1
SUPPORTING
STATEMENT
Air
Emissions
Reporting
Requirements
(
AERR)
EPA
ICR
#
2170.01
PART
A
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
"
Air
Emissions
Reporting
Requirements
(
AERR)
­
Proposed
Amendments."

1(
b)
Short
Characterization/
Abstract
The
United
States
(
U.
S.)
Environmental
Protection
Agency
(
EPA)
is
proposing
amendments
to
revise
the
Air
Emissions
Reporting
Requirements
(
AERR)
that
include
new
reporting
requirements
and
combines
these
new
requirements
with
existing
requirements
from
the
Rule
to
Reduce
Interstate
Transport
of
Fine
Particulate
Matter
and
Ozone
(
Clean
Air
Interstate
Rule)
(
CAIR),
the
Consolidated
Emissions
Reporting
Rule
(
CERR),
the
Emission
Reporting
Requirements
for
Ozone
State
Implementation
Plan
(
SIP)
Revisions
Relating
to
Statewide
Budgets
for
NO
X
Emissions
to
Reduce
Regional
Transport
of
Ozone
(
NO
X
SIP
Call)
and
the
Acid
Rain
Program
under
Title
IV
of
the
CAA
Amendments
of
1990.
Three
of
these
four
existing
requirements
has
an
approved
ICR
in
place.
The
current
ICRs
are:
for
the
CERR,
ICR
#
0916.10,
for
the
NO
X
SIP
Call,
ICR
#
1857.03
and
for
the
Acid
Rain
Program,
ICR
#
1633.13.
For
the
promulgated
CAIR,
the
proposed
ICR
is
ICR
#
2152.01.

This
supporting
statement
and
ICR
is
being
submitted
to
account
for
the
incremental
burden
associated
with
the
AERR.
As
such,
this
supporting
statement
references
the
burden
analysis
included
in
ICR
#
s
2152.01,
0916.10,
1857.03
and
1633.13
and
estimates
the
change
in
burden
resulting
from
the
proposed
AERR
on
each
of
these
ICRs.

EPA
is
publishing
proposed
amendments
in
the
Federal
Register
that
among
other
things,
details
the
changes
to
reporting
requirements
associated
with
AERR.
These
changes
revise
or
consolidate
existing
requirements
for
emission
reporting
under
the
CAIR,
CERR
and
NO
X
SIP
Call.

Taken
together,
the
existing
emissions
reporting
requirements
under
the
CAIR,
CERR
and
NO
X
SIP
Call
are
already
rather
comprehensive
in
terms
of
the
States
covered
and
the
information
2
required.
Therefore,
the
practical
impact
of
the
changes
proposed
is
to
impose
several
new
requirements
and
propose
to
accelerate
the
overall
calendar
for
emission
reporting.

In
all
States,
AERR
proposes
to
expand
the
definition
of
what
sources
must
report
in
point
source
format,
so
that
fewer
sources
would
be
included
in
nonpoint
source
emissions.
AERR
proposes
to
base
the
requirement
for
point
source
format
reporting
on
whether
the
source
is
a
major
source
under
40
CFR
part
70
for
the
pollutants
for
which
reporting
is
required,
i.
e.,
for
CO,
VOC,
NOx,
SO
2,
PM
2.5,
PM
10
and
ammonia
but
without
regard
to
emissions
of
hazardous
air
pollutants.
Currently,
the
requirement
for
point
source
reporting
is
based
on
actual
emissions
in
the
year
of
the
inventory
report.
This
change
may
require
more
sources
than
at
present
to
be
reported
as
point
sources
every
third
year.
The
new
approach
will
make
it
possible
to
better
track
source
emissions
changes,
shutdowns,
and
start
ups
over
time.
It
will
result
in
a
more
stable
universe
of
reporting
point
sources,
which
in
turn
will
facilitate
elimination
of
overlaps
and
gaps
in
estimating
point
source,
as
compared
to
nonpoint
source,
emissions.
Under
this
proposal,
States
will
know
well
in
advance
of
the
start
of
the
inventory
year
which
sources
will
need
to
be
reported.
AERR
proposes
that
these
new
requirements
begin
with
the
2008
inventory
year,
the
report
for
which
will
be
due
to
EPA
by
December
31,
2009.

Several
proposed
changes
will
alter
reporting
requirements
on
States
or
provide
them
with
additional
options:

°
The
NOx
SIP
Call
rule
required
the
affected
States
to
submit
emissions
inventory
reports
for
a
given
ozone
season
to
EPA
by
December
31
of
the
following
year.
The
CERR
requires
similar
but
not
identical
reports
from
all
States
by
the
following
June
1,
5
months
later.
The
EPA
believes
that
harmonizing
these
dates
would
be
efficient
for
both
States
and
EPA.
We
are
proposing
to
move
the
June
1,
reporting
requirement
to
the
previous
December
31.
The
first
reports
due
under
this
proposal
would
be
for
the
year
2008
to
be
reported
by
December
31,
2009.

°
We
are
proposing
that
the
reporting
schedule
be
further
accelerated
for
the
triennial
year
2011
and
all
following
years
by
requiring
that
point
sources
be
reported
within
six
months
from
the
end
of
the
calendar
year,
i.
e.,
by
June
30
of
the
year
following.
Reporting
on
all
other
sources
would
be
required
within
twelve
months,
i.
e.,
by
December
31
of
the
year
following.

°
We
propose
to
remove
a
requirement
in
the
existing
CERR
for
reporting
annual
and
typical
ozone
season
day
biogenic
emissions.

°
We
are
proposing
a
new
provision
which
would
allow
States
the
option
of
providing
emissions
inventory
estimation
model
inputs
in
lieu
of
actual
emissions
estimates,
for
source
categories
for
which
prior
to
the
submission
deadline
EPA
develops
or
adopts
suitable
emissions
inventory
estimation
models
and
by
guidance
defines
their
necessary
inputs.
We
propose
this
option
be
available
starting
with
the
reports
on
2005
emissions.
We
are
proposing
to
delete
the
existing
requirement
that
all
States
report
emissions
for
a
winter
work
week
day.
3
°
We
are
proposing
to
add
several
required
data
elements
in
the
proposed
rule
text.
These
are
contact
name,
contact
phone
number,
emission
release
point
type,
control
status,
emission
type,
and
method
accuracy
description
(
MAD)
codes.

