SUPPORTING STATEMENT

Consolidated Emissions Reporting (Renewal)

OMB # 2060-0088, EPA ICR # 0916.13 tc "SUPPORTING STATEMENT

Final Consolidated Emissions Reporting Rule 

OMB # 2060-0088, EPA ICR # 0916.10" 

1.	IDENTIFICATION OF THE INFORMATION COLLECTION  tc "1.	IDENTIFICATION
OF THE INFORMATION COLLECTION " \l 2 

	1(a) Title of the Information Collection  tc "	1(a) Title of the
Information Collection " \l 3 

	“Consolidated Emissions Reporting (Renewal)”

	1(b) Short Characterization/Abstract  tc "	1(b) Short
Characterization/Abstract " \l 3 

	The United States Environmental Protection Agency (EPA) promulgated the
Consolidated Emissions Reporting Rule (CERR) to coordinate new emissions
inventory reporting requirements with existing requirements of the Clean
Air Act (CAA) and 1990 Amendments.  An Information Collection Request
(ICR) entitled “Consolidated Emissions Reporting – Final Rule,”
presented burden estimates for respondents to comply with annual
inventory provisions required by 40 CFR 51 subpart A [Office of
Management and Budget (OMB) #2060-0088].  EPA recently promulgated the
Air Emissions Reporting Requirements (AERR) rule which will replace the
CERR.  The AERR updates data reporting under the CERR and further
consolidates, simplifies and harmonizes data reporting requirements. 
The first year of data reporting under the AERR was initially targeted
for 2008.  The final AERR rule was published on December 17, 2008 which
delayed the first year of data reporting until 2009.  Due to the delay
in implementing the AERR, data reporting for 2008 will be under the CERR
which necessitates renewing the CERR ICR since it will expire on October
31, 2009 and state data reporting activities for 2008 will not conclude
until June 1, 2010.

	This ICR is being submitted to renew EPA’s authority to collect
emissions related information from state and local air pollution control
agencies.  EPA has reviewed the analysis done under the Consolidated
Emissions Reporting – Final Rule supporting statement and updated the
assumptions with respect to labor rates and point source reporting using
the latest available data.

	Under the final CERR ICR, 55 state and territorial air quality
agencies, including the District of Columbia (DC), as well as an
estimated 49 local air quality agencies, must annually submit emissions
data for point sources emitting specified levels of volatile organic
compounds (VOCs), oxides of nitrogen (NOx), carbon monoxide  (CO),
sulfur dioxide (SO2), particulate matter less than or equal to
10 micrometers in diameter (PM10), particulate matter less than or
equal to 2.5 micrometers in diameter (PM2.5), and ammonia (NH3).  

	Every 3 years, states1 will be required to submit a point source
inventory, as well as a statewide stationary nonpoint, nonroad mobile,
onroad mobile, and biogenic source inventory for all criteria pollutants
and their precursors.  The emissions data submitted for the annual and
3-year cycle inventories for stationary point, nonpoint, nonroad mobile,
and onroad mobile sources will be used by EPA’s Office of Air Quality
Planning and Standards (OAQPS) to assist in developing ambient air
quality emission standards, performing regional modeling, and preparing
national trends assessments and other special analyses and reports

This ICR also estimates burden hours and costs incurred by a portion of
industry sources 

to estimate and report PM2.5 and NH3 point source emissions.  The burden
estimates for industry to report PM2.5 and NH3 emissions were included
in the original CERR ICR to address this new statewide reporting
requirement.  These estimates have been retained in this renewal
although reporting PM2.5 and NH3 emissions is no longer a new
requirement and reporting these emissions continues to be the
responsibility of the states.

2.	NEED FOR AND USE OF THE COLLECTION  tc "2.	NEED FOR AND USE OF THE
COLLECTION " \l 2 

	2(a) Need/Authority for the Collection  tc "	2(a) Need/Authority for
the Collection " \l 3 

	The purpose of the CERR is to coordinate the various state emission
inventory reporting requirements, and streamline the activities involved
in submitting the emissions data to EPA.  The CERR has enabled the EPA
to achieve uniformity and completeness in a national inventory to
support national, regional, and local air quality planning and
attainment.  As EPA moves towards a regional focus in addressing air
quality issues, there is a greater need for states to develop consistent
inventories and to share their emissions inventory data with other
groups.

	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.  Sections
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.

	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, NOx, 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.  Although the periodic
reporting requirements in the CAA only apply to pollutant nonattainment
areas, consolidated emissions reporting requirements for the 3-year
cycle inventory are statewide, regardless of the attainment status of an
area.  As the regional nature of pollution is recognized, the
availability of multistate inventory data representative of a complete
state is vital, especially for those downwind states with nonattainment
problems caused in part by pollution transported across state
boundaries.

	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.  This authority is used, for example, in requiring a periodic
inventory of PM10 emissions for PM10 nonattainment areas.  To support
state efforts to attain the PM2.5 NAAQS, this requirement is extended
statewide for PM10, and includes PM2.5 emissions, as well as NH3, NOx,
SO2, and VOC.

