INFORMATION COLLECTION REQUEST

FOR CHANGES TO

THE PART 70 OPERATING PERMIT REGULATIONS,

THE PART 71 OPERATING PERMIT REGULATIONS,

AND

THE PARTS 51 and 52 PREVENTION OF SIGNIFICANT DETERIORATION AND 

NONATTAINMENT NEW SOURCE REVIEW REGULATIONS

FOR FLEXIBLE AIR PERMITS

EPA ICRS Nos.

1587.08 for Part 70

1713.07 for Part 71

1230.20 for Parts 51 and 52

Prepared by:

Office of Policy, Economics, and Innovation

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue NW

Washington, D.C.  20460

and 

Office of Air Quality Planning and Standards

U.S. Environmental Protection Agency

Research Triangle Park, NC  27711

TABLE OF CONTENTS

1. 	Identification of the Information Collection	1

1.1  Title	1

1.2 Description	1

2. 	Need and Use of the Collection	5

2.1  Need/Authority for the Collection	5

2.2  Practical Utility/Users of the Data	6

2.3  Caveats and Considerations	7

Non-duplication, Consultation, and other Collection Criteria	8

3.1  Non-duplication	8

3.2  Public Notice Requirements	8

3.3  Consultations	8

3.4  Effects of Less Frequent Collection	9

3.5  General Guidelines	9

3.6  Confidentiality	9

3.7  Sensitive Questions	9

The Respondents and the Information Requested	10

4.1  Respondents	10

4.2  Information Requested	12

4.2.1  Data Items Submitted	12

4.2.2  Activities	13

The Information Collected - Collection Methodology

and Information Management	15

5.1   Collection Methodology and Management	15

5.2   Small Entity Flexibility   	15

5.3   Collection Schedule	15

TABLE OF CONTENTS

(continued)

Estimating the Burden and Cost of the Collection	17

6.1   Estimating the Number of Respondents	17

6.2   Estimating Burden	21

6.2.1    Estimating Source Burden	21

6.2.2    Estimating Permitting Authority Burden	26

6.2.3    Estimating EPA Burden	29

6.3   Estimating Costs	32

6.3.1    Estimating Source Costs 	32

6.3.2	Estimating Permitting Authority and Agency Burden 	33

6.3.3    Bottom Line Burden Hours and Costs	40

6.4.  Changes in the Burden	40

6.5   Burden Statement	40

       

TABLE OF CONTENTS

(continued)

Index of Tables 

Table 1    Industry Sources Likely to Seek Flexible Permits	11

Table 2    Data Items Submitted	12

Table 3    Activities	13

Table 4    Schedule for Data Items Submitted	16

Table 5    Number of Title V Sources Obtaining a Flexible Permit	18

Table 6    Source Respondent Burden Hours Under Parts 51/52 NSR
Regulations for Tier 1 Permits in Attainment Areas	23

Table 7    Source Respondent Burden Hours Under Parts 51/52 NSR
Regulations for Tier 1 Permits in Nonattainment Areas	24

Table 8    Source Incremental Burden Hour Reductions by Activity	25

Table 9    State and Local Permitting Authority Respondent Burden Hours
Under Parts 51/52 NSR Regulations for Tier 1 Permits in Attainment Areas
27

Table 10  State and Local Permitting Authority Respondent Burden Hours
Under Parts 51/52 NSR Regulations for Tier 1 Permits in Nonattainment
Areas	28

Table 11  State and Local Permitting Authority Incremental Burden Hour
Reductions by Activity	29

Table 12  Agency Burden Hours Under Parts 51/52 NSR Regulations for Tier
1 Permits	31

Table 13  Agency Incremental Burden Hour Reductions by Activity	32

Table 14  Source Burden and Cost, 2008-2010	34

Table 15  Permitting Authority Burden and Cost, 2008-2010	36

Table 16  Agency Burden and Cost, 2008-2010	38

Table 17  Bottom Line Burden and Costs (Cost Savings), 2008-2010	40

Table 18  Burden Statement	41

1	Identification of the Information Collection

1.1 	Title		This document fulfills the Agency's requirements under the
Paperwork Reduction Act (PRA) to determine the regulatory burden
associated with the promulgation of new regulations intended to clarify
and provide more certainty about how sources and permitting authorities
can use flexible air permitting approaches under the title I NSR Program
and the title V Operating Permit Program to authorize additions of new
capacity and different operations of existing equipment.  It has been
assigned EPA tracking numbers 1587.08, 1713.07, and 1230.20 because it
affects three existing, approved collections.  The title of this
Information Collection Request (ICR) is “Information Collection
Request for Changes to the Part 70 Operating Permit Regulations, the
Part 71 Operating Permit Regulations, and the Parts 51 and 52 Prevention
of Significant Deterioration and Nonattainment New Source Review
Regulations for Flexible Air Permits.”  This ICR modifies the
following three approved collections:  ICR #1587.07 titled “State
Operating Permit Regulations (40 CFR part 70)”; ICR #1713.06 titled "
Federal Operating Permit Regulations (40 CFR part 71)”; and ICR
#1230.19 titled “Prevention of Significant Deterioration and
Nonattainment New Source Review (40 CFR Parts 51 and 52).”  The
present ICR calculates the incremental burden and cost of flexible
permits as they relate to the baseline burden and cost estimated across
these three ICRs.

1.2	Description	Historically, title V of the Clean Air Act requires
States to develop and implement a program for issuing operating permits
to all sources that fall under the Act’s definition of major and
certain other non-major sources that are subject to Federal air quality
regulations.  The Act further requires EPA to develop regulations that
establish the minimum requirements for those State operating permit
programs and to oversee their implementation.  The EPA regulations
setting forth requirements for the State operating permit programs were
codified at 40 CFR part 70 on July 21, 1992.  In addition, the Act
requires EPA to administer an operating permit program in any State that
fails to develop and operate an acceptable program, as well as those
areas outside the jurisdiction of any State.  The Federal operating
permit program was codified at 40 CFR part 71 on July 1, 1996.

The major New Source Review (NSR) Program regulates emissions increases
due to new major sources and modifications at existing major sources in
an effort to achieve and maintain the National Ambient Air Quality
Standards (NAAQS).  Amendments enacted in 1990 to title I of the Clean
Air Act included changes to State and Federal programs for
preconstruction review and permitting of major new and modified sources
pursuant to part C “Prevention of Significant Deterioration” (PSD)
and part D “Program Requirements for Nonattainment Areas” (NA NSR). 
The EPA regulations setting forth requirements for the PSD and NA NSR
programs are codified at 40 CFR parts 51 and 52.  In December 2002, EPA
finalized the NSR Improvement Rule with regulations for plantwide
applicability limits (PALs), 67 FR 80186.  The Act also requires States
to implement a minor NSR program to address emissions from new sources
and modifications that are too small to be subject to major NSR (i.e.,
PSD and NA NSR).  The EPA regulations for these programs are codified in
40 CFR part 51.

In response to our experience in and evaluation of flexible permitting
techniques used in the last decade on a pilot permit basis, and
comments, discussions and recommendations from the public and
stakeholders, the EPA is proposing to revise regulations in the
operating permits program to facilitate use of these flexible permitting
techniques.  This rulemaking proposes several changes to the operating
permits and major NSR programs by:

Clarifying the scope of alternative operating scenarios (AOSs), which
were already included in the part 70/71 regulations but generally have
been interpreted and implemented narrowly;

Adding a definition for “approved replicable methodology” (ARM) in
the part 70/71 regulations to clarify the acceptability of operating
permit terms that allow a source to carry out calculations for
compliance and applicability purposes in a prescribed manner without the
need for a permit revisions; and

Adding provisions for “Green Groups” to the major NSR regulations
allowing a source to obtain a Green Group permit for a section of the
facility, which provides advance approval for a range of physical and
operational changes without further NSR review.

In addition, the preamble to this rulemaking discusses advance approval
of physical and operational changes under State minor NSR programs.  We
are not proposing any revisions to the regulations governing such
programs.

The following activities, which will occur during the period of this,
ICR include those activities that EPA estimates represent incremental
increases and decreases in burden associated with flexible permitting.

Parts 70 and 71

Flexible permitting sources applying for permit renewal

Permitting authorities and EPA renewing permits

Newly subject flexible permitting sources submitting permit applications

Permitting authorities and EPA reviewing applications for new permits

Flexible permitting sources working with permitting authorities and EPA
to prepare draft permits

EPA reviewing new or renewal permits issued by permitting authorities

Permitting authorities and EPA collaborating to support sources in the
development of their permits

Flexible permitting sources not needing to submit applications for
permit revisions

Permitting authorities and EPA not needing to process permit revisions

Permitting authorities revising their part 70 programs, where necessary



Parts 51 and 52

Permitting authorities working with their respective States to make
appropriate modifications to their State Implementation Plans (SIPs) 

Flexible permitting sources applying for PSD or NA NSR permits

Permitting authorities and EPA reviewing flexible permitting sources’
applications for PSD and NA NSR permits

Flexible permitting sources applying for minor NSR permits including
advance approvals and/or plantwide applicability limitations (PALs)

Permitting authorities reviewing flexible permitting sources’
applications for minor NSR permits including advance approvals and/or
PALs

Flexible permitting sources not needing to apply for  minor NSR permits

Permitting authorities not needing to process minor NSR permits

Flexible permitting sources avoiding subsequent PSD and NA NSR permits
during the permit term

Permitting authorities and EPA avoiding processing subsequent PSD and NA
NSR permits during the permit term

All of these data are made available for public review and comment.  The
activities to carry out these tasks are considered mandatory and
necessary for implementation of titles I and V and the proper operation
of the NSR and operating permits programs.  The information will also be
available for public inspection at any time in the offices of the
permitting authorities.  