The
NO
X
SIP
Call
rule
and
the
CERR
contain
detailed
lists
of
required
data
elements
in
addition
to
emissions,
and
each
rule
has
its
own
set
of
definitions.
The
two
sets
of
data
elements
overlap
but
are
not
identical.
The
NO
X
SIP
Call
rule
required
a
few
more
data
elements
to
be
reported
and
named
or
defined
some
data
elements
differently
than
the
CERR.
The
EPA
has
reviewed
both
lists
in
light
of
more
recent
experiences
and
insight
into
the
difficulty
States
face
in
collecting
and
submitting
these
data
elements
and
their
utility
to
EPA,
other
States,
and
other
users.
We
are
proposing
to
combine
the
separate
lists
of
required
elements
into
a
single
new
list
of
required
data
elements.
A
few
data
elements
are
proposed
to
be
eliminated.

We
are
proposing
to
retain
the
requirement
for
reporting
of
summer
day
emissions
from
all
sources
(
except
biogenic
sources)
at
3­
year
intervals,
but
to
restrict
it
to
only
States
with
ozone
nonattainment
areas
or
for
which
we
are
proposing
a
finding
of
significant
contribution
to
ozone
nonattainment
in
another
State.
The
NO
X
SIP
Call
requires
the
reporting
of
only
NO
X
emissions
for
a
typical
summer
day,
while
the
CERR
requires
the
reporting
of
all
pollutants.
We
propose
to
restrict
the
requirement
to
VOC
and
NO
X
emissions.

We
propose
to
modify
§
51.35
of
subpart
A,
to
provide
that
if
States
obtain
one­
third
of
their
necessary
emissions
estimates
from
point
sources
and/
or
prepare
one­
third
of
their
nonpoint
or
mobile
source
emissions
estimates
each
year
on
a
rolling
basis,
they
should
submit
their
data
as
a
single
package
on
the
required
every­
third
year
submission
date.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
One
of
the
goals
of
this
proposed
rulemaking
is
to
consolidate
the
emission
inventory
reporting
requirements
found
in
several
existing
regulations
and
streamline
the
activities
involved
in
submitting
the
emissions
data
to
EPA.
This
will
enable
the
EPA
to
achieve
uniformity
and
completeness
in
emission
inventories
used
to
support
national,
regional,
and
local
air
quality
planning
and
attainment.

While
the
CAA
does
not
provide
a
specific
authorization
for
a
national
emissions
data
base,
the
CAA
provides
the
EPA
ample
legislative
authority
for
acquiring
such
data.
Emissions
data
are
of
vital
importance
to
the
EPA
for
fulfilling
a
host
of
monitoring,
standard­
setting,
rulemaking,
reviewing,
and
reporting
duties.
Section
110
and
301(
a)
of
the
CAA
provide
a
primary
authority
for
a
national
emissions
data
base.
Section
110
requires
each
State
to
prepare
a
plan
which
provides
for
implementation,
maintenance,
and
enforcement
of
the
primary
standard
for
each
pollutant
for
which
air
quality
criteria
have
been
issued.
This
plan
must
include
provisions
for
periodic
reports
identifying
sources
and
listing
amounts
of
emissions.
Section
301(
a)
authorizes
the
Administrator
to
promulgate
necessary
regulations.
4
Congressional
support
for
collecting
and
reporting
emissions
data
is
demonstrated
in
three
sections
of
the
CAA.
Section
110(
a)(
2)(
F)
requires
that
each
State
provide
for
periodic
reports
on
the
nature
and
amounts
of
emissions
of
criteria
pollutants
from
stationary
sources.

Sections
182(
a)(
3)(
A)
and
187(
a)(
5)
of
the
CAA
specify
periodic
inventory
requirements
for
ozone
and
CO
nonattainment
areas,
respectively.
Section
182(
a)(
3)(
A)
requires
States
with
ozone
nonattainment
areas
to
submit
a
current
inventory
of
actual
emissions
of
VOC,
NO
x,
and
CO
every
3
years.
Section
187(
a)(
5)
requires
a
similar
inventory
of
actual
CO
emissions
for
CO
nonattainment
areas.
Periodic
inventories
include
emission
estimates
for
all
point,
nonpoint,
onroad
mobile,
nonroad
mobile,
and
biogenic
sources.
Section
172(
c)(
3)
also
provides
the
Administrator
with
discretionary
authority
to
require
other
emissions
data
as
deemed
necessary
for
State
Implementation
Plan
(
SIP)
development
in
nonattainment
areas
to
meet
the
NAAQS.
In
1998,
EPA
promulgated
the
NOx
SIP
Call
which
requires
the
affected
States
and
the
District
of
Columbia
to
submit
SIP
revisions
providing
for
NOx
reductions
to
reduce
their
adverse
impact
on
downwind
ozone
nonattainment
areas
(
63
FR
57356,
October
27,
1998).
As
part
of
that
rule,
codified
in
40
CFR
51.122,
EPA
established
emissions
reporting
requirements
to
be
included
in
the
SIP
revisions
required
under
that
action.
Another
set
of
emissions
reporting
requirements,
termed
the
Consolidated
Emissions
Reporting
Rule
(
CERR),
was
promulgated
by
EPA
in
2002,
and
is
codified
at
40
CFR
part
51
subpart
A.
(
67
FR
39602,
June
10,
2002).
These
requirements
replaced
the
requirements
previously
contained
in
subpart
Q,
expanding
their
geographic
and
pollutant
coverages
while
simplifying
them
in
other
ways.

As
noted
above,
at
present,
two
sections
of
title
40
of
the
CFR
contain
emissions
reporting
requirements
applicable
to
States:
subpart
A
of
part
51
(
the
CERR)
and
section
51.122
in
subpart
G
of
part
51
(
the
NOx
SIP
Call
reporting
requirements).
The
proposed
rulemaking
would
consolidate
these,
with
modifications
as
proposed
below.
The
modifications
are
intended
to
achieve
the
additional
reporting
needed
to
verify
the
reductions
required
by
the
CAIR,
to
harmonize
the
emissions
reporting
requirements,
to
reduce
and
simplify
them,
and
to
make
them
more
easily
understood.

