
Mgr.
Tech.
Capital/
Total
$
66.05
$
45.44
Respondent
Labor
Startup
O
&
M
Number
of
Hours/
Total
/
Hour
/
Hour
Hours/
Year
Cost/
Year
Costs
Cost
Respondents
Year
Cost/
Year
Information
Collection
Activity
2000
2000
2000
2000
2000
2000
2000
2000
2000
Allowance
Transfers
1
1
2
$
111
$
0
$
0
2,415
4,830
$
269,248
Application
for
Early
Reduction
Credits
0
0
0
$
0
$
0
$
0
0
0
$
0
Subtotal
101,983
$
11,344,975
Non­
Trading
rule
units
1.
Read
the
reporting
requirements
0
0
0
$
0
$
0
$
0
352
0
$
0
2.
Revise
Title
V
operating
permit
0
0
0
$
0
$
0
$
0
352
0
$
0
3.
Perform
NOx
monitoring
activities
Cement
Plants
a.
Annual
testing
0
0
0
$
0
$
0
$
0
57
0
$
0
b.
Prepare
and
submit
reports,
monitoring
plan
update
0
0
0
$
0
$
0
$
0
57
0
$
0
IC
Engines
a.
Annual
testing
0
0
0
$
0
$
0
$
0
295
0
$
0
b.
Prepare
and
submit
reports,
monitoring
plan
update
0
0
0
$
0
$
0
$
0
295
0
$
0
Subtotal
0
$
0
TOTAL
101,983
$
11,344,975
Table
6­
6.
Annual
Industry
Respondent
Burden
and
Cost
by
Activity,
2001
Annualized
Mgr.
Tech.
Capital/
Total
$
66.05
$
45.44
Respondent
Labor
Startup
O
&
M
Number
of
Hours/
Total
/
Hour
/
Hour
Hours/
Year
Cost/
Year
Costs
Cost
Respondents
Year
Cost/
Year
Information
Collection
Activity
2001
2001
2001
2001
2001
2001
2001
2001
2001
Trading
units
Title
V
pemit
application
4
0
4
$
264
$
0
$
0
1156
4,624
$
305,415
Permit
to
Construct
Application
20
20
40
$
2,230
$
0
$
0
112
4,480
$
249,738
Startup/
Capital
Items
(
Inc.
initial
cert.
for
new
equip.)