	In addition, the EPA has promulgated regulations outlining a visibility
protection program to address regional haze in mandatory Class I Federal
Areas (certain large national parks and wilderness areas).  As part of
this requirement, it is important for states to develop inventories for
sources that are reasonably anticipated to contribute to regional haze
visibility impairment.  These inventories are used as inputs to regional
models and used as the basis for regional pollutant trading programs. 
The need for enhanced inventory development and expanded regional
modeling capabilities has been greatly emphasized by a number of
organizations, including the Grand Canyon Visibility Transport
Commission (GCVTC) and the Clean Air Act Advisory Council (CAAAC). 
Emissions of VOC, NOx, SO2, NH3, and primary PM all result in visibility
impairment, so developing and reporting enhanced statewide emission
inventories for these pollutants will support the regional haze program
as well.

	2(b) Practical Utility/Users of the Data  tc "	2(b) Practical
Utility/Users of the Data " \l 3 

	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.

	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 AERMOD, CAMx and CMAQ.  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 and
Analysis Group (EIAG) 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 universities and
others involved in research.

	The respondents to the CERR also use and benefit from the emissions
data required by this ICR.  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) have been used by the
Regional Planning Organizations (RPOs) as the starting point for the
development of statewide emission inventories to define control
strategies for the regional haze program. 

3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA  tc "3.
NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA " \l 2 

	3(a) Nonduplication  tc "	3(a) Nonduplication " \l 3 

	Previous reporting requirements have occasionally forced state agencies
into inefficient data collecting and reporting activities.  The final
CERR 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, emission statement data are currently collected by
states but not reported to EPA.  Emission statements are required from
specified VOC and NOx emission sources in ozone nonattainment areas, as
well as higher emitting VOC and NOx point sources in the ozone transport
region.  As appropriate, states may use emission statement data to meet
annual and 3-year cycle point source inventory reporting requirements. 
Additionally, under the NOx SIP Call rule, the EPA is requiring states
to submit annual inventories for all NOx sources for which states adopt
control measures to meet their NOx budget.  Every 3 years, statewide NOx
inventories of all controlled and uncontrolled sources are required. 
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.

	The CERR established reporting requirements for PM2.5 and NH3.  In
light of the PM2.5 NAAQS, accurate emissions data for PM2.5 and its
precursor, NH3, are important to successfully develop a control strategy
and implement controls for areas determined to be nonattainment for the
PM2.5 NAAQS.

	3(b) Public Notice Required Prior to ICR Submission to OMB  tc "	3(b)
Public Notice Required Prior to ICR Submission to OMB " \l 3 

	The Federal Register notice, announcing the ICR renewal, was published
on April 15, 2009.  No public comments were received.  

	3(c) Consultations  tc "	3(c) Consultations " \l 3 

	EPA participates regularly on monthly conference calls chaired by the
National Association of Clean Air Agencies (NACAA) to discuss issues
raised by state agencies related to emission inventories.  In addition,
EPA recently formed a workgroup that consists of state agencies to
assist with development of a new EPA database known as the Emission
Inventory System (EIS).  The EIS will serve as a repository for state
agency data submitted to EPA under the CERR requirements.  Issues
related to data development and submittal are regularly discussed with
state agencies during workgroup conference calls.  

     

	3(d) Effects of Less Frequent Collection  tc "	3(d) Effects of Less
Frequent Collection " \l 3 

	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.  Although the CERR did reduce the
frequency of reporting for the majority (i.e., approximately 78 percent)
of all point sources (i.e., from annually to once every 3 years), annual
reporting of emissions data for larger stationary sources of pollution
is still required.  Annual reporting for Type A point sources is needed
to track state efforts to reduce pollutant emissions from these sources.
 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 annually for Type A
sources, or every 3 years for all other sources that comprise a complete
state emissions inventory, 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  tc "	3(e) General Guidelines " \l 3 

	This ICR does not violate any of OMB’s guidelines for information
collections.

	3(f) Confidentiality  tc "	3(f) Confidentiality " \l 3 

	Any data that is submitted to EPA under the CERR is in the public
domain and cannot be treated as confidential.  

	3(g) Sensitive Questions  tc "	3(g) Sensitive Questions " \l 3 

	This section is not applicable to this ICR because no information
including matters of a sensitive nature is collected.  

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED  tc "4.	THE RESPONDENTS
AND THE INFORMATION REQUESTED " \l 2 

	4(a) Respondents/North American Industry Classification System (NAICS)
Codes  tc "	4(a) Respondents/Standard Industrial Classification (SIC)
Codes " \l 3 

	The emissions data required by the CERR will generally be submitted by
state air pollution control agencies.  An estimated 55 state and
territorial air pollution control agencies, as well as 49 local air
agencies 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 affected NAICS code would be 92411, Air and Water Resource and
Solid Waste Management, which includes governmental environmental
protection and control agencies, and pollution control agencies. 

	This ICR also estimates a burden for a portion of industry sources to
estimate and report PM2.5 and NH3 point source emissions.  These
industry sources are expected to fall within multiple NAICS codes
covering primarily the combustion and chemical manufacturing sectors. 
NAICS codes within those sectors include 22, Utilities and 31 – 33 for
Manufacturing.