Under
the
NOx
SIP
Call
requirements
in
section
51.122,
emissions
of
NO
X
for
a
defined
5­
month
ozone
season
(
May
1
through
September
30)
from
sources
that
the
State
has
subjected
to
emissions
control
to
comply
with
the
requirements
of
the
NOx
SIP
Call
are
required
to
be
reported
by
the
affected
States
to
EPA
every
year.
However,
emissions
of
sources
reporting
directly
to
EPA
as
part
of
the
NOx
trading
program
are
not
required
to
be
reported
by
the
State
to
EPA
every
year.
The
affected
States
are
also
required
to
report
ozone
season
emissions
and
typical
summer
daily
emissions
of
NOx
from
all
sources
every
third
year
(
2005,
2008,
etc.).
Section
51.122
also
requires
that
a
number
of
data
elements
be
reported
in
addition
to
ozone
season
NOx
emissions.
These
data
elements
describe
certain
of
the
source's
physical
and
operational
parameters.

Emissions
reporting
under
the
NOx
SIP
Call
as
first
promulgated
was
required
starting
for
the
emissions
reporting
year
2002,
the
year
prior
to
the
start
of
the
required
emissions
reductions.
The
reports
are
due
to
EPA
on
December
31
of
the
calendar
year
following
the
inventory
year.
For
example,
emissions
from
all
sources
and
types
in
the
2002
ozone
season
were
required
to
be
reported
on
December
31,
2003.
However,
because
the
Court
which
heard
challenges
to
the
5
NOx
SIP
Call
delayed
the
implementation
by
1
year
to
2004,
no
State
was
required
to
start
reporting
until
the
2003
inventory
year.
In
addition,
EPA
promulgated
a
rule
to
subject
Georgia
and
Missouri
to
the
NOx
SIP
Call
with
an
implementation
date
of
2007.
(
See
69
FR
21604,
April
21,
2004.)
For
them,
emissions
reporting
begins
with
2006.
These
emissions
reporting
requirements
under
the
NOx
SIP
Call
affect
the
District
of
Columbia
and
20
of
the
25
States
affected
by
the
CAIR.

As
noted
above,
the
other
set
of
emissions
reporting
requirements
is
codified
at
subpart
A
of
part
51.
Although
entitled
the
CERR,
this
rule
left
in
place
the
separate
§
51.122
for
the
NOx
SIP
Call
reporting.
The
CERR
requirements
were
aimed
at
obtaining
emissions
information
to
support
a
broader
set
of
purposes
under
the
CAA
than
were
the
reporting
requirements
under
the
NOx
SIP
Call.
The
CERR
requirements
apply
to
all
States.

Like
the
requirements
under
the
NOx
SIP
Call,
the
CERR
requires
reporting
of
all
sources
at
3­
year
intervals
(
2002,
2005,
etc.).
It
requires
reporting
of
certain
large
sources
every
year.
However,
the
required
reporting
date
under
the
CERR
is
5
months
later
than
under
the
NOx
SIP
Call
reporting
requirements.
Also,
emissions
must
be
reported
for
the
whole
year,
for
a
typical
day
in
winter,
and
a
typical
day
in
summer,
but
not
for
the
5­
month
ozone
season
as
is
required
by
the
NOx
SIP
Call.
Finally,
the
CERR
and
the
NOx
SIP
Call
differ
in
what
non­
emissions
data
elements
must
be
reported.

2(
b)
Use/
Users
of
the
Data
Emissions
data
and
related
information
on
stationary
point
and
nonpoint
sources,
as
well
as
nonroad
mobile
and
onroad
mobile
sources,
are
routinely
used
by
the
OAQPS
and
the
EPA
Regional
Offices
in
carrying
out
a
variety
of
activities.
These
activities
support
regulatory
functions
as
well
as
functions
that
are
more
programmatic
in
nature
such
as
trends
analyses.
Such
projects
include:

°
Evaluation
of
existing
control
strategies,
such
as
the
NO
X
SIP
Call
and
CAIR,
for
States
and
larger
areas;

°
Evaluation
of
proposed
control
strategies
for
States
and
larger
areas,
including
applications
of
regional
scale
models;

°
Development
of
national
control
strategies
and
preparation
of
Regulatory
Impact
Analyses
(
RIA);

°
Preparation
and
publication
of
national
summaries
of
emissions
including
trend
analyses;

°
As
a
data
base
to
assist
in
the
identification
of
important
source
categories
for
future
regulation;
and
°
Preparation
of
the
stationary
source
portion
of
a
report
to
Congress
on
SO
2
emissions.
This
report
is
required
by
Section
406
of
the
CAA
and
is
due
on
a
5­
year
cycle
that
6
began
on
January
1,
1995.
The
report
must
contain
an
inventory
of
national
annual
SO
2
emissions
from
industrial
sources
(
as
defined
in
Title
IV
of
the
CAA).

EPA's
Office
of
Research
and
Development
(
ORD)
uses
emissions
source
data
in
determining
priorities
for
control
technology
research
and
as
a
key
data
component
in
the
application
of
regional
scale
models.
The
EPA's
Regional
Offices
use
emissions
and
other
source
parameters
to
support
source
inspections
and
in
the
analyses
of
the
impact
of
new
or
modified
sources
within
an
area.
EPA's
Emission
Inventory
Group
(
EIG)
use
the
data
to
assess
and
analyze
trends
in
criteria
pollutant
emissions
over
time.

In
addition
to
supporting
projects
and
initiatives
internal
to
EPA,
both
the
OAQPS
and
the
Regional
Offices
respond
to
numerous
requests
for
reports
on
emission
sources.
Typically
this
is
done
under
the
Freedom
of
Information
Act.
Most
requests
come
from
contractors
and
consultants
involved
in
special
studies;
a
smaller
number
come
from
the
press
and
universities
and
others
involved
in
research.

