INFORMATION
COLLECTION
REQUEST
RENEWAL
FOR
THE
ACID
RAIN
PROGRAM
UNDER
THE
CLEAN
AIR
ACT
AMENDMENTS
TITLE
IV
April
4,
2006
1
INFORMATION
COLLECTION
REQUEST
RENEWAL
FOR
THE
ACID
RAIN
PROGRAM
UNDER
THE
CLEAN
AIR
ACT
AMENDMENTS
TITLE
IV
(
JULY
2006
THROUGH
JUNE
2009)

SUPPORTING
STATEMENT
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1.1
Background
Title
IV
of
the
Clean
Air
Act
Amendments
of
1990
(
the
acid
rain
title)
established
goals
to
reduce
annual
emissions
of
sulfur
dioxide
(
SO2)
and
nitrogen
oxides
(
NOX)
and
placed
a
national
cap
on
sulfur
dioxide
emissions
beginning
in
the
year
2000.
Emissions
reductions
were
mandated
in
two
phases:

°
During
Phase
I,
which
covered
1995
through
1999,
emissions
were
reduced
about
50
percent
for
SO2
and
32
percent
for
NOX
from
1990
levels
from
the
263
highest­
emitting
sources;

°
Phase
II,
which
began
in
2000
for
both
SO2
and
NOX,
affects
more
than
3,500
sources
at
virtually
all
fossil
fuel
power
plants.

To
help
meet
emissions
reduction
goals,
Title
IV
provides
for
a
program
that
allocates
emissions
allowances
to
affected
utility
units
based
on
a
national
target
for
SO2
reductions,
and
allows
market
forces
to
achieve
the
targeted
reductions
in
the
most
cost­
effective
manner.
Under
this
program,
each
affected
unit
receives
its
allocation
of
allowances
for
every
year.
An
affected
unit
must
hold
one
allowance
for
each
ton
of
SO2
it
emits.
Affected
utilities
and
individuals
may
buy
and
sell
allowances,
or
save
them
for
future
use
or
sale.

The
ability
to
buy
and
sell
(
or
transfer)
allowances
provides
substantial
economic
benefits,
by
encouraging
the
greatest
emissions
reductions
where
costs
of
reductions
are
lowest.
This
concept
of
allowance
transfers
cannot
be
implemented,
however,
unless
regulations
governing
emissions
monitoring
and
permitting
of
acid
rain
sources
are
in
place
as
well.
To
ensure
compliance
with
the
emissions
reduction
requirements
and
to
provide
the
national
consistency
needed
to
foster
the
allowance
market,
sections
408
and
412
of
Title
IV
require
the
designated
representative
of
the
owners
and
operators
of
each
affected
acid
rain
source
to
obtain
an
operating
permit
for
the
affected
source
and
to
certify
that
an
approved
emissions
monitoring
system
has
been
installed
and
is
properly
operated
at
each
affected
unit's
source
of
emissions.

Emissions
monitoring
and
reporting
is
the
foundation
upon
which
the
allowance
trading
system
is
based.
Without
accurate
monitoring
and
reporting
of
emissions,
the
integrity
of
the
allowance
system
would
be
undermined,
and
there
would
be
no
assurance
that
emissions
had
been
reduced.
2
Acid
rain
permits
allow
sources
the
flexibility
to
comply
with
the
emissions
reduction
requirements
of
Title
IV
for
both
SO2
and
NOX.
The
procedures
specified
in
the
acid
rain
permits
regulations,
including
the
use
of
standardized
forms,
ensure
that
the
intended
flexibility
and
accountability
is
preserved
as
the
Acid
Rain
Program
is
implemented
nationwide
by
different
permitting
authorities.

Participation
in
the
annual
auction
is
voluntary.
Information
is
collected
by
EPA's
Clean
Air
Markets
Division
and
used
to
conduct
and
facilitate
the
administration
of
the
auction.
Auction
participants
must
submit
a
bid
form
and
payment
method.

Section
410
of
Title
IV
provides
that
sources
of
SO2
emissions
that
are
not
regulated,
i.
e.,
small
utility
units
and
industrial
boilers,
may
elect
to
"
opt
in"
to
the
allowance
allocation
and
trading
program.
To
opt
in,
the
source
owner
or
operator
must
submit
an
opt­
in
permit
application
to
EPA.
Sources
that
opt
in
(
1)
become
affected
sources,
(
2)
receive
an
annual
allocation
of
allowances,
and
(
3)
may
sell
any
allowances
they
do
not
use
for
their
own
emissions.
Because
opting
in
is
voluntary,
only
those
unaffected
sources
that
would
profit
by
opting
in
are
expected
to
do
so.

Although
the
principal
purpose
of
Title
IV
of
the
Clean
Air
Act
is
to
reduce
acid
rain
by
requiring
reductions
in
emissions
of
SO2
and
NOX,
it
is
also
the
purpose
of
this
title
to
encourage
energy
conservation
and
pollution
prevention
as
a
long­
range
strategy
for
reducing
air
pollution
and
other
adverse
effects
of
energy
production
and
use.
As
an
incentive
for
electric
utilities
to
(
1)
implement
energy
conservation
measures
and
(
2)
use
renewable
energy,
section
404(
f)
of
Title
IV
establishes
provisions
for
qualifying
electric
utilities
to
receive
allowances
from
the
Conservation
and
Renewable
Energy
Reserve
for
SO2
emissions
avoided
through
either
of
these
two
options.

The
NOX
emission
reductions
are
achieved
through
maximum
allowable
emission
rates
for
coal­
fired
utility
boilers.
The
allowable
rate
for
a
given
boiler
depends
on
the
type
of
boiler.
The
NOX
regulations
for
coal­
fired
boilers
are
applied
to
two
groups
of
boilers,
as
specified
by
the
Clean
Air
Act
Amendments
of
1990
(
CAAA).
Boilers
in
each
group
become
affected
at
different
times,
as
described
below.
Group
1
boilers
are
(
1)
dry
bottom
wall­
fired
boilers
that
do
not
apply
cell
burner
technology
or
(
2)
tangentially
fired
boilers.
Group
2
boilers
are
all
other
types
of
utility
boilers,
including
(
1)
wet
bottom
wall­
fired
boilers,
(
2)
cyclones,
and
(
3)
boilers
applying
cell
burner
technology.
In
Phase
II,
which
began
January
1,
2000,
NOX
emission
limitations
became
effective
for
both
groups
of
boilers.

1.2
Information
to
Be
Collected
EPA
has
developed
regulations
to
implement
the
emissions
reduction
provisions
of
Title
IV
of
the
Clean
Air
Act
Amendments
that
cover
°
Allowance
tracking
and
transfers
(
section
403);
°
Energy
conservation
and
renewable
energy
incentives
(
section
404);
3
°
Permits
(
section
408);
°
Emissions
monitoring
(
section
412);
°
Auctions
(
section
416);
°
Opt­
in
(
section
410
a­
g);
and
°
NOX
permitting
(
section
407).

This
Information
Collection
Request
(
ICR)
addresses
the
paperwork
burden
related
to
(
1)
transferring
and
tracking
allowances;
(
2)
obtaining
and
distributing
allowances
from
the
Conservation
and
Renewable
Energy
Reserve;
(
3)
obtaining
and
issuing
permits
(
e.
g.,
submitting
permit
applications);
(
4)
submitting
and
certifying
emissions
monitoring
data;
(
5)
the
opt­
in
program;
(
6)
NOX
permitting.
Burden
estimates
provided
in
this
ICR
are
for
the
period
from
July
1,
2006
to
June
30,
2009
(
i.
e.,
the
years
2007
through
2009).

Allowance
Transfers
Participants
in
the
allowance
transfer
system
now
have
two
options
for
submitting
transfers:
to
submit
electronically
using
the
internet
to
record
their
own
allowance
transfers,
either
by
entering
the
data
on
screen
or
by
submitting
an
XML
file;
or
complete
a
paper
form
and
send
it
the
Agency.
Participants
in
the
transfer
system
that
are
not
affected
sources
under
Title
IV
are
also
be
required
to
file
a
one
time
account
information
application
using
a
paper
form
to
establish
an
account
in
the
Allowance
Tracking
System
(
ATS).
As
part
of
the
annual
compliance
determination
process,
designated
representatives
have
the
option
of
submitting
an
allowance
deduction
form
to
identify
specific
serial
numbered
allowances
to
be
deducted
for
annual
compliance
Conservation
and
Renewable
Energy
Reserve
To
receive
allowances
for
emissions
avoided
through
the
use
of
energy
conservation
measures
or
renewable
energy,
utilities
must
submit
an
application
to
receive
allowances
that
(
1)
designates
and
verifies
the
measures
used
to
avoid
emissions,
(
2)
calculates
the
tons
of
emissions
avoided,
and
(
3)
demonstrates
qualification
to
receive
allowances
from
the
Conservation
and
Renewable
Energy
Reserve.

Permits
Permit
applicants
are
required
to
submit
an
acid
rain
permit
application
for
each
affected
source.
The
permit
application
must
include,
for
each
unit
at
the
source,
(
1)
general
information
on
the
unit,
(
2)
a
complete
compliance
plan
for
each
unit,
and
(
3)
the
Acid
Rain
Program
standard
requirements.

Emissions
Monitoring
To
meet
the
emissions
monitoring
record­
keeping
and
reporting
requirements,
affected
units
are
required
to
(
1)
submit
a
monitoring
plan
and
certification
of
monitors,
(
2)
record
hourly
pollutant
and
flow
monitor
data,
and
(
3)
submit
electronic
quarterly
reports
of
their
emissions
data
to
EPA.
Operators
of
new
electric
generating
units
of
25
megawatts
(
MW)
capacity
or
less
may
receive
a
CEMS
exception
if
they
certify
their
use
of
very­
low­
sulfur
fuel.
4
Submissions
Purposes
and
Procedures
Allowance
transfer
notifications
may
be
submitted
to
EPA
electronically
or
on
paper.
Emissions
reports
must
be
submitted
electronically.
All
Phase
II
permit
applications
must
be
submitted
on
paper.

The
allowance
transfer
submittal
is
used
to
record
allowance
transfers
for
compliance
purposes
and
to
track
the
disposition
of
all
allowances
in
the
system.
Applications
for
allowances
from
the
Energy
Conservation
and
Renewable
Energy
Reserve
provide
information
on
the
emissions
avoided
through
the
use
of
energy
conservation
measures
and
renewable
energy,
and
are
used
to
allocate
allowances
from
the
reserve.

Acid
rain
permit
applications
are
used
to
issue
operating
permits
to
affected
sources
under
the
Acid
Rain
Program.
Because
the
permit
applications
and
permits
are
public
documents,
they
provide
an
opportunity
for
the
affected
public
to
examine
activities
undertaken
by
affected
sources.
The
designated
representative
certification,
which
designates
a
responsible
official
through
whom
the
owners
and
operators
of
each
affected
source
and
each
affected
unit
can
trade
allowances
and
obtain
and
maintain
permits,
serves
to
remove
EPA
from
involvement
in
disputes
between
owners
and
operators
of
affected
units.

Monitoring
plan
submissions
are
used
by
EPA
to
verify
that
the
emissions
monitoring
system
at
a
unit
meets
the
requirements
set
forth
in
Title
IV
of
the
Act
and
in
the
implementing
regulations.
Results
of
continuous
emission
monitoring
system
performance
tests
allow
EPA
to
certify
that
monitors
perform
well
enough
to
produce
accurate
emissions
data.
Emissions
data
is
used
to
monitor
compliance
with
emissions
requirements
under
Title
IV
and
to
provide
a
basis
for
analyzing
progress
in
meeting
air
quality
objectives.
Allowance
tracking
information,
emissions
data,
and
the
contents
of
permit
applications
all
provide
information
for
the
allowance
market
and
the
general
public.

Opt­
in
Program
This
ICR
also
addresses
the
paperwork
burden
for
small
utility
units
and
industrial
boilers
that
opt­
in.
The
Agency
has
identified
five
burden
areas
associated
with
a
source's
opting
in
to
the
allowance
allocation
and
trading
program.
These
areas
are
(
1)
completing
the
permit
application,
(
2)
recording
and
reporting
emissions
data,
(
3)
compliance
reporting,
and
(
4)
withdrawing
from
the
program.
Estimates
for
the
opt­
in
program
detail
the
burden
for
both
operating
and
shut­
down
opt­
ins.

The
Opt­
in
program
requires
respondents
to
submit
an
acid
rain
permit
application.
For
all
respondents,
the
application
must
provide
(
1)
general
information
about
the
source,
(
2)
specific
data
about
the
source's
fuel
consumption
and
operating
data
for
1985,
1986,
1987,
and
(
3)
data
on
the
source's
actual
and
allowable
emission
rates
for
1985,
as
well
as
the
current
allowable
emission
rate.
The
permit
application
and
proposed
thermal
energy
compliance
plan
for
sources
that
opt
in
and
shut
down
must
include
information
describing
the
source's
plans
for
the
replacement
of
thermal
energy.

To
meet
emissions
monitoring,
record­
keeping
and
reporting
requirements,
sources
that
5
opt­
in
and
continue
operating
will
be
required
to
(
1)
submit
a
monitoring
plan
and
certification
of
monitors,
(
2)
record
hourly
pollutant
and
flow
monitor
data,
and
(
3)
submit
quarterly
reports
of
their
emissions
data
to
EPA.
Sources
that
opt
in
and
shut
down
will
not
have
to
perform
tasks
associated
with
emissions
monitoring,
reporting,
and
recording.

Meanwhile,
to
meet
requirements
for
reporting
compliance,
respondents
must
submit
an
annual
compliance
report
in
which
they
(
1)
report
their
utilization
information,
(
2)
report
any
replacement
of
thermal
energy,
and
(
3)
report
on
allowances
transferred
as
a
result
of
the
replacement
of
thermal
energy.
Finally,
all
sources
that
have
opted
in
and
later
decide
to
withdraw
are
required
to
complete
withdrawl
notification.

NOX
Permitting
An
owner
or
operator
of
a
unit
subject
to
a
NOX
emission
limitation
may
meet
the
requirements
through
one
of
three
compliance
options:

°
meeting
the
standard
limit
°
obtaining
approval
for
an
emissions
averaging
plan
°
obtaining
an
alternative
emissions
limitation
(
AEL)

Two
or
more
units
may
average
their
NOX
emissions,
as
provided
for
by
Title
IV.
In
an
approved
NOX
emissions
averaging
group,
the
NOX
emission
rates
of
some
of
the
individual
units
may
exceed
their
respective
emission
limitations,
as
long
as
the
Btu­
weighted
average
NOX
emission
rate
for
the
entire
group
is
less
than
or
equal
to
the
weighted
average
of
the
emission
limitations
for
the
individual
units.
The
ability
to
average
emissions
allows
utilities
to
meet
the
NOX
requirements
at
lower
cost.

Title
IV
also
provides
that
an
owner
or
operator
of
an
affected
unit
may
petition
EPA
for
a
higher,
alternative
emission
limitation
(
AEL)
if
the
unit
cannot
meet
the
emission
limitations
even
after
a
retrofit
with
low
NOX
burner
technology
.
The
opportunity
to
obtain
AELs
will
allow
for
adjustment
of
emission
limitations
for
specific
units
where
the
technologies
on
which
the
limitations
were
based
do
not
provide
the
expected
level
of
emission
reductions
in
practice.

Meeting
the
standard
limit
is
the
least
burdensome
administratively
for
sources.
All
owners
and
operators
of
affected
units
are
eligible
to
comply
with
the
NOX
regulations
using
this
option.
The
submission
of
an
application
for
emissions
averaging,
or
an
AEL,
is
optional
and
voluntary.
For
units
that
comply
by
meeting
the
standard
limits
applicants
are
required
only
to
identify
the
unit.