	4(b) Information Requested  tc "	4(b) Information Requested " \l 3 

	The CERR consolidated emission inventory data that were being collected
by states and reported to EPA under several different provisions of the
CAA, including periodic or 3-year cycle inventories, and annual point
source inventories.  Every year, state agencies are required to submit
emissions data for large stationary point sources emitting one or more
of the following pollutants above a specified level:  VOC, NOx, CO, SO2,
PM10, PM2.5, and NH3.  The CERR also requires states to report point,
nonpoint, nonroad mobile, onroad mobile, and biogenic source emissions
data for all criteria pollutants and their precursors every 3 years on a
statewide basis.  There are no annual reporting requirements for sources
of Lead (Pb), however, lead emissions must be included in the 3-year
cycle inventories.  The thresholds for triennial point source reporting
are consistent with the thresholds established for the existing annual
point source inventory, and are lower than the thresholds required for
annual point source reporting under the final CERR.

Data elements that must be reported by state agencies for point,
nonpoint, and onroad and nonroad mobile sources are listed in Appendix A
to Subpart A of 40 CFR part 51

	(ii) Respondent activities

	For the point source inventory reporting requirements of the CERR,
respondent activities generally involve taking emissions and related
parameters from an automated file, resolving any errors or anomalies
identified through edits or other qualitative reviews, and providing it
to EPA electronically using eXtensible Markup Language (XML) format. 
Thus, the activities for generating criteria pollutant point source
inventories are primarily data processing and typically do not involve
the development of new data which does not already exist in the
state’s files.  However, compiling a triennial statewide nonpoint,
mobile, and biogenic source inventory is expected to involve additional
effort by a state.  The specific state and industry respondent
activities associated with the CERR are outlined below, and are grouped
into annual and triennial activities.

		

2,500 tons per year (tpy) of NOx, CO, or SO2, or 250 tpy of VOC,
or PM2.5, PM10; and NH3.

	

	Annual industry activities include calculating and submitting emissions
data for Type A point sources emitting 250 tons per year (tpy) of
PM2.5 or NH3 to state and local agencies.  Renewal of this ICR will
continue the existing reporting requirements for PM2.5 and NH3 but will
not impose any new reporting burdens on industry or states.

	Triennial state activities include:

100 tpy of VOC, NOx, SO2, PM10, PM2.5, NH3 or 1,000 tpy of CO, as
well as emissions data for Type A sources;

•	Developing and reporting statewide inventory for stationary
nonpoint, nonroad mobile, and onroad mobile for all pollutants; and

•	Compiling and reporting baseline biogenic emissions inventory for
all applicable pollutants (but only if land use characteristics or the
method used to estimate emissions are changed from baseline inventory).

100 tons per year (tpy) of PM2.5 or NH3 to state and local agencies. 
Renewal of the ICR continues the existing reporting requirements for
PM2.5 and NH3 but will not impose any new reporting burdens on industry
or states.

	For states without nonattainment areas for the criteria air pollutants,
the burden associated with preparing statewide stationary nonpoint,
nonroad mobile, and onroad mobile source inventories was a new
requirement for the 2002 inventory.  However, many states had existing
nonattainment areas and had already prepared stationary nonpoint,
nonroad mobile, and onroad mobile source inventories for their
nonattainment counties.  states with existing ozone nonattainment areas
had also prepared an initial biogenic emission inventory for their
nonattainment counties.  For states with existing nonattainment areas,
the incremental burden associated with preparing statewide stationary
nonpoint, nonroad mobile, and onroad mobile source inventories every 3
years was associated with extending the inventories to cover attainment
counties.  This incremental burden will vary by state depending on the
total number of counties as well as the number of nonattainment versus
attainment counties within each state.  Renewal of the ICR will pose no
new burden on states for statewide emissions reporting since states have
reported statewide emissions for the 2002 and 2005 triennial
inventories.

5.	THE INFORMATION COLLECTED–AGENCY ACTIVITIES, COLLECTION METHODS,
AND INFORMATION MANAGEMENT  tc "5.	THE INFORMATION COLLECTED–AGENCY
ACTIVITIES, COLLECTION METHODS, AND INFORMATION MANAGEMENT " \l 2 

	5(a) Agency Activities  tc "	5(a) Agency Activities " \l 3 

	The EPA activities associated with the CERR 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  tc "	5(b) Collection
Methodology and Management " \l 3 

	The EPA has established a central repository of inventory data for all
states called 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.  

	To support the CERR, the EPA assumed the responsibility of creating and
maintaining a central repository of inventory data for all states, but
the data must be supplied by the states in electronic form.  Electronic
data reporting will be conducted using eXtensible Markup Language (XML)
format.

	5(c) Small Entity Flexibility  tc "	5(c) Small Entity Flexibility " \l
3 

	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 2000 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 populations
are less than 50,000.

	These local agencies are likely to have experience and resources for
compiling point source inventories.  However, the additional burden of
developing complete nonpoint and mobile source inventories for all
counties in their jurisdiction may place a significant economic impact
on a small agency.  To assist in alleviating this burden on small
entities, EPA is providing respondents the option of using EPA’s NEI
estimates to comply with the statewide nonpoint, biogenic and mobile
source reporting provisions.