1.
AR­
NOTC
a.
NOx
and
Flow
CEMS
0
0
0
$
0
$
800
$
0
228
0
$
182,400
b.
NOx
CEMS
&
Fuelmeter
0
0
0
$
0
$
700
$
0
0
0
$
0
c.
App.
E
&
Fuelmeter
0
0
0
$
0
$
400
$
0
0
0
$
0
2.
NAR­
OTC
a.
NOx
and
Flow
CEMS
38
8
46
$
2,873
$
5,900
$
0
25
1,150
$
219,336
b.
NOx
CEMS
&
Fuelmeter
0
0
0
$
0
$
1,400
$
0
0
0
$
0
c.
App.
E
&
Fuelmeter
0
0
0
$
0
$
700
$
0
0
0
$
0
3.
NAR­
NOTC
a.
NOx
and
Flow
CEMS
0
0
0
$
0
$
29,600
$
0
112
0
$
3,315,200
b.
NOx
CEMS
&
Fuelmeter
0
0
0
$
0
$
23,400
$
0
0
0
$
0
c.
App.
E
&
Fuelmeter
0
0
0
$
0
$
3,600
$
0
0
0
$
0
EMISSIONS
MONITORING
Review
Instructions
and
Requirements
1.
NAR­
OTC
1
1
2
$
111
$
0
$
0
25
50
$
2,787
2.
NAR­
NOTC
0
0
0
$
0
$
0
$
0
0
0
$
0
3.
NAR­
NOTC
(
Early
Elec.
Units)
4
4
8
$
446
$
0
$
0
112
896
$
49,948
Respond
to
EPA
Generated
Error
Messages
1.
NAR­
NOTC
0
0
0
$
0
$
0
0
0
$
0
2.
NAR­
NOTC
(
Early
Elec.
Units)
4
8
12
$
628
$
0
$
0
112
1,344
$
70,305
Debug
Computer
Software
1.
NAR­
OTC
1
4
5
$
248
$
0
$
0
25
125
$
6,195
2.
NAR­
NOTC
0
0
0
$
0
$
0
$
0
0
0
$
0
3.
NAR­
NOTC
(
Early
Elec.
Units)
4
12
16
$
809
$
0
$
0
112
1,792
$
90,662
Certify
Existing
monitors
and
App.
E
Methods/
Recertify
Early
Elec.
Monitors
1.
NAR­
NOTC
a.
NOx
and
Flow
CEMS
0
0
0
$
0
$
0
$
2,800
0
0
$
0
b.
NOx
CEMS
&
Fuelmeter
0
0
0
$
0
$
0
$
2,800
0
0
$
0
c.
App.
E
0
0
0
$
0
$
0
$
10,000
0
0
$
0
2.
NAR­
NOTC
(
Early
Elec.
Units)
35
40
75
$
4,129
$
0
$
2,800
11
825
$
76,223
Peform
QA
Testing
and
Maintenance
1.
NAR­
NOTC
a.
NOx
and
Flow
CEMS
0
0
0
$
0
$
0
$
20,800
0
0
$
0
b.
NOx
CEMS
&
Fuelmeter
0
0
0
$
0
$
0
$
17,400
0
0
$
0
c.
App.
E
&
Fuelmeter
0
0
0
$
0
$
0
$
1,800
0
0
$
0
2.
NAR­
NOTC
(
Early
Elec.
Units)
40
400
440
$
20,818
$
0
$
20,800
112
49,280
$
4,661,216
Table
6­
6.
Annual
Industry
Respondent
Burden
and
Cost
by
Activity,
2001
Annualized
Mgr.
Tech.
Capital/
Total
$
66.05
$
45.44
Respondent
Labor
Startup
O
&
M
Number
of
Hours/
Total
/
Hour
/
Hour
Hours/
Year
Cost/
Year
Costs
Cost
Respondents
Year
Cost/
Year
Information
Collection
Activity
2001
2001
2001
2001
2001
2001
2001
2001
2001
Assure
Data
Quality,
Prepare
Reports
(
Inc.
monitor
plan
update),
Submit
Reports
1.
NAR­
NOTC
0
0
0
$
0
$
0
$
0
0
0
$
0
2.
NAR­
NOTC
(
Early
Election
Units)
20
52
72
$
3,684
$
0
$
0
112
8,064
$
412,595
Year
End
Compliance
Certification
0
0
0
$
0
$
0
$
0
0
0
$
0
Allowance
Transfers
1
1
2
$
111
$
0
$
0
2850
5,700
$
317,747
Application
for
Early
Reduction
Credits
4
4
8
$
446
$
0
$
0
435
3,480
$
193,993
Subtotal
81,810
$
10,153,757
Non­
Trading
rule
units
1.
Read
the
reporting
requirements
1
0
1
$
66
$
0
$
0
352
352
$
23,250
2.
Revise
Title
V
operating
permit
0
0
0
$
0
$
0
$
0
352
0
$
0
3.
Perform
NOx
monitoring
activities
Cement
Plants
a.
Annual
testing
0
0
0
$
0
$
0
$
0
57
0
$
0
b.
Prepare
and
submit
reports,
monitoring
plan
update
0
0
0
$
0
$
0
$
0
57
0
$
0
IC
Engines
a.
Annual
testing
0
0
0
$
0
$
0
$
0
295
0
$
0
b.
Prepare
and
submit
reports,
monitoring
plan
update
0
0
0
$
0
$
0
$
0
295
0
$
0
Subtotal
352
$
23,250
TOTAL
82,162
$
10,177,007
Table
6­
7.
Annual
Industry
Respondent
Burden
and
Cost
by
Activity,
2002
Annualized
Mgr.
Tech.
Capital/
Total
$
66.05
$
45.44
Respondent
Labor
Startup
O
&
M
Number
of
Hours/
Total
/
Hour
/
Hour
Hours/
Year
Cost/
Year
Costs
Cost
Respondents
Year
Cost/
Year
Information
Collection
Activity
2002
2002
2002
2002
2002
2002
2002
2002
2002
Trading
units
Title
V
pemit
application
4
0
4
$
264
$
0
$
0
1157
4,628
$
305,679
Permit
to
Construct
Application
20
20
40
$
2,230
$
0
$
0
111
4,440
$
247,508
Startup/
Capital
Items
(
Inc.
initial
cert.
for
new
equip.)