Applicants
seeking
approval
for
emissions
averaging
are
required
to
identify
the
units
in
the
group,
assign
alternative
contemporaneous
emissions
limitations
to
each
unit,
and
demonstrate
that
the
Btu­
weighted
average
of
these
alternative
limits
is
less
than
or
equal
to
the
Btu­
weighted
average
of
the
limits
that
would
apply
in
the
absence
of
averaging.

All
applicants
for
AELs
are
required
to
demonstrate
that
they
are
eligible
for
an
AEL,
by
6
providing
(
1)
evidence
that
the
appropriate
emissions
control
equipment
has
been
installed,
and
(
2)
monitoring
data
showing
that
the
unit
cannot
meet
the
applicable
emission
rate.

The
respondent
reporting
burden
for
this
collection
of
information
is
estimated
to
be
1,971,276
hours
each
year
for
the
years
2007
through
2009.
The
burden
to
EPA
is
estimated
to
be
31,974
hours
in
2003
each
year
for
the
years
2007
through
2009.

1.3
Terms
of
Clearance
Below
are
the
Terms
of
Clearance
for
the
previous
ICR
renewal.

This
ICR
is
approved
for
three
years.
The
agency
should
continue
to
ensure
that
future
extensions
of
the
ICR
appropriately
represent
capital
costs
that
have
been
capitalized
over
more
than
three
years.
Also,
the
agency
should
continue
to
include
in
future
extensions
of
the
ICR
any
cyclical
reporting
such
as
NOx
compliance
plans.

A
discussion
of
the
capital
cost
issue
can
be
found
in
section
6.4.2
of
this
document,
and
the
cyclical
nature
of
reporting
is
taken
into
account
for
both
Permitting,
sections
4.2.2
and
6.3.1,
and
NOx
Compliance,
sections
4.2.2
and
6.7.1.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
This
section
describes
EPA's
need
for
the
information
collections
described
above
and
the
legal
authority
for
conducting
collections.
The
users
of
collected
information
are
also
described.

2.1
Need/
Authority
for
the
Collection
Section
403(
b)
of
Title
IV
of
the
Clean
Air
Act
Amendments
of
1990
provides
for
the
transfer
of
allowances
among
designated
representatives
of
owners
and
operators
of
affected
sources
and
any
person
who
holds
allowances.
Transfers
of
allowances
are
not
deemed
effective
until
written
certification
of
the
transfer,
signed
by
a
responsible
official
of
each
party
to
the
transfer,
is
received
and
recorded
by
EPA.
Section
403(
d)
of
Title
IV
requires
that
EPA
develop
a
system
for
issuing,
recording,
and
tracking
allowances
(
intended
to
help
ensure
an
orderly
and
competitive
allowance
system).

Conservation
and
Renewable
Energy
Reserve
Section
404(
f)
of
Title
IV
establishes
provisions
for
qualifying
electric
utilities
to
receive
allowances
from
the
Conservation
and
Renewable
Energy
Reserve
for
SO2
emissions
avoided
through
the
use
of
qualifying
energy
conservation
measures
or
renewable
energy.
The
allowances
are
allocated
on
a
first
come,
first
served
basis
during
the
period
from
January
1,
1992
to
December
31,
2009.

Permits
7
Section
408
of
Title
IV
and
Title
V
of
the
Clean
Air
Act
Amendments
of
1990
require
that
the
designated
representative
of
the
owners
and
operators
of
each
affected
source
under
the
Acid
Rain
Program
obtain
a
permit.
In
Phase
II,
section
408
also
specifies
that
the
permitting
authority,
usually
a
State
or
local
agency,
issue
the
permits
with
a
term
of
five
years.

Emissions
Monitoring
Section
412(
a)
of
Title
IV
requires
the
use
of
CEM
systems
(
or
alternative
monitoring
systems
demonstrated
to
be
equivalent)
at
each
affected
unit's
source
of
emissions.
Section
504(
a)
of
Title
V
requires
that
the
results
of
any
required
monitoring
be
submitted
to
the
permitting
authority
no
less
often
than
every
six
months.
The
information
collection
is
consistent
with
satisfying
these
minimum
statutory
requirements.
Note
that
reports
are
submitted
quarterly
rather
than
semiannually.
The
Acid
Rain
Advisory
Committee
recommended
that
EPA
collect
emissions
data
on
a
quarterly
basis
and
this
schedule
has
proven
to
allow
for
effective
implementation
of
the
program.

Auctions
Although
participation
in
the
annual
auction
is
voluntary,
the
information
to
be
collected
is
necessary
to
operate
and
administer
the
program
and
is
required
specifically
under
Title
IV,
Section
416(
d)(
2).

Opt­
in
Section
410(
a)
of
Title
IV
of
the
Clean
Air
Act
Amendments
of
1990
allows
the
owner
or
operator
of
any
SO2
source
that
is
not
an
affected
unit
under
section
403(
e),
404,
or
405
to
elect
to
designate
that
source
as
an
affected
source
and
receive
allowances
under
Title
IV.
Section
410(
a)
requires
sources
opting
in
to
submit
a
permit
application
and
a
compliance
plan
to
the
Administrator.

Section
410(
b)
requires
the
Administrator
to
establish
a
baseline
utilization
rate
for
SO2
emissions
for
opt­
in
sources
based
on
fuel
consumption
and
operating
data
for
calendar
years
1985,
1986,
1987.
Section
410(
c)
requires
the
Administrator
to
establish
a
limit
for
SO2
emissions
based
on
the
baseline
utilization
rate
and
the
lesser
of
the
source's
actual
or
allowable
1985
emissions.

Section
410(
e)
requires
that
the
Administrator
issue
allowances
to
sources
that
become
affected
sources
under
Section
410.
The
number
of
allowances
is
to
be
based
on
calculations
made
under
Section
410(
c).

NOX
Permitting
Section
408
of
Title
IV
of
the
Clean
Air
Act
Amendments
of
1990
specifies
that
utility
owners
and
operators
of
units
affected
under
Title
IV
must
submit
permit
applications
and
compliance
plans
(
including
NOX
compliance
plans),
and
that
EPA
must
issue
permits.
°
Section
408
provides
general
authority
for
the
information
collections
under
this
ICR
related
to
compliance
options.
In
addition,

°
Section
407(
e)
of
Title
IV
allows
the
owner
or
operator
of
two
or
more
affected
units
to
petition
the
permitting
authority
for
a
NOX
averaging
plan.

°
Section
407(
d)
provides
for
AELs
for
utility
units
that
cannot
meet
the
applicable
limitation
using
low
NOX
burner
technology
or
the
technology
on
which
the
limitation
was
based.
Section
407(
d)
specifies
that
an
owner
or
operator
requesting
an
AEL
must
show
the
permitting
authority
that
(
1)
appropriate
control
equipment
has
been
properly
installed,
and
(
2)
the
equipment
has
been
properly
operated
for
a
period
of
fifteen
months
(
or
another
period
of
time
as
established
by
regulation)
and
operating
and
monitoring
data
for
such
period
demonstrate
that
the
unit
cannot
meet
the
applicable
emission
rate.
The
owner
or
operator
must
also
specify
an
emission
rate
that
the
unit
can
meet
on
an
annual
average
basis.

2.2
Practical
Utility/
Users
of
the
Data
Allowance
Transfers
Information
collected
on
allowance
transfers
is
used
by
EPA
to
track
allowances
for
the
purpose
of
determining
compliance
with
the
Acid
Rain
Program.
Information
on
allowance
transfers
is
also
used
by
participants
in
the
allowance
market
and
the
public
to
evaluate
the
activities
of
utilities,
and
by
EPA
for
program
evaluation.

Auctions
EPA
or
its
designated
agent
uses
the
information
collected
for
the
allowance
auction
to
conduct
and
facilitate
administration
of
auctions.
The
basic
information
requested
requires
little
evaluation.
Bids
submitted
for
auctions
are
ranked
to
select
winning
bidders
and
to
conduct
transfers
of
emission
allowances.
The
auction
information
results
are
also
used
by
participants
in
the
allowance
market.

Conservation
and
Renewable
Energy
Reserve
Information
collected
on
the
use
of
energy
conservation
measures
and
renewable
energy
is
used
by
EPA
to
issue
allowances
from
the
Conservation
and
Renewable
Energy
Reserve.

Permits
Acid
rain
permit
applications
are
used
by
EPA
and
permitting
authorities
to
issue
operating
permits.
A
permit
application
is
legally
binding
on
the
owners,
operators,
and
designated
representative
of
a
source
until
the
actual
permit
is
issued.
This
aspect
of
the
permit
application
reduces
significantly
the
uncertainty
imposed
on
a
source
due
to
possible
delays
at
EPA
or
the
permitting
authority.
Affected
sources
may
rely
on
the
permit
for
information
on
the
requirements
with
which
they
must
comply.
Because
permit
applications
and
permits
are
public
documents,
they
may
be
used
by
the
public
to
examine
activities
undertaken
by
affected
sources.

Emissions
Monitoring
9
Data
from
emissions
monitoring
is
indispensable
to
successful
implementation
of
the
Acid
Rain
Program
for
two
reasons:

°
Title
IV
of
the
Act
clearly
states
that
its
primary
purpose
is
to
reduce
the
adverse
effects
of
acid
deposition
by
reducing
annual
emissions
of
sulfur
dioxide
and
nitrogen
oxides.
For
sulfur
dioxide
emissions,
the
statutory
objective
is
achieved
through
an
emissions
trading
program.
For
nitrogen
oxide
emissions,
the
statutory
objective
is
achieved
through
annual
emission
limitations
on
certain
units.

°
EPA
can
only
enforce
the
sulfur
dioxide
trading
program
and
the
nitrogen
oxide
emission
limitation
program
by
having
accurate
emissions
data
for
each
affected
unit.

Electric
utilities,
energy
consultants,
and
power
marketing
companies
can
use
the
Acid
Rain
program
emissions
data
to
project
future
SO2
allowance
costs
and
availability.
Academic
institutions
can
perform
data
modeling
to
evaluate
environmental
benefits
and
estimate
health
effects
of
SO2
reductions.
EPA
and
other
agencies
use
it
to
try
to
correlate
the
reduction
of
SO2
and
NOX
emissions
with
a
decrease
in
acid
precipitation,
and
also
to
measure
the
impacts
of
other
existing
and
proposed
emissions
trading
programs.

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

Opt­
in
Information
collected
on
opt­
in
respondents
is
used
by
EPA
to
record
which
sources
are
to
be
designated
affected
sources,
and
hence
are
to
be
bound
by
the
regulations
of
the
CAAA
that
are
relevant
to
affected
sources.

Opt­
in
permit
applications
are
used
by
EPA
to
issue
operating
permits.
Fuel
usage
and
emissions
rate
data
in
the
opt­
in
application
is
used
to
allocate
allowances
to
the
opt­
in
source.

The
information
on
annual
utilization
and
the
replacement
of
thermal
energy,
if
covered
by
a
Thermal
Energy
Plan,
contained
in
the
annual
compliance
report
is
used
by
EPA
to
determine
compliance
with
the
Act.

For
respondents
who
choose
to
withdraw
from
the
program,
the
withdrawl
notification
is
essential
to
notify
EPA
to
discontinue
the
allocation
of
allowances
to
the
source
and
enforcement
of
the
acid
rain
provisions.

NOX
Permitting
Information
collected
on
NOX
compliance
plans
is
used
by
EPA
to
evaluate
these
compliance
plans.
Information
collected
on
applications
for
emissions
averaging
groups
or
AELs
is
used
by
EPA
to
determine
whether
to
approve
these
applications.
This
information
may
also
be
used
by
the
regulated
community
and
the
public
to
evaluate
the
activities
of
utilities,
and
10
by
EPA
for
program
evaluation.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
This
section
describes
(
1)
efforts
by
EPA
to
learn
whether
the
information
requested
is
available
from
other
sources,
(
2)
consultations
with
respondents
and
data
users
to
plan
collections,
monitor
their
usefulness,
and
minimize
the
collection
burden,
(
3)
effects
of
less
frequent
collections,
and
(
4)
justification
for
deviations
from
OMB's
general
guidelines.

3.1
Nonduplication
Almost
all
information
requested
from
respondents
under
this
ICR
is
required
by
statute
and,
in
most
cases,
is
not
available
from
other
sources.
Review
of
earlier
and
proposed
forms
resulted
in
the
elimination
of
many
redundant
requirements.
Where
EPA
needs
information
that
has
already
been
submitted,
EPA
is
simply
requiring
a
photocopy
of
the
prior
submittal.

EPA
notes
that
many
of
the
units
that
are
subject
to
the
Acid
Rain
Program
are
also
subject
to
other
programs,
such
as
the
New
Source
Performance
Standards
(
NSPS).
Under
programs
such
as
NSPS,
sources
are
required
to
submit
monitoring
data
reports
that
match
the
particular
format
and
averaging
time
of
the
applicable
emission
limits
under
those
standards.
Although
not
the
same
information
as
the
information
provided
under
the
Acid
Rain
Program,
the
information
is
often
generated
by
the
same
monitoring
equipment.

3.2
Consultations
The
data
requirements
for
the
Acid
Rain
Program
were
developed
with
the
benefit
of
extensive
consultation
with
the
Acid
Rain
Advisory
Committee
(
ARAC)
during
five
meetings
in
1991
lasting
two
to
three
days
each.
The
Committee
was
composed
of
representatives
of
those
entities
most
affected
by
or
interested
in
the
information
requirements
of
the
Acid
Rain
Program.
Representation
on
the
Committee
was
provided
for
industry,
states,
and
environmental
groups.
Other
parties
consulted
include
the
Utility
Air
Regulatory
Group
(
UARG),
the
State
and
Territorial
Air
Pollution
Program
Administrators
(
STAPPA),
and
the
Association
of
Local
Air
Pollution
Control
Officers
(
ALAPCO).

Recommendations
provided
by
ARAC
strongly
supported
the
use
of
standardized
reporting
forms
for
acid
rain
permit
applications:

°
Utilities
affirmed
that
standardized
forms
reduce
uncertainty
about
what
constitutes
a
complete
application
and
thus
reduce
the
need
to
supply
additional
information
in
a
second
submission;

°
States
asserted
that
the
use
of
standardized
forms
developed
by
EPA
would
reduce
the
time
and
effort
states
will
need
to
implement
an
acid
rain
permit
program;
and
11
°
Environmental
groups
argued
that
the
use
of
standardized
forms
provides
greater
assurance
that
permits
will
be
enforceable
in
a
consistent
manner
nationwide.

Many
ARAC
recommendations
were
incorporated
into
the
acid
rain
regulations
regarding
permits
and
the
related
standardized
forms.

Furthermore,
since
the
beginning
of
implementation
of
the
Acid
Rain
Program,
representatives
from
the
utility
industry,
monitoring
equipment
vendors,
software
programmers,
consultants
working
together
with
utilities,
and
other
interested
parties
have
offered
comments
on
the
existing
rule
requirements,
standard
forms
and
electronic
data
reporting
formats
used
to
implement
the
Part
75
program.
The
EPA
has
used
these
comments
to
revise
the
rules,
forms
and
reporting
formats,
especially
changes
in
the
formats
to
cover
a
wider
group
of
units.
In
particular,
the
revised
forms
and
electronic
data
reporting
format
have
been
revised
in
the
past
to
address
reporting
requirements
for
gas­
fired
units
and
oil­
fired
units
that
are
using
pre­
approved
monitoring
exceptions
to
the
use
of
CEMS.
Industry
groups
have
also
worked
together
with
EPA
to
revise
the
recordkeeping
and
reporting
requirements
in
revisions
to
Part
75
in
1995,
1996,
and
1999.
Comments
and
suggestions
from
working
groups,
comprised
of
UARG,
Class
of
85
Regulatory
Response
Group,
and
the
PJM
Powerpool
also
were
incorporated
in
designing
the
annual
compliance
forms.