The Agency anticipates total direct cost savings to subject sources
attributable to the changes to the part 70 permit program for flexible
air permits for the three years of the ICR to be approximately $24
million.  This represents the direct administrative cost savings for an
estimated 5,321 sources, of approximately $4,510 per source or 144 hours
per source during the period of this ICR.  The Agency estimates the cost
savings of the changes to the part 70 permit program for flexible air
permits for the three years of the ICR to permitting authorities to be
approximately $9.3 million, or $1,750 in cost savings due to 48 fewer
burden hours per source (or $83,000 cost savings attributable to 2,258
hours saved per permitting authority).  The Agency assumes that 90
percent of State and local part 70 programs already provide the legal
authority necessary to issue flexible permits.  The Agency estimates
costs to the Federal Government due to the changes to the part 70 permit
program for the three years of the ICR of approximately $1.2 million, or
$226 attributable to approximately 6 hours more worked per source.

The Agency anticipates total direct cost savings to subject sources
attributable to the changes to the part 71 permit program for flexible
air permits for the three years of the ICR to be approximately $146,000.
 These represent the direct administrative cost savings for an estimated
31 sources, or approximately $4,710 per source during the period of this
ICR or 148 hours saved per source.  Under the part 71 program, EPA is
the only permitting authority.  In this function, the Agency estimates
the Federal cost savings of the changes to the part 71 permit program
for flexible air permits for the three years of the ICR to be
approximately $56,500, or $1,800 in cost savings due to 49 fewer burden
hours per source (or $56,500 cost savings attributable to 1,526 hours
saved by the single Federal permitting authority).

The Agency anticipates total direct cost savings to subject sources
attributable to the changes to the parts 50 and 51 PSD/NSR program for
flexible air permits for the three years of the ICR to be approximately
$11.6 million.  These represent the direct administrative costs for the
estimated 1,774 sources, or approximately $6,500 in cost savings per
source during the period of this ICR, or 100 fewer burden hours per
source.  The Agency estimates the cost savings of the changes to the
parts 50 and 51 PSD/NSR program for flexible air permits for the three
years of the ICR to permitting authorities to be approximately $9.7
million, or $5,500 in cost savings attributable to 147 fewer burden
hours per source (or $86,600 attributable to 2,335 fewer hours worked
per permitting authority).  The Agency estimates Federal costs for
changes to the parts 50 and 51 PSD/NSR program for the three years of
the ICR will be approximately $237,500 to review minor and major NSR
permits during the term of this ICR, or $134 in costs attributable to
about 4 more burden hours per source (or $237,500 attributable to 6,560
more hours worked by the Agency, which is the lone Federal entity).   

2	Need and Use of the Collection

2.1	Need/Authority	In implementing title V of the Act and EPA’s part
70 operating permits 

for the 		regulations, State and local permitting authorities must
develop programs

Collection		and submit them to EPA for approval (section 502(d)). 
Sources subject to the program must prepare operating permit
applications and submit them to the permitting authority within one year
after approval of the program by EPA (section 503).  Permitting
authorities will then issue permits (section 503(c)) and thereafter
enforce, revise, and renew those permits at least every five years
(section 502(b)(5)).  Permit applications and proposed permits will be
provided to, and are subject to review by, EPA (section 505(a)).  The
permit and all information submitted by a source shall be available for
public review except for confidential information, which will be
protected from disclosure (section 503(e)), and the public shall be
given public notice of, and an opportunity for comment on, permit
actions (section 502(b)(6)).  Sources will submit monitoring reports
semi-annually and compliance certification reports annually to the
permitting authorities (section 503(b)(2)).  The EPA has the
responsibility to oversee implementation of the program (section
502(c)).  Sources seeking flexible air permits are subject to the same
requirements.  This ICR will address only the incremental burden and
cost associated with flexible permits.

Section 110 of the CAA requires all States to submit an implementation
plan which contains a preconstruction review program for all new or
modified stationary sources, including any provisions necessary for this
program to meet the specific requirements of parts C and D of title I of
the CAA related to construction of major sources and modifications. 
Part C, also known as the prevention of significant deterioration (PSD)
rules, outlines specific construction requirements for new and modified
sources constructing in attainment areas; and part D, also known as NA
NSR rules, provides requirements for sources constructing in
nonattainment areas.  The PSD rules require a demonstration of best
available technology (BACT) and that the NAAQS and increments will not
be exceeded, and the protection of Federal Class I areas from adverse
impacts.  The NSR rules require a demonstration of lowest achievable
emission rate (LAER), a certification that all major sources owned by
the same entity are in compliance, and compliance with specific
statutory offset ratios.  The requirements of the CAA for minor NSR
programs require much less prescriptive, requiring only that States
assure that new minor sources and minor modifications do not cause or
contribute to violation of the NAAQS.  This ICR will address the
incremental burden and cost associated with flexible permit sources that
seek minor a NSR, NA NSR, or PSD permit and also avoid future minor NSR,
NA NSR, and PSD permit processing.     

2.2	Practical		The burden estimates included in this ICR include the
total incremental

Utility/Users of	burden of implementing the parts 70 and 71 operating
permits program 

the Data 		and parts 51/52 New Source Review program for flexible air
permits.  For the three-year period covered by this ICR, all State part
70 operating permit programs (including those portions of States for
which an operating permits program is being implemented by a local
agency) have been submitted to EPA and have been granted full approval. 
The EPA part 71 program covers Indian country sources and source on the
Outer Continental Shelf.  All State and local agencies have approved
minor NSR and NA NSR programs, but several States have not developed PSD
programs; these States have been delegated authority to implement the
Federal PSD program of part 52 (referred to as “delegated States”). 
The EPA implements the part 52 program in Indian country.  When the
proposed rulemaking is finalized, all State and local agencies will need
to submit conforming revisions to their title I NA NSR programs to their
respective EPA Regional Offices for review and approval to implement
Green Group permits.  States with their own approved PSD programs
(referred to as “SIP-approved States”) will also need to revise
their title I PSD programs.  Based on our experience with flexible
permit pilots, we anticipate that most permitting authorities will be
able to issue flexible part 70 permits under their existing title V
operating permits program without revision.  (None of the permitting
authorities taking part in the pilot permitting projects were precluded
from issuing flexible permits by their part 70 programs.)  Nevertheless,
in order to estimate the burden to permitting authorities, we assume
that 10 percent of permitting authorities will need to revise their
part 70 programs.  These permitting authorities will be required to
submit their proposed revisions to their respective EPA Regional Offices
for review and approval.  We invite comment on our assumption that 10
percent of permitting authorities will have to revise their part 70
programs to be able to issue flexible permits as proposed.

For major sources to be constructed or modified in attainment or
nonattainment areas, the owner or operator of a facility must submit an
NSR or PSD application to the permitting authority.  Once the
application is complete, the permitting authority makes a preliminary
determination regarding the approvability of the permit application and
makes this determination, along with the application and supporting
information, available to the public for at least 30 days.  The public
then has an opportunity to comment on the provisions of the flexible
permit, the permitting authority will respond to public comments, and
take action on the final permit.  

  				

2.3	Caveats and		The information included in this ICR is based upon the
best data sources 

Considerations	available to the Agency at this time.  However,
incomplete information regarding how many sources may seek, and be
eligible for, flexible permits, and sampling limitations imposed upon
the Agency by the Paperwork Reduction Act necessitated a certain amount
of extrapolation and “best-guess” estimations by Agency experts. 
Consequently, the reader should not consider the conclusions to be an
exact representation of the level of burden or cost that will occur
during the three years of this ICR.  Instead, this ICR should be
considered a directionally correct assessment of the impact the flexible
air permitting approach of the operating permit program will have over
the next three years.  

Throughout this ICR, the reader will observe estimated values that show
accuracy to the single hour or dollar.  Because this ICR estimates the
expected impact of the flexible air permitting approaches on the
operating permit and NSR programs, reporting values at the single unit
value may be misleading.  In most situations, the proper way to present
estimated data would be to determine an appropriate level of precision
and truncate values accordingly, usually in terms of thousands or
millions of units.  To avoid the loss of information through rounding,
however, this ICR reports all values at the single unit level and
reminds the reader that there is no implied precision inherent in this
style of reporting of the impact the flexible air permitting approach of
the operating permit and NSR programs will have over the next three
years.

Finally, readers should note that many of the increases in burden under
the proposed rulemaking will occur in the first three years of
implementation, which are covered by this ICR,  while many of the
decreases in burden will continue beyond the period covered by this ICR.
 Consequently, this ICR does not present the full net burden reduction
that is expected to be achieved by this rulemaking.

3	Non-Duplication, Consultation, and Other Collection Criteria

3.1	Non-Duplication	While much of the information requested under this
ICR existed prior to the creation of the operating permits program, an
operating permit for flexible air permits is a compilation of existing
requirements; the purpose being to bring all requirements applicable to
a source into one document.  The intent of this compilation is to (1)
resolve any questions of applicability at the time of permit issuance,
(2) provide certainty to sources as to their obligations, and (3)
provide the public access to a source's obligations and compliance
status.  The Agency has no leeway to not require such previously
existing information under this ICR since consolidation of the
information into the operating permit and providing public access is the
whole purpose of the statute. 

The information collection activities required under the NSR regulations
are not routinely performed elsewhere by EPA.  However, similar
information may be collected during the development of certain
environmental impact statements (EIS).  In such cases, regulations and
policies require that information collected for EISs and NSR programs be
coordinated to the maximum extent possible so as to minimize duplicating
the collection of data.  Some of the required information also may
already be available from States or other federal agencies.  However,
even when these data are available, they are not generally adequate to
address completely the relevant NSR requirements.