1.
AR­
NOTC
a.
NOx
and
Flow
CEMS
2
4
6
$
314
$
800
$
0
573
3,438
$
638,242
b.
NOx
CEMS
&
Fuelmeter
3
4
7
$
380
$
700
$
0
16
112
$
17,279
c.
App.
E
&
Fuelmeter
3
4
7
$
380
$
400
$
0
98
686
$
76,431
2.
NAR­
OTC
a.
NOx
and
Flow
CEMS
13
3
16
$
995
$
5,900
$
0
75
1,200
$
517,123
b.
NOx
CEMS
&
Fuelmeter
3
6
9
$
471
$
1,400
$
0
251
2,259
$
469,568
c.
App.
E
&
Fuelmeter
3
6
9
$
471
$
700
$
0
86
774
$
100,688
3.
NAR­
NOTC
a.
NOx
and
Flow
CEMS
24
3
27
$
1,722
$
29,600
$
0
299
8,073
$
9,365,134
b.
NOx
CEMS
&
Fuelmeter
64
10
74
$
4,682
$
23,400
$
0
369
27,306
$
10,362,110
c.
App.
E
&
Fuelmeter
20
10
30
$
1,775
$
3,600
$
0
108
3,240
$
580,543
EMISSIONS
MONITORING
Review
Instructions
and
Requirements
1.
NAR­
OTC
5
5
10
$
557
$
0
$
0
412
4,120
$
229,669
2.
NAR­
NOTC
24
24
48
$
2,676
$
0
$
0
664
31,872
$
1,776,705
3.
NAR­
NOTC
(
Early
Elec.
Units)
4
4
8
$
446
$
0
$
0
112
896
$
49,948
Respond
to
EPA
Generated
Error
Messages
1.
NAR­
NOTC
4
8
12
$
628
$
0
$
0
664
7,968
$
416,806
2.
NAR­
NOTC
(
Early
Elec.
Units)
4
8
12
$
628
$
0
$
0
112
1,344
$
70,305
Debug
Computer
Software
1.
NAR­
OTC
1
4
5
$
248
$
0
$
0
412
2,060
$
102,098
2.
NAR­
NOTC
16
88
104
$
5,056
$
0
$
0
664
69,056
$
3,356,865
3.
NAR­
NOTC
(
Early
Elec.
Units)
4
12
16
$
809
$
0
$
0
112
1,792
$
90,662
Certify
Existing
monitors
and
App.
E
Methods/
Recertify
Early
Elec.
Monitors
1.
NAR­
NOTC
a.
NOx
and
Flow
CEMS
32
10
42
$
2,568
$
0
$
2,800
76
3,192
$
407,968
b.
NOx
CEMS
&
Fuelmeter
32
10
42
$
2,568
$
0
$
2,800
92
3,864
$
493,856
c.
App.
E
8
24
32
$
1,619
$
0
$
10,000
108
3,456
$
1,254,848
2.
NAR­
NOTC
(
Early
Elec.
Units)
35
40
75
$
4,129
$
0
$
2,800
11
825
$
76,223
Peform
QA
Testing
and
Maintenance
1.
NAR­
NOTC
a.
NOx
and
Flow
CEMS
40
400
440
$
20,818
$
0
$
20,800
223
98,120
$
9,280,814
b.
NOx
CEMS
&
Fuelmeter
20
375
395
$
18,361
$
0
$
17,400
369
145,755
$
13,195,809
c.
App.
E
&
Fuelmeter
5
30
35
$
1,693
$
0
$
1,800
108
3,780
$
377,293
2.
NAR­
NOTC
(
Early
Elec.
Units)
40
400
440
$
20,818
$
0
$
20,800
112
49,280
$
4,661,216
Assure
Data
Quality,
Prepare
Reports
(
Inc.
monitor
plan
update),
Submit
Reports
1.
NAR­
NOTC
20
52
72
$
3,684
$
0
$
0
664
47,808
$
2,446,096
2.
NAR­
NOTC
(
Early
Election
Units)
20
52
72
$
3,684
$
0
$
0
112
8,064
$
412,595
Year
End
Compliance
Certification
2
0
2
$
132
$
0
$
0
1610
3,220
$
212,681
Allowance
Transfers
1
1
2
$
111
$
0
$
0
2804
5,608
$
312,618
Application
for
Early
Reduction
Credits
4
4
8
$
446
$
0
$
0
435
3,480
$
193,993
Table
6­
7.
Annual
Industry
Respondent
Burden
and
Cost
by
