PROPOSED INFORMATION COLLECTION REQUEST (ICR)

DRAFT OMB-83 SUPPORTING STATEMENT PREPARED FOR NPRM

ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF AIR & RADIATION

EPA DOCKET NUMBER EPA-HQ-OAR-2005-0161

Addendum to Renewable Fuels Standard (RFS2) Program Supporting Statement
- EPA ICR No. 2333.01

	The estimates in this addendum relate to third party disclosure of
information from biofuel feedstock producers, including but not limited
to farmers,  private forest owners, and  biofuels producers.  These
estimates are in addition to those provided in to document entitled,
“Renewable Fuels Standard (RFS2) Program – EPA ICR No. 2333.01.” 
(The referenced document has already been docketed.)  

	 The proposed RFS2 regulation does not specify the exact method of
third party disclosure; however the proposed definition of “renewable
biomass” references documentation that a feedstock producer should
already have in its possession and which would presumably need to
communicate to the biofuel producer.  

	The proposed definition of “renewable biomass” at § 80.1401 is as
follows:  

	Renewable biomass means each of the following:

(1) 	Planted crops and crop residue harvested from existing agricultural
land.

(2)	Planted trees and slash from a tree plantation located on
non-federal land (including land belonging to an Indian tribe or an
Indian individual that is held in trust by the U.S. or subject to a
restriction against alienation imposed by the U.S.) that was cleared at
any time prior to December 19, 2007, and has been continuously actively
managed since December 19, 2007.  Active management is evidenced by any
of the following:

(i)	Records of sales of planted trees or slash, or records of purchases
of seeds, seedlings, or other nursery stock.

(ii)	A written management plan for silvicultural purposes.

(iii)	Documented participation in a silvicultural program administered
by a Federal, state, or local government agency.

(iv)	Documented management in accordance with a certification program
for silvicultural products.

(3)	Animal waste material and animal byproducts.

(4)	Slash and pre-commercial thinnings from non-federal forestland
(including forestland belonging to an Indian tribe or an Indian
individual, that are held in trust by the United States or subject to a
restriction against alienation imposed by the United States) that is not
ecologically sensitive forestland.

(5)	Biomass (organic matter that is available on a renewable or
recurring basis) obtained from within 200 feet of buildings,
campgrounds, and other areas regularly occupied by people, or of public
infrastructure, such as utility corridors, bridges, and roadways, in
areas at risk of wildfire.

(6)	Algae.

(7)	Separated yard waste or food waste, including recycled cooking and
trap grease.

 	Our estimates are found in Table A-1, “Third Party Disclosure by
Biofuel Feedstock Producers.”  We have identified three categories of
biofuels feedstock producers.  These are 1) plantation/private forest
owners, 2) farmers, and 3) foreign biofuel feedstock producers.

	The number of private forest owners in our estimate is derived from a
presentation given by Brett J. Butler, United States Forest Service,
entitled “Private Forest Owners:  Past, Present, and Future,” dated
October 23-27, 2007.  See page 9.  A copy of this presentation has been
placed in the docket, as part of this addendum.  From a 10,000,000
population total, we project that 0.1%, or 10,000 plantation/private
forest owners, will be biofuel feedstock producers subject to this
proposed information collection. We estimate one disclosure per party
per year, and a response time of 15 minutes for each disclosure. 

	The number of farmers in our estimate is derived from the total number
of corn and soy bean farmers.  The number of farmers who produce corn as
a crop is based upon the Corn Farmers Coalition, The Corn Fact Book,
“The Farmer.”  We have estimated 300,000 corn farmers.   The
American Soybean Growers estimates 22,000 soybean producers on their
website. When these two parties are totaled, we estimate 322,000
feedstock producers.   Of this number, we estimate 10 % of the 322,000
or 32,200 farmers in the feedstock market will be subject to this
information collection.  We anticipate two harvests per year and an
average of five customers per farmer, for a total of ten disclosures per
year.  We estimate a response time of 15 minutes for each disclosure.

	We estimate the number of foreign biofuel feedstock producers to be
1,266, which is 3% of the total number of domestic biofuel feedstock
producers.  We are using a 3% estimate based on our experience with
other fuels programs.  We estimate that there are 42,200 domestic
biofuel producers.  This estimate is equal to the total number of
plantation/private forest owners and the total number of famers (corn,
soy) that we believe are subject to this information collection, i.e.,
10,000 added to 32,200, respectively.  (Ref. Table A-1, below.)  For
foreign biofuel producers, we have estimated two responses per year and
a total response time of 15 minutes per response.       

	For purposes of this estimate and for the related NPRM, we are assuming
that third party disclosure will be of documents that the disclosing
party should already have in its possession.  Hence, we estimate 15
minutes per disclosure. If we were to require more specific disclosure
in response to comments received on the proposal, or if we were to
require information in a format other than the disclosing party already
has and is familiar with, then we may expect the time and cost per
response, and the overall burden in terms of hours and cost to increase.
 

	Our estimates in Table A-1 are as follows:  

Information Collection Burden by Type of Party

Table A-1:  Third Party Disclosure by Biofuel Feedstock Producer



	Collection Activity	Number of Parties	Number of Responses per Party
Total Number of Responses	Time per Response	Cost per Response	Total
Hours	Total Cost

Plantation/Private Forest Owners	10,000	1	10000	0.25	17.75	2500	177500

(0.1% of 10,000,000)







	Farmers (corn, soy)	32,200	10	322000	0.25	17.75	80500	5715500

10% of 322,000, 







	assumes 5 customers,







	2 harvests/year







	Foreign Biofuel Feedstock Producers	1,266	2	2532	0.25	17.75	633	44943

(3%of the total domestic)







	TOTAL	43,466

334532

	83633	5937943



 Corn Farmers Coalition, The Corn Fact Book, “The Farmer,” at  
HYPERLINK "http://cornfarmerscoalition.org/fact-book" 
http://cornfarmerscoalition.org/fact-book .  (Accessed April 14, 2009.)

 America Soybean Association,    HYPERLINK "http://www.soygrowers.com" 
http://www.soygrowers.com  on the tab labeled “About ASA.  (Accessed
April 14, 2009.)  

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