3.2	Public Notice		 

Requirements		A public comment period will be provided after proposal,
during which all affected parties will be given the opportunity to
comment on the proposed changes.  All received comments will be
considered, and some may be reflected in the development of the final
regulatory language.

3.3	Consultations		In preparing this ICR, EPA relied on information
gathered for developing ICR #1587.06 titled “Information Collection
Request for Part 70 Operating Permit Regulations;” ICR #1713.05 titled
“Information Collection Request for Part 71 Operating Permit
Regulations;” ICR #2074.01 titled “Information Collection Request
for Changes to the 40 CFR Parts 51 and 52 PSD and NSR Applicability
Requirements for Modifications to Existing Sources;” and ICR #1230.17
titled “Information Collection Request for 40 CFR Parts 51 and 52
Prevention of Significant Deterioration and Nonattainment New Source
Review.”  EPA also employed information obtained from an in-depth
review of six pilot flexible permits.  After conducting our review, EPA
issued a report setting forth the results of the analysis.  A copy of
the report as well as individual pilot permit reviews can be found at: 
http://www.epa.gov/ttn/oarpg/t5pgm.html.

 													

3.4	Effects of Less	In general, the information collections included in
this ICR are one-time 

Frequent		submittals per activity (e.g., permit application, permit
issuance, permit

Collection		renewal).  The exceptions to this are avoided significant
and minor permit modifications under the operating permit program, which
EPA estimates at one significant modification per source per five years
and two to nine minor modifications per source per year;  avoided minor
NSR permits under the NSR program, which EPA estimates at zero to seven
per source per year; and avoided PSD/NSR permits under the NSR program,
which EPA estimates at one per source per five years.  See section 6.3
of this ICR for more information on these estimates.

 

3.5 	General 		  SEQ CHAPTER \h \r 1 None of the reporting or
recordkeeping requirements violate any of the 

Guidelines		regulations established by OMB at 5 CFR 1320.5.  Parts 51,
52, 70, and 71 require retention of all monitoring data and support
information and all permit applications, proposed permits, and final
permit records for a period of 5 years.  These records are necessary to
fulfill the intent of titles I and V to assure compliance with
applicable requirements.  Questions regarding the obligations of a
source and its status of compliance can be resolved through such
records. 		

3.6	Confidentiality	All information, other than confidential business
information, relating to the permitting of sources under the operating
permit and NSR programs and related to compliance monitoring are
required by section 503(e) of the Act to be subject to public review at
all times.  Section 70.4(b)(3)(viii) requires the permitting authority
to make available to the public any permitting information except that
entitled to protection from disclosure under section 114(c) of the Act. 
Protected information may be required to be submitted directly to EPA. 
Such information will be stored in EPA’s Confidential Business
Information office. 

3.7	Sensitive 		The consideration of sensitive questions (i.e., sexual,
religious, personal or

Questions		other private matters) is not applicable to the NSR or
operating permit programs.  The information gathered for purposes of
establishing an operating permit for a source do not include personal
data on any owner or operator.

4	The Respondents and the Information Requested

4.1	Respondents		Respondents to this information collection come from
two groups: permitting authorities (PAs) and sources required to obtain
an operating permit and/or NSR permit.

All States are required by title V to develop a part 70 operating
permits program.  In many instances, local agencies administer a program
in their jurisdiction in lieu of the State and are thereby subject to
the same program requirements as States.  In total, there are 112 State,
territorial, and local agencies administering operating permits
programs.  Approximately twelve PAs have already been involved in
developing flexible air permits for operating permit sources as part of
EPA’s pilot program.  For sources located in Indian country and the
Outer Continental Shelf, and when permitting authorities fail to
administer the part 70 operating permit program, EPA issues part 71
Federal operating permits.  

Under title V, all major stationary sources must obtain an operating
permit.  However, not all major sources will be interested in pursuing a
flexible air permit.  Based on EPA’s pilot experience, sources most
likely to benefit from comprehensive flexible permitting techniques
(e.g., Green Groups and advance approval of changes subject to minor
NSR) include those facilities with short time-to-market demands; the
need to accommodate rapid shifts of product lines, processes, and
production levels; active manufacturing programs that require rapid and
iterative changes to operations and equipment; upcoming renovation or
expansion projects; and active pollution prevention programs with
continuous process improvements.  Additional sources are likely to
benefit from simpler flexible permitting techniques, such as alternative
operating scenarios (AOSs) and approved replicable methodologies (ARMs)
that do not involve NSR.

Information provided to the EPA by permitting authorities indicates that
there were 17,434 sources subject to the operating permit program as of
December 2003, and the Agency estimates that 50 new sources become
subject each year.  Thus, when the period covered by this ICR begins
(calendar year 2008), EPA estimates that there will be 17,634 sources
subject to State and local part 70 programs.  EPA estimates that there
are 105 part 71 sources.  This results in an estimated total of 17,739
title V sources (i.e., the sum of part 70 and part 71 sources).      

 

To determine the overall number of major sources likely to benefit from
a flexible permit, EPA conducted the following analysis.  EPA identified
4,669 major air sources from the AIRS (Aerometric Information Retrieval
System) database that match the SIC codes identified in Table 1.  EPA
selected these SIC codes based on the types of sources that took part in
or inquired about pilots.  (Such sources benefit from the more
comprehensive flexible permits.) This represents approximately 26
percent of the total estimated sources subject to the operating permit
program (i.e., 4,669 potential flexible permit sources divided by 17,739
total parts 70/71 operating permit sources).  We do not believe that all
sources in these source categories share the characteristics of the
pilot sources, and therefore estimate that 10 percent of all sources
will seek comprehensive flexible permits involving a Green Group or
minor NSR advance approval.  We further estimate that an additional 20
percent of  all sources will seek simpler flexible permits that do not
involve NSR.  See section 6.1 and Table 5 for more detailed information
on the universe of respondents. 

Table 1

Industry Sources Likely to Seek Comprehensive Flexible Permits



Industry Group	

SIC	

NAICS



Aerospace Manufacturing	

372	

336411, 336412, 332912, 336411, 335413



Automobile Manufacturing	

371	

336111, 336112, 336712, 336211, 336992, 336322, 336312, 33633, 33634,
33635, 336399, 336212, 336213



Industrial Organic Chemicals 	

286	

325191, 32511, 325132, 325192, 225188, 325193, 32512, 325199 



Converted Paper and Paperboard Products	

267	

322221, 322222, 322223, 322224, 322226, 322231, 326111, 326112, 322299,
322291, 322232, 322233, 322211



Magnetic Tape Manufacturing	

369	

334613



Petroleum Refining	

291	

32411



Other Coating Operations	

226, 229, 251, 252, 253, 254, 267, 358, 363	

313311, 313312, 314992, 33132, 337122, 337121, 337124, 337215, 337129,
37125, 337211, 337214, 337127, 322221, 322222, 322226, 335221, 335222,
335224, 335228, 333312, 333415, 333319



Paper Mills	

262	

322121, 322122



Pharmaceutical Manufacturing	

283	

325411, 325412, 325413, 325414



Printing and Publishing	

275	

323114, 323110, 323111, 323113, 323112, 323115, 323119



Semiconductors	

367	

334413



Specialty Chemical Batch Processes	

282, 283, 284, 285, 286,287, 289, 386	

3251, 3252, 3253, 3254, 3255, 3256,

3259, except 325131 and 325181.



4.2	Information		This ICR reflects all information collection activities
associated with the

Requested		changes to parts 70 and 71 operating permit programs and
parts 51 and 52 NSR program arising from flexible air permits. 
Following are lists of the data items submitted by sources and
permitting authorities and program activities performed by permitting
authorities and sources.  These lists include only those items and
activities that represent the incremental burden impact associated with
flexible air permitting.

4.2.1	Data Items		Table 2 lists the data items submitted by sources and
permitting authorities

Submitted		that are relevant to flexible permitting and pursuant to the
requirements of the parts 70 and 71 operating permit program and parts
51/52 NSR program.

Table 2

Data Items Submitted



Citation	

Data Item	

Recipient(s)



Sources



Parts 70/71	

Application for permits and permit renewals	

EPA and

Permitting

Authorities



	

Significant Permit Modifications





Minor Permit Modifications

	

Parts 51/52	

Minor NSR Application





PSD Application





NSR Application

	

Permitting Authorities



Part 70	

Application for permits and permit renewals	

EPA

	

Draft/proposed permits or permit renewals





Final permits





Revisions to part 70 program (first  year only)

	

Parts 51/52	PSD Application



NSR Application



Revisions to SIP (first year only)

	

4.2.2	Activities		Table 3 lists activities relevant to flexible
permitting and pursuant to the requirements of parts 70/71 operating
permit program and parts 51/52 NSR program.