Activity,
2002
Annualized
Mgr.
Tech.
Capital/
Total
$
66.05
$
45.44
Respondent
Labor
Startup
O
&
M
Number
of
Hours/
Total
/
Hour
/
Hour
Hours/
Year
Cost/
Year
Costs
Cost
Respondents
Year
Cost/
Year
Information
Collection
Activity
2002
2002
2002
2002
2002
2002
2002
2002
2002
Subtotal
551,716
$
62,099,371
Non­
Trading
rule
units
1.
Read
the
reporting
requirements
1
1
2
$
111
$
0
$
0
352
704
$
39,244
2.
Revise
Title
V
operating
permit
0
1
1
$
45
$
0
$
0
352
352
$
15,995
3.
Perform
NOx
monitoring
activities
0
Cement
Plants
a.
Annual
testing
0
160
160
$
7,270
$
0
$
0
57
9,120
$
414,413
b.
Prepare
and
submit
reports,
monitoring
plan
update
10
52
62
$
3,023
$
0
$
0
57
3,534
$
172,333
IC
Engines
a.
Annual
testing
0
140
140
$
6,362
$
0
$
0
295
41,300
$
1,876,672
b.
Prepare
and
submit
reports,
monitoring
plan
update
10
52
62
$
3,023
$
0
$
0
295
18,290
$
891,897
Subtotal
73,300
$
3,410,554
TOTAL
625,016
$
65,509,925
Table
6­
8.
Annual
Agency
Respondent
Burden
and
Cost
by
Activity,
2000­
2002
Hours
Hours
Hours
Other
Other
Other
$
40.00
$
40.00
$
40.00
Labor
Labor
Labor
Direct
Direct
Direct
Total
Total
Total
/
Hour
/
Hour
/
Hour
Cost/
Year
Cost/
Year
Cost/
Year
Costs
Costs
Costs
Costs
Costs
Costs
Information
Collection
Activity
2000
2001
2002
2000
2001
2002
2000
2001
2002
2000
2001
2002
Emission
trading
program
activities
Processing
Emissions
Data
224
224
1,624
$
8,960
$
8,960
$
64,960
$
0
$
0
$
0
$
8,960
$
8,960
$
64,960
'
Monitoring
recertifications
0
110
110
$
0
$
4,400
$
4,400
$
2,000
$
85,620
$
0
$
2,000
$
90,020
$
4,400
'
Allowance
tracking
system
3,630
3,630
3,630
$
145,200
$
145,200
$
145,200
$
170,000
$
170,000
$
170,000
$
315,200
$
315,200
$
315,200
'
Emissions
tracking
system
17,070
17,070
17,070
$
682,800
$
682,800
$
682,800
$
136,000
$
136,000
$
136,000
$
818,800
$
818,800
$
818,800
'
EPA
Permitting
0
1,156
1,157
$
0
$
46,240
$
46,280
$
1,040
$
44,522
$
0
$
1,040
$
90,762
$
46,280
§
51.122
activities
'
QA
and
input
data
0
0
1,373
$
0
$
0
$
54,920
$
0
$
0
$
55,000
$
0
$
0
$
109,920
TOTAL
20,924
22,190
24,964
$
836,960
$
887,600
$
998,560
$
309,040
$
436,142
$
361,000
$
1,146,000
$
1,323,742
$
1,359,560
A­
1
Appendix
A
to
the
ICR
Supporting
Statement:
Data
Items
Required
to
be
Reported
Electronically
for
the
NOx
Trading
Program
Under
the
Recordkeeping
and
Reporting
Sections
of
Part
75
This
Appendix
lists
the
sections
of
40
CFR
75
which
contain
NOx
mass­
related
data
elements
that
must
be
recorded
and
reported
electronically
under
the
rule.
These
sections
are:

C
Monitoring
Plan
Requirements
(
§
75.53)
C
General
Recordkeeping
Requirements
(
§
75.57)
C
Recordkeeping
For
Special
Situations
(
§
75.58)
C
Quality
Assurance
Recordkeeping
(
§
75.59)
C
Certification
Application
(
§
75.63)
C
Quarterly
Reports
(
§
75.64)
B­
1
Appendix
B
to
the
ICR
Supporting
Statement:
Other
Data
Items
Required
for
the
NOx
Trading
Program
Under
the
Recordkeeping
and
Reporting
Sections
of
Part
75
In
addition
to
the
data
collected
electronically
in
the
EDR,
the
following
additional
NOx
mass­
related
recordkeeping
and/
or
reporting
is
required
under
Part
75.
Items
which
must
be
recorded
and
kept
onsite
rather
than
reported/
submitted
to
the
Agency,
are
marked
with
an
asterisk.

Monitoring
Plan
Requirements
(
§
75.53):

C
Information,
including
identification
of
the
test
strategy;
protocol
for
the
relative
accuracy
test
audit;
other
relevant
test
information;
calibration
gas
levels
for
the
calibration
error
test
and
linearity
check;
calculations
for
determining
maximum
potential
concentration,
maximum
expected
concentration,
maximum
potential
flow
rate,
maximum
potential
NOx
emission
rate,
and
span;
and
apportionment
strategies
C
Description
of
site
locations
for
each
monitoring
component
in
the
continuous
emission
monitoring
systems
C
A
data
flow
diagram
denoting
the
complete
information
handling
path
from
output
signals
of
continuous
emission
monitoring
system
components
to
final
reports
C
A
schematic
diagram
identifying
entire
gas
handling
system
from
boiler
to
stack
for
all
affected
units
C
Stack
and
duct
engineering
diagrams
showing
the
dimensions
and
location
of
fans,
turning
vanes,
air
preheaters,
monitor
components,
probes,
reference
method
sampling
ports,
and
other
equipment
that
affects
the
monitoring
system
location,
performance,
or
quality
control
checks
General
Recordkeeping
Requirements
(
§
75.57):

C
Causes
of
any
missing
data
periods
and
the
actions
taken
to
cure
such
causes*

Recordkeeping
For
Special
Situations
(
§
75.58):

For
units
with
add­
on
NOx
emission
controls
following
the
provisions
of
§
75.34(
a)(
1)
or
(
a)(
2):

C
Parametric
data
which
demonstrate
the
proper
operation
of
the
add­
on
emission
controls*
C
A
flag
indicating
that
the
add­
on
emission
controls
are
operating
properly*
B­
2
Quality
Assurance
Recordkeeping
(
§
75.59):

For
calibration
error
tests
of
continuous
emission
or
flow
monitoring
systems:

C
Certification
from
the
cylinder
gas
vendor
or
CEMS
vendor
that
calibration
gas,
as
defined
in
the
applicable
sections
of
Part
75,
was
used
to
conduct
calibration
error
testing*
C
Description
of
any
adjustments,
corrective
actions,
or
maintenance
following
test*

For
daily
interference
checks
of
flow
monitoring
systems:

C
Description
of
any
adjustments,
corrective
actions,
or
maintenance
following
test*

For
relative
accuracy
test
audits:

C
Description
of
any
adjustments,
corrective
actions,
or
maintenance
following
test*
C
The
flow
polynomial
equation
used
to
linearize
the
flow
monitor
and
the
numerical
values
of
the
polynomial
coefficients
of
that
equation*

Other
required
quality
assurance
test
data
items:

C
Hardcopy
quality
assurance
relative
accuracy
test
reports,
certification
reports,
or
recertification
reports
for
pollutant
concentration
or
stack
flow
CEMS
including
test
results,
printouts,
reference
method
data,
equations,
calibration
gas
certificates,
laboratory
calibrations,
test
protocols,
diagrams,
and
names
of
personnel
involved
in
the
testing.
For
each
relative
accuracy
test
audit,
supporting
information
sufficient
to
substantiate
compliance
with
all
applicable
sections
and
appendices
in
this
Part.*
(
not
reported
unless
requested)
C
An
indication
of
which
data
have
been
excluded
from
the
quarterly
span
and
range
evaluations
of
the
NOX
monitor(
s)
and
the
reasons
for
excluding
the
data*

Excepted
monitoring
systems
for
gas­
fired
and
oil­
fired
units:

C
Test
results
for
each
transmitter
or
transducer
accuracy
test
for
an
orifice­,
nozzle­,
or
venturi­
type
flowmeter*
(
note:
test
summary
is
reported
electronically)
C
For
units
with
add­
on
NOx
emission
controls
following
the
provisions
of
§
75.34(
a)(
1)
or
(
a)(
2):
a
list
of
operating
parameters
for
the
add­
on
emission
controls,
and
the
range
of
each
operating
parameter
in
the
list
that
indicates
the
add­
on
emission
controls
are
properly
operating
B­
3
Notifications
(
§
75.61):

The
designated
representative
(
DR)
shall
submit
notification
for
the
following
events
on
an
as­
applicable
basis:

C
Initial
certification
tests,
recertification
tests,
new
unit/
stack,
unit
shutdown/
recommencement,
use
of
backup
fuels
for
Appendix
E
procedures,
combustion
of
emergency
fuels
under
Appendix
D
or
E.

Certification
Application
(
§
75.63):

Each
application
for
initial
certification
or
recertification
shall
contain
the
following
information,
as
applicable:

C
Certification
or
recertification
application
form
(
EPA
form
7610­
14)
C
The
results
of
the
test(
s)
required
by
§
75.20,
including
the
type
of
test
conducted,
testing
date,
information
required
by
§
75.56
or
§
75.59,
as
applicable,
and
the
results
of
any
failed
tests
that
affect
data
validation
C
Any
changed
portions
of
the
hardcopy
monitoring
plan
information
required
under
§
§
75.53(
c)
and
(
d),
or
§
§
75.53(
e)
and
(
f),
as
applicable
C
Designated
representative
signature
C
If
the
owner
or
operator
is
applying
to
use
the
optional
low
mass
emissions
excepted
methodology
in
§
75.19(
c)
in
lieu
of
a
certified
monitoring
system,
a
statement
that
the
unit
burns
only
natural
gas
or
fuel
oil
and
a
list
of
the
fuels
that
are
burned
or
a
statement
that
the
unit
is
projected
to
burn
only
natural
gas
or
fuel
oil
and
a
list
of
the
fuels
that
are
projected
to
be
burned;
a
statement
that
the
unit
meets
the
applicability
requirements
in
§
§
75.19(
a)
and
(
b);
and
any
unit
historical
actual
and
projected
emissions
data
and
calculated
emissions
data
demonstrating
that
the
affected
unit
qualifies
as
a
low
mass
emissions
unit
under
§
§
75.19(
a)
and
(
b)

Quarterly
Reports
(
§
75.64):

C
Compliance
certification
(
in
hardcopy
or
optionally
in
electronic
format)

Quality
Assurance/
Quality
Control
Program
(
Section
1
of
Appendix
B
to
Part
75)
B­
4
C
Written
QA/
QC
plan
that
describes
in
detail
(
or
that
refers
to
separate
documents
containing)
complete,
step­
by­
step
procedures
and
operations
For
preventative
maintenance,
quality
assurance
testing,
fuel
sampling
and
sample
retention*
C
Maintenance
records
of
all
testing,
maintenance,
and
repair
activities,
including:
date,
time,
and
description
of
any
testing,
adjustment,
repair,
replacement,
or
preventive
maintenance
action*