Finally,
EPA
promulgated
revisions
to
Part
75
in
May
2002.
For
these
revisions,
EPA
solicited
and
obtained
input
from
a
number
of
affected
utilities
and
other
interested
parties.
The
Agency
received
numerous
written
comments
on
the
proposed
revisions,
and
used
those
comments,
in
part,
to
develop
the
final
revisions.
In
particular,
EPA
modified
the
proposal
to
avoid
certain
changes
that
would
have
imposed
reporting
and
recordkeeping
burdens
where
the
comments
indicated
that
the
benefit
of
the
proposed
changes
would
not
necessarily
outweigh
the
burdens.
Examples
of
these
changes
include
treatment
of
partial
hour
reporting
for
determining
regulatory
grace
periods
and
the
approach
to
allowing
a
new
option
for
missing
data
for
units
that
operate
control
devices
on
a
seasonal
basis.
The
result
of
the
final
rules
were
minor
changes
to
the
reporting
and
recordkeeping
requirements
for
the
majority
of
sources
that
should
have
only
a
minimal
impact
on
respondents'
burdens
and
costs,
with
some
increased
one­
time
software
costs,
especially
for
sources
that
decide
to
adopt
one
or
more
of
the
new
options
allowed
for
under
the
final
rule
revisions.

3.3
Effects
of
Less
Frequent
Collection
Collection
of
allowance
transfer
information
for
each
transfer
of
allowances
is
necessary
to
effectively
implement
a
system
for
issuing,
recording,
and
tracking
allowances,
which
is
required
by
statute.

Conservation
and
Renewable
Energy
Reserve
Collection
of
applications
for
allowances
from
the
Conservation
and
Renewable
Energy
Reserve
for
emissions
avoided
through
the
use
of
conservation
measures
or
renewable
energy
is
required
by
statute
and
is
vital
to
(
1)
determine
qualification
for
these
allowances,
and
(
2)
12
establish
the
sequence
for
allocating
allowances
on
a
first­
come,
first­
served
basis.

Permits
The
requirement
for
the
designated
representatives
of
owners
and
operators
of
affected
sources
to
submit
permit
applications
every
five
years
is
a
statutory
requirement.

Emissions
Monitoring
Submission
of
monitoring
plans
once
and
submission
of
the
results
of
any
required
monitoring
to
EPA
no
less
often
than
every
six
months
are
required
by
statute.
More
frequent
collections
of
emissions
data
(
i.
e.,
quarterly),
however,
allows
the
opportunity
to
check
data
for
errors
and
provide
rapid
feedback
on
needed
adjustments
to
data
collection
systems,
and
thereby
promotes
accurate
and
reliable
emissions
data.
For
this
same
reason,
existing
federal
and
state
emission
monitoring
programs
often
require
quarterly
reporting,
or
in
some
cases,
monthly.
Less
frequent
collection,
such
as
semi­
annually
or
annually,
would
increase
the
amount
of
preparation
and
review
time
at
the
end
of
the
year
both
for
regulated
sources
and
for
EPA.
This
would
slow
down
the
process
of
true
up
and
end
of
year
verification
of
compliance.

Records
of
monitoring
information
are
to
be
kept
at
the
source
for
three
years
after
the
date
of
creation
of
the
record.
In
certain
circumstances,
fuel
flowmeter
calibration
and
Appendix
E
testing
records
may
have
to
be
kept
for
up
to
five
years
if
the
owner
or
operator
takes
advantage
of
rule
provisions
that
allow
up
to
five
years
between
tests.
These
five
year
recordkeeping
requirements
only
apply
if
the
owner
or
operator
voluntarily
elects
either
of
these
options
as
a
cost­
effective
approach
for
the
owner
or
operator's
specific
circumstances.

Opt­
in
Collection
of
permit
applications
for
the
opt­
in
program
occurs
only
once
every
five
years,
thus
minimizing
the
respondent
burden.
This
collection
is
necessary
for
the
operation
of
the
program;
without
it,
EPA
would
not
know
which
sources
wanted
to
opt
in,
nor
their
baseline
utilization,
nor
the
lower
of
their
1985
actual
or
allowable
emission
rate.
Collection
of
withdrawal
notifications
also
occurs
once;
this
is
also
a
necessary
collection.

NOX
Permitting
The
Agency
is
required
by
statute
to
include
NOX
compliance
plans
as
part
of
the
Acid
Rain
permits.
As
mentioned
earlier,
Acid
Rain
permits
are
renewed
every
five
years,
so
NOX
affected
sources
must
submit
a
NOX
compliance
plan
once
every
five
years.

3.4
General
Guidelines
Section
403(
d)
of
Title
IV
requires
that
EPA
establish
a
system
for
issuing,
recording,
and
tracking
allowances.
To
track
allowances
accurately
and
to
help
ensure
the
orderly
and
competitive
functioning
of
the
allowance
system,
it
is
essential
that
participants
be
able
to
report
information
on
allowance
transfers
as
they
occur.

The
general
requirement
that
permit
applicants
submit
information
on
standard
forms
is
13
established
by
Section
502(
b)
of
Title
V.
The
five­
year
life
of
an
acid
rain
permit
is
established
by
Section
408(
a)
of
Title
IV.
This
information
collection
does
not
violate
the
guidelines
set
forth
by
OMB.
In
some
cases,
records
of
Part
75,
Appendix
E
test
results
or
fuel
flowmeter
calibration
test
results
may
need
to
be
retained
for
up
to
five
years,
but
only
if
the
owner
or
operator
chooses
to
take
advantage
of
the
ability
to
extend
the
period
between
tests
up
to
five
years.
In
all
other
circumstances,
Part
75
monitoring
records
must
be
kept
for
only
three
years.

3.5
Confidentiality
and
Sensitive
Questions
Information
collected
through
this
activity
is
not
confidential
or
of
a
sensitive
nature.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
This
section
lists
the
major
categories
of
businesses
that
participate
in
the
Acid
Rain
Program,
the
data
items
requested
from
program
participants,
and
the
activities
in
which
the
participants
must
engage
to
assemble
or
submit
the
required
data
items.

4.1
Respondents/
NAICS
&
SIC
Codes
Title
IV
applies
to
"
utility
units,"
which
are
defined
to
include
units
that
serve
a
generator
producing
electricity
for
sale
or
that
did
so
in
1985.
Entities
owning
"
utility
units"
that
are
likely
to
participate
in
allowance
transactions
are
Fossil
Fuel
Electric
Power
Generators
(
NAICS
code
221111)
electric
service
providers
(
SIC
code
4911)
and
selected
firms
in
the
non­
utility
generation
industry,
such
as
Coal
Mining
(
NAICS
code
2121)
coal
mining
service
companies
(
SIC
code
1241).
Participants
in
transactions
and
the
annual
auctions
include
security
and
commodity
contracts
intermediation
and
brokerages
(
NAICS
code
5231)
(
SIC
code
62).

Emissions
Monitoring
Utility
units
are
required
to
submit
emissions
monitoring
data
under
this
ICR.

Opt­
in
Potential
participants
in
the
opt­
in
program
are
facilities
that
emit
SO2
but
are
not
designated
affected
units
under
Title
IV.
Such
facilities
include
utility
units
that
serve
an
electric
generator
of
less
than
25
MW
that
produces
electricity
for
sale
or
that
did
so
in
1985.
Entities
owning
utility
units
under
25
MW
that
may
participate
in
the
opt­
in
program
are
electric
service
providers
(
SIC
code
4911).
Other
potential
participants
are
industrial
boilers
that
are
represented
in
a
wide
range
of
SIC
categories.

4.2
Information
Requested
This
section
lists
the
data
items
requested
from
affected
sources
for
the
collections
described
in
this
ICR.
This
section
also
defines
the
activities
in
which
respondents
must
engage
to
assemble,
submit,
or
store
these
data
items.
14
4.2.1
Data
items,
Including
Recordkeeping
Requirements
Allowance
Transfers
All
participants
to
allowance
transfers
are
required
to
provide
the
following
information
for
each
allowance
transfer:

°
Allowance
tracking
system
account
number;
°
Name,
phone
number,
and
facsimile
number
of
the
authorized
account
representative,
along
with
the
representative's
signature
and
date
of
submission;
and
°
Serial
numbers
of
allowances
to
be
transferred.

In
addition,
if
the
designated
representative
chooses
to
identify
the
specific
serialized
allowances
to
be
deducted
from
the
unit's
ATS
account
for
annual
reconciliation,
then
the
following
information
is
required:

°
Allowance
Tracking
System
account
number;
°
Type
of
deduction;
°
Serial
numbers
of
the
allowance
blocks
to
be
deducted;
and
°
Dated
signature
of
the
designated
representative.

Certificate
of
Representation
Affected
sources
are
assigned
an
allowance
tracking
system
number
and
appoint
a
designated
representative
by
submitting
a
certificate
of
representation.
The
data
items
requested
for
the
certificate
of
representation
are
as
follows:

°
Source
identification;
°
Unit
identification,
including;
a)
unit
type
and
category
b)
commence
commercial
operation
date
c)
generator
IDs
of
generators
served
by
unit
d)
nameplate
capacity(
s)
of
the
generators
served
by
the
unit
e)
list
of
applicable
programs
that
the
unit
is
subject
to
f)
NAICS
Code
°
Name,
address,
e­
mail,
telephone
and
facsimile
number
of
the
designated
representative;
°
Name,
address,
e­
mail,
telephone
and
facsimile
number
of
the
alternate
designated
representative;
°
List
of
"
owners
and
operators"
of
the
source
and
each
unit
at
the
source;
°
Certification
statement;
°
Signature
of
designated
representative;
°
Signature
of
alternate
designated
representative;
and
°
Date
signed.
15
Notification
for
Distribution
of
Proceeds
from
EPA
Auctions
EPA
disburses
one
payment
using
electronic
funds
transfer/
direct
deposit
(
EFT/
DD)
for
each
plant
represented
for
the
proceeds
from
the
annual
auctions
of
allowances.
The
following
information
is
required
for
this
notification
for
distribution
of
proceeds:

°
Authorized
Account
Representative
(
AAR)
Identification;
°
Name
of
the
company
receiving
the
payment;
°
The
company's
taxpayer
identification
number;
°
Bank
account
information;
°
Plant
name
and
plant
code;
and
°
Signature
of
AAR.

General
Account
Holders
(
Allowance
Market
Participants)
Entities
that
are
not
affected
sources
(
such
as
individuals
holding
allowances)
are
required
to
submit
a
completed
account
information
application
or
provide
the
following
information
to
obtain
an
allowance
tracking
system
account
number,
prior
to
or
simultaneous
with
the
first
transfer:

°
Organization
or
company
name
(
if
applicable);
°
Name,
mailing
address,
phone
number,
facsimile
number,
and
e­
mail
address
of
the
authorized
account
representative;
°
Name
of
the
alternate
authorized
account
representative
(
optional);
°
A
list
of
all
persons
subject
to
a
binding
agreement
for
the
authorized
account
representative
to
represent
their
ownership
interest
with
respect
to
the
allowances
held
in
the
account;
and
°
Certification
statement
and
the
signatures
and
date
for
the
authorized
account
representative,
and
alternate
authorized
account
representative,
if
any.

Conservation
and
Renewable
Energy
Reserve
In
order
to
receive
allowances
from
the
Conservation
and
Renewable
Energy
Reserve
for
emissions
avoided,
each
electric
utility
must
submit
an
application
to
EPA.
The
application
requires
the
following
items:

°
Name
and
phone
number
of
the
person(
s)
who
completed
the
application;
and
name
and
phone
number
of
contact
person.
°
Demonstration
of
qualification
to
receive
allowances
for
emissions
avoided;
°
A
list
of
the
qualified
energy
conservation
measures
implemented
and
the
qualified
renewable
energy
sources
used
for
purposes
of
avoiding
emissions
during
the
previous
calendar
year;
°
Verification
of
(
1)
installation
of
energy
conservation
measures
and
the
energy
savings
attained,
and
(
2)
plant
operation
using
renewable
energy
and
the
energy
generation
attributable
to
renewable
energy
input;
°
For
utilities
using
the
EPA
Conservation
Verification
Protocol,
the
information
and
methodologies
used
in
determining
energy
savings,
including
a
description
of
16
the
conservation
measures,
the
dates
of
claimed
savings,
the
number
of
installations,
the
calculations
used
to
determine
energy
savings,
aggregate
statistical
information
needed
to
calculate
confidence
levels,
and
a
description
of
any
comparison
groups;
°
Calculations
of
the
number
of
tons
of
emissions
avoided
by
implementing
conservation
measures
or
using
renewable
energy;
and
°
Identification
of
allowance
tracking
account(
s)
to
which
the
Reserve
allowances
are
to
be
allocated.

Permits
Every
affected
source
is
required
to
have
an
Acid
Rain
permit.
Acid
Rain
permits
have
five
year
permit
terms.
The
permitting
authority's
operating
permits
rule
governs
the
issuance
of
permits
to
new
units
and
for
renewal
of
existing
Acid
Rain
permits.

A
complete
Acid
Rain
permit
application
includes
the
following
information:

°
Identification
of
the
source
(
plant
name,
ORIS
code,
State);
°
Identification
of
affected
units;
°
A
complete
compliance
plan;
°
Standard
requirements
at
40
CFR
72.9;
°
For
new
units,
commence
operation
date
and
monitor
certification
deadline;
°
Standard
certification;
and
°
Name
and
signature
of
designated
representative.

New
Unit
Exemption
§
72.7
Operators
of
new
units
that
serve
generators
with
a
nameplate
capacity
of
25
MW
or
less
and
use
fuel
with
a
sulfur
content
by
weight
of
less
than
0.05
percent
may
obtain
an
exemption
from
monitoring,
permitting,
and
allowance
requirements
if
they
submit
a
certification
with
the
following
information:

°
Unit
Identification;
°
Nameplate
capacity
of
each
of
the
generators
served
by
the
unit;
°
The
first
full
calendar
year
that
the
unit
will
meet
the
exemption
requirements;
°
The
fuels
currently
burned
by
the
unit,
and
that
will
be
burned
in
the
future,
and
their
sulfur
content
by
weight;
°
Certification
that
the
owners
and
operators
will
comply
with
all
necessary
requirements;
and
°
Standard
certification
at
§
72.21(
d)(
2).

Retired
Unit
Exemption
Operators
of
affected
units
that
are
retired
may
obtain
an
exemption
from
the
Acid
Rain
Program
if
they
submit
a
retired
unit
exemption
form
with
the
following
information:

°
Unit
identification;
°
The
date
that
the
unit
was
(
or
will
be)
permanently
retired;
17
°
The
first
full
calendar
year
that
the
unit
will
meet
the
exemption
requirements;
°
Certification
that
the
unit
is
permanently
retired
and
will
comply
with
all
necessary
requirements;
and
°
Standard
certification
at
§
72.21(
d)(
2).

All
data
items
requested
from
permit
applicants
must
be
submitted
on
standard
forms.
Most
of
the
information
requested
in
the
forms
is
specifically
required
by
law.