Table 3

Activities



Citation	Activities Relevant Under Traditional Permitting Scenario
Activities Relevant Under Flexible Permitting Scenario

Sources

Parts 70/71	Permit Application	Permit Application

	Draft Permit Preparation	Draft Permit Preparation

	Permit Renewal	Permit Renewal

	Significant Permit Modifications	Significant Permit Modifications

	Minor Permit Modifications

	Parts 51/52	Minor NSR	Minor NSR

	PSD 	PSD 

	NA NSR	NA NSR

Permitting Authorities

Part 70	Permit Application Review	Permit Application Review

	Draft Permit Preparation	Draft Permit Preparation

	Permit Renewal Preparation	Permit Renewal Preparation

	Interaction with EPA	Interaction with EPA

	Review of Significant Permit Modifications	Review of Significant Permit
Modifications

	Review of Minor Permit Modifications



	Revisions to part 70 program  (first year only)

Parts 51/52	Review of minor NSR permit applications



Review of PSD permit applications



Review of NA NSR permit applications



	Revisions to SIP (first year only)

EPA

Part 70	Proposed Permit Review	Proposed Permit Review

	Interaction with Permitting Authorities	Interaction with Permitting
Authorities

	Review of Significant Permit Modifications	Review of Significant Permit
Modifications



Review of part 70 revisions (second year only)

Part 71	Permit Application Review	Permit Application Review

	Draft Permit Preparation	Draft Permit Preparation

	Permit Renewal Preparation	Permit Renewal Preparation

	Review of Significant Permit Modifications	Review of Significant Permit
Modifications

	Review of Minor Permit Modifications

	Parts 51/52	Review of minor NSR permits	Review of minor NSR permits

	Review of PSD permits	Review of PSD permits

	Review of NA NSR permits	Review of NA NSR permits



Review of SIP revisions (second year only)

5	The Information Collected - Collection Methodology and Information
Management

5.1	Collection		The Agency will receive proposed permits or permit
revisions in hard copy

Methodology		or electronically, depending on permitting authority
capability.  Each EPA

and			Regional Office has determined with their permitting authorities
the most

Management		efficient system to exchange information.  There is no need
to maintain complete files of permit actions for public access since
these are maintained by permitting authorities.

5.2	Small Entity		EPA anticipates that small entities will not be
seeking flexible air permits. 

Flexibility		Therefore, in accordance with the analytical requirements
established under the Regulatory Flexibility Act (RFA) and the Small
Business Regulatory Enforcement Fairness Act (SBREFA), the Agency has
determined that there are no adverse effects to be identified vis a vis
small entities and small businesses.  

5.3	Collection		Table 4 below lists the items identified in section
4.2.1 and their schedule

Schedule		for  submission.



Table 4

Schedule for Data Items Submitted



Citation	

Data Item	

Schedule	

Recipient(s)



Sources	



Part 70	

Application for permits and permit renewals	

New permit applications: within one year after a source becomes subject
to the program.

Permit renewal applications: at least six months prior to the permit’s
expiration.	EPA and

Permitting Authorities

	

Significant Permit Modifications	No schedule; at each source’s
discretion.

	Parts 51/52	

PSD Application	

No schedule; at each source’s discretion dependent upon its
anticipated construction commencement date.	

EPA and

Permitting Authorities

	

NSR Application





Permitting Authorities	



Part 70	

Application for permits and permit renewals	

Submitted with the proposed permit or permit revision.	EPA

	

Draft/proposed permits or permit renewals	

Submitted when state wants to commence EPA review period.





Final permits	

Recommended soon after it is issued, but no formal deadline.





Revisions to part 70 program (first year only)	No schedule.  For the
purposes of this ICR, EPA assumes that 11  permitting authorities (i.e.,
10 percent of the 112) will modify their part 70 program in the
ICR’s first year.

	Parts 51/52	

Revisions to SIP (first year only)	

No schedule.  For the purposes of this ICR, EPA assumes that all 112
permitting authorities will modify their SIP in the ICR's first year.

	

6	Estimating the Burden and Cost of the Collection

6.1	Estimating 		There are 112 permitting authorities within the United
States.  Forty-nine

the Number of	states operate as permitting authorities, with California
employing 34 local

Respondents		air quality management organizations in lieu of a statewide
permitting authority.  Puerto Rico, the Virgin Islands, and Washington
D.C. all have operating permit programs, and there are 26 county or
regional permitting authorities within states that operate in a manner
similar to that of California. There are a similar number of State and
local reviewing authorities under minor and major NSR.

As described in section 4.1, EPA adopts the number of title V sources
identified in the part 70 and part 71 operating permits ICRs.  EPA
estimates that 10 percent of the total 17,739 existing sources subject
to title V (i.e., approximately 1,774 sources) will obtain a
comprehensive flexible permit (a “Tier 1” permit) over the course of
the three-year ICR period.  We define a Tier 1 flexible permit as one
that involves advance approval of physical or operational changes at the
source, utilizing either (1) a Green Group (which must be issued through
major NSR), or (2) a combination of minor NSR advance approvals with a
PAL or an emissions cap on potential emissions.  We further estimate
that an additional 20 percent of all existing sources and new sources
subject to title V (a total of approximately 3,578 sources) will seek
simpler flexible permits that incorporate alternative operating
scenarios (AOSs) and/or approved replicable methodologies (ARMs), but
not advance approval under major or minor NSR (“Tier 2” permits). 
Table 5 presents EPA’s estimate of the number of sources that will be
issued Tier 1 and Tier 2 flexible permits in each year of the three-year
ICR period.

         

Table 5

Number of Title V Sources Obtaining a Flexible Permit

Year	TIER 1	TIER 2	Total

	Green Groups	Minor NSR	Total Tier 1	Existing Sources	New Sources	Total
Tier 2



PSD	NA NSR	AAs1	NAAs2





	2008	45	0	222	222	489	1,064	9	1,073	1,223

2009	155	45	222	221	643	1,242	11	1,253	2,065

2010	154	45	221	222	642	1,242	10	1,252	2,064

TOTAL	354	90	665	665	1,774	3,548	30	3,578	5,352

1 Sources in attainment areas.

2 Sources in nonattainment area.



The figures in Table 5 are based on a number of assumptions.  The
following assumptions pertain to Tier 1 permits:

Approximately 25 percent of Tier 1 permits will be Green Group permits;
approximately 75 percent will be minor NSR/PAL/emissions cap permits. 
This assumption is based on the fact that most of the pilot permits were
of the latter type.

Of Green Group permits, approximately 80 percent will be PSD permits. 
Under the NA NSR Green Group regulations, sources must obtain offsets up
front for the full amount of the emissions increases allowed under the
Green Group permit although the emissions increases may occur up to 10
years later or not at all.  This makes Green Groups less attractive in
nonattainment areas.

Of the minor NSR/PAL/emissions cap Tier 1 permits, approximately half
will be issued to sources in attainment areas and half to sources in
nonattainment areas.  This estimate roughly mirrors the percentage of
the U.S. population that lives in ozone attainment and nonattainment
areas; there is no regulatory factor pushing in either direction.

All permitting authorities will have to revise their NA NSR programs,
and those with SIP-approved PSD programs will have to revise these
programs, to add provisions for Green Groups before they can issue any
Green Group permits.  These permitting authorities will revise their
SIPs in the first year of the three-year ICR period and begin issuing
Green Group permits in the second year.  Thus, no Green Group permits
will be issued under NA NSR in the first year of the ICR, and Green
Group permits will only be issued under PSD in those areas subject to
the Federal PSD program (i.e., delegated States, Indian country, and the
Outer Continental Shelf).  As indicated in the November 2002 ICR for the
NSR Improvement regulations, we assume that 38 percent of sources are
subject to the Federal PSD program.

No permitting authorities will need to revise their SIPs to be able to
issue minor NSR/PAL/emissions cap Tier 1 permits.  All permitting
authorities will begin issuing such permits in the first year covered by
this ICR.

Where there is no need for enabling SIP revisions, the permits will be
issued in equal numbers in each year covered by the ICR.  This is the
case for the minor NSR/PAL/emissions cap Tier 1 permits.  Where
permitting is constrained by the need for enabling SIP revisions in the
first year, the number of permits will increase in the second and third
years to reach the projected total for the entire three-year period of
the ICR.  This is the case for Green Group permits.

Based on the preceding assumptions, EPA estimates that there will be 45
Green Group permits issued in the first year covered by this ICR. This
was determined as follows.  An estimated total of 444 Green Group
permits will be issued in the three years of this ICR (i.e., 25 percent
of the estimated total of 1,774 Tier 1 permits).  In the absence of any
constraints, 148 Green Group permits would be issued (i.e., one third of
the 444 total Green Group permits).  However, Green Group permits will
be issued only through PSD permits (80 percent of all Green Group
permits) in areas subject to the Federal program (38 percent of PSD
sources).  This results in 45 Green Group permits in the first year (148
x 0.8 x 0.38 ( 45).  The 103 sources that are unable to obtain Green
Group permits in the first year will get them instead in the second and
third years.

The following assumptions pertain to the estimated numbers of Tier 2
permits in each of the three years covered by this ICR:

Of the 17,739 existing sources subject to title V at the outset of the
three-year period covered by this ICR, 20 percent (about 3,548) will
obtain Tier 2 permits during the period.  Of the 50 new sources that
become subject to title V each year, 20 percent will have Tier 2
features included in their initial permits (i.e., 10 per year for a
total of 30 over the three-year period of the ICR).

Ninety percent of permitting authorities will be able to issue Tier 2
permits without revising their part 70 programs; 10 percent will
determine that their program must be revised.  We estimate these
percentages based on the fact that all permitting authorities involved
in the pilot permits were able to issue such permits without rulemaking,
but believe it possible that some permitting authorities may believe
that program revisions are required to enable such permits.  The
permitting authorities that revise their part 70 programs will do so in
the first year of the three-year ICR period and begin issuing Tier 2
flexible permits in the second year.

As noted above for Tier 1 permits, where there is no need for enabling
program revisions, the permits will be issued in equal numbers in each
year covered by the ICR. Where permitting is constrained by the need for
enabling program revisions in the first year, the number of permits will
increase in the second and third years to reach the projected total for
the entire three-year period of the ICR.