	5(d) Collection Schedule  tc "	5(d) Collection Schedule " \l 3 

	States must annually report all required emissions data for Type A
point sources of VOC, NOx, CO, SO2, PM10, PM2.5, and NH3.  Beginning
with inventory year 2002, and every 3 years thereafter, states are
required to submit emissions data for all smaller point sources (i.e.,
Type B sources) emitting specified thresholds for the same pollutants
required for Type A sources.  As part of the 3-year cycle reporting
requirement, states must also submit statewide stationary nonpoint,
nonroad mobile, and onroad mobile source emissions for VOC, NOx, CO,
SO2, PM10, PM2.5, Pb and Pb compounds, and NH3.  

	The CERR also contains a provision that allows states the option of
estimating one-third of their 3-year cycle inventories, including Type B
sources, in any given year.  This enables states to spread out the
effort required to prepare a complete 3-year cycle inventory over 3
years.  Some conditions apply if a state chooses this reporting option
(e.g., emission estimates for each year that comprise a complete 3-year
cycle inventory must be compiled identically), and states subject to the
NOx SIP Call may not report triennial NOx emissions inventories in this
manner.

	For all of the above reporting activities, EPA requires that states
submit the appropriate emissions data within 17 months of the end of the
inventory year (e.g., a statewide pollutant emissions inventory for the
year 8 would be required by June 1 of 2010).  One exception, however, is
for states subject to NOx SIP call reporting provisions.  These states
are required to report their data within 12 months of the end of each
applicable inventory year (according to §51.122).

6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION  tc "6.	ESTIMATING
THE BURDEN AND COST OF THE COLLECTION " \l 2 

	6(a) Estimating Respondent Burden  tc "	6(a) Estimating Respondent
Burden " \l 3 

	The respondent burden for complying with the reporting requirements of
the CERR ICR is estimated based on the burden associated with existing
annual inventory and 3-year cycle inventory reporting requirements. 
These burden estimates were initially estimated for the original CERR
ICR (0916.10).  The burden estimates have been adjusted using recent
point source reporting data from the National Emission Inventory and
updated labor rates.

	The following sections discuss the assumptions used to develop burden
hour estimates for annual 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 3-year period that the affected
states would have to report emissions data to EPA.  In this case, that
period corresponds to the years 2009, 2010, and 2011 [since they would
likely begin collecting data for the year 2008 during 2009, and would
report the data within 17 months of the end of 2008 (i.e., June 1,
2010)].  Table 6-2 shows the required activities that a state must
perform each year, beginning in the year 2009 through 2011.  Table 6-3
presents the state and local respondent annual burden hours and costs by
activity.  Table 6-4 presents the industry respondent annual burden
hours and costs by activity.

		Annual activities  tc "Annual activities " \l 4 

	Based upon reporting data from the 2005 NEI, fewer sources are expected
to be reported annually as Type A compared to the burden estimates
developed for ICRs 0916.10 and 0916.12.  The updated analysis follows.

	Every 2 of 3 years, state, territorial, and local agencies would only
submit point source data for Type A sources.  Because the Type A source
thresholds are higher than the emission levels specified by the existing
annual point source inventory, emissions data are required annually for
a smaller number of sources, and this item represents a decrease in
state burden.  The burden for states to report emissions data for Type B
point sources was already accounted for in the ICR for the existing
annual point source inventory (OMB #2060-0088).  When accounting for all
the burden items involved in compiling and reporting an annual point
source inventory, the existing ICR estimated an average of 212 hours per
year per respondent.  As such, the decrease in burden hours every 2 of 3
years was calculated relative to this existing burden estimate.

	To estimate the decrease in burden resulting from compiling and
reporting emissions data for fewer sources, EPA estimated the number of
sources that would be subject to the annual reporting thresholds, and
compared this to the number of sources covered by the existing annual
reporting thresholds.  This was done by performing a query of the 2005
NEI to determine the number of sources (i.e., plants) emitting 2,500 tpy
of SO2, NOx, or CO, or 250 tpy of VOC or PM10.  The number of sources
meeting these criteria was 1,783.  A second query of the 2005 NEI was
performed to estimate the number of sources emitting 100 tpy of SO2,
NOx, VOC, or PM10, or 1,000 tpy of CO.  The number of sources meeting
these criteria for the second query was 6,410.  Since 1,783 is 28
percent of 6,410, the decrease in burden associated with the CERR annual
threshold was estimated to be 72 percent of the burden estimate
associated with the original approved ICR (OMB #2060-0088).  Every 2 of
3 years, the revised respondent burden for a state to report annual
point source emissions for the CERR was, therefore, estimated to be
60 hours per year (28 percent of 212 hours per year = 59.4 which was
rounded up to 60).  The technical and managerial hour burden was
estimated at 57 and 3 hours, respectively.  Hours corresponding to
sub-activities were allocated according to the distribution in the ICR
for the existing annual point source inventory.

	The requirements to estimate and report PM2.5 and NH3 emissions were
new when the CERR was developed and separate estimates were developed
for ICR 0916.10 to account for the increase in burden.  These estimates
have been updated in this ICR and continue to be reported separately
although the requirements are no longer new.

	For the PM2.5 and NH3 point source reporting burden calculations, we
assume that a certain fraction of industry sources emitting at or above
the Type A or Type B point source levels for PM2.5 and NH3 would incur
burden as a result of this reporting requirement (i.e., the state and
local agency respondents would request the PM2.5 and NH3 emissions data
from the sources in their jurisdiction).  The remaining sources were
assumed to be located in states or local jurisdictions that will
estimate PM2.5 and NH3 point source emissions themselves without passing
this requirement on to industry.