Emissions
Monitoring
Emissions
monitoring
requirements
specify
that
affected
sources
must
(
1)
submit
a
monitoring
plan
for
each
affected
unit
at
a
source,
(
2)
submit
data
for
certification
of
each
monitor,
and
(
3)
record
hourly
operational,
pollutant
monitor,
and
flow
monitor
data
for
each
affected
unit
and
submit
quarterly
reports
of
their
emissions
data
to
EPA.
Appendices
A
and
B
to
this
ICR
contain
a
list
of
the
data
items
required
by
the
recordkeeping
and
reporting
provisions
of
Part
75.

Respondents
are
required
by
40
CFR
75.64
to
submit
the
quarterly
emissions
data
electronically,
by
direct
electronic
submission
to
EPA,
and
must
also
include
a
certification
statement
by
the
designated
representative
of
the
unit.
Under
the
2002
rule
revisions,
EPA
requires
the
certification
statement
to
be
submitted
electronically
unless
it
approves
a
hardcopy
submission.
All
records
are
to
be
kept
for
three
years,
with
two
possible
exceptions
under
voluntary
options
that
are
discussed
in
section
3.3
of
this
ICR.

The
2002
Part
75
revisions
add
or
revise
some
recordkeeping
and
reporting
terms.
Some
of
these
are
necessary
for
the
rule
requirements
to
match
the
actual
reporting
practices
incorporated
in
the
Electronic
Data
Reporting
formats
used
for
the
Acid
Rain
Program.
Others
reflect
minor
rule
changes.

Auctions
For
auctions,
participants
are
required
to
submit
a
bid
form
and
payment
method
at
least
six
days
prior
to
the
date
of
the
auction.
Sealed
bids
are
submitted
on
a
standard
bid
form
developed
by
EPA.
Each
bid
provides
the
following
basic
information:

°
Name;
°
Account
number
(
or
new
account
information);
°
Allowance
quantity
and
price;
and
°
Type
of
auction.

The
bid
also
specifies
an
acceptable
method
of
payment
for
the
total
bid
price
regardless
of
the
type
of
auction
(
spot
or
advance).
Full
payment
for
allowances
­­
in
an
acceptable
form
­­
is
required
with
the
bid
at
the
time
of
submission.

Opt­
in
To
obtain
an
opt­
in
permit,
applicants
are
required
to
submit
a
certificate
of
representation
and
an
opt­
in
permit
application
for
each
source.
For
all
respondents,
the
18
application
must
provide
(
1)
general
information
on
the
source,
(
2)
specific
data
about
the
source's
fuel
consumption
and
operating
data
for
1985,
1986,
and
1987,
and
(
3)
data
on
the
source's
actual
and
allowable
emission
rates
for
1985,
as
well
as
the
current
allowable
emission
rate.
For
permit
applicants
who
plan
to
opt
in
and
shut
down,
the
compliance
plan
is
based
on
a
statement
describing
the
source's
plans
for
shutting
down
and
replacing
thermal
energy.

The
general
information
required
of
all
opt­
in
sources
include
the
following
items,
as
listed
in
Section
74.16
or
another
section
as
listed
below:

°
Source
name
and
location;
°
Name,
address,
telephone
and
facsimilie
number
of
the
designated
representative;
°
Name,
address,
telephone
and
facsimilie
number
of
the
alternate
designated
representative;
°
Statement
of
certification;
°
Complete
record
of
fuel
consumption
and
operating
data
for
calendar
years
1985,
1986,
1987,
or
other
acceptable
baseline;
°
Actual
and
allowable
emission
rates
for
1985,
or
if
source
was
not
operating
in
1985,
for
a
calendar
year
to
be
determined
by
the
Administrator,
as
well
as
the
current
allowable
emission
rate;
°
Statement
provisions
as
indicated
at
72.9;
and
°
Signature
of
designated
representative
and
date
of
signature.

In
addition,
sources
that
opt
in
and
continue
to
operate
must
meet
the
emission
monitoring
requirements
that
were
listed
above.

As
part
of
the
annual
compliance
certification
report
required
in
Section
74.43
for
opt­
in
units,
respondents
must
report
utilization
information,
and
replacement
of
thermal
energy
and
resulting
transfer
of
allowances.
The
following
information
must
be
reported,
as
required
in
Sections
74.44
and
74.47:

°
Source
name
and
location;
°
Name,
mailing
address,
telephone
and
facsimilie
number
of
source
representative;
°
Benchmark
utilization,
annual
utilization,
average
utilization,
end­
of­
year
determination
of
reduced
utilization,
and
the
calculation
of
allowances
deducted
for
reduced
utilization
(
if
any);
°
Amount
of
thermal
energy
replaced
(
if
the
source
has
shut
down
or
if
the
utilization
rate
has
fallen
due
to
replacement
of
thermal
energy
by
another
source),
and
the
name
and
location
of
the
source
or
sources
providing
replacement
thermal
energy;
°
A
calculation
of
the
number
of
allowances
transferred
to
each
source
providing
replacement
thermal
energy;
°
Allowance
tracking
system
account
number
of
the
replacement
units;
and
°
Dated
signatures
for
all
designated
representatives.

All
respondents
who
choose
to
withdraw
from
the
program
are
required
to
notify
the
19
Agency
of
their
decision
and
provide
the
following
information,
as
required
in
Section
74.18:

°
Source
account
number;
°
Name,
address,
telephone
and
facsimilie
number
of
the
designated
representative;
and
°
A
certification
that
emissions
requirements
will
be
met
through
Dec.
31
of
the
current
year,
and
that
all
remaining
allowances
will
be
surrendered
at
that
time.

NOx
Permitting
Regardless
of
the
compliance
option
selected,
the
following
elements
must
be
included
in
the
compliance
plan
for
each
source:

°
Identification
of
the
source;
°
Identification
of
each
affected
unit
at
the
source
that
is
subject
to
these
regulations;
°
Identification
of
the
boiler
type
of
each
unit;
and
°
Identification
of
the
compliance
option
proposed
for
each
unit.

For
units
that
are
choosing
either
standard
or
early
election
limits,
the
designated
representative
must
simply
check
the
appropriate
box(
es)
to
indicate
the
NOx
compliance
plan
that
is
chosen.

For
units
that
are
in
an
averaging
plan,
the
following
additional
information
must
be
submitted:

°
Identification
of
each
unit
in
the
plan;
°
Each
unit's
standard
emission
limitation;
°
The
alternative
contemporaneous
applicable
emission
limitation
for
each
unit
(
in
lb/
mmBtu);
°
The
annual
heat
input
limit
for
each
unit
(
in
mmBtu);
°
The
calculation
for
the
equation
outlined
in
Step
2
of
the
EPA
form
for
emissions
averaging;
and
°
The
calendar
years
for
which
the
averaging
plan
applies..

For
an
AEL,
the
designated
representative
must
submit
the
following
information:

AEL
Demonstration
Period
For
an
AEL,
the
designated
representative
must
first
submit
an
application
for
an
AEL
demonstration
period.
The
application
must
contain
the
following
information
in
accordance
with
40
CFR
§
76.10(
d):

°
Identification
of
the
unit;
°
The
type
of
control
technology
installed.
If
low
NOx
burner
technology
incorporating
advanced
and/
or
separated
overfire
air
is
technically
infeasible,
a
20
justification
including
a
technical
analysis
and
evaluative
report
from
the
vendor
of
the
system
or
from
an
independent
architectural
and
engineering
firm
explaining
why;
°
Documentation
that
the
installed
NOx
emission
control
system
has
been
designed
to
meet
the
applicable
emission
limitation
and
that
the
system
has
been
properly
installed;
°
The
date
the
specific
unit
commenced
operation
following
the
installation
of
the
NOx
control
equipment,
or
the
date
the
specific
unit
became
subject
to
the
emission
limitations
(
whichever
is
later);
°
The
dates
of
the
operating
period
(
minimum
of
3
continuous
months);
°
Certification
by
the
designated
representative
that
the
unit
and
the
NOx
control
equipment
were
operated
during
the
operating
period
in
accordance
with
specifications
and
procedures
designed
to
achieve
the
applicable
emission
limitation,
with
the
operating
conditions
upon
which
the
design
of
the
NOx
control
equipment
was
based,
and
with
vendor
specifications
and
procedures;
°
A
brief
statement
describing
the
reason
or
reasons
an
AEL
demonstration
period
is
required
for
the
specific
unit;
°
For
the
control
technology,
load
range,
O2
range,
coal
volatile
matter
range,
and
percentage
of
combustion
air
introduced
through
overfire
air
ports;
°
Description
of
planned
modifications;
°
List
of
parametric
tests
to
be
conducted
in
accordance
with
40
CFR
§
76.15;
°
Identification
of
the
continuous
emission
monitoring
data
submitted
pursuant
to
40
CFR
Part
75
that
is
to
be
used
in
assessing
this
application;
°
An
interim
AEL,
in
lb/
mmBtu;
and
°
The
proposed
dates
of
the
demonstration
period.

Final
AEL
After
the
demonstration
period,
the
owner
or
operator
may
petition
the
permitting
authority
for
a
final
AEL.
The
petition
must
include
the
following
information
in
accordance
with
40
CFR
§
76.10(
e):

°
Identification
of
the
unit;
°
Certification
that
the
affected
unit
and
the
NOx
control
equipment
have
been
properly
operated
during
the
demonstration
period;
°
Certification
that
the
affected
unit
has
installed
all
emission
control
equipment,
made
any
operational
modifications,
and
completed
any
upgrades
and/
or
maintenance
to
equipment
specified
in
the
demonstration
period
plan;
°
A
clear
description
of
each
step
or
modification
taken
during
the
demonstration
period;
°
Engineering
design
calculations
and
drawings
that
show
the
technical
specifications
for
installation
of
any
additional
operational
or
emission
control
modifications
installed
during
the
demonstration
period;
°
Identification
of
the
continuous
monitoring
data
submitted
pursuant
to
40
CFR
Part
75
that
is
to
be
used
in
assessing
this
application;
21
°
A
report,
based
on
the
parametric
testing,
that
describes
the
reasons
for
the
failure
of
the
installed
NOx
control
equipment
to
meet
the
applicable
emission
limitation;
°
The
minimum
NOx
emission
rate,
in
lb/
mmBtu,
that
the
affected
unit
is
able
to
achieve
on
an
annual
average
basis;
°
All
supporting
data
and
calculations
documenting
the
determination
of
the
proposed
AEL;
and
°
For
affected
units
that
have
installed
an
alternative
technology,
demonstration
that
the
annual
average
reduction
of
NOx
emissions
is
greater
than
65
percent.

Recordkeeping
All
records
are
to
be
kept
for
three
years,
except
for
permitting
records
which
are
to
be
kept
for
the
duration
of
the
permit,
or
up
to
five
years
and
certain
new
monitoring
provisions.

4.2.2
Respondent
activities
Allowance
Transfers
Participants
in
the
allowance
transfer
system
that
are
not
affected
units
are
required
to
perform
two
tasks:
(
1)
negotiate
an
agreement
to
designate
an
authorized
account
representative
and
file
an
account
information
application
to
open
an
Allowance
Tracking
System
general
account;
and
(
2)
complete
and
submit
allowance
transfers.
Designating
an
authorized
account
representative
and
filing
an
account
information
application
is
required
one
time
only,
prior
to
or
concurrent
with
conducting
the
first
transfer
of
allowances.
For
each
transfer
of
allowances,
participants
are
required
to
complete
and
submit
an
allowance
transfer
form
or
provide
the
required
information
using
the
On­
line
Allowance
Transfer
System
(
OATS).
Affected
units
that
were
required
to
submit
a
certification
of
representation
under
the
initial
ICR,
must
continue
to
prepare
and
submit
allowance
transfer
information
for
each
allowance
transfer,
and
if
the
designated
representative
chooses,
identifying
the
serial
numbers
of
allowances
to
be
deducted
for
annual
reconciliation
using
the
Allowance
Deduction
Form.

General
account
holders
and
affected
units
may
change
the
authorized
account
representatives
by
submitting
a
subsequent
allowance
account
information
form
or
certificate
of
representation
form
respectively.

Conservation
and
Renewable
Energy
Reserve
The
tasks
that
must
be
performed
by
utilities
applying
for
allowances
from
the
Conservation
and
Renewable
Energy
Reserve
are
(
1)
designate
the
qualified
energy
conservation
measures
implemented
and
the
qualified
renewable
energy
sources
used
to
avoid
emissions,
(
2)
verify
installation
of
energy
conservation
measures
or
the
plant
operation
using
renewable
energy,
and
the
resulting
benefits,
(
3)
calculate
the
tons
of
emissions
avoided,
and
(
4)
demonstrate
qualification
to
receive
allowances
for
emissions
avoided.
Generally,
because
utilities
already
perform
these
tasks
to
satisfy
state
requirements,
utilities
do
not
need
to
duplicate
these
efforts
to
apply
for
allowances
from
the
Reserve.
Rather,
utilities
primarily
assemble
the
information
resulting
from
these
activities
in
an
application
and
submit
this
application
to
EPA.
22
Obtaining
a
Permit
The
primary
tasks
to
obtain
a
permit
are
listed
below.
These
tasks
are
performed
by
existing
sources
required
to
renew
their
permits
and
new
units
during
the
period
covered
by
this
ICR.
In
general,
sources
with
existing
units,
must
reapply
at
least
6
months
prior
to
the
expiration
of
an
existing
permit,
but
the
actual
timeframe
is
governed
by
the
permitting
authority's
operating
permits
rules.

°
Designate
a
representative
of
the
owners
and
operators
of
a
source.
Read
the
designated
representative
certification
procedures.
Negotiate
an
agreement
to
designate
a
representative
for
each
unit
at
a
source.
Complete
and
submit
the
certification.
This
task
is
only
relevant
for
a
new
Phase
II
source
or
if
a
source
changes
the
designated
representative.
°
Prepare
the
permit
application.
Read
the
permit
application
instructions,
then
collect
relevant
information
for
the
permit
application.
Complete
the
Phase
II
acid
rain
permit
application.
Where
appropriate,
provide
specific
information
to
support
the
use
of
compliance
options
for
NOX.
Review
the
information
for
accuracy
and
appropriateness
and
report
the
information
to
the
permitting
authority.

Emissions
Monitoring
The
primary
tasks
that
are
performed
by
respondents
to
meet
the
emissions
monitoring
requirements
are
(
1)
completing
and
submitting
appropriate
monitoring
plan
forms
for
each
affected
source
and
each
affected
unit
at
a
source;
(
2)
conducting
tests
to
certify
the
operation
of
monitors,
and
submitting
test
results
to
EPA;
(
3)
recording
hourly
emissions
data
(
this
activity
generally
is
performed
electronically);
(
4)
operation
and
maintenance
activities
associated
with
the
monitoring,
including
quality
assurance
activities;
(
5)
assuring
data
quality,
preparing
quarterly
reports
of
emissions
data
and
submitting
these
reports
to
EPA;
and
(
6)
responding
to
error
messages
generated
by
EPA
as
a
part
of
automated
data
checks
or
electronic
audits,
or
to
field
audits
conducted
by
EPA.
In
addition,
respondents
must
purchase
the
necessary
monitoring
hardware
(
or
pay
for
fuel
sampling
and
analysis
in
some
cases)
and
purchase
the
electronic
data
reporting
software
(
or
software
upgrades).
To
enable
sources
to
perform
self­
audits
of
submissions,
EPA
also
has
developed
the
Monitoring
Data
Checking
(
MDC)
software
for
use
by
affected
sources.
This
software
enables
sources
to
run
automated
quality
checks
of
reports
prior
to
submittal
to
EPA
and
reduces
the
burden
of
having
to
respond
to
EPA
generated
error
messages
or
follow­
up
EPA
audits.