Based on the preceding assumptions, EPA estimates that will be about
1,073 Tier 2 permits issued in the first year (to 1,064 existing sources
and 9 new sources).  This represents 90 percent of the sources that
would like to obtain such permits in the first year, accounting for the
estimated 10 percent of permitting authorities that undertake revisions
to their part 70 programs prior to issuing Tier 2 permits.  Those
sources that are unable to obtain Tier 2 permits in the first year are
assumed to get such permits in the second or third year covered by this
ICR.

6.2	Estimating	Burden means the total time, effort, or financial
resources expended by

Burden	persons to generate, maintain, retain, disclose or provide
information to or for a Federal agency.  This includes the incremental
time to develop a flexible air operating permit for facilities
interested in pursuing this option; as well as the incremental time
spent by permitting authorities and EPA to develop and ensure compliance
with the flexible permit.  The Agency estimates incremental burden based
on its experience with the flexible permitting pilot initiative and an
in-depth review of six pilot flexible permits.

    

6.2.1	Estimating 	To estimate the incremental source burden associated
with flexible air

Source 	permit preparation and applications, EPA assumes that flexible
permits 

Burden	fall into two tiers of permitting.  As discussed previously in
section 6.1, the so-called “Tier 1” flexibility provisions are more
complicated (i.e., include either a Green Group issued under major NSR
or a combination of minor NSR advance approvals and a PAL or cap on
potential emissions).  Accordingly, the Tier 1 permits entail a burden
under the NSR program to obtain the necessary NSR permit.  The estimated
 burden for these NSR permits varies depending on whether the permit is
a Green Group permit or a minor NSR permit, and depending on whether the
source is located in an attainment area or nonattainment area for the
pollutant(s) involved.  EPA’s estimates of the NSR permitting burden
associated with such permits are presented in Tables 6 and 7.  As shown
in the tables, for a PSD or NA NSR Green Group permit, we estimate a
relatively small increase in burden over the current burden for a PSD or
NA NSR permit.  In the case of a minor NSR permit for a Tier 1 permit,
we estimate a significant increase over the current burden for a minor
NSR permit, which is 40 hours.  We believe that in this situation, the
permitting process and burden for minor NSR permits for Tier 1 permits
will be more similar to major NSR permits than to typical minor NSR
permits.

In addition to the NSR permitting burden, we estimate that each source
will incur an incremental burden of 160 hours to add the NSR permit
terms and conditions to its title V permit and to supplement these
requirements with terms and conditions to address any other applicable
requirements and to create AOSs and ARMs as necessary, thereby creating
a Tier 1 flexible air permit. This may occur either through a
significant permit modification (SPM) or at the time of permit renewal. 
(New sources are not eligible for Green Group permits, and we believe it
unlikely that new sources will pursue Tier 1 permits through minor NSR
since new sources typically are permitted and built to handle
foreseeable growth.)  The current burden assigned to an SPM is
80 hours, but we believe that 160 hours is a better estimate for a
complicated, Tier 1 permit.  We estimate a similar incremental burden
for adding Tier 1 permit terms and conditions at the time of title V
permit renewal.

EPA estimates that there will be significant burden reduction after
issuance of Tier 1 flexible air permits.  We estimate that each source
with a Tier 1 permit will avoid one major NSR permit action in the five
years following issuance of the Tier 1 permit.  Each source also will
avoid the SPM that otherwise would have been required to add the major
NSR permit terms and conditions to its title V permit.  In addition, we
estimate that each source with a Tier 1 permit will avoid seven minor
NSR permit actions per year, and the seven title V minor permit
modifications (MPMs) that it would have otherwise needed to add the
minor NSR permit terms and conditions to it title V permit.  Finally, we
estimate that each source with a Tier 1 permit will avoid two additional
MPMs each year for changes at the source that do not involve minor or
major NSR.  Table 8 presents the incremental burden reduction for each
type of permit action avoided as a result of a flexible permit.

  SEQ CHAPTER \h \r 1 The so-called “Tier 2” flexible air permits
involve less complicated title V permit terms and conditions (e.g., AOSs
for known process changes, ARMs). They do not include advance approval
under minor or major NSR, and therefore do not result in any incremental
burden increases or decreases under the NSR program.  EPA estimates that
each source will incur an incremental burden of 80 hours to add Tier 2
flexibility features to its title V permit, thereby creating a Tier 2
flexible air permit.  For existing sources, this may be accomplished
either with an SPM or at the time of permit renewal.  New sources may
incorporate Tier 2 flexibility at initial permit issuance.  After a
source obtains a Tier 2 flexible permit, we estimate that it avoids two
MPMs per year.

The preceding burden estimates are based on EPA’s experience with
pilot permits.  We believe that our estimates of incremental burden
reduction are conservative in that our evaluation of six flexible permit
pilots describes the range of permit actions avoided from five for one
facility to 150 for another facility.   

  SEQ CHAPTER \h \r 1 Table 6

Source Respondent Burden Hours Under Parts 51/52 NSR Regulations for
Tier 1 Permits

 tc "Table 6-1

Industrial Respondent Burden and Cost (Annual) " \f D   in Attainment 
Areas

Activity	Current Burden per PSD Permit1	Burden per Green Group PSD
Permit	Burden per Minor NSR/ PAL/Cap Permit

Preparation and Planning

        Determination of Compliance Requirements	170	170	170

        Obtain Guidance on Data Needs	120	120	120

        Preparation of BACT Engineering Analysis	85	127	40

Data Collection and Analysis

        Air Quality Modeling	200	200	70

Determination of Impact on Air Quality Related Values	100	100	0

        Post-construction Air Quality Monitoring	50	50	0

Permit Application

        Preparation and Submittal of Permit Application	50	50	50

        Public Hearings	24	39	39

        Revisions to Permit	40	40	40

TOTAL	839	896	529

1 United States Environmental Protection Agency.  Information Collection
Request for 40 CFR Parts 51 and 52 Prevention of Significant
Deterioration and Nonattainment New Source Review.  ICR No. 1230.17. 
January 2005, page 17.



  SEQ CHAPTER \h \r 1 Table 7

Source Respondent Burden Hours Under Parts 51/52 NSR Regulations for
Tier 1 Permits

 tc "Table 6-1

Industrial Respondent Burden and Cost (Annual) " \f D   in Nonattainment
Areas

Activity	Current Burden per NA NSR Permit1	Burden per Green Group NA NSR
Permit	Burden per Minor NSR/ PAL/Cap Permit

Preparation and Planning

        Determination of Compliance Requirements	150	150	150

        Obtain Guidance on Data Needs	100	100	100

Data Collection and Analysis

        Preparation of LAER Engineering Analysis	40	40	20

        Demonstrate Offsets	40	40	0

        Prepare Analysis of Alternative Sites, Processes, etc.	60	60	0

        Air Quality Modeling	100	100	20

Permit Application

        Preparation and Submittal of Permit Application	38	38	38

        Public Hearings	25	40	40

        Revisions to Permit	24	24	24

TOTAL	577	592	392

1 United States Environmental Protection Agency.  Information Collection
Request for 40 CFR Parts 51 and 52 Prevention of Significant
Deterioration and Nonattainment New Source Review.  ICR No. 1230.17. 
January 2005, page 17.





Table 8

Source Incremental Burden Hour Reductions by Activity Avoided



Activity Avoided	

Current Burden1, 2	

Flexible Permitting Burden 	

Incremental Burden Reduction



Parts 70/71: Operating Permit Regulations



Significant Permit Modification	

80	

0	

-80



Minor Permit Modification	

40	

0	

-40



Parts 51/52



Minor NSR Permit	

40	

0	

-40



PSD Permit 	

839	

0	

-839



NA NSR Permit	

577	

0	

-577

1 Parts 70/71 current burdens from Information Collection Request for
Part 70 Operating Permit Regulations. ICR No. 1587.06.  United States
Environmental Protection Agency.  November 2004, page 16.

2 Parts 51/52 current burdens from Information Collection Request for 40
CFR Parts 51 and 52 Prevention of Significant Deterioration and
Nonattainment New Source Review.  ICR No. 1230.17.  United States
Environmental Protection Agency.  January 2005, page 17.



Additional assumptions or purposes of estimating burden reductions:

Sources with Tier 1 permits avoid one major NSR permit and one
associated SPM per five years.  For purposes of the three years covered
by this ICR, we assume that 20 percent of sources will avoid a major NSR
permit and SPM for each year that they have a Tier 1 permit.  Thus, of
sources that receive a Tier 1 permit in the first year under this ICR,
60 percent will avoid a major NSR permit and SPM over the course of the
three years covered by this ICR (i.e., 20 percent per year).  Forty
percent of the sources that receive Tier 1 permits in the second year
and 20 percent of the third year sources will avoid a major NSR permit
and SPM during the three years covered by this ICR.

Sources with Tier 1 permits avoid 7 minor NSR permits and 9 MPMs in each
full year after receiving the Tier 1 permit.  In the year that sources
receive a Tier 1 permit, we assume that they avoid an average of 3 minor
NSR permits and 4 MPMs to account for the fact that the Tier 1 permit
could be issued at any point in the year.  Similarly, for sources with
Tier 2 permits, we assume that they avoid 1 MPM in the year that they
receive the permit and 2 MPMs for each full year after that.

6.2.2	Estimating 	To estimate the incremental permitting authority
burden associated with 

Permitting	flexible permits, we begin again with the burden associated
with the NSR 

Authority	permits that underlie Tier 1 flexible air permits.  As
discussed in section 

Burden	6.2.1, there are four types of such NSR permits – Green Group
PSD permits, minor NSR permits in attainment areas, Green Group NA NSR
permits, and minor NSR permits in nonattainment areas.  EPA’s estimate
of the burden associated with these permitting actions, as compared with
the current burden for PSD and NA NSR permits, is presented in Tables 9
and10.