The
collection
of
emissions
data
specific
to
nonattainment
areas
for
certain
criteria
air
pollutants
is
necessary
to
comply
with
requirements
specified
in
Title
I
of
the
CAA.
States
with
nonattainment
areas
rely
on
current
information
for
point,
nonpoint,
and
mobile
sources
to
revise
their
SIPs
and
to
plan
for
emission
reductions
mandated
by
the
CAA.
In
addition,
a
statewide
inventory
compiled
at
least
every
3
years
for
all
point,
nonpoint,
and
mobile
sources
is
considered
to
be
a
key
tool
to
assist
States
in
meeting
CAA
requirements
that
address
emissions
tracking,
compliance
issues,
and
mid­
course
adjustments.
Statewide
emission
inventories
can
be
used
by
States
affected
by
pollution
transport
from
upwind
areas
to
develop
more
efficient
control
strategies
to
meet
the
NAAQS.
Statewide
emission
inventories
that
were
developed
by
EPA
(
the
NEI)
are
being
used
by
the
Regional
Planning
Organizations
(
RPOs)
as
the
starting
point
for
the
development
of
statewide
emission
inventories
used
in
the
regional
haze
program
to
define
control
strategies.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
Previous
reporting
requirements
have
occasionally
forced
State
agencies
into
inefficient
collecting
and
reporting
activities.
The
proposed
rule
seeks
to
simplify
emission
inventory
reporting
by
States
to
EPA,
offer
options
for
data
collection
and
exchange,
and
unify
reporting
dates
for
various
categories
of
inventories
to
avoid
duplication
of
effort.
For
example,
under
the
NO
x
SIP
Call
rule,
the
EPA
is
requiring
States
to
submit
annual
inventories
for
all
NO
x
sources
for
which
States
adopt
control
measures
to
meet
their
NO
x
budget.
Every
3
years,
statewide
NO
x
inventories
of
all
controlled
and
uncontrolled
sources
are
required.
The
CERR
rule
also
requires
annual
and
triennial
emission
inventory
reporting
of
many
of
the
same
data
elements.
By
aligning
reporting
dates
and
combining
data
from
these
collection
activities
will
avoid
duplication
of
information
collected
from
sources,
minimize
the
burden
on
the
industry,
and
reduce
the
effort
for
State
and
local
government
agencies
to
compile
the
data.
7
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
Not
required.
This
is
a
rule
related
ICR.

3(
c)
Consultations
The
emission
reporting
requirements
for
AERR
were
developed
after
comments
were
received
on
the
CAIR
SNPR.
The
decision
to
issue
a
separate
rulemaking
(
AERR)
was
a
direct
result
of
the
consultative
process
through
the
comments
received.
The
primary
motivation
of
the
AERR
proposed
amendments
is
to
allow
the
regulated
community
ample
time
to
review
and
respond
to
the
revised
emissions
reporting
requirements.

3(
d)
Effects
of
Less
Frequent
Collection
The
submittal
dates
required
for
reporting
of
emissions
data
to
EPA
have
been
established
to
minimize
the
burden
on
State
and
local
agencies,
but
also
to
ensure
that
State
and
local
agencies
are
collecting
timely
and
sufficient
emissions
inventory
data
to
support
their
air
pollution
control
efforts.
A
statewide
inventory
compiled
at
least
every
3
years
for
all
point,
nonpoint,
and
mobile
sources
is
considered
important
to
assist
States
in
meeting
various
CAA
requirements.

If
the
information
collection
were
not
carried
out
every
3
years
for
all
sources
and
annually
for
major
point
sources,
the
EPA
would
not
be
able
to
maintain
a
central,
national
repository
of
emissions
data
from
which
to
extract
updated
information
needed
to
fulfill
EPA
mandates.

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

3(
f)
Confidentiality
Any
data
that
is
submitted
to
EPA
under
this
proposed
rule
will
be
considered
in
the
public
domain
and
cannot
be
treated
as
confidential.
The
data
collected
in
this
ICR
is
not
considered
to
be
confidential,
but
some
States
limit
release
of
this
type
of
data.
Any
data
submitted
to
EPA
under
this
proposed
rule
will
be
considered
in
the
public
domain
and
cannot
be
treated
as
confidential.
If
Federal
and
State
requirements
are
inconsistent,
the
EPA
Regional
Office
may
be
consulted
for
a
final
reconciliation.

3(
g)
Sensitive
Questions
This
information
collection
does
not
ask
any
questions
concerning
sexual
behavior
or
attitudes,
religious
beliefs,
or
other
matters
usually
considered
private.
8
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
Standard
Industrial
Classification
(
SIC)
Codes
The
emissions
data
required
by
the
proposed
amendments
will
generally
be
submitted
by
State
air
pollution
control
agencies.
Under
the
CERR,
there
are
55
State
and
Territorial
air
pollution
control
agencies,
as
well
as
49
local
air
agencies
that
will
be
subject
to
the
national
reporting
requirements
and
will
be
required
to
compile
and
report
emissions
information
for
large
stationary
point
sources
on
an
annual
basis,
and
for
smaller
point
sources,
stationary
nonpoint
and
mobile
sources
on
a
3­
year
basis.
The
NO
X
SIP
Call
required
20
States
to
report
NO
X
emission
related
data
on
an
annual
and
trienniel
basis.
Under
CAIR
five
states,
Arkansas,
Florida,
Iowa,
Louisiana
and
Mississippi,
are
being
added
to
the
20
States
subject
to
the
NOx
SIP
Call.
For
these
five
states,
the
required
emissions
reporting
will
be
expanded
to
match
those
of
the
20
States.
In
addition,
the
23
States
and
the
District
of
Columbia
subject
to
the
CAIR
for
reasons
of
PM2.5
must
report
to
EPA
each
year
a
set
of
specified
data
elements
for
all
sources
subject
to
new
controls
adopted
specifically
to
meet
the
CAIR
requirements
related
to
PM2.5,
unless
the
sources
participate
in
an
EPA­
administered
emissions
trading
program.
The
affected
SIC
code
would
be
9511
­
Air
and
Water
Resource
and
Solid
Waste
Management,
which
includes
governmental
environmental
protection
and
control
agencies,
and
pollution
control
agencies.

4(
b)
Information
Requested
The
CERR
and
NO
X
SIP
Call
established
the
basic
emission
reporting
requirements.
The
proposed
AERR
would
change
some
of
these
requirements
such
that
the
previously
accounted
for
reporting
burden
would
also
change.
Only
the
changes
to
the
CERR,
NO
X
SIP
Call
and
CAIR
reporting
requirements
that
would
change
reporting
burden
are
discussed
here.