Opt­
in
In
order
to
provide
the
information
discussed
in
the
previous
section,
participants
must
complete
three
tasks
to
participate
in
the
opt­
in
program:
(
1)
submit
a
permit
application,
(
2)
meet
monitoring
requirements,
and
(
3)
submit
annual
compliance
reports.
Respondents
who
choose
to
withdraw
are
required
to
submit
a
withdrawal
notification.

The
primary
tasks
that
must
be
completed
to
obtain
a
permit
and
the
activities
associated
with
them
are
listed
below.
These
tasks
will
be
performed
only
once
during
the
period
covered
by
this
ICR.
23
°
Designate
a
representative
of
the
owners
and
operators
of
a
source.
Read
the
designated
representative
certification
procedures.
Negotiate
an
agreement
to
designate
a
representative
for
each
source.
Complete
and
submit
the
certification.
°
Prepare
the
permit
application.
Read
the
permit
application
instructions,
then
collect
relevant
information
for
the
permit
application.
Complete
written
forms,
including
an
application
for
an
opt­
in
permit.
Review
the
information
for
accuracy
and
appropriateness.
Submit
the
information
to
EPA,
sending
copies
to
the
appropriate
EPA
regional
office.

Respondents
who
opt
in
and
continue
to
operate
must
also
perform
the
task
required
under
the
emissions
monitoring
section
above.
Respondents
who
opt
in
and
shut
down
do
not
need
to
perform
any
tasks
related
to
monitoring.

To
withdraw
from
the
program,
respondents
must
notify
EPA
of
their
decision
to
withdraw.
Notification
entails
providing
EPA
with
the
data
items
presented
in
Section
3.2.1..

Opt­
in
sources
covered
by
a
thermal
energy
plan,
must
also
report
information
concerning
the
replacement
of
thermal
energy,
including
the
identification
of
the
source
or
sources
providing
replacement
thermal
energy,
and
the
allowances
transferred
as
a
result
of
the
replacement
of
thermal
energy.

NOX
Permitting
The
primary
tasks
for
a
NOX
compliance
plan
are
listed
below.

°
Prepare
the
NOX
compliance
plan
application.
Read
the
application
instructions,
then
collect
relevant
information.
Analyze
compliance
options
and
plan
compliance.
Complete
written
forms.
Review
the
information
for
accuracy
and
appropriateness
and
report
the
information
to
the
permitting
authority
and
send
a
copy
to
the
EPA.
Preparing
a
NOX
compliance
plan
application
may
include
interpreting
the
rule,
collecting
information
and
completing
and
submitting
a
NOX
averaging
plan,
or
an
AEL
petition.

Because
each
source
must
renew
its
Acid
Rain
permit
every
five
years,
EPA
assumes
the
tasks
for
permitting
will
be
performed
by
20%
of
all
NOX
affected
sources
annually,
in
accordance
with
Section
408.

5.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
The
first
part
of
this
section
describes
Agency
(
EPA)
activities
related
to
the
acquisition,
analysis,
storage,
and
distribution
of
the
information
collected
from
(
1)
participants
in
allowance
transfers,
(
2)
applicants
for
allowances
from
the
Conservation
and
Renewable
Energy
Reserve,
(
3)
permit
applicants,
(
4)
designated
representatives
of
affected
sources
that
are
required
to
24
submit
monitoring
plans
and
emissions
data,
(
5)
participants
in
the
annual
auction,
and
(
6)
the
opt­
in
program,
and
(
7)
NOX
permitting.
The
second
part
describes
the
information
management
techniques
employed
to
increase
the
efficiency
of
collections.
The
third
part
discusses
the
burden
or
benefits
of
the
collection
activities
described
in
this
ICR
to
small
entities.
The
last
part
outlines
the
schedule
for
collecting
information.

5.1
Agency
Activities
Allowance
Transfers
Collections
associated
with
operating
the
allowance
transfer
system
requires
EPA
to
(
1)
track
allowance
holders
and
maintain
allowance
accounts,
(
2)
review
allowance
transfer
information
for
completeness
and
ensure
that
all
requirements
are
met,
(
3)
record
allowance
transfers,
and
(
4)
notify
both
participants
in
a
transfer
whether
the
transfer
was
recorded.
EPA
has
developed
a
computer
system
called
the
Allowance
Tracking
System
(
ATS)
to
track
allowances
and
maintain
information
on
accounts.
In
addition,
EPA
now
has
a
system
that
allows
market
participants
to
submit
transfers
over
the
internet
and
that
provides
real
time
transfers
and
instantaneous
confirmation.

Conservation
and
Renewable
Energy
Reserve
Activities
that
must
be
performed
by
EPA
to
distribute
allowances
from
the
Conservation
and
Renewable
Energy
Reserve
include
(
1)
registering
applications
and
reviewing
applications
for
completeness,
(
2)
performing
substantive
reviews
of
applications
to
determine
whether
all
necessary
criteria
to
receive
allowances
have
been
met,
(
3)
transferring
allowances
from
the
Reserve
or
notifying
applicants
of
their
failure
to
qualify
for
allowances
from
the
Reserve,
and
(
4)
for
utilities
using
the
EPA
Conservation
Verification
Protocol,
verifying
the
quantified
energy
savings
from
conservation
measures.

Permits
EPA
staff
administering
the
permit
program
perform
the
following
task:

°
Review
certificates
of
representation,
enter
the
information
in
the
Clean
Air
Markets
Database
(
CAMD),
and
notify
the
representative.

Permitting
authority
staff,
generally
at
the
state
or
local
level,
perform
the
following
tasks:

°
Review
permit
applications
and
issue
permits.
Receive
and
review
permit
applications
and
record
submissions.
Provide
notice
to
applicants
whether
permit
applications
are
complete.
Reformat
collected
data
items
to
constitute
proposed
and
final
permits.
Provide
opportunities
for
public
comment
and
participation.

Emissions
Monitoring
The
major
EPA
activities
related
to
emissions
monitoring
and
reporting
include
(
1)
reviewing
monitoring
plans
and
certification
applications,
and
(
2)
processing,
reviewing
and
evaluating
reports
of
quarterly
emissions
data
from
affected
units.
EPA
has
developed
a
25
computer
system
called
the
Emissions
Tracking
System
(
ETS)
to
track
and
maintain
this
information.
EPA
also
answers
respondent
questions
and
conducts
audits
of
data
submissions
and
field
audits
of
monitoring
systems.
The
use
of
the
Monitoring
Data
Checking
software
streamlines
EPA's
process
for
conducting
many
of
these
checks.

Auctions
EPA
staff
administering
the
auctions
receive
the
sealed
bids
and
payments,
enters
the
information
provided
on
bid
forms
into
a
computer
system,
and
deposits
the
checks
into
a
designated
bank
account.
(
Collectively,
these
activities
comprise
handling
of
bids
and
checks.)
After
bids
are
recorded,
they
are
ranked
using
a
computer
program
and
then
the
allowances
are
allocated.
EPA
announces
the
results
by
posting
them
on
the
EPA
website.
Finally,
after
payment
is
verified,
EPA
records
the
transfer
of
allowances
and
transfers
the
proceeds
from
the
auction
to
the
owners
and
operators
from
whom
the
allowances
were
withheld.
EPA
has
developed
a
computer
system
to
track
the
payment
of
proceeds.

Opt­
in
EPA
staff
administering
the
opt­
in
permit
program
perform
the
following
tasks
for
each
opt­
in
applicant:

°
Review
certificate
of
representation,
record
information,
and
notify
representative.
°
Review
permit
application.
Receive
and
review
permit
application
and
record
submission.
Provide
notice
to
applicant
as
to
whether
permit
application
is
complete.
Reformat
collected
data
items
to
constitute
proposed
and
final
permit.
°
Notify
applicant
regarding
allowances.
Notify
the
opt­
in
permit
applicant
of
the
number
of
allowances
the
applicant
would
receive
each
year
as
an
opt­
in
source.

EPA
activities
related
to
withdrawals
will
be
to
process
the
withdrawal
notification,
and
ensure
that
all
unused
allowances
have
been
surrendered
at
the
end
of
the
calendar
year.

NOX
Permitting
Agency
staff
perform
the
following
task.

°
Review
NOx
compliance
plan
applications.
Receive
and
review
applications
and
record
submissions.
Provide
notice
to
applicants
whether
applications
are
complete.

5.2
Collection
Methodology
and
Management
To
ensure
consistency
nationwide
and
to
expedite
(
1)
data
entry,
(
2)
the
allocation
of
allowances
from
Reserves,
and
(
3)
permit
issuance,
EPA
requires
that
standard
reporting
forms
or
equivalent
formats
or
standard
electronic
reporting
formats
be
used
to
submit
all
information
to
be
collected
under
this
ICR.
The
standard
forms
are
included
in
Appendix
C.

Currently,
respondents
to
collections
for
allowance
transfer
information
may
submit
the
26
required
information
on
a
standard
written
form,
or
using
an
electronic
format.
Permit
applications
are
submitted
on
standard
paper
forms,
as
are
certifications
for
new
and
retired
unit
exemptions.
EPA
requires
that
standard
electronic
data
reporting
(
EDR)
formats
be
used
to
submit
information
to
be
collected
under
Part
75
and,
under
the
1999
rule
revisions,
EPA
also
required
that
data
be
sent
via
direct
electronic
submission
to
EPA
beginning
in
the
year
2001.
The
current
EDR
formats
(
version
2.2)
are
included
in
Appendix
C
to
this
document.

Several
computer
systems
and
associated
databases
have
been
developed
to
(
1)
track
allowances,
(
2)
record
quarterly
emissions
monitoring
data,
(
3)
track
auction
proceed
payments,
and
(
4)
calculate
the
number
of
allowances
to
be
deducted
each
year.
In
2001,
EPA
also
made
available
the
On­
line
Allowance
Transfer
System
to
permit
online
allowance
transfers
and
allowance
account
maintenance
activities.
The
systems
and
databases
are
designed
to
coordinate
the
information
for
easy
access
and
use
by
the
Agency,
states,
regulated
community,
and
the
public.

The
Data
and
Maps
section
of
the
EPA's
Clean
Air
Markets
Home
Page
on
the
Internet,
includes
detailed
information
collected
from
emissions
reports,
allowance
transfer
activity,
and
facility
or
source
data.
Those
without
access
to
the
Internet
may
use
the
Acid
Rain
Hotline
to
request
information.

5.3
Small
Entity
Flexibility
For
the
purposes
of
the
Acid
Rain
Program,
EPA
has
adopted
the
Small
Business
Administration's
definition
of
a
"
small"
electric
power
utility
as
one
that
generates
a
total
of
less
than
4
billion
kilowatt­
hours
per
year.
Generally,
although
about
two­
thirds
of
the
affected
sources
in
Phase
II
generate
a
total
of
less
than
4
billion
kilowatt­
hours
per
year
and
are
required
to
participate
in
some
collections
under
this
ICR
(
e.
g.,
submitting
information
for
certification
of
monitors
and
submitting
quarterly
emissions
monitoring
reports),
the
costs
to
these
sources
for
collections
under
this
ICR
are
small
relative
to
the
revenues
they
generate.

All
affected
sources
under
the
Clean
Air
Act
Amendments
of
1990
are
required
to
submit
permit
applications
and
to
respond
to
other
collections
under
this
ICR,
according
to
the
same
parameters
(
with
the
exception
of
operators
of
new
units
of
25
MW
or
less,
who
may
receive
an
exemption
from
the
Acid
Rain
Program
requirements
if
they
qualify).
Retired
units
may
also
be
exempted
from
some
reporting
requirements.

The
use
of
standardized
forms
will
enable
small
entities
to
understand
and
complete
permit
application
submissions
without
the
level
of
staffing
which
would
be
necessary
in
the
absence
of
such
forms.

In
the
January
11,
1993
final
Acid
Rain
Core
Rules,
EPA
provided
for
a
conditional
exemption
from
the
emissions
reduction,
permitting,
and
emissions
monitoring
requirements
of
the
Acid
Rain
Program
for
new
units
having
a
nameplate
capacity
of
25
MWe
or
less
that
burn
fuels
with
a
sulfur
content
no
greater
than
0.05
percent
by
weight,
because
of
the
high
cost
of
monitoring
emissions
from
these
sources
and
the
de
minimis
nature
of
their
emissions.
27
The
Part
75
rule
revisions
also
create
an
additional
small
unit
exception.
This
exception
incorporates
optional
reduced
monitoring,
quality
assurance,
and
reporting
requirements
into
Part
75
for
units
that
combust
gas
and/
or
fuel
oil
and
that
have
low
levels
of
mass
emissions
(
referred
to
as
low
mass
emissions
(
LME)
units).
Originally,
EPA
required
that
LME
units
emit
no
more
than
25
tons
of
SO2
and
no
more
than
50
tons
of
NOx
annually,
and
that
they
calculate
no
more
than
25
tons
of
SO2
and
no
more
than
50
tons
of
NOx
annually
based
on
required
procedures
for
calculating
and
reporting
emissions.
As
part
of
the
2002
Part
75
revisions,
EPA
has
increased
the
NOx
threshold
to
<
100
tons
per
year
(
and,
for
units
that
are
subject
to
the
NOx
SIP
Call,
no
more
than
50
tons
per
ozone
season).
Qualifying
LME
units
are
no
longer
required
to
keep
monitoring
equipment
installed
on
(
or
conduct
sulfur­
in­
fuel
sampling
for)
low
mass
emissions
units,
nor
are
they
required
to
perform
quality
assurance
or
quality
control
tests.
Moreover,
emissions
reporting
requirements
are
significantly
simplified
for
these
units.

Even
if
a
gas­
or
oil­
fired
unit
does
not
qualify
for
the
LME
provisions,
Part
75
allows
gas
and
oil­
fired
units
to
use
methods
other
than
continuous
emission
monitoring
systems
(
CEMS).
The
1999
Part
75
revisions
significantly
reduced
the
costs
and
burdens
associated
with
fuel
sampling
and
QA
activities
for
these
non­
CEMS
methods.
As
discussed
in
the
Regulatory
Impact
Analysis
(
RIA)
of
the
final
Acid
Rain
Implementation
Regulations
(
October
19,
1992),
smaller
utilities
are
more
likely
to
be
dependent
on
these
oil­
and
gas­
fired
units,
especially
very
small
utilities
(
see
p.
5­
14
of
that
RIA
document).

Further
reductions
in
requirements
aimed
specifically
for
small
entities
are
limited
because
of
the
statutory
requirements
that
all
affected
units
use
CEMS
(
or
an
equivalent
method)
to
record
and
report
emissions
data
for
Title
IV
purposes.

5.4
Collection
Schedule
Allowance
Transactions
There
is
no
specific
collection
schedule
associated
with
allowance
transactions.

Conservation
and
Renewable
Energy
Reserve
Submitting
applications
for
allowances
from
the
Conservation
and
Renewable
Energy
Reserve
is
voluntary.
Allowances
from
the
Reserve
will
be
allocated
on
a
first­
come,
firstserved
basis
during
the
period
from
January
1,
1992
to
December
31,
2009.

Permits
In
general,
each
Acid
Rain
permit
is
effective
for
five
years.
Revisions
to
the
permit
may
be
submitted
at
any
time.

Emissions
Monitoring
Monitoring
plans
must
be
submitted
only
once,
although
certain
elements
of
the
monitoring
plan
are
submitted
(
and
updated
as
necessary)
routinely
as
part
of
the
EDR
format.
Only
new
units
will
have
to
apply
for
certification
during
the
2003­
2005
time
period.
While
some
monitors
will
be
required
to
apply
for
recertification,
there
is
no
set
schedule
for
28
recertification.