	To estimate this burden, PM2.5 and NH3 facility counts were obtained
from EPA’s 2005 National Emissions Inventory (NEI), Version 2.0. 
According to the 2005 NEI, 1,347 facilities report annual PM2.5
emissions and 999 facilities report annual NH3 emissions equal to or
greater than 100 tpy.   This results in 2,346 total combined PM2.5 and
NH3 sources exceeding the Type B point source thresholds.  To address
the annual reporting burden for Type A sources only, source counts were
obtained by applying the higher Type A thresholds.  The 2005 NEI has 692
facilities with annual PM2.5 emissions and 566 facilities with annual
NH3 emissions equal to or greater than 250 tpy. 

	It was estimated that a majority of state and local agencies will pass
this PM2.5 and NH3 reporting requirement on to industry (from ICR #
0916.10).  Using this information, we assumed that 75 percent of the
total state and local agency respondents, or 78 respondents, will
request that industry sources provide them with estimates of PM2.5 and
NH3 point source emissions.  We do not have information to identify
which specific states or local agencies will comply in this manner. 
Therefore, we assume that 75 percent of the sources, or 1,759 industry
sources in the 78 state/local jurisdictions, will incur this burden
(i.e., 0.75 x 2,346 PM2.5 and NH3 sources = 1,759).

	

	For the industry burden, 75 percent of the Type A sources (i.e., 944
sources) were assumed to incur some burden for annually estimating and
reporting PM2.5 and NH3 emissions.  The number of PM2.5 and NH3 point
sources exceeding the Type A point source thresholds is 1,258, with 692
sources reporting PM2.5 emissions and 566 sources reporting NH3
emissions (2005 NEI).  For PM2.5 reporting, if a plant exceeds the
threshold for PM2.5, it also exceeds the threshold for PM10, and,
therefore, would already be subject to the annual inventory requirements
for PM10.  The incremental burden for PM2.5 would be associated with
only compiling and reporting PM2.5 emissions, as all other data elements
should already be reported as a result of the PM10 requirements. 
Facilities emitting major source levels of NH3 may not be as likely to
be major sources for other pollutants.  The average effort associated
with reporting a PM2.5 and NH3 point source inventory was estimated to
be 1 managerial hour and 3 technical hours per year per source for
PM2.5, and 1 managerial hour and 5 technical hours per year per source
for NH3.

	The estimate for annually reporting PM2.5 and NH3 was assumed to be the
same whether the state requested the emissions estimates from the
sources or estimated the emissions themselves.  If requested by states
to estimate emissions, industry would need to report their emissions to
the state agency, and the state in turn would submit their data to EPA
(i.e., generally industry will not submit their point source data
directly to EPA, unless they are an electricity-generating unit subject
to Title IV Acid Rain provisions).  Once the calculations were
established for estimating PM2.5 and NH3 emissions, the average
additional effort for a state or local agency to incorporate and report
a PM2.5 and NH3 point source inventory was estimated to be 20 hours per
year per agency (i.e., 19 hours of technical staff time, and 1 hour of
managerial staff time).

		Triennial activities  tc "Triennial activities " \l 4 

	Every 3 years, states are required to submit emissions data for
specified pollutants for all point, nonpoint, nonroad mobile, and onroad
mobile sources within the state.  States are already submitting a
statewide emissions inventory of all criteria pollutant point sources
under the existing annual inventory requirements.  The burden for
submitting the Type B point source inventory was estimated to be 212
hours (i.e., 200 hours of technical staff time and 12 hours of
managerial staff time).  This is equivalent to the burden established
for the existing annual inventory, since one of every 3 years this
burden is not expected to change for reporting point source data.  For
PM2.5 and NH3 point sources, the 20 hour burden estimate for state
agencies previously discussed covers Type B sources.

	To estimate the triennial industry burden, it was assumed that the
burden per source was the same as the annual industry burden (i.e., 1
managerial hour and 3 technical hours per source for PM2.5, and 1
managerial hour and 5 technical hours per source for NH3).  However the
number of sources subject to Type B reporting thresholds will be higher.
 The number of PM2.5 and NH3 point sources exceeding the Type B point
source thresholds is 2,346, with 1,347 sources reporting PM2.5 emissions
and 999 sources reporting NH3 emissions (2005 NEI).  Therefore,
75 percent of the Type B sources (i.e., 1,759 sources) were assumed to
incur some burden for estimating and reporting PM2.5 and NH3 Type B
emissions every 3 years.

	A burden is expected for states to develop statewide stationary
nonpoint, nonroad mobile, and onroad mobile source inventories every 3
years.  The incremental burden for local agencies to develop and
estimate statewide inventories was estimated to entail the use of 0.5
FTE(1040 hours or 346.67 hours/year).  2,080 technical labor hours
(693.33 hours/year) were estimated to be the burden for a state to
calculate and report statewide inventories every 3 years.  Additional
managerial hours of 104 (34.67 hours/year) were added for this activity.