The
following
section
describes
the
required
data
items
that
would
be
changed
by
the
proposed
AERR.

(
i)
Data
items,
including
recordkeeping
requirements
The
proposed
AERR
would
eliminate
the
following
data
related
items
from
previous
requirements:

°
All
data
items
required
for
the
reporting
of
annual
and
ozone
season
biogenic
emissions;
°
Winter
work
weekday
emissions
for
point
sources,
nonpoint
sources,
onroad
mobile
sources
and
nonroad
mobile
sources.

(
ii)
Respondent
activities
For
the
emission
inventory
reporting
requirements
of
the
proposed
AERR,
respondent
activities
are
very
similar
to
what
has
been
required
to
satisfy
reporting
under
CERR,
NO
X
SIP
Call
and
the
CAIR.
The
specific
State
respondent
activities
associated
with
the
AERR
that
are
changes
from
the
existing
CERR,
NO
X
SIP
Call
and
the
CAIR
requirements
are
outlined
below,
and
are
grouped
into
one­
time,
annual,
and
triennial
activities.
9
The
one­
time
State
burden
items
include:

°
Read
the
reporting
requirements
of
the
rule;

Annual
State
activities
include:

°
Adopts
the
definition
of
a
point
source
as
being
a
major
source
under
40
CFR
part
70
for
the
pollutants
for
which
reporting
is
required,
i.
e.,
for
CO,
VOC,
NO
X,
SO
2,
PM
2.5,
PM
10
and
NH
3
but
without
regard
to
emissions
of
hazardous
air
pollutants
°
Harmonizes
the
reporting
dates
under
CERR
and
NO
X
SIP
Call.

Triennial
State
activities
include:

°
Adopts
the
definition
of
a
point
source
as
being
a
major
source
under
40
CFR
part
70
for
the
pollutants
for
which
reporting
is
required,
i.
e.,
for
CO,
VOC,
NO
X,
SO
2,
PM
2.5,
PM
10
and
NH
3
but
without
regard
to
emissions
of
hazardous
air
pollutants
°
Harmonizes
the
reporting
dates
under
CERR
and
NO
X
SIP
Call.

5.
THE
INFORMATION
COLLECTED
 
AGENCY
ACTIVITIES,
COLLECTION
METHODS,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
The
EPA
activities
associated
with
the
proposed
amendments
include:

°
Receiving,
reviewing,
and
storing
emission
inventory
data
submitted
by
each
State;

°
Processing
and
updating
data
submitted
by
States,
including
performing
quality
assurance
of
data,
and
coordination
of
efforts
to
resolve
errors
and
anomalies;
and
°
Fulfilling
information
requests.

5(
b)
Collection
Methodology
and
Management
The
EPA
has
establishing
a
central
repository
of
inventory
data
for
all
States
termed
the
National
Emissions
Inventory
(
NEI)
database.
Emissions
inventory
data
reported
electronically
will
be
stored
in
the
NEI
database
and
used
by
the
EPA
and
by
other
States
for
air
modeling,
tracking
progress
in
meeting
CAA
requirements,
setting
policy
and
answering
questions
from
the
public.

The
EPA
has
created
and
maintains
the
NEI
database
as
a
central
repository
of
inventory
data
for
all
States,
but
the
data
must
be
supplied
by
the
States
in
electronic
form.
The
EPA
currently
requires
that
States
use
the
NEI
Input
Format
(
NIF)
for
electronic
data
reporting
(
EDR).
10
5(
c)
Small
Entity
Flexibility
State
and
Territorial
control
agencies
are
not
considered
to
be
small
entities.
According
to
EPA's
ICR
Handbook,
OMB's
definition
for
a
small
entity
includes
small
governmental
jurisdictions
with
populations
of
less
than
50,000.
According
to
1999
population
data
from
the
U.
S.
Census
Bureau,
no
State
or
Territory
has
a
population
below
this
threshold.
However,
certain
local
air
pollution
agencies
may
be
in
charge
of
individual
counties
or
multi­
county
areas
whose
population
is
less
than
50,000.

These
local
agencies
have
had
experience
compiling
their
2002
inventories
that
were
submitted
to
EPA
in
June
2004
as
required
by
the
CERR.
The
emission
reporting
requirements
in
AERR
are
estimated
to
result
in
a
net
burden
reduction
for
the
reporting
agencies.

5(
d)
Collection
Schedule
There
is
one
requirement
in
the
proposed
AERR
that
will
impact
the
reporting
schedule
for
the
States.
EPA
is
harmonizing
the
reporting
due
dates
in
the
CERR
and
NO
X
SIP
Call.
Instead
of
having
a
due
date
of
12
months
following
the
end
of
the
year
for
the
NO
X
SIP
Call
and
17
months
for
CERR
required
reporting,
EPA
is
proposing
12
months
for
both
requirements.
For
the
emission
reporting
year
2011
and
following
years,
EPA
is
proposing
to
further
accelerate
the
reporting
schedule
by
having
point
source
reporting
due
6
months
after
the
end
of
the
year
and
all
other
sources
reported
12
months
after
the
end
of
the
year.
Because
there
is
no
change
in
what
is
required
to
be
reported,
EPA
did
not
estimate
any
change
in
burden
resulting
from
the
proposed
schedule
change.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
The
respondent
burden
for
complying
with
the
reporting
requirements
of
the
proposed
amendments
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
CERR,
NO
X
SIP
Call
and
the
CAIR
inventory
requirements.
The
changes
to
the
existing
reporting
requirements
are
specified
in
Section
4(
b)(
i)
of
this
supporting
statement.

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

°
Collecting
emissions
data
and
other
associated
information;

°
Training
staff
in
coding
and
submissions
techniques;

°
Quality­
assuring
emissions
data
and
resolution
of
errors
and
anomalies
identified
by
EPA;
11
°
Maintaining
records
associated
with
data
submitted
by
sources;
and
°
Preparing
and
submitting
required
inventory
data
items
in
approvable
format.