Quarterly
reports
are
due
for
each
quarter
during
the
life
of
this
information
collection
request.
In
addition,
EPA
has
provided
for
notifications
to
the
Agency
for
semi­
annual
or
annual
quality
assurance
testing
and
for
situations
where
a
unit
will
have
a
revised
certification
deadline
(
for
example,
notifications
of
unit
start­
up
for
new
units).

Auctions
The
spot
and
advance
auctions
are
currently
held
before
March
31
of
each
year.
The
cutoff
date
for
submission
of
bids
is
only
a
few
days
prior
to
the
auction
in
order
to
limit
the
time
EPA
holds
the
bidders'
money.

Opt­
in
Opting
in
to
the
allowance
program
requires
just
one
information
collection
(
although
monitoring
information
for
affected
sources
must
be
collected
quarterly).
Opt­
in
permit
applications
may
be
submitted
to
EPA
and
the
permitting
authority
at
any
time.
Permits
must
be
renewed
at
that
time,
and
every
five
years
thereafter.
Revisions
to
the
permit
may
be
submitted
at
any
time.

Monitoring
plans
must
be
submitted
only
once,
at
the
time
the
opt­
in
permit
application
is
submitted.
The
data
upon
which
EPA
will
base
its
certification
of
each
emissions
monitor
may
be
submitted
after
the
source
receives
a
draft
opt­
in
permit,
but
must
be
submitted
before
the
source
may
be
designated
an
affected
source.
(
Monitors
must
be
installed,
certified
by
EPA,
and
operating
before
the
source
may
be
designated
an
affected
source.)
Emissions
data
to
meet
reporting
requirements
are
collected
quarterly,
30
days
after
the
end
of
each
calendar
quarter,
beginning
at
the
end
of
the
first
quarter
in
which
the
source
becomes
an
affected
source.

Compliance
reports
must
be
sent
annually.
Allowance
transfer
information
must
be
submitted
once
for
each
transfer;
a
certificate
of
representation
needs
to
be
submitted
only
once,
at
the
same
time
as
the
opt­
in
application.

Withdrawing
requires
only
one
information
collection.

NOX
Permitting
Acid
Rain
permits,
including
NOX
compliance
plans
must
be
renewed
every
five
years.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
COLLECTIONS
This
section
estimates
the
paperwork
burden
and
cost
of
(
1)
tracking
and
transferring
allowances,
(
2)
obtaining
and
distributing
allowances
from
the
Conservation
and
Renewable
Energy
Reserve,
(
3)
obtaining
and
issuing
permits,
(
4)
submitting
monitoring
plans,
obtaining
certification
of
each
monitor,
and
recording
and
reporting
data
from
CEM
systems,
(
5)
the
auction
program,
(
6)
the
opt­
in
program,
and
(
7)
NOX
permitting.
29
First,
assumptions
regarding
allowance
transfers
are
presented,
followed
by
the
annual
respondent
and
Agency
burden
and
cost
estimates
associated
with
allowance
transfers.
Subsequent
sections
separately
address
allowances
for
energy
conservation
and
renewable
energy
use,
permits,
emissions
monitoring,
auctions,
opt­
in,
and
NOX
permitting.
Finally,
aggregate
annual
burden
hour
and
cost
estimates
to
respondents
and
to
EPA
for
collections
covered
by
this
ICR
are
presented.

Estimating
Labor
Costs
To
calculate
labor
costs,
EPA
used
the
following
amounts:
$
84.43
per
hour
for
managers,
$
58.00
per
hour
for
technicians
and
clerical
workers.
As
noted
above,
these
rates
were
derived
by
using
the
rates
from
the
previous
ICR
and
updating
them
with
the
Employment
Cost
Index
to
January
2006.

The
labor
cost
to
the
Agency,
$
54.65
per
hour,
was
also
derived
by
updating
the
rate
from
the
previous
ICR.

6.1
Tracking,
Transferring,
and
Deducting
Allowances
Labor
burden
and
costs
for
collections
associated
with
tracking
and
transferring
allowances
are
functions
of
the
number
of
transfers
anticipated.
Based
on
number
of
transfers
recorded
by
EPA
in
2004
and
2005,
EPA
could
assume
that
about
5,200
privately
submitted
allowance
transfers
will
be
made
each
year,
2007
through
2009.
However,
given
that
the
Acid
Rain
Program
is
moving
to
facility
level
compliance
beginning
in
2006,
this
number
would
turn
out
to
be
a
substantial
overestimate.
That's
because
a
large
number
of
transfers
are
made
to
move
allowances
among
the
different
unit
accounts
at
a
facility
for
compliance
purposes.
Switching
to
a
single
facility
account
for
compliance
will
eliminate
all
of
these
transfers.
Since
there
are
an
average
of
three
units
per
facility,
EPA
is
assuming
that
the
number
of
privately
submitted
allowance
transfers
will
be
about
1,700
(
one
third
of
the
5,200
from
prior
years)
each
year,
2007
through
2009.

Affected
facilities
have
the
option
of
identifying
specific
serial
numbered
allowances
to
be
deducted
by
EPA.
Based
on
past
experience,
EPA
assumes
that
approximately
half
of
all
affected
facilities
will
submit
an
optional
allowance
deduction
form
each
year.
EPA
estimates
that
an
average
of
645
facilities
will
be
submit
the
optional
deduction
forms
each
year
during
the
period
covered
by
this
ICR
(
2007
­
2009).

6.1.1
Estimate
of
Respondent
Burden
and
Costs
for
Transfers
and
Deductions
Exhibit
1
presents
the
annual
burden
and
costs
to
participants
in
allowance
transfers
and
deductions.
Participants
that
are
not
affected
units
are
required
to
negotiate
an
agreement
to
designate
an
authorized
account
representative
and
file
a
new
account
application;
this
activity
is
required
only
one
time,
prior
to
or
simultaneous
with
the
participant's
first
transfer
of
allowances.
All
participants
are
required
to
complete
and
submit
allowance
transfer
information
for
each
transfer
of
allowances.
EPA
estimates
about
10
hours
to
designate
an
authorized
account
30
representative
and
to
open
a
general
account,
about
2
hours
to
prepare
and
submit
information
for
an
allowance
transfer,
and
about
3
hours
to
prepare
and
submit
an
optional
allowance
deduction.

Assuming
that
55
participants
file
new
general
account
applications,
1,700
transfers
will
be
made
annually,
and
645
deduction
forms
are
submitted
the
burden
to
respondents
will
be
about
5,885
hours
annually.
The
cost
to
respondents
will
be
about
$
407,669
annually.
31
EXHIBIT
1
ANNUAL
RESPONDENT
BURDEN/
COST
ESTIMATES
FOR
ALLOWANCE
TRANSFERS
AND
DEDUCTIONS
Tasks
Burden
Hours
per
Occurrence
Cost
per
Occurrencea
Total
Burdenb
Total
Cost
Designate
an
authorized
account
representative
and
file
new
account
application
Managerial
3
$
253.29
165
$
13,930.95
Technical
7
$
406.00
385
$
22,330.00
Prepare
and
submit
allowance
transfer
information
Managerial
1
$
84.43
1,700
$
143,531.00
Technical
1
$
58.00
1,700
$
98,600.00
Allowance
deduction
form
(
optional)

Managerial
1
$
84.43
645
$
54,457.35
Technical
2
$
116
1,290
$
74,820.00
TOTAL
5,885
$
407,669.30
a
2006
dollars.
b
Assumes
55
participants
file
new
account
applications,
1,700
transfers
are
made,
and
645
optional
deduction
forms
are
submitted.

6.1.2
Estimate
of
Agency
Burden
and
Costs
for
Transfers
Agency
burden
and
costs
are
divided
into
those
costs
associated
with
enhancing
a
tracking
system,
and
those
associated
with
transferring
and
deducting
allowances.

Allowance
Tracking
System
The
allowance
system
regulations
set
the
general
requirements
for
the
tracking
system,
which
has
been
developed
by
EPA.
In
order
to
track
allowances,
the
allowance
tracking
system
must
include
information
on
(
1)
allowance
allocations
for
each
affected
facility,
(
2)
allowance
transfers
and
deductions,
and
(
3)
allowance
holders.
Also,
to
allow
for
the
transfer
of
future
year
allowances,
the
allowance
tracking
system
will
contain
allowance
information
for
thirty
years
into
the
future.
EPA
has
made
the
information
compiled
in
the
allowance
tracking
system
publicly
available
in
several
formats
on
the
internet
and
is
continually
working
to
improve
electronic
access.
32
EPA
incurs
annual
operation
and
maintenance
(
O&
M)
costs
for
running
an
electronic
transmission
network,
system
enhancement,
general
maintenance,
and
employee
salaries.
These
O&
M
costs
are
estimated
at
$
1.5
million
annually.

Allowance
Transfer
System
Upon
receipt
of
an
allowance
transfer
notification
in
hard
copy
form,
EPA
will
(
1)
review
allowance
transfer
information
for
completeness
and
ensure
that
all
requirements
have
been
met,
(
2)
record
allowance
transfers,
and
(
3)
notify
both
participants
to
a
transfer
whether
the
transfer
was
recorded.
EPA
estimates
that
it
will
require
an
average
of
one
hour
to
perform
these
activities
for
each
notification.
Upon
receipt
of
an
optional
allowance
deduction
form,
in
hard
copy,
EPA
will
record
the
data
into
the
EPA
data
system.
This
is
estimated
to
take
about
30
minutes
per
form.

Assuming
500
(
out
of
the
1,700
total)
transfers
will
be
made
using
paper
forms
each
year
and
100
(
out
of
the
645
total)
deduction
submissions
will
be
on
paper,
the
annual
burden
to
EPA
will
be
about
550
hours.
There
is
no
Agency
burden
when
participants
use
the
electronic
on­
line
transfer
system
(
also
used
for
the
optional
deduction
submission),
since
all
EPA
functions
are
automated.
Costs
for
maintaining
the
on­
line
system
are
included
in
the
O&
M
costs.
The
total
cost
to
EPA
will
be
about
$
30,058
annually.
Exhibit
2
summarizes
the
Agency
burden
and
cost
estimates
for
recording
and
transferring
allowances.

EXHIBIT
2
ANNUAL
AGENCY
BURDEN/
COST
ESTIMATES
FOR
ALLOWANCE
TRANSFERS
Tasks
Burden
Hours
Per
Occurrence
Cost
Per
Occurrencea
Total
Burdenb
(
Hours)
Total
Cost
Review
allowance
transfer
information,
record
transfer,
and
notify
transfer
participants
1
$
54.65
500
$
27,325.00
Enter
deduction
data
and
deduct
allowances
0.5
$
27.33
50
$
2,733.00
TOTAL
550
$
30,058.00
a
2006
dollars.
b
Assumes
500
transfers
and
100
optional
deduction
forms
are
submitted
annually.

6.2
Obtaining
and
Distributing
Allowances
From
the
Conservation
and
Renewable
Energy
Reserve
Although
it
is
difficult
to
predict
the
number
of
utilities
that
will
apply
for
allowances
from
the
Conservation
and
Renewable
Energy
Reserve,
based
on
the
previous
two
years
this
analysis
assumes
that
no
applications
will
be
submitted
each
year
(
2007
through
2009).
33
6.2.1
Estimate
of
Respondent
Burden
and
Costs
Exhibit
3
depicts
the
annual
respondent
burden
and
costs
associated
with
obtaining
allowances
from
the
Conservation
and
Renewable
Energy
Reserve.
Each
utility
applying
for
allowances
from
the
Reserve
is
required
to
perform
the
following
tasks:
(
1)
designate
energy
conservation
measures
implemented
and
renewable
energy
sources
used
to
avoid
emissions;
(
2)
verify
savings
from
energy
conservation
measures
and/
or
amount
of
generation
from
renewable
energy;
(
3)
calculate
the
tons
of
emissions
avoided;
and
(
4)
demonstrate
qualification
to
receive
allowances
for
emissions
avoided.
Because
most
states
already
collect
information
on
these
activities
from
utilities,
the
primary
burden
to
utilities
would
be
that
associated
with
assembling
and
submitting
to
EPA
the
application
to
receive
allowances
from
the
Reserve.
If
someone
chose
to
apply,
EPA
assumes
it
would
take
about
46
hours
to
assemble
and
submit
an
application
to
receive
allowances
from
the
Reserve
to
EPA,
and
an
additional
32
hours
if
the
applicant
chose
to
assemble
and
submit
the
information
required
in
the
EPA
Conservation
Verification
Protocol.
34
EXHIBIT
3
ANNUAL
RESPONDENT
BURDEN/
COST
ESTIMATES
FOR
CONSERVATION
AND
RENEWABLE
ENERGY
ALLOWANCES
Tasks
Burden
Hours
per
Application
Cost
per
Applicationa
Total
Burden
(
Hours)
Total
Costs
Assemble
and
submit
an
application
to
receive
allowances
from
the
Reserveb
Managerial
11
$
928.73
0
$
0
Technical
35
$
2,030.00
0
$
0
Assemble
and
submit
the
information
required
in
the
EPA
Conservation
Verification
Protocolc
Managerial
7
$
591.01
0
$
0
Technical
25
$
1,450.00
0
$
0
TOTAL
0
$
0
a
2006
dollars.
b
Assumes
0
applications
each
year
(
2007­
2009).
c
Assumes
0
applicants
will
utilize
the
EPA
Conservation
Verification
Protocol
each
year.

6.2.2
Estimate
of
Agency
Burden
and
Costs
Exhibit
4
depicts
the
annual
burden
and
costs
to
EPA
associated
with
distributing
allowances
from
the
Conservation
and
Renewable
Energy
Reserve.
Tasks
performed
by
EPA
related
to
the
distribution
of
allowances
from
the
Reserve
include
the
following:
(
1)
register
applications
and
review
applications
for
completeness;
(
2)
perform
substantive
reviews
of
applications
to
determine
whether
all
necessary
criteria
to
receive
allowances
have
been
met;
(
3)
transfer
allowances
from
the
Reserve
or
notify
applicants
of
their
failure
to
qualify
for
allowances
from
the
Reserve;
and
(
4)
for
utilities
that
choose
to
use
the
EPA
Conservation
Verification
Protocol,
verify
the
quantified
energy
savings
from
conservation
measures.
EPA
assumes
it
takes
about
11
hours
to
process
each
application
and
transfer
allowances
(
or
notify
applicants).
35
EXHIBIT
4
ANNUAL
AGENCY
BURDEN/
COST
ESTIMATES
FOR
CONSERVATION
AND
RENEWABLE
ENERGY
ALLOWANCES
Tasks
Burden
Hours
per
Application
Cost
per
Applicationa
Total
Burden
(
Hours)
Total
Costs
Register
application
and
review
for
completenessb
1
$
54.65
0
$
0
Perform
substantive
review
of
applicationb
4
$
218.60
0
$
0
Transfer
allowances
from
the
Reserve
or
notify
applicantsb
1
$
54.65
0
$
0
Verify
energy
savings
based
upon
the
EPA
Conservation
Verification
Protocolc
5
$
273.25
0
$
0
TOTAL
0
$
0
a
2006
dollars.
b
Assumes
0
applications
each
year
(
2007­
2009).
c
Assumes
0
applicants
will
utilize
the
EPA
Conservation
Verification
Protocol.