	For local agencies responsible for developing and reporting nonpoint
and mobile source emissions for each county within their jurisdiction,
the triennial burden was estimated to be one-half of that attributed to
state agencies (i.e., ½ of 2,080 = 1,040 technical hours plus 52
managerial hours).  Additional hours were also estimated for all local
agencies (i.e., 49 agencies) to coordinate and provide some de minimis
emissions inventory data or supporting information to their
corresponding state agency.  The time estimated for each local agency to
perform these activities every 3 years was estimated to be 80 technical
hours and 4 managerial hours.

	Burden hours were also estimated for all states to establish a baseline
biogenic emission inventory and report this information to EPA.  For
each subsequent 3-year cycle inventory of biogenic emissions, a state
would not be required to submit its inventory unless land-use
characteristics or the method used to estimate emissions are changed. 
This activity was estimated to take 40 technical hours and
2 managerial hours per state, assuming that a state uses the Biogenic
Emissions Inventory System (BEIS) model supplied by EPA to generate
emission estimates.  For the burden calculations, local agencies are not
assumed to be responsible for developing a biogenic inventory.  In
addition, it is expected that EPA will generate biogenic emissions
inventories to be provided to each state for comment, so these burden
hours are likely to represent an upper-bound estimate. 

	

	6(b) Estimating Respondent Costs  tc "	6(b) Estimating Respondent Costs
" \l 3 

	Table 6-3 presents state and local respondent annualized hours and
costs for each information collection activity.  To estimate annualized
hours and costs for triennial activities, the burden estimate is divided
by 3 to estimate the burden over a 3-year period.  For annual
activities, annualized hours are already calculated.  However, in the
case of the annual Type A point source reporting every 2 of 3 years, the
annualized hours are estimated by multiplying the burden estimate (i.e,
60 hours) by 2 and dividing by 3 (since every 3 years the point source
reporting burden is accounted for under triennial activities).  The
annualized hours are estimated to be 2 x 60 = 120/3 = 40 hours per year.

	Table 6-4 presents industry respondent annualized hours and associated
costs for each information collection activity.  Annualized hours and
costs for annual and triennial activities were estimated the same as the
state and local respondents hours and costs.

		(i) Estimating Labor Costs  tc "(i) Estimating Labor Costs " \l 4 

	For this ICR, the labor rate for technical staff at state, territorial,
and local agencies uses the following labor rates.  For management,
professional and related, a rate of $96.38 was used ($48.19 per hour +
100% overhead), and for technical staff, a rate of $78.60 was applied
($39.30 per hour + 100% overhead).  These rates were obtained from
“Table 4. Employer costs per hour worked for employee compensation and
costs as a percent of total compensation: state and local government
workers, by occupational and industry group, December 2008,” published
by the U.S. Department of Commerce, Bureau of Labor Statistics.  When
considering both technical and managerial hours, labor costs for state
and territorial agencies are estimated to be about $69,000 per year per
respondent, and labor costs for local agencies are estimated to be about
$31,000 per year per respondent.

	

	In order to estimate the industry labor costs, this ICR uses the
following labor rates.  For management, professional and related, a rate
of  $101.82 was used ($48.49 per hour + 110% overhead), and for
technical staff, a rate of $60.06 was applied ($28.60 per hour + 110%
overhead).  These rates were obtained from “Table 2. Employer costs
per hour worked for employee compensation and costs as a percent of
total compensation:  Civilian workers, by occupational and industry
group, December 2008,” published by the U.S. Department of Commerce,
Bureau of Labor Statistics.  The industry labor costs are estimated to
be approximately $685 per year per respondent.

		(ii) Estimating Capital and Operations and Maintenance Costs  tc "(ii)
Estimating Capital and Operations and Maintenance Costs " \l 4 

	The methodology for estimating capital and operations and maintenance
costs presented below is based on the method used in the ICR for the
annual inventory (EPA ICR #0916.12, OMB #2060-0088).  Assumptions
regarding the number of respondents and work stations are unchanged.

	The number of respondents reflects the number of agencies (state,
territorial and local) believed to be reporting data directly to EPA. 
The number of work stations assumed for each respondent reflects the
number of work stations that would be dedicated to reporting under the
CERR.  It was assumed that each state or local agency would require five
(5) work stations to comply with the reporting provisions of the CERR (1
for point sources, 1 for nonpoint sources, 1 for onroad mobile, 1 for
nonroad mobile, and 1 for managerial/coordination activities).  These
costs are accounted for in Table 6-3 under the annual activity
involving the submittal of Type A point source data by states, although
the estimates are anticipated to cover the costs involved in developing
statewide nonpoint and mobile source inventories as well.

	The cost for replacing a work station, when replacement becomes
necessary, is assumed to be approximately $2,100 per agency.  For this
ICR, it is assumed that 20 percent of the work stations will be
replaced each year.  Thus, the costs of replacement per agency would be:

	5 work stations/agency x 20% replacement/year x $2100/work station =
$2100/agency/year

	Cost of work station replacement for all agencies equals:

	$2100/replacement costs/year x 104 agencies/year = $218,400/year

	Maintenance costs are attributed to the normal maintenance of the work
stations used to submit the required annual and triennial reports to
EPA.  These costs are estimated to be approximately $120 per agency. 
Thus, total maintenance costs for the respondents are:

	$120/agency x 104 agencies = $12,480/year

	6(c) Estimating Agency Burden and Cost  tc "	6(c) Estimating Agency
Burden and Cost " \l 3 

	EPA’s costs which relate to this collection can be grouped into three
areas:

	1)	NEI Data Base support;

2)	Processing of data; and

3)	Information requests.