To complete a Tier 1 flexible permit, we estimate that permitting
authority will incur an incremental burden of 120 hours to incorporate
the NSR permit terms and conditions into the source’s title V permit
along with necessary additional title V flexibility terms and
conditions.  This title V permit action may occur through an SPM or at
the time of permit renewal.  The current burden associated with an SPM
is 60 hours, but be believe that intricacies of Tier 1 permits will
require additional effort.

After the added burden associated with issuing flexible permits,
permitting authorities will experience a significant burden reduction as
a result of major and minor NSR permits and the associated title V SPMs
and MPMs that will subsequently be avoided.  See section 6.2.1 above for
a discussion EPA’s estimate of the numbers of each such permitting
action that will be avoided by Tier 1 sources and, therefore, their
permitting authorities.  See Table 11 for our estimate of the
incremental burden reduction for permitting authorities when each type
of permit is avoided.  The same assumptions regarding the timing of
burden reductions presented at the end of section 6.2.1 apply also to
permitting authorities.

EPA estimates that permitting authorities will incur an incremental
burden of 60 hours for each source to which they issue a Tier 2
flexible air permit under title V.  For existing sources, this may be
accomplished either with an SPM or at the time of permit renewal.  New
sources may incorporate Tier 2 flexibility at initial permit issuance. 
After a source obtains a Tier 2 flexible permit, we estimate that it,
and the permitting authority avoid two MPMs per year.

EPA estimates that State and local permitting authorities will require
40 hours to prepare modifications to their SIPs to add Green Group NSR
provisions.  In addition, we estimate that 10 percent of permitting
authorities (i.e., 11 agencies) will determine that that they need to
revise their part 70 rules in order to be able to issue flexible title V
permits.  We estimate that this also will require 40 hours.  In both
cases, we estimate that the permitting authorities will complete and
their SIP and part 70 program revisions in the first year covered by
this ICR.

  SEQ CHAPTER \h \r 1 Table 9

State and Local Permitting Authority Respondent Burden Hours Under Parts
51/52 NSR Regulations for Tier 1 Permits tc "Table 6-1

Industrial Respondent Burden and Cost (Annual) " \f D   in Attainment
Areas

Activity	Current Burden per PSD Permit1	Burden per Green Group PSD
Permit	Burden per Minor NSR/ PAL/Cap Permit

Attend Preapplication Meetings	  SEQ CHAPTER \h \r 1 36	45	36

Answer Respondent Questions	20	25	20

Log In and Review Data Submissions	16	16	12

Request Additional Information 	8	8	6

Analyze for and Provide Confidentiality Protection	24	24	18

Prepare Completed Applications for Processing	32	40	32

File and Transmit Copies 	8	8	8

Prepare Preliminary Determination	24	30	24

Prepare Notices for and Attend Public Hearings	40	55	55

Application Approval	40	50	40

Notification of Applicant of PA Determination	8	8	8

Submittal  of Information  on BACT / LAER to RBLC	16	16	0

TOTAL	272	325	259

1 United States Environmental Protection Agency.  Information Collection
Request for 40 CFR Parts 51 and 52 Prevention of Significant
Deterioration and Nonattainment New Source Review.  ICR No. 1230.17. 
January 2005, page 18.





  SEQ CHAPTER \h \r 1 Table 10

State and Local Permitting Authority Respondent Burden Hours Under Parts
51/52 NSR Regulations for Tier 1 Permits  tc "Table 6-1

Industrial Respondent Burden and Cost (Annual) " \f D   in Nonattainment
Areas

Activity	Current Burden per NA NSR Permit1	Burden per Green Group NA NSR
Permit	Burden per Minor NSR/ PAL/Cap Permit

Attend Preapplication Meetings	  SEQ CHAPTER \h \r 1 7	9	7

Answer Respondent Questions	10	12	10

Log In and Review Data Submissions	8	8	6

Request Additional Information 	4	4	3

Analyze for and Provide Confidentiality Protection	4	4	3

Prepare Completed Applications for Processing	12	15	12

File and Transmit Copies 	4	4	4

Prepare Preliminary Determination	8	10	8

Prepare Notices for and Attend Public Hearings	18	33	33

Application Approval	16	20	16

Notification of Applicant of PA Determination	2	2	2

Submittal  of Information  on BACT / LAER to RBLC	16	16	0

TOTAL	109	137	104

1 United States Environmental Protection Agency.  Information Collection
Request for 40 CFR Parts 51 and 52 Prevention of Significant
Deterioration and Nonattainment New Source Review.  ICR No. 1230.17. 
January 2005, page 18



Table 11

State and Local Permitting Authority Incremental Burden Hour Reductions
by Activity Avoided



Activity Avoided	

Current Burden1, 2	

Flexible Permitting Burden 	

Incremental Burden Reduction



Part 70: Operating Permit Regulations



Significant Permit Modification	

60	

0	

-60



Minor Permit Modification	

20	

0	

-20



Parts 51/52



Minor NSR Permit	

30	

0	

-30



PSD Permit 	

272	

0	

-272



NA NSR Permit	

109	

0	

-109

1 Parts 70/71 current burdens from Information Collection Request for
Part 70 Operating Permit Regulations. ICR No. 1587.06.  United States
Environmental Protection Agency.  November 2004, page 16.

2 Parts 51/52 current burdens from Information Collection Request for 40
CFR Parts 51 and 52 Prevention of Significant Deterioration and
Nonattainment New Source Review.  ICR No. 1230.17.  United States
Environmental Protection Agency.  January 2005, page 18.



6.2.3	Estimating 	The EPA provides oversight to the NSR program,
reviewing major NSR 

EPA		permits and selected minor NSR permits.  Our estimate of the burden


Burden	incurred by the Agency associated with the review of the NSR
permits underlying Tier 1 flexible air permits is presented in Table
12.  

The EPA also provides oversight to the State and local permitting
authorities’ part 70 programs.  We estimate that that the Agency will
incur an average incremental burden of 20 hours in this role for each
Tier 1 part 70 permit flexible permit.  This total includes 16 hours to
review each such permit action (versus 8 hours to review a typical SPM).
 In addition, EPA typically consults with permitting authorities on
about 25 percent of SPMs.  We estimate that for Tier 1 permits such
consultations will require 16 hours (versus 8 hours for a typical SPM). 
Thus, consultations will average about 4 hour per Tier 1 permit.

After Tier 1 flexible permit have been issued, EPA will experience
incremental burden reductions associated with the major and minor NSR
permits and SPMs and MPMs that the sources with Tier 1 permits will
avoid in the ensuing years.  See Table 13 for our estimate of the
incremental burden reduction for EPA when each type of permit is
avoided.  See section 6.2.1 above for a discussion EPA’s estimate of
the numbers of each such permitting action that will be avoided by Tier
1 sources.  The same assumptions regarding the timing of burden
reductions presented at the end of section 6.2.1 apply also to EPA.

EPA estimates that the Agency will incur incremental burden averaging 10
hours for each Tier 2 flexible permit issued under part 70.  This is
comparable to the existing burden for an SPM (8 hours) plus an average
of 2 hours per permit incurred for consultations with the permitting
authority (consulting on 25 percent of the permits; 8 hours per
consultation).  After a source obtains a Tier 2 flexible permit, we
estimate that it, and the Agency, avoid action on two MPMs per year. 

The EPA also will be required to review and approve the SIP NSR
revisions and part 70 program revisions submitted by the permitting
authorities.  We estimate that they relatively minor changes will
require 5 hours of Agency review for each.  All permitting authorities
(112) will submit SIP revisions for NSR, while we estimate that 10
percent will (11) will submit part 70 program revisions.  The EPA will
incur a one-time burden to review these revisions in the second year of
this ICR.

In addition to EPA’s oversight role under part 70, the Agency acts as
a permitting authority under part 71.  In this role, EPA will experience
the same level of burden for each permitting action that is discussed
above in section 6.2.2.  EPA currently administers part 71 permits for
approximately 105 existing sources.  Thus, approximately 11 (i.e., 10
percent) are estimated to obtain Tier 1 flexible permits during the
three years covered by this ICR, and approximately 21 (i.e., 20 percent)
are estimated to obtain Tier 2 flexible permits during the period.