6.3
Obtaining
and
Issuing
Permits
This
part
presents
estimates
of
the
level
of
effort
required
and
the
associated
costs
to
permit
applicants
and
either
EPA
or
the
permitting
authority
of
obtaining
and
issuing
permits.
This
analysis
estimates
the
cost
and
burden
for
new
sources
required
to
obtain
permits
for
Phase
II,
for
sources
changing
designated
representatives,
and
sources
renewing
their
permit.

All
applicants
for
permits
will
be
required
to
submit
a
general
acid
rain
permit
application
for
each
affected
source
that
covers
all
units
at
the
source.

6.3.1
Estimate
of
Respondent
Burden
and
Costs
for
Permiting
Exhibit
5
depicts
the
burden
and
costs
to
respondents
for
(
1)
selecting
a
new
designated
representative,
(
2)
submitting
Phase
II
permit
application,
(
3)
submitting
a
retired
unit
exemption,
and
(
4)
submitting
a
new
unit
exemption.
Based
on
the
past
two
years
of
operation,
EPA
assumes
that
each
year
800
Certificate
of
representation
forms
will
be
submitted
to
appoint
new
designated
representatives,
20%
of
all
sources
will
submit
Phase
II
permit
applications
(
this
number
includes
both
new
sources
and
sources
renewing
their
permits),
33
units
will
submit
retired
unit
exemptions,
and
33
units
will
submit
new
unit
exemptions.

The
total
annual
respondent
burden
is
estimated
to
be
13,531
hours.
The
costs
36
associated
with
the
permitting
process
are
estimated
at
$
1,012,000
annually.

EXHIBIT
5
RESPONDENT
BURDEN/
COST
ESTIMATES
FOR
PERMITS
Tasks
Burden
Hours
Per
Occurrence
Cost
Per
Occurrencea
Total
Burden
Total
Cost
Change
Designated
Representaiveb
Managerial
10
$
844.30
8,000
$
675,440.00
Technical
5
$
290.00
4,000
$
232,000.00
Phase
II
Permit
Applicationsc
Managerial
2
$
168.86
520
$
43,903.60
Technical
3
$
174.00
780
$
45,240.00
Retired
Unit
Exemptiond
Managerial
1
$
84.43
33
$
2,786.19
Technical
2
$
116.00
66
$
3,828.00
New
Unit
Exemptione
Managerial
1
$
84.43
33
$
2,786.19
Technical
3
$
174.00
99
$
5,742.00
TOTAL
13,531
$
1,011,726.00
a
2006
dollars.
b
Assumes
that
800
certificate
of
representation
forms
will
be
submitted.
c
Assumes
260
sources
(
20%
of
all
affected
sources)
will
submit
Phase
II
permit
applications
each
year.
d
Assumes
33
units
will
submit
retired
unit
exemptions
each
year.
e
Assumes
33
units
will
submit
new
unit
exemptions
each
year.
37
6.3.2
Estimate
of
Agency/
Permitting
Authority
Burden
and
Costs
for
Permitting
Exhibit
6
presents
the
burden
and
costs
to
EPA
and
the
permitting
authority
to
review
and
process
permit
information.
The
primary
tasks
performed
by
EPA
are
reviewing
certificates
of
representation,
and
reviewing
permit
applications.
The
primary
tasks
performed
by
the
permitting
authority
are
reviewing
and
processing
permit
applications,
notifying
the
public,
and
issuing
proposed
and
final
permits,
and
reviewing
new
and
retired
unit
exemptions.
Reviewing
a
certificate
of
representation
and
determining
completeness
notice
is
estimated
to
require
half
an
hour.
Reviewing
the
permit
application,
notifying
the
public,
and
issuing
proposed
and
final
permits
is
estimated
to
require
9
hours
per
occurrence.
The
Agency's
total
annual
effort
will
be
680
hours.
The
total
cost
to
EPA
for
all
permitting
activities
will
be
about
$
37,156.
The
total
annual
estimated
burden
and
cost
to
the
Permitting
Authorities
is
2,212
hours
and
$
120,885.

EXHIBIT
6
ANNUAL
AGENCY/
PERMITTING
AUTHORITY
BURDEN/
COST
ESTIMATES
FOR
PERMITS
Tasks
Burden
Hours
Per
Occurrence
Cost
Per
Sourcea
Total
Burden
(
Hours)
Total
Cost
EPA
reviews
certificates
of
representation
and
records
informationb
0.5
$
27.33
400
$
21,864.00
Review
permit
application,
and
issue
draft,
proposed,
and
final
permitc
Permitting
Authority
action
8
$
437.20
2,080
$
113,672.00
EPA
review
1
$
54.65
260
$
14,209.00
Receive
and
process
retired
and
new
unit
exemptionsd
Permitting
Authority
action
2
$
109.30
132
$
7,213.80
EPA
review
0.3
$
16.40
20
$
1,082.40
TOTAL
2,892
$
158,041.20
a
2006
dollars.
b
Assumes
800
sources
submit
a
certificate
of
representation.
c
Assumes
260
sources
(
20%
of
all
affected
sources)
will
submit
Phase
II
permit
applications
each
year.
d
Assumes
33
retired
and
33
new
unit
exemptions
are
submitted
each
year.

6.4
Emissions
Monitoring
Recording
and
Reporting
This
section
estimates
the
paperwork
burden
and
cost
of
submitting
monitoring
plans,
obtaining
certification
of
each
monitoring
system,
conducting
monitor
quality
assurance
38
activities,
and
recording
and
reporting
data
from
CEM
systems
(
or
approved
alternatives),
and
other
ancillary
activities
(
such
as
responding
to
EPA
generated
error
messages,
or
responding
to
EPA
audits).

The
legislative
requirements
in
Title
IV
require
all
affected
Phase
I
and
Phase
II
sources
to
install
SO2
and
NOx
CEM
systems,
opacity
monitors
(
COMS),
and
flow
monitors
(
or
approved
alternatives).
Data
handling
or
reporting
is
required
by
the
law,
but
not
specified.
Under
the
promulgated
regulations,
however,
EPA
imposes
data
handling,
reporting,
and
recordkeeping
requirements.
The
EPA
requires
that
all
affected
units
required
to
install
CEM
systems
use
a
data
acquisition
and
handling
system
(
DAHS)
to
record
hourly
CEM
and
flow
monitor
data
in
the
EDR
format.
Affected
gas­
and
oil­
fired
units
may
elect
to
use
the
approved
alternative
SO2
monitoring
method
and
record
fuel
sulfur
analysis
data,
and
then
use
a
DAHS
to
record
and
report
hourly
fuel
flow
values
from
a
fuel
flow
meter
in
the
EDR
format.
In
addition,
peaking
units
that
burn
natural
gas
and/
or
fuel
oil
may
use
an
excepted
method
for
calculating
NOx
emission
rates.
Finally,
EPA
allows
certain
low
mass
emissions
(
LME)
units
to
use
assumed
emission
factors
together
with
operational
data
to
calculate
emissions.

Affected
sources
are
required
to
complete
and
submit
a
monitoring
plan
and
obtain
certification
of
each
monitor
(
on
standard
forms)
for
each
affected
unit
at
the
source.
These
plans
and
certifications,
which
are
only
submitted
once,
have
already
been
submitted
for
most
units.
Sources,
however,
may
need
to
submit
revised
plans
or
even
recertify
if
they
change
some
aspect
of
their
existing
plan.
New
units
will
still
need
to
submit
plans
and
certifications
for
the
first
time.
In
addition,
all
affected
units
are
required
to
submit
quarterly
reports
of
their
emissions
data
to
EPA;
these
reports
include
much
of
the
basic
monitoring
plan
data
as
well.

To
develop
this
renewal
ICR,
EPA
relied
primarily
on
the
extensive
efforts
to
identify
and
calculate
burdens
for
the
prior
two
ICR
renewals
and
the
CAIR
ICR.
In
1999,
EPA
promulgated
significant
revisions
to
Part
75
to
address
a
number
of
implementation
concerns
that
affected
sources
had
raised.
In
2002,
EPA
promulgated
less
significant
revisions
to
Part
75
that
addressed
a
number
of
procedural
and
technical
issues,
the
possibility
of
non­
load
based
units
using
Part
75
as
part
of
the
NOx
SIP
Call,
and
the
expanded
use
of
the
LME
provisions.

To
quantify
the
respondents'
burdens
and
costs,
EPA
has
analyzed
existing
data
reported
by
the
affected
sources
and
developed
model
unit
categories
to
classify
and
characterize
the
affected
population.

A
projection
of
the
number
of
new
units
that
will
come
on
line
in
2007
­
2009
was
also
made
and
included
in
the
unit
counts.
The
new
unit
estimates
were
based
on
the
four
year
average
of
new
units
coming
on
line
in
the
2002
 
2005
period
(
203
units/
year).
New
units
were
apportioned
to
the
different
monitoring
methodologies
based
on
the
four
year
average
of
new
units
coming
on
line
for
each
methodology.

The
result
of
this
analysis
characterizes
the
total
number
of
reporting
units
into
the
following
model
categories:

Model
A
(
units
with
SO2,
flow,
NOx,
and
CO2
CEMS):
1010
total
units.
39
Model
B
(
units
with
opacity
CEMS
solely
as
a
result
of
Title
IV):
500
total
units.

(
Note:
these
units
also
are
classified
under
other
models
for
SO2,
NOx,
and
CO2
requirements.)

Model
C
(
units
with
Appendix
D
monitoring
for
SO2
and
CEMS
for
NOx):
2111
total
units.

Model
D
(
units
using
both
Appendix
D
and
Appendix
E
for
SO2
and
NOx):
308
total
units.

Model
E
(
units
using
the
LME
methodology):
108
total
units
Model
F
(
units
with
moisture
monitors
necessary
for
moisture
correction):
100
total
units.
(
Note:
These
units
are
also
classified
under
other
models
for
SO2,
NOx,
and
CO2
requirements.)

To
estimate
the
burden
and/
or
cost
for
each
model,
EPA
has
relied
on
the
estimates
included
in
the
prior
ICR
renewal
for
labor
hour
estimates
of
each
activity.
In
addition,
the
hourly
labor
rates
for
managerial,
technical
and
clerical
staff
reflect
the
labor
rates
used
in
the
existing
ICR
but
are
updated
to
2006
dollars
using
the
Employment
Cost
Index,
consistent
with
Agency
ICR
guidance.

6.4.1
Estimating
Respondent
Burden
The
primary
tasks
performed
by
owners
and
operators
of
affected
units
are
(
1)
reviewing
the
regulations,
forms
and
instructions,
(
2)
responding
to
EPA
generated
error
messages
and
audits,
(
3)
reprogramming
a
DAHS
and
debugging
the
software,
(
4)
completing
and
submitting
monitoring
plans
for
each
unit
at
the
source,
(
5)
performing
appropriate
tests
and
providing
test
results
to
certify
each
monitor,
(
6)
performing
quality
assurance
testing
and
maintenance
upon
monitors,
(
7)
assuring
the
quality
of
emissions
data,
preparing
quarterly
reports
of
emissions
data,
and
submitting
reports
to
EPA;
and
(
8)
fuel
sampling.

(
i)
Regulatory
Review.

The
estimate
for
time
to
review
instructions
and
requirements
remains
consistent
with
the
labor
estimates
used
in
previous
ICRs
(
4
manager
hours
and
4
technician
hours)
where
no
substantial
changes
have
been
made
to
the
Rule.
EPA
continues
to
make
available
online
fully
searchable
versions
of
the
Part
75
Emissions
Monitoring
Policy
Manual
and
the
Electronic
Data
Reporting
Instructions
(
Versions
2.1
and
2.2),
and
is
in
the
process
of
adding
a
fully
searchable
unofficial
version
of
Part
75
to
this
integrated
search
Webpage.
In
addition,
EPA
in
2005
posted
online
a
text
version
of
its
Plain
English
Guide
to
Part
75.

(
ii)
Response
to
Error
Messages/
Audits.

The
EPA
provides
feedback
to
sources
so
that
suspected
errors
in
submissions
by
sources
are
noted
and
corrected.
With
the
use
of
the
MDC
software,
EPA
believes
that
the
burdens
for
this
activity
have
decreased
over
time.
At
the
same
time,
however,
EPA
has
increased
its
audit
oversight
and
expects
to
conduct
a
number
of
electronic
and
field
audits
of
facilities
over
the
next
few
years.
In
particular,
EPA
anticipates
making
significant
use
of
electronic
audits
as
a
means
to
provide
continuous
data
quality
improvement.
This
effort
will
result
in
increased
burdens
for
respondents.
In
addition,
if
EPA
conducts
a
field
audit,
the
burden
to
a
source
could
40
involve
from
24
to
36
hours.
However,
on
a
per
unit
basis,
these
field
audit
impacts
are
less
significant
because
not
every
unit
will
be
subject
to
an
audit
in
a
particular
year.
EPA
projects
no
more
than
10
audits
per
year.
If
the
average
burden
of
an
audit
is
30
hours
per
audit,
the
per
unit
burden
for
all
units
that
would
be
associated
with
EPA's
audit
activities
is
less
than
one
hour
of
burden
per
respondent.
Note
that,
because
this
activity
should
be
inapplicable
for
the
simplified
reporting
required
of
low
mass
emissions
units,
the
total
number
of
respondents
for
this
activity
excludes
the
LME
units.

(
iii)
DAHS
Upgrade
and
Debugging.

Each
source
must
purchase
(
or
create)
and
install
computer
software
designed
to
implement
the
electronic
data
reporting
(
EDR)
formats
required
under
the
Acid
Rain
Program.
EPA
anticipates
that
EPA
will
promulgate
revisions
to
Part
75
in
late
2006
to
accommodate
planned
changes
in
EPA's
data
systems
that
manage
the
data
submitted
by
respondents.
These
data
system
changes
are
necessary
to
modernize
EPA's
data
systems,
and
over
time
should
streamline
reporting.
The
costs
of
the
required
upgrade
are
being
analyzed
in
a
separate
ICR
that
will
be
issued
in
conjunction
with
the
Part
75
revisions.
At
this
time,
EPA
does
not
believe
that
there
is
adequate
information
to
expect
reduced
reporting
burdens
under
the
Acid
Rain
Program
as
a
result
of
those
rule
revisions,
although
EPA
anticipates
that
will
be
the
long
term
result.
Upon
the
next
renewal
of
this
ICR,
EPA
will
examine
this
issue
in
more
detail
as
the
impacts
of
the
rule
revisions
and
data
system
changes
on
the
reporting
burdens
will
be
better
understood
at
that
time.
For
the
time
period
of
this
ICR,
2007­
2009,
no
other
changes
would
require
a
DAHS
upgrade
and
therefore
the
burden
hours
for
this
activity
are
reduced
to
zero."

(
iv)
Monitoring
Plans.

Consistent
with
the
existing
ICR,
completing
and
submitting
monitoring
plans
is
estimated
to
require
an
average
of
about
20
hours
per
unit
initially.
For
existing
units,
initial
monitoring
plan
submissions
will
be
received
prior
to
the
time
period
covered
in
this
renewal
ICR,
and,
consistent
with
the
existing
ICR,
EPA
does
not
include
burden
hours
for
existing
units
under
this
initial
monitoring
plan
development
task
area
during
2007­
2009.
The
burden
associated
with
revising
the
monitoring
plan
is
included
in
the
time
for
preparing
and
submitting
each
quarterly
emissions
report.

For
new
units,
EPA
has
used
the
average
number
of
new
units
for
2002,
2003,
2004,
and
2005
as
a
projection
for
the
average
number
of
new
units
expected
in
2007­
2009.
These
units
have
a
separate
line
item
for
initial
monitoring
plan
preparation.

(
v)
Monitor
Certification.