	As of fiscal year 2005, approximately 2.5 FTE positions and $250,000
were used per year to manage the NEI Oracle Data Base.  This involves
developing and maintaining software, and providing basic support
services to users, including training on the NEI Input Format.  After
EPA transitions to the new Emission Inventory System (EIS), the annual
operation and maintenance costs are estimated to be as follows:  3.0 FTE
positions, $300 K in Working Capital Funds and $750 K for an Information
Technology contractor.

	The costs of processing data submitted by states include costs relating
to data editing, coordination of efforts to resolve any errors or
anomalies identified through the edits or other reviews, and updating of
the files after the quality assurance and reconciliation assurance
efforts have been completed.  Within the EPA, the Regional Offices
annually use about two FTEs to coordinate state efforts in making their
submissions, perform software edits and other quality reviews, and if
required, coordinate updates performed by the OAQPS.  The OAQPS uses
approximately one FTE at a cost of $100,000 to track and process annual
data.  Therefore, approximately 3 FTEs at an annual cost of $300,000 are
used by EPA to track and process data.

	6(d) Estimating the Respondent Universe and Total Burden and Costs  tc
"	6(d) Estimating the Respondent Universe and Total Burden and Costs "
\l 3 

	The number of respondents is estimated to be 51 states (including DC),
4 territories and 49 local agencies, resulting in 104 total
respondents.  The total annual hourly burden for all state respondents
is estimated to be 51,771 hours per year and the total annual cost is
estimated to be $4,345,089 (Table 6-3)

The number of industry respondents is estimated to be 1,759.  The total
hourly burden

is estimated to be 5,927 hours per year and the total annual cost is
estimated to be $406,630 (Table 6-4).

	6(e) Bottom Line Burden Hours and Cost Tables   tc "	6(e) Bottom Line
Burden Hours and Cost Tables  " \l 3 

Total Estimated Respondent Burden and Cost Summary

Burden Element/Cost	State Respondents	Industry Respondents	Total

Number of Respondents1	104	1,759	1,863

Number of Activities2	832	7,036	7,868

Total Hours Per year3	51,771	5,927	57,698





	Annual Capital Cost4	$218,400	0	$218,400

Annual O&M Cost4	$12,480	0	$12,480

Total Annual Capital and O&M Costs	$230,880	0	$230,880





	Labor Cost Per Year	$4,114,209	$406,630	$4,520,839

Total Cost Per Year	$4,345,089	$406,630	$4,751,719

1.  For state Respondents – Section 6(d), for Industry Respondents –
Section 6(d)

2.  On average, each state Respondent is assumed to perform 8 discrete
activities associated with CERR, as indicated in Table 6-3.  Each
Industry Respondent is assumed to perform 4 discrete activities
associated with the CERR, as indicated in Table 6-4.

3.  Section 6 (d)

4.  Section 6 (b)

	6(f) Reasons for Change in Burden  tc "	6(f) Reasons for Change in
Burden " \l 3 

	The ICR shows a slight reduction in reporting burden (58,172 approved
hours – 57,698 hours requested = (474) hours).  This is due to use of
updated point source reporting data from the 2005 NEI that indicates
fewer Type A sources will be reported annually than estimated in ICR #
0916.12.

	6(g) Burden Statement  tc "	6(g) Burden Statement " \l 3 

	Table 6-3 indicates that reporting of emissions data required by the
CERR will involve 1,265 hours per year for state, territorial and local
air pollution control agencies that perform all reporting activities. 
However, many agencies will perform a subset of the activities and the
average annual reporting burden for state, territorial and local air
pollution control agencies is estimated to require 498 hours.  Table 6-4
indicates that the burden for each industry performing all reporting
activities will be 10 hours per year.  Similar to state agencies, many
industries will perform a subset of the activities and the average
annual reporting burden for each industry is estimated to be 3.4 hours. 

	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-2005-0490, 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 Building, 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 Docket 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-2005-0490 and OMB Control Number 2060-0088 in any
correspondence.

Table 6-1.  State Respondent Burden Hours by Activity  tc "6-1.  State
Respondent Burden Hours by Activity " \f D 

Information Collection Activity	Hours Per Respondent

	Managerial Hours	Technical Hours	Total

Annual

Every 2 of 3 years, submit emissions data for Type A point sources
emitting specified thresholds for SO2, NOx, CO, VOC, or PM10 [§51.15]	3
57	60

  1.  Train staff in coding and submissions techniques	1	6	7

  2.  Resolution of errors and anomalies identified by EPA	1	41	42

  3.  Maintain log of magnetic tape or other media submitted	1	6	7

  4.  Prepare automated submission to EPA	0



Calculate and submit emissions data for PM2.5 and NH3 [§51.15(a)]	1	19
20

Triennial

Submit emissions data for Type A and Type B point sources emitting
100 tpy VOC, NOx, SO2, or PM10, or 1,000 tpy CO [§51.15]	12	200
212