The
following
sections
discuss
the
assumptions
used
to
develop
burden
hour
estimates
for
one­
time
only
activities,
annual
activities,
and
triennial
activities.
Table
6­
1
lists
the
burden
items
included
under
these
categories,
and
presents
their
associated
burden
hours
for
1
year.
In
general,
managerial
time
was
estimated
to
be
5
percent
of
technical
staff
time.
Burden
hours
and
associated
costs
were
estimated
for
the
first
3­
year
period
that
the
affected
States
would
have
to
start
reporting
emissions
data
to
EPA.
In
this
case,
that
period
corresponds
to
the
years
2008,
2009,
and
2010.
Table
6­
2
shows
the
required
activities
that
a
State
must
perform
each
year,
beginning
in
the
year
2008
through
2010.
Table
6­
3
presents
the
State
and
local
respondent
annual
burden
hours
and
costs
by
activity.

One­
time
activity
The
time
for
States,
Territorial,
and
local
agencies
to
read
and
interpret
the
reporting
requirements
of
the
rule
was
estimated
to
be
1
hour
for
technical
staff
and
1
hour
for
managerial
staff.

Annual
activities
There
are
two
annual
burden
items
associated
with
this
ICR.
In
the
first,
the
proposed
AERR
would
adopt
the
definition
of
a
point
source
as
being
a
major
source
under
40
CFR
part
70
for
the
pollutants
for
which
reporting
is
required,
i.
e.,
for
CO,
VOC,
NO
X,
SO
2,
PM
2.5,
PM
10
and
NH
3
but
without
regard
to
emissions
of
hazardous
air
pollutants.
Annual
burden
for
this
proposed
change
was
estimated
as
follows.
EPA
has
done
an
analysis
of
the
change
in
the
number
of
sources
that
the
States
would
be
required
to
report
under
this
proposed
change.
This
analysis
looked
at
the
number
of
point
sources
that
were
actually
reported
to
EPA
by
the
States
in
their
1999
emission
inventory
submittal
and
compared
these
with
the
number
of
sources
that
would
have
been
required
to
report
under
the
CERR
definition
and
the
number
that
would
be
required
using
the
40
CFR
part
70
proposed
definition.
(
Note:
States
were
not
required
to
report
under
the
CERR
until
the
2002
inventory
year.
The
2002
point
source
results
were
not
available
in
time
for
this
analysis.
The
1999
results
are
believed
to
be
representative.)
The
results
of
this
analysis
are
given
in
Table
6­
4.
Nationally,
the
States
are
reporting
a
total
of
52,277
point
sources.
The
CERR
definition
would
require
that
7385
point
sources
be
reported.
Using
the
proposed
40
CFR
part
70
definition,
the
reporting
requirement
would
increase
to
17,316,
still
well
below
the
number
of
the
sources
that
are
being
reported.
On
a
State
level
basis,
there
are
seven
states,
AK,
AR,
FL,
GA,
HI,
IA
and
SD,
plus
the
District
of
Columbia
that
report
fewer
point
sources
to
the
NEI
than
would
be
required
under
the
proposed
definition
of
40
CFR
part
70.
Since
each
of
these
eight
respondents
is
required
to
maintain
records
on
the
sources
under
40
CFR
part
70,
the
additional
burden
to
estimate
emissions
from
these
sources
and
report
them
to
EPA
should
be
modest.
EPA
estimates
that
each
respondent
would
spend
40
hours
of
technical
staff
time
and
2
hours
of
managerial
staff
time.
12
The
second
item
will
result
in
a
decrease
in
reporting
burden
to
the
States
by
harmonizing
the
reporting
dates
under
the
CERR
and
the
NO
X
SIP
Call.
To
estimate
the
decrease
in
burden,
EPA
estimated
that
each
of
the
20
respondents
subject
to
the
NO
X
SIP
Call
reporting
requirements
would
save
40
hours
of
technical
staff
time
and
2
hours
of
managerial
time
by
having
to
make
a
single
emissions
report
instead
of
the
two
currently
required.

The
proposed
AERR
also
proposes
to
eliminate
the
requirement
that
all
States
report
emissions
for
a
winter
work
weekday.
While
this
will
result
in
some
reduction
in
burden,
EPA
believes
that
it
will
be
small
and
did
not
estimate
it.

Triennial
activities
The
major
items
that
impact
triennial
burden
are
the
same
as
for
annual
burden.
The
discussion
under
"
annual
activities"
is
repeated
here
for
completeness.
The
proposed
AERR
would
adopt
the
definition
of
a
point
source
as
being
a
major
source
under
40
CFR
part
70
for
the
pollutants
for
which
reporting
is
required,
i.
e.,
for
CO,
VOC,
NO
X,
SO
2,
PM
2.5,
PM
10
and
NH
3
but
without
regard
to
emissions
of
hazardous
air
pollutants.
Annual
burden
for
this
proposed
change
was
estimated
as
follows.
EPA
has
done
an
analysis
of
the
change
in
the
number
of
sources
that
the
States
would
be
required
to
report
under
this
proposed
change.
This
analysis
looked
at
the
number
of
point
sources
that
were
actually
reported
to
EPA
by
the
States
in
their
1999
emission
inventory
submittal
and
compared
these
with
the
number
of
sources
that
would
have
been
required
to
report
under
the
CERR
definition
and
the
number
that
would
be
required
using
the
40
CFR
part
70
proposed
definition.
(
Note:
States
were
not
required
to
report
under
the
CERR
until
the
2002
inventory
year.
The
2002
point
source
results
were
not
available
in
time
for
this
analysis.
The
1999
results
are
believed
to
be
representative.)
The
results
of
this
analysis
are
given
in
Table
6­
4.
Nationally,
the
States
are
reporting
a
total
of
52,277
point
sources.
The
CERR
definition
would
require
that
7385
point
sources
be
reported.
Using
the
proposed
40
CFR
part
70
definition,
the
reporting
requirement
would
increase
to
17,316,
still
well
below
the
number
of
the
sources
that
are
being
reported.
On
a
State
level
basis,
there
are
seven
states,
AK,
AR,
FL,
GA,
HI,
IA
and
SD,
plus
the
District
of
Columbia
that
report
fewer
point
sources
to
the
NEI
than
would
be
required
under
the
proposed
definition
of
40
CFR
part
70.
Since
each
of
these
eight
respondents
is
required
to
maintain
records
on
the
sources
under
40
CFR
part
70,
the
additional
burden
to
estimate
emissions
from
these
sources
and
report
them
to
EPA
should
be
modest.
EPA
estimates
that
each
respondent
would
spend
40
hours
of
technical
staff
time
and
2
hours
of
managerial
staff
time.