  SEQ CHAPTER \h \r 1 Table 12

Agency Burden Hours Under Parts 51/52 NSR Regulations for Tier 1
Permits

Activity	Current Burden per Major NSR Permit1	Burden per Green Group
Permit	Burden per Minor NSR/ PAL/Cap Permit

Attainment Areas

  SEQ CHAPTER \h \r 1 Review and Verify Applicability Determination	 
SEQ CHAPTER \h \r 1 2	2	2

  SEQ CHAPTER \h \r 1 Review Control Technology Determination	3	4	2

  SEQ CHAPTER \h \r 1 Evaluate Air Quality Monitoring 	4	4	0

  SEQ CHAPTER \h \r 1 Evaluate Alternative and Secondary Impact Analysis
2	2	2

  SEQ CHAPTER \h \r 1 Evaluate Class I Area Analysis	2	2	0

  SEQ CHAPTER \h \r 1 Administrative Tasks 	1	1	1

TOTAL	14	15	7

Nonattainment Areas

  SEQ CHAPTER \h \r 1 Review and Verify Applicability Determination	2	2
2

  SEQ CHAPTER \h \r 1 Review Control Technology Determination	3	4	2

  SEQ CHAPTER \h \r 1    SEQ CHAPTER \h \r 1 Evaluate Offsets	1	1	0

Evaluate Air Quality Monitoring   SEQ CHAPTER \h \r 1 	4	4	0

Evaluate Alternative and Secondary Impact Analysis   SEQ CHAPTER \h \r 1
	2	2	2

  SEQ CHAPTER \h \r 1 Administrative Tasks 	1	1	1

TOTAL	13	14	7

1 United States Environmental Protection Agency.  Information Collection
Request for 40 CFR Parts 51 and 52 Prevention of Significant
Deterioration and Nonattainment New Source Review.  ICR No. 1230.17. 
January 2005, page 18



Table 13

Agency Incremental Burden Hour Reductions by Activity Avoided



Activity Avoided	

Current Burden1, 2	

Flexible Permitting Burden 	

Incremental Burden Reduction



Part 70: Operating Permit Regulations



Significant Permit Modification	

10	

0	

-10



Minor Permit Modification	

1	

0	

-1



Parts 51/52



Minor NSR Permit3   SEQ CHAPTER \h \r 1 	

1	

0	

-1



PSD Permit 	

14	

0	

-14



NA NSR Permit	

13	

0	

-13

1 Parts 70/71 current burdens from Information Collection Request for
Part 70 Operating Permit Regulations. ICR No. 1587.06.  United States
Environmental Protection Agency.  November 2004, page 17.

2 Parts 51/52 current burdens from Information Collection Request for 40
CFR Parts 51 and 52 Prevention of Significant Deterioration and
Nonattainment New Source Review.  ICR No. 1230.17.  United States
Environmental Protection Agency.  January 2005, page 19.

3 Synthetic/netting-based minor NSR permits; about 4 percent of total
minor NSR permits.



6.3	Estimating Costs

6.3.1	Estimating	The purpose of this ICR is to estimate the incremental
change in burden 

Source	and cost as compared to the three approved collections that the
flexible air 

Costs		permits rulemaking will affect.  For this reason, EPA adopts the
source wage rates estimated in the approved collections for that portion
of the incremental burden that affects each respective collection.  That
is, we apply the source wage rate in the part 70 ICR renewal to the part
70 incremental burden hours, the part 71 wage rate to the part 71
incremental burden hours, and the parts 51/52 wage rate to the parts
51/52 incremental burden hours.  These hourly wages are as follows:

Part 70:  $32/hr based on in-house labor for all permitting task except
the initial permit applications.  For the initial permit application,
which applies only to new sources obtaining a Tier 2 permit, the wage
rate is $111/hr.

Part 71:  Same as part 70 rates.

Parts 51/52:  $65.50 based on a mix of contractor labor and in-house
labor for all tasks. 



		Section 6.2.1 above describes the incremental burden for each flexible
permitting source.  Table 14 below includes the total burden and cost
and the average annual burden and cost for Tier 1 and Tier 2 permits and
for each program (parts 51/52, part 70, and part 71) 

6.3.2	Estimating 	To best compare the incremental impacts to the
existing, approved 

Permitting	collections, EPA adopts the permitting authority wage rates
estimated in the 

Authority	respective approved collections.  Similarly, we adopt the
labor rates for 

and Agency	EPA used in each of these existing, approved ICRs.  These
rates are as 

Burden	follows:

Part 70:  $37/hr for both permitting authorities and EPA.

Part 71:  Same as part 70 rates.

Parts 51/52:  $43.53 for permitting authorities; $36.21 for EPA.

Sections 6.2.2 and 6.2.3 above describe the incremental burden
associated with flexible permitting for permitting authorities and EPA. 
Tables 15 and 16 below include the permitting burden in hours and costs
for permitting authorities and EPA.  

Table 14

Source Burden and Cost, 2008-2010

Information Collection Activity	Incremental Burden

(hr/activity)	No. of Respondents/Frequency	Labor Cost ($/hr)	Total Hours
Total Cost

($)	Annual Hours	Annual Cost

($)



2008	2009	2010







	TIER 1 FLEXIBLE PERMITS

Parts 51/52:  NSR Regulations

Green Group – PSD	896	45	155	154	65.50	317,184	20,775,552 	    105,728
	6,925,184 

Minor NSR – AA	529	222	222	221	65.50	351,785	  23,041,918 	    117,262
	7,680,639 

Green Group – NA NSR	592	0	45	45	65.50	53,280	3,489,840 	   17,760 
1,163,280 

Minor NSR - NAA	392	222	221	222	65.50	260,680	  17,074,540 	      
86,893 	5,691,513 

PSD avoided (1 in 5 yrs)1	-839	160	151	75	65.50	-323,854	-21,212,437
-107,951	-7,070,812

NAA NSR avoided (1 in 5 yrs)2	-577	133	106	54	65.50	-169,061	-11,073,496
-56,354	-3,691,165

Minor NSR avoided (7/yr)3	-40	8,313	6,430	1,926	65.50	-666,760
-43,672,780	-222,253	-14,557,593

NSR SUBTOTAL





-176,746	-11,576,863	-58,915	-3,858,954

Parts 70/71:  Title V Regulations

Tier 1 Flexible Air Permit	160	489	643	642	32	       283,840 	9,082,880	
    94,613 	3,027,627

SPM avoided (1 in 5 yrs)4	-80	294	257	128	32	-54,320	-1,738,240	-18,107
-579,413

MPM avoided (9/yr)5	-40	10,758	8,359	2,568	32	-867,400	-27,756,800
-289,133	-9,252,267

TITLE V SUBTOTAL





-637,880	-20,412,160	-212,627	-6,804,053

TIER 1 TOTAL





-814,626

-271,542

	TIER 2 FLEXIBLE PERMITS

Parts 70/71:  Title V Regulations

Tier 2 Flexible Permit – new sources	80	9	11	10	111	2,400	266,400	800
88,800

Tier 2 Flexible Permit – existing sources	80	1,064	1,242	1,242	32
283,840	9,082,880	94,613	3,027,627

MPM avoided (2/yr)6	-40	5,365	3,759	1,252	32	-415,040	-13,281,280
-138,347	-4,427,093

TIER 2 TOTAL – Parts70/71





-128,800	-3,932,000	-42,933	-1,310,667

TOTALS BY PROGRAM

Parts 51/52:  NSR Regulations





-176,746	-11,576,863	-58,915	-3,858,954

Parts 70/71:  Title V Regulations





-766,680	-24,344,160	-255,560	-8,114,720

Part 70 alone7





-775,880	-24,198,095	-254,027	-8,066,032

Part 71 alone7





-4,600	-146,065	-1,533	-48,688

1 2008:  (Green Group PSD + minor NSR AA) x 0.6.  2009 uses 0.4 factor,
2010 uses 0.2.  

2 2008:  (Green Group NAA NSR + minor NSR NAA) x 0.6.  2009 used 0.4;
2010 uses 0.2.

3 1st year of permit, average of 3 minor NSR permits avoided (to account
for when in the year the Tier 1 permit was issued).  Source permitted in
2008 avoids 17 minor NSR permits over the course of the 3-year ICR.  

4 2008:  Total Tier 1 permits x 0.6.  2009 uses 0.4 factor, 2010 uses
0.2.  

5 1st year of permit, average of 4 MPMs avoided (to account for when in
the year the Tier 1 permit was issued).  Source permitted in 2008 avoids
22 MPMs over the course of the 3-year ICR.  

6 1st year of permit, average of 1 MPM avoided (to account for when in
the year the Tier 2 permit was issued).  Source permitted in 2008 avoids
5 MPMs over the course of the 3-year ICR.  

7 Calculated using ratio of part 71 permits to all title V permits
(105/17,739 = 0.006) to apportion the total for parts 70/71 to part 70
and part 71.

 



Table 15

Permitting Authority Burden and Cost, 2008-2010

Information Collection Activity	Incremental Burden

(hr/activity)	No. of Respondents/Frequency	Labor Cost ($/hr)	Total Hours
Total Cost

($)	Annual Hours	Annual Cost

($)



2008	2009	2010







	TIER 1 FLEXIBLE PERMITS

Parts 51/52:  NSR Regulations

Green Group – PSD	325	45	155	154	43.53	       115,050 	5,008,127 
38,350 	1,669,376 

Minor NSR – AA	259	222	222	221	43.53	       172,235 	7,497,390 	     
57,412 	2,499,130 

Green Group – NA NSR	137	0	45	45	43.53	        12,330 	536,725 	     
4,110.0 	178,908 

Minor NSR - NAA	104	222	221	222	43.53	        69,160 	3,010,535 	      
23,053 	1,003,512 

PSD avoided (1 in 5 yrs)	-272	160	151	75	43.53	-104,992	-4,570,302
-34,997	-1,523,434

NAA NSR avoided (1/5yrs)	-109	133	106	54	43.53	-31,937	-1,390,218
-10,646	-463,406

Minor NSR avoided (7/yr)	-30	8,313	6,430	1,926	43.53	-500,070
-21,768,047	-166,690	-7,256,016

SIP revisions	40	112	0	0

4,480	195,014	1,493	65,005

NSR SUBTOTAL





-263,744	-11,480,776	-87,915	-3,826,925

Parts 70/71:  Title V Regulations

Tier 1 Flexible Air Permit	120	489	643	642	37	       212,880 	7,876,560	
    70,960 	2,625,520

SPM avoided (1 in 5 yrs)	-60	294	257	128	37	-40,740	-1,507,380	-13,580
-502,460

MPM avoided (9/yr)	-20	10,758	8,359	2,568	37	-433,700	-16,046,900
-144,567	-5,348,967