For state agencies, develop and report statewide inventory for
stationary nonpoint, nonroad mobile, and onroad mobile sources for all
pollutants [§51.15, 51.25]	104	2,080	2,184

For local agencies, develop and report county-level inventories for
stationary nonpoint, nonroad mobile, and onroad mobile sources for all
pollutants [§51.15, 51.25]	52	1,040	1,092

For local agencies, coordinate with state agencies to complete
stationary nonpoint, nonroad mobile, and onroad mobile sources for all
pollutants  [§51.15, 51.25]	4	80	84

For 3-year cycle inventory, develop and report baseline biogenic
emissions inventory for all applicable pollutants [§51.15, 51.25]	2	40
42

Calculate and submit emissions data for PM2.5 and NH3 [§51.15(a)]	1	19
20

a Subtotal estimates for Type A inventory reporting every 2 of 3 years.



Table 6-2.  Activities Required by States Every Year
During the Period 2006 through 2008  tc "6-2.  Activities Required
by States Every Year During the Period 2003 through 2005 " \f D 1

Information Collection Acitivity	2008	2009	2010

Annual

Every 2 of 3 years, submit emissions data for Type A point sources
emitting specified thresholds for SO2, NOx, CO, VOC, or PM10 [§51.15]

	

Calculate and submit emissions data for PM2.5 and NH3 [§51.15(a)]

	

Triennial

Submit emissions data for Type A and Type B point sources emitting
100 tpy VOC, NOx, SO2, or PM10, or 1,000 tpy CO [§51.15]	



For state agencies, develop and report statewide inventory for
stationary nonpoint, nonroad mobile, and onroad mobile sources for all
pollutants [§51.15, 51.25]	



For local agencies, develop and report county-level inventories for
stationary nonpoint, nonroad mobile, and onroad mobile sources for all
pollutants [§51.15, 51.25]	



For local agencies, coordinate with state agencies to complete
stationary nonpoint, nonroad mobile, and onroad mobile sources for all
pollutants [§51.15, 51.25]	



For 3-year cycle inventory, develop and report baseline biogenic
emissions inventory for all applicable pollutants [§51.15, 51.25]	



Calculate and submit emissions data for PM2.5 and NH3 [§51.15(a)]	



1For purposes of this table, activities associated with developing an
emissions inventory for a particular year are assumed to take place
during the year following the inventory year (e.g., activities for
compiling a 20088 triennial inventory take place during 2009).  However,
unless subject to the NOx SIP call, respondents have up to 17 months
following the end of the subject inventory year (e.g., June 1, 20101 for
inventory year 2008) to report the required data.



Table 6-3.  Annual State Respondent Burden and Cost by Activity

Information Collection Activity	Hours and Costs Per Respondent	Total
Hours and Costs

	Mgr. Hrs/yr @

$96.38/Hr	Tech. Hrs/yr @

$78.60/Hr	Respondent

Hours/Year	Labor

Cost/Year	Capital/

Startup Cost	O & M

Cost	Number of

Respondents	Total

Hours/Year1	Total

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਀55	770	61,177

Calculate and submit emissions data for PM2.5 and NH3 	0.33	6.33	6.7	529
0.00	0.00	104	697	55,052

Total	61	1204	1265	100,476	218,400	12,480	varies	51,771	   4,345,089 



1      Hours per year are rounded to the nearest hour.

2	Costs per year are rounded to the nearest dollar.

3	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.

4	These costs represent the total annual cost for all agencies, not the
cost per agency.





Table 6.4.  Annual Industry Burden and Cost by Activity

Information Collection Activity	Hours and Costs Per Respondent	Total
Hours and Costs

	Mgr. Hr/yr @

$101.82/Hr	Tech. Hr/yr @

$60.06/Hr	Respondent

Hours/Year	Labor

Cost/Year	Capital/

Startup Cost	O & M

Cost	Number of

Respondents	Total

Hours/Year1	Total

Cost/Year2

Annual

Estimate and report emissions data for Type A point sources emitting 250
tpy or greater PM2.5 to the state or local agencies	0.67	2.00	2.67
188.34	0.00	0.00	519	1,386	$97,748

Estimate and report emissions data for Type A point sources emitting 250
tpy or greater NH3 to the state or local agencies	0.67	3.33	4.00	268.22
0.00	0.00	425	1,700	$113,994

Triennial

Estimate and report emissions data for Type B point sources emitting 100
tpy or greater PM2.5 to state or local agencies	0.33	1.00	1.33	93.66
0.00	0.00	1,010	1,343	$94,597

Estimate and report emissions data for Type B point sources emitting 100
tpy or greater NH3 to state or local agencies	0.33	1.67	2.00	133.90	0.00
0.00	749	1,498	$100,291

Total	2	8	10	684.12	0	0	varies	5,927	$406,630











	1 Hours per year are rounded to the nearest hour.









	2 Costs per year are rounded to the nearest dollar.









	

	1Except where noted, future reference to “state(s)” in this
supporting statement includes 50 states, 4 territories, 49 local
agencies, and the District of Columbia (DC).

   Point sources exceeding the 5 tons per year reporting threshold for
Pb were not included in this exercise.  However, excluding these sources
does not significantly affect the results since no more than a dozen
sources exceed the point source Pb reporting threshold.

  PAGE  1 

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