The
second
item
will
result
in
a
decrease
in
reporting
burden
to
the
States
by
harmonizing
the
reporting
dates
under
the
CERR
and
the
NO
X
SIP
Call.
To
estimate
the
decrease
in
burden,
EPA
estimated
that
each
of
the
20
respondents
subject
to
the
NO
X
SIP
Call
reporting
requirements
would
save
40
hours
of
technical
staff
time
and
2
hours
of
managerial
time
by
having
to
make
a
single
emissions
report
instead
of
the
two
currently
required.

In
addition
to
these
two
items,
there
is
one
other
item
that
will
impact
triennial
burden.
The
AERR
proposes
the
elimination
of
the
CERR
reporting
requirement
that
States
report
annual
and
ozone
season
biogenic
emissions
to
EPA.
The
CERR
ICR
estimated
this
burden
to
be
40
hours
13
of
technical
staff
and
2
hours
of
managerial
staff
time
for
each
of
the
55
State
and
Territorial
respondents.

There
are
two
additional
proposed
AERR
changes
that
would
only
impact
triennial
burden.
The
proposed
AERR
proposes
to
change
the
requirement
for
the
reporting
of
summer
day
emissions.
The
proposal
would
require
the
reporting
of
summer
day
emissions
only
from
States
that
have
ozone
nonattainment
areas,
or
which
can
be
shown
to
make
a
significant
contribution
to
ozone
formation
in
another
State,
instead
of
from
all
States.
This
will
result
in
a
small
reduction
in
burden
which
was
not
estimated.
The
proposed
AERR
also
proposes
to
eliminate
the
requirement
that
all
States
report
emissions
for
a
winter
work
weekday.
While
this
will
result
in
some
reduction
in
burden,
EPA
believes
that
it
will
be
small
and
did
not
estimate
it.

6(
b)
Estimating
Respondent
Costs
Table
6­
3
presents
state
and
local
respondent
annualized
hours
and
costs
for
each
information
collection
activity.
To
estimate
annualized
hours
and
costs
for
one­
time
and
triennial
activities,
the
burden
estimate
is
divided
by
3
to
estimate
the
burden
over
a
3­
year
period.

(
i)
Estimating
Labor
Costs
For
this
ICR,
the
labor
rate
used
for
technical
staff
at
State
agencies
is
$
34.36
per
hour,
and
the
labor
rate
for
managerial
employees
at
State
agencies
is
$
41.63.
These
labor
rates
include
benefits
and
overhead.
These
labor
rates
are
derived
from
data
shown
on
the
U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics,
web
site
at
http://
stats.
bls.
gov/
news.
release/
ecec.
toc.
htm.
Wage
and
salary
rates
are
given
in
Employee
Costs
for
Employee
Compensation
"
Table
3.
State
and
local
government,
by
major
occupation
and
industry
group
(
March
2004)."
The
wage
and
salary
rates
from
this
table
account
for
benefits
provided
to
workers.
When
considering
both
technical
and
managerial
hours,
labor
costs
for
State
and
Territorial
agencies
are
estimated
to
be
$
46,000
per
year
per
respondent,
and
labor
costs
for
local
agencies
are
estimated
to
be
$
30,000
per
year
per
respondent.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
EPA
has
concluded
that
the
Capital
and
Operations
and
Maintenance
Costs
estimated
under
the
CERR
and
the
NO
X
SIP
Call
are
sufficient
to
accommodate
the
modest
changes
in
reporting
burden
for
the
proposed
CAIR.
Therefore,
no
estimate
of
Capital
and
Operations
and
Maintenance
Costs
were
made
for
this
ICR.

6(
c)
Estimating
Agency
Burden
and
Costs
No
costs
for
development
of
the
information
collection
requirements,
operational
costs,
or
cost
for
publication
and
distribution
of
the
reported
emissions
data
are
attributable
to
this
ICR.
No
travel
costs
are
associated
with
Agency
activities
associated
with
this
ICR.
The
only
costs
that
the
Federal
government
will
incur
are
user
costs
associated
with
analysis
of
the
reported
information.
The
proposed
amendments
will
not
significantly
increase
EPA's
activities,
labor
hours,
or
costs
beyond
the
current
level.
14
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
number
of
respondents
is
estimated
to
be
51
States
(
including
DC),
4
Territories
and
49
local
agencies,
resulting
in
104
total
respondents.
Most
of
the
activities
detailed
in
Table
6­
1
apply
to
a
subset
of
the
104
potential
respondents.
The
total
hourly
burden
for
all
respondents
is
estimated
to
be
a
decrease
of
1373
hours
per
year
from
the
approved
ICRs
for
the
CERR,
NO
X
SIP
Call
and
the
CAIR.
During
the
first
3­
year
period
that
the
rule
is
in
effect,
the
respondents
should
save
$
47,450.

6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
(
i)
Respondent
tally
Total
Estimated
Respondent
Burden
and
Cost
Summary
Number
of
Respondents
Number
of
Activities1
Total
Hours
Per
Year
Total
Labor
Costs
Per
Year
State
Respondents
Varies
from
8
to
104
219
(
1373)
DECREASE
($
47,450)
DECREASE
1On
average,
each
State
respondent
is
assumed
to
perform
6
discrete
activities
associated
with
the
AERR
emission
reporting
requirements,
as
indicated
in
Table
6­
3.
This
total
is
the
sum
of
the
"
Number
of
Respondents"
column
in
Table
6­
3.

(
ii)
Variations
in
the
annual
bottom
line.
This
section
does
not
apply
since
no
significant
variation
is
expected.

6(
f)
Reasons
for
Change
in
Burden
The
net
change
in
emission
reporting
burden
as
compared
with
the
approved
ICRs
for
the
CERR,
NO
X
SIP
Call
and
the
CAIR
is
a
decrease
of
1373
hours.
The
change
in
the
AERR
point
source
definition
resulted
in
an
increase
in
burden,
but
this
change
only
impacted
8
respondents.
By
combining
the
reporting
dates
for
both
the
CERR
and
the
NO
X
SIP
Call,
a
burden
reduction
has
resulted
that
impacts
20
respondents.
The
elimination
of
the
CERR
triennial
requirement
that
States
report
biogenic
emissions
impacts
55
respondents.