Part 70 revisions (10%)1	40	11	0	0	37	440	16,280	147	5,427

TITLE V SUBTOTAL





-261,560	-9,677,720	-87,187	-3,225,907

TIER 1 TOTAL





-525,304

-175,101

	TIER 2 FLEXIBLE PERMITS

Parts 70/71:  Title V Regulations

Tier 2 Flexible Permit – new sources	60	9	11	10	37	1,800	66,600	600
22,200

Tier 2 Flexible Permit – existing sources	60	1,064	1,242	1,242	37
212,880	7,876,560	70,960	2,625,520

MPM avoided (2/yr)	-20	5,365	3,759	1,252	37	-207,520	-7,678,240	-69,173
-2,559,413

TIER 2 TOTAL – Parts70/71





7,160	264,920	2,387	88,307

TOTALS BY PROGRAM

Parts 51/52:  NSR Regulations





-261,560	-9,677,720	-87,187	-3,225,907

Parts 70/71:  Title V Regulations





-254,400	-9,412,800	-84,800	-3,137,600

Part 70 alone





-252,874	-9,356,323	-84,291	-3,118,774

Part 71 alone2





-1,526	-56,477	-509	-18,826

1 EPA assumes that 10% of permitting authorities will determine that
part 70 program revisions are necessary.

2 These values represent EPA burden and costs in its role as the part 71
permitting authority.  It is calculated based on the ratio of part 71
permits to all title V permits as explained in Note 7 on Table 14. 
These values are reproduced in Table 16.

See the notes on Table 14 for explanation of other calculations.



Table 16

Agency Burden and Cost, 2008-2010

Information Collection Activity	Incremental Burden

(hr/activity)	No. of Respondents/Frequency	Labor Cost ($/hr)	Total Hours
Total Cost

($)	Annual Hours	Annual Cost

($)



2008	2009	2010







	TIER 1 FLEXIBLE PERMITS

Parts 51/52:  NSR Regulations – oversight

Green Group – PSD	15	45	155	154	36.21	          5,310 	192,275 	      
  1,770 	64,092 

Minor NSR – AA	7	222	222	221	36.21	          4,655 	168,558 	        
1,552 	56,186 

Green Group – NA NSR	14	0	45	45	36.21	          1,260 	45,625 	       
    420 	15,208 

Minor NSR - NAA	7	222	221	222	36.21	          4,655 	168,558 	        
1,552 	56,186 

PSD avoided (1 in 5 yrs)	-14	160	151	75	36.21	-5,404	-195,679	-1,801
-$65,226

NAA NSR avoided (1/ 5 yrs)	-13	133	106	54	36.21	-3,809	-137,924	-1,270
-45,975

Minor NSR avoided (7/yr)1	-1	333	257	77	36.21	-667	-24,143	-222	-8,048

Reviewing SIP revisions	5	0	112	0	36.21	560	20,278	187	6,759

NSR SUBTOTAL





6,560	237,546	2,187	79,182

Part 70:  Title V Regulations - oversight

Tier 1 Flexible Air Permit	20	489	643	642	37	        35,480 	1,312,760	 
   11,827 	437,587

SPM avoided (1 in 5 yrs)	-10	294	257	128	37	-6,790	-251,230	-2,263
-83,743

MPM avoided (9/yr)	-1	10,758	8,359	2,568	37	-21,685	-802,345	-7,228
-267,448

Part 70 revisions (10%)	5	0	11	0	37	55	2,035	18	678

TITLE V SUBTOTAL





7,005	259,185	2,335	86,395

TIER 1 TOTAL





13,565

4,522

	TIER 2 FLEXIBLE PERMITS

Part 70:  Title V Regulations - oversight

Tier 2 Flexible Permit – new 	10	9	11	10	37	300	11,100	100	3,700

Tier 2 Flexible Permit – existing	10	1,064	1,242	1,242	37	35,480
1,312,760	11,827	437,587

MPM avoided (2/yr)	-1	5,365	3,759	1,252	37	-10,376	-383,912	-3,459
-127,971

TIER 2 TOTAL – Parts70/71





25,404	939,948	8,468	313,316

PART 71:  PERMITTING AUTHORITY ROLE

Part 71 permitting for Tier 1 and Tier 2 flexible permits2	-1,526
-56,477	-509	-18,826

TOTALS BY PROGRAM

Parts 51/52:  NSR Oversight





6,560	237,546	2,187	79,182

Part 70:  Title V Oversight





32,409	1,199,133	10,803	399,711

Part 71:  Permitting authority2





-1,526	-56,477	-509	-18,826

1 EPA typically reviews only about 4% of minor NSR permits, where they
involve synthetic minors or netting.  Thus, the overall number of such
permits is multiplied by this factor.

2These values are calculated as 0.6% of the permitting authority burden
and cost for all title V permits based on the ratio of part 71 permits
to all title V permits (see Table 15).  

See the notes on Tables 14 and 15 for explanation of other calculations.

6.3.3	Bottom 	Tables 6 through 13 display the activities of the parts
70/71 and 

Line  		parts 51/52program for flexible permits for sources, permitting
authorities, 

Burden	and the Federal government.  Tables 14, 15, and 16 display the
costs 

Hours and	associated with each of these categories.  Table 17 below
summarizes the 

Costs		estimated incremental burden and costs for sources, permitting
authorities, and the Federal government for implementation of flexible
air permitting approaches under the title I NSR Program and the title V
Operating Permit Program for the years 2008 through 2010.

Table 17

Bottom Line Burden and Costs (Cost Savings), 2008-2010

2008-2010



Respondent	Total Hours	Total Cost

Sources	(943,000)	($36 million)

Permitting Authorities	(514,000)	($19 million)

EPA	37,000	$1.4 million



6.4	Changes in	The activities associated with implementing flexible
permits under  

the Burden	parts 70/71 and parts 51/52 represent incremental increases
and decreases in the burdens associated with conventional permitting. 
Tables 6 through 13 provide, for sources, permitting authorities, and
EPA, detailed burden hour increases and decreases by activity.

6.5	Burden	It is impractical to attempt to delineate burden by
respondent and activity

Statement	due to uncertainties associated with the number of potential
respondents, the variation in the circumstances for each respondent, and
the varied nature of the activities of the program.  Following is the
apportioned burden for each respondent.  This is derived from the total
permitting authority hourly burden divided by the number of permitting
authorities, and similarly for sources. 



Table 18

Burden Statement

Costs (Cost Savings)



	

Number of Respondents	

2008-2010

Total Burden

(Cost Savings)	

2008-2010

Burden per Respondent

(Cost Savings)



Part 70



Sources	

5,321	

($24 million)	

($4,510)



Permitting Authorities	

112	

($9.3 million)	

($83,000)



Federal 	

1	

$1.2 million	

$1.2 million

Part 71

Sources	31	($146,000)	($4,710)

Federal	1	($56,500)	($56,500)



Parts 50 and 51 



Sources	

1,774	

($11.6 million)	

($6,500)



Permitting Authorities	

112	

($9.7 million)	

($86,600)



Federal	

1	

$237,500	

$237,500



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

To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
EPA-HQ-OAR-2004-0087, which is available for online viewing at  
HYPERLINK "http://www.regulations.gov"  www.regulations.gov , or in
person viewing at the Air and Radiation Docket and Information Center in
the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution
Avenue, NW, Washington, D.C.  The EPA Docket Center Public Reading Room
is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding
legal holidays.  The telephone number for the Reading Room is (202)
566-1744, and the telephone number for the Air and Radiation Docket and
Information Center is (202) 566-1742.  An electronic version of the
public docket is available at www.regulations.gov.  This site can be
used to submit or view public comments, access the index listing of the
contents of the public docket, and to access those documents in the
public docket that are available electronically.  When in the system,
select “search,” then key in the Docket ID Number identified above. 
Also, you can send comments to the Office of Information and Regulatory
Affairs, Office of Management and Budget, 725 17th Street, NW,
Washington, D.C. 20503, Attention: Desk Officer for EPA.  Please include
the EPA Docket ID Number EPA-HQ-OAR-2004-0087 and OMB Control Number
2060-0336, 2060-0243, or 2060-0003 in any correspondence.

 United States Environmental Protection Agency.  Information Collection
Request for Part 70 Operating Permit Regulations.  ICR No. 1587.06. 
November 2004, pages 8 and 13.

 United States Environmental Protection Agency.  Information Collection
Request for Part 71 Federal Operating Permit Regulations.  ICR No.
1713.05.  November 2004, page 11.

 United States Environmental Protection Agency.  Information Collection
Request for Changes to the 40 CFR Parts 51 and 52 PSD and NSR
Applicability Requirements for Modifications to Existing Sources.  ICR
No. 2074.01.  November 2002, page 19.

	 United States Environmental Protection Agency.  Information Collection
Request for 40 CFR Parts 51 and 52 Prevention of Significant
Deterioration and Nonattainment New Source Review.  ICR No. 1230.17. 
January 2005, page 17.

	 United States Environmental Protection Agency.  Information Collection
Request for Part 70 Operating Permit Regulations.  ICR No. 1587.06. 
November 2004, page 16.

 PAGE  i 

INFORMATION COLLECTION REQUEST FOR CHANGES TO THE PART 70 OPERATING
PERMIT REGULATIONS, THE PART 71 OPERATING PERMIT REGULATIONS, AND THE
PARTS 51 and 52 PREVENTION OF SIGNIFICANT DETERIORATION AND
NONATTAINMENT NEW SOURCE REVIEW REGULATIONS FOR FLEXIBLE AIR PERMITS

  PAGE  42 