6(
g)
Burden
Statement
Reporting
of
emissions
data
required
by
the
AERR
is
estimated
to
involve
an
average
decrease
of
13
hours
per
year
for
each
State,
Territorial
and
local
air
pollution
control
agency.

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
15
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggestions
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OAR­
2004­
0489,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B­
102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Air
Docket
is
(
202)
566­
1742.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
docket.
Use
EDOCKET
to
submit
or
view
public
comments,
and
to
access
the
index
listing
of
the
contents
of
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,",
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
No.
OAR­
2004­
0489
in
any
correspondence.

PART
B
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
data
collection
associated
with
the
proposed
amendments.

Table
6­
1.
Emission
Reporting
Requirements
­
State
Respondent
Burden
Hours
by
Activity
Information
Collection
Activity
Hours
Per
Respondent
Managerial
Hours
Technical
Hours
Total
One­
time
Read
the
reporting
requirements
of
the
rule
1
1
2
Annual
Revised
definition
of
a
point
source
to
conform
to
the
definition
in
40
CFR
part
70
exclusive
of
hazardous
air
pollutants
2
40
42
Harmonize
reporting
dates
under
the
CERR
and
NOX
SIP
Call
(
DECREASE)
2
40
42
Triennial
Revised
definition
of
a
point
source
to
conform
to
the
definition
in
40
CFR
part
70
exclusive
of
hazardous
air
pollutants
2
40
42
Harmonize
reporting
dates
under
the
CERR
and
NOX
SIP
Call
(
DECREASE)
2
40
42
Elimination
of
the
CERR
reporting
requirement
for
biogenic
emissions
(
DECREASE)
2
40
42
.
16
Table
6­
2.
Emission
Reporting
Requirements
­
Activities
Required
by
States
Every
Year
During
the
Period
2006
through
2008
Information
Collection
Acitivity
2008
2009
2010
One­
time
(
Annualized)

Read
the
reporting
requirements
of
the
rule

Annual
Revised
definition
of
a
point
source
to
conform
to
the
definition
in
40
CFR
part
70
exclusive
of
hazardous
air
pollutants]


Harmonize
reporting
dates
under
the
CERR
and
NO
X
SIP
Call
(
DECREASE)


Triennial
Revised
definition
of
a
point
source
to
conform
to
the
definition
in
40
CFR
part
70
exclusive
of
hazardous
air
pollutants

Harmonize
reporting
dates
under
the
CERR
and
NO
X
SIP
Call
(
DECREASE)

Elimination
of
the
CERR
reporting
requirement
for
biogenic
emissions
(
DECREASE)

17
Table
6­
3.
Annual
State
Respondent
Burden
and
Cost
by
Activity
Information
Collection
Activity
Hours
and
Costs
Per
Respondent
Total
Hours
and
Costs
Mgr.

$
41.63/
Hr1
Tech.

$
34.36/
Hr1
Respondent
Hours/
Year
Labor
Cost/
Year
Number
of
Respondents
Total
Hours/
Year2
Total
Cost/
Year3
One­
time
(
Annualized)

Read
the
reporting
requirements
of
the
rule
0.33
0.33
0.66
25.08
104
69
2,608
Annual
Revised
definition
of
a
point
source
to
conform
to
the
definition
in
40
CFR
part
70
exclusive
of
hazardous
air
pollutants
2.00
40.00
42.004
1,458
8
336
11,664
Harmonize
reporting
dates
under
the
CERR
and
NO
X
SIP
Call
(
DECREASE)
2.00
40.00
42.00
(
1,458)
20
(
840)
(
29,160)

Triennial
Revised
definition
of
a
point
source
to
conform
to
the
definition
in
40
CFR
part
70
exclusive
of
hazardous
air
pollutants
0.67
13.33
14
486
8
112
3,888
Harmonize
reporting
dates
under
the
CERR
and
NO
X
SIP
Call
(
DECREASE)
0.67
13.33
14
(
486)
20
(
280)
(
9,720)

Elimination
of
the
CERR
reporting
requirement
for
biogenic
emissions
(
DECREASE)
0.67
13.33
14
(
486)
55
(
770)
(
26,730)

Total
varies
(
1,373)
(
47,450)

1
See
Section
6
(
b)
(
i)
for
labor
and
overhead
rates.

2
Hours
per
year
are
rounded
to
the
nearest
hour.

3
Costs
per
year
are
rounded
to
the
nearest
dollar.

4
Includes
the
following
activities
associated
with
annual
point
source
reporting:
1)
Train
staff
in
coding
and
submissions
techniques;
2)
Resolution
of
errors
and
anomalies
identified
by
EPA;
3)
Maintain
log
of
magnetic
tape
or
other
media
submitted;
and
4)
Prepare
automated
submission
to
EPA.
Table
6­
4.
Analysis
Results
of
Point
Source
Definition
Change
State
Facilities
Reported
to
`
99
NEI
Facilities
Required
by
CERR
Facilities
Required
Using
40
CFR
part
70
AL
989
231
301
AK
28
13
245
AZ
283
49
115
AR
180
127
292
CA
9642
261
1193
CO
4661
134
131
CT
175
36
95
DE
106
20
85
DC
9
5
34
FL
1063
194
1653
GA
304
169
374
HI
84
36
128
ID
59
41
51
IL
7843
354
723
IN
1201
305
716
IA
67
60
294
KS
698
230
363
KY
1829
181
315
LA
953
401
578
ME
159
41
73
MD
179
59
165
MA
2167
79
164
MI
1620
228
489
MN
833
123
329
MS
608
269
317
MO
718
124
390
MT
206
48
59
NE
635
44
133
NV
102
16
48
NH
90
27
53
NJ
717
83
405
NM
323
136
183
NY
553
151
532
NC
2307
281
415
ND
58
27
50
OH
713
261
712
OK
1047
224
376
OR
168
62
150
PA
1461
287
786
RI
77
14
49
SC
690
115
299
SD
16
13
200
TN
913
294
322
TX
1891
856
1532
UT
426
55
74
VT
53
13
20
VA
779
175
289
WA
318
81
129
WV
413
123
178
WI
1677
136
557
WY
186
93
152
TOTAL
52277
7385
17316