Based
on
information
gathered
as
part
of
the
1999
rule
revisions,
EPA
included
assumptions
in
the
previous
ICR
renewal
to
include
labor
burdens
for
monitor
certification
activity
as
well
as
test
contractor
costs.
For
existing
units,
only
recertifications
are
included
in
the
estimated
activities
for
2007­
2009
The
Agency
estimates
a
labor
burden
of
50
hours
and
a
contractor
cost
of
$
3,400
per
respondent.
The
cost
and
burden
figures
exclude
the
costs
and
burdens
associated
with
conducting
a
RATA
as
part
of
the
recertification
process
because
those
41
costs
are
incorporated
within
the
annual
QA
costs
for
previously
certified
monitoring
systems.
For
new
units,
the
monitor
certification
costs
are
included
in
the
capital/
startup
costs.

(
vi)
Quality
Assurance.

Quality
assurance
(
QA)
testing
and
maintenance
upon
monitoring
systems
is
the
largest
burden
item
under
the
monitoring,
reporting
and
recordkeeping
requirements
for
the
Acid
Rain
Program.
The
requirements
include
daily,
quarterly
and
annual
QA
requirements,
depending
on
the
monitoring
approach
being
used.
For
reporting
units
that
use
a
full
set
of
CEMS
(
SO2,
flow,
NOx
and
CO2),
the
Agency
has
developed
a
per
unit
labor
burden
based
primarily
on
information
gathered
from
affected
sources.
For
units
that
also
are
required
to
install
and
maintain
a
continuous
opacity
monitoring
system
(
COMS)
as
a
result
of
Part
75,
additional
labor
burdens
apply.
For
units
that
rely
on
Appendix
D
excepted
methods
for
SO2
but
use
a
NOx
and
CO2
CEMS,
reduced
labor
burden
estimates
apply
because
the
quality
assurance
activities
for
the
excepted
methods
are
less
than
for
a
CEMS.
The
labor
burdens
for
these
excepted
methods
were
derived
primarily
from
cost
estimates
provided
by
a
group
of
affected
utilities
(
see
Docket
A­
97­
35,
Item
II­
D­
48).
For
units
that
rely
on
the
excepted
methods
under
both
Appendix
D
and
E
(
i.
e.,
units
without
CEMS),
the
burden
estimates
are
reduced
further
because
no
CEMS
QA
is
required.
For
the
relatively
small
number
of
units
that
require
moisture
correction,
labor
burdens
for
moisture
monitoring
QA
activities
have
been
added
based
on
information
supplied
by
an
affected
utility
(
see
Docket
A­
97­
35,
Item
II­
D­
94).
Finally,
for
units
that
use
the
LME
provisions,
no
QA
requirements
apply
except
for
units
that
use
the
unit­
specific
default
value
option.
Those
units
are
required
to
test
the
unit
to
determine
a
unit
specific
value.
That
cost
has
been
included
as
a
contractor
cost
for
all
new
LME
units.
Using
the
data
discussed
above,
EPA
estimates
that
the
average
respondent
(
using
a
weighted
average
for
the
units
that
fall
under
Models
A­
F)
will
require
approximately
450
labor
hours
to
meet
the
QA
requirements
of
Part
75.
Consistent
with
the
existing
ICR,
this
labor
is
expected
to
be
almost
entirely
technician
labor.

(
vii)
Quarterly
Reports.

Tasks
performed
by
utilities
in
preparing
quarterly
reports
include:
(
1)
assuring
the
quality
of
the
data,
(
2)
preparing
the
quarterly
report,
(
3)
revising
the
monitoring
plan,
if
necessary,
(
4)
preparation
of
hard
copy
documentation
accompanying
the
quarterly
reports,
and
(
5)
managerial
review.
EPA
has
been
improving
electronic
file
transfer
procedures
over
the
past
few
years
and
has
been
developing
automated
tools
that
allow
sources
to
quality
assure
their
reports.
EPA
believes
these
efforts
have
reduced
the
average
burdens
per
report
over
time.
In
addition,
because
the
program
is
maturing,
the
respondents
have
developed
procedures
and
methods
to
increase
their
efficiency
with
reporting.
The
1996
ICR
estimated
240
hours
per
unit
for
this
activity.
As
a
result
of
the
1999
Part
75
revisions,
this
estimate
was
decreased
to
204
hours,
but
that
estimate
was
not
based
on
consideration
of
potential
changes
in
burden
that
may
have
occurred
outside
the
scope
of
the
specific
reduced
reporting
requirements
in
the
1999
rule
revisions.
Based
on
consultations
with
a
few
utility
representatives
in
2002,
EPA
determined
that
this
burden
activity
area
significantly
overstated
the
average
burden
levels,
although
it
may
have
been
accurate
for
some
units.
The
contacts
provided
a
fairly
wide
range
of
estimates
for
this
activity,
however,
and
thus
EPA
conservatively
used
a
102
hour
per
unit
estimate
in
the
2002
ICR
renewal
(
a
50%
reduction
from
the
1999
ICR).
This
burden
estimate
is
being
used
this
42
renewal
as
well.
As
noted
above,
future
changes
to
EPA's
data
systems
may
enable
respondents
to
streamline
their
reporting
burdens,
and
EPA
anticipates
examining
that
issue
in
detail
as
part
of
the
next
renewal
of
this
ICR.
For
LME
units,
the
estimate
remains
at
16
hours
per
year
for
each
LME
unit.

6.4.2
Estimating
Respondent
Costs
Exhibit
7
summarizes
the
annual
respondent
costs.
The
following
discussion
describes
how
those
costs
were
derived.

(
i)
Estimating
Total
Capital
and
Annual
Operations
and
Maintenance
Costs
Capital/
start­
up
costs
include
the
cost
of
installing
required
CEMS
or
alternatives.
The
Agency
developed
the
capital
cost
estimates
for
the
CEM
and
other
equipment
based
on
EPA
CEM
cost
models,
existing
ICRs,
and
comments
from
various
affected
utilities.
The
cost
estimates
vary
depending
on
the
number
and
type
of
monitors
that
are
required.
Annualized
capital
cost
estimates
are
included
for
each
of
the
Models
A­
F
on
Exhibit
7.
These
annualized
capital
costs
are
from
the
Rule
to
Reduce
Interstate
Transport
of
Fine
Particulate
Matter
and
Ozone
(
Clean
Air
Interstate
Rule)
EPA
ICR
#
2152.02.
The
annualized
costs
ranged
from
$
28,879
for
units
with
a
full
set
of
CEMS
(
Model
A),
to
$
18,750
for
a
unit
that
uses
NOx
CEMS
and
Appendix
D
methods
(
Model
C),
to
$
2,250
for
units
that
use
both
Appendix
D
and
Appendix
E
methods
without
any
CEMS
(
Model
D).
There
are
no
capital/
start­
up
costs
for
LME
units.
A
discussion
of
how
the
capital/
start­
up
costs
were
annualized
follows
in
Section
1.2(
iii).

In
addition
to
capital/
start­
up
costs,
respondents
incur
operation
and
maintenance
costs
(
exclusive
of
labor
costs)
that
reflect
ongoing
costs
to
a
unit.
These
costs
include
both
contractor
costs
for
the
required
recertification,
diagnostic,
and
quality
assurance
(
QA)
testing,
and
other
direct
maintenance­
related
expenses
(
e.
g.,
spare
parts
and
calibration
gases).
The
cost
estimates
used
in
this
renewal
ICR
are
generally
the
same
as
the
Rule
to
Reduce
Interstate
Transport
of
Fine
Particulate
Matter
and
Ozone
(
Clean
Air
Interstate
Rule)
EPA
ICR
#
2152.02,
and
have
been
derived
from
EPA
CEM
cost
models,
existing
ICRs,
Agency
staff
experience
under
the
Acid
Rain
Program,
information
gathered
during
development
of
the
1999
and
2002
Part
75
revisions,
and
supplemental
estimates
provided
by
affected
utilities
and
others
related
to
the
various
cost
items
(
see,
e.
g.,
EPA
Air
Docket
A­
97­
35,
Item
II­
D­
48).
The
total
cost
for
these
operation
and
maintenance
cost
items
(
other
than
fuel
sampling)
is
estimated
at
$
31,200
for
a
unit
with
a
full
set
of
CEMS,
while
units
that
use
alternate
methodologies
have
reduced
costs.

Note
that
testing
contractor
costs
for
certification,
recertification
and
annual
RATAs
also
are
presented
as
other
direct
costs
and
are
not
converted
to
equivalent
source
labor
hours.
This
approach
is
consistent
with
the
common
business
practice
for
obtaining
outside
contractors
to
conduct
certification/
recertification
tests
and
annual
relative
accuracy
test
audits.
For
initial
certification,
the
certification
test
costs
are
commonly
bundled
with
equipment
purchase
contracts,
according
to
information
provided
by
a
range
of
CEMS
equipment
vendors.
For
RATAs
that
are
conducted
either
as
part
of
the
annual
quality
assurance
requirements
or
as
part
of
recertification,
industry
contacts
have
indicated
that
RATA
testing
is
usually
performed
under
a
fixed
price
contract
basis,
except
for
travel
costs
that
may
be
billed
on
an
hourly
basis
beyond
the
basic
contract
cost.
For
annual
RATAs,
the
sources
indicated
that
an
annual
contract
between
43
a
testing
company
and
utility
is
often
used.
One
municipal
utility
representative
indicated
that
the
applicable
municipal
regulations
required
that
outside
contracts
be
on
a
flat
fee,
not
hourly,
basis.

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

(
iii)
Annualizing
Capital
Costs
The
relevant
capital
costs
for
the
emissions
trading
portion
of
this
ICR
were
annualized
at
a
rate
of
7%
(
i.
e.,
the
annualized
capital
cost
was
calculated
assuming
money
to
purchase
the
capital
equipment
was
borrowed
at
a
7%
annual
interest
rate).
The
cost
of
the
loan
was
amortized
over
the
life
of
the
loan
to
repay
original
borrowed
amount
plus
interest.
The
result
is
the
annualized
capital
cost
reported.)
The
annualized
cost
of
the
necessary
capital
purchases
varies
from
$
2,250
to
$
28,879,
per
year,
per
unit,
depending
on
the
type
of
monitoring
methodology.
Exhibit
1
contains
a
breakdown
of
annual
costs
by
monitoring
methodology.
The
capital
costs
are
from
the
Rule
to
Reduce
Interstate
Transport
of
Fine
Particulate
Matter
and
Ozone
(
Clean
Air
Interstate
Rule)
EPA
ICR
#
2152.02.

(
iv)
Fuel
Sampling
To
calculate
heat
input
where
the
source
is
using
the
fuel
flowmeter
option
for
an
oil
or
gas­
fired
unit,
the
source
must
obtain
gross
calorific
value
data
from
sampling
in
accordance
with
Appendix
D
of
Part
75.
For
purposes
of
this
ICR,
it
is
assumed
that
the
GCV
data
would
be
collected
as
part
of
standard
business
operating
procedures
to
assure
compliance
with
contractual
specifications.
Thus
no
additional
fuel
sampling
burdens
or
costs
should
be
incurred.
This
is
consistent
with
the
Rule
to
Reduce
Interstate
Transport
of
Fine
Particulate
Matter
and
Ozone
(
Clean
Air
Interstate
Rule)
EPA
ICR
#
2152.02.

6.4.3
Estimating
Agency
Burden
and
Cost
The
tasks
that
will
be
performed
by
EPA
include
processing,
reviewing,
and
evaluating
emissions
data
reports
submitted
by
utilities,
and
conducting
appropriate
audit
activities
to
verify
the
information
provided.
The
estimated
Agency
burdens
remain
the
same
as
the
2002
ICR
on
a
per
report
basis
(
two
hours).
Even
though
EPA
intends
to
increase
its
audit
oversight
efforts,
there
is
no
increased
per
report
burden
because
of
offsetting
burden
reductions
from
increasing
familiarity
with
the
program
and
improved
automated
tools.
Assuming
that
affected
sources
will
submit
3,537
emissions
reports
to
EPA
per
quarter,
the
total
annual
burden
incurred
by
the
Agency
will
be
14,148
hours.
The
total
annual
cost
to
EPA
for
processing,
reviewing,
and
evaluating
these
quarterly
emissions
reports
will
be
approximately
$
1,546,376.
Exhibit
8
summarizes
the
Agency
burden
and
costs
associated
with
emissions
reporting.

6.4.4
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
EPA
estimates
that:
(
a)
1,244
sources
will
review
instructions
and
requirements;
(
b)
1139
sources
(
this
number
excludes
sources
with
only
low
mass
emissions
units
and
new
units)
will
44
reprogram
and
debug
DAHS
computer
software;
(
c)
3,537
units
will
submit
quarterly
reports;
and
(
d)
3,429
units
will
respond
to
EPA
generated
error
messages
(
of
which
about
10
units
will
also
respond
to
EPA
audit
activities),
and
perform
QA
testing
and
maintenance
(
units
using
the
LME
methodology
are
excluded
from
these
activities).
In
addition,
EPA
estimates
that
approximately
294
units
will
recertify
per
year.
Exhibit
7
shows
the
total
burden
and
total
cost
based
on
this
respondent
universe.
45
46
EXHIBIT
7
ANNUAL
RESPONDENT
BURDEN/
COST
ESTIMATES
FOR
EMISSIONS
MONITORING
INFORMATION
COLLECTION
ACTIVITY
Mgr.

$
84.43/

Hour
Tech.

$
58.00/

Hour
Respondent
Hrs./
Year
Labor
Cost/
Year
Cont./
O&
M
Cost
Capital/

Startup
Cost
No.
of
Respondents
Total
Hours/
Year
Total
Cost/
Year
1.
Review
Instructions
and
Requirements
4
4
8
$
570
$
0
$
0
1244
9,952
$
709,080
2.
Respond
to
EPA
Generated
Error
Messages,
Field
Audits
6
18
24
$
1,551
$
0
$
0
3429
82,296
$
5,318,379
3a.
DAHS
Upgrade
0
0
0
$
0
$
0
$
0
0
0
$
0
3b.
DAHS
Debugging
4
12
16
$
1,034
$
0
$
0
1139
18,224
$
1,177,726
4.
New
Unit
Monitoring
Plans
10
10
20
$
1,424
$
0
$
0
203
4,060
$
289,072
5.
Recertify
Monitors
38
12
50
$
3,904
$
3,400
$
0
294
14,700
$
2,147,376
6.
Startup/
Capital
Items
and
Perform
QA
Testing
and
Maintenance
(
a)
Model
A
(
CEMS)
50
480
530
$
32,062
$
31,200
$
28,879
1010
535,300
$
93,062,410
(
b)
Model
B
(
COMS)
0
171
171
$
9,918
$
288
$
3,560
500
85,500
$
6,883,000
(
c)
Model
C
(
App
D­
Nox
CEM)
20
375
395
$
23,439
$
17,400
$
18,750
2111
833,845
$
125,792,379
(
d)
Model
D
(
App
D
and
E)
5
30
35
$
2,162
$
1,800
$
2,250
308
10,780
$
1,913,296
(
e)
Model
E
(
LME)
0
0
0
$
0
$
1,944
$
0
108
0
$
209,952
(
f)
Model
F
(
H2O)
0
40
40
$
2,320
$
8,000
$
854
100
4,000
$
1,117,400
7a.
Assure
Data
Quality,
Prepare
Reports
(
inc.
monitor
plan
update),
Submit
Reports
20
82
102
$
6,445
$
0
$
0
3429
349,758
$
22,099,905
7b.
LME
Reporting
4
12
16
$
1,034
0
0
108
1,728
$
111,672
8.
Annual
Fuel
Sampling
0
0
0
$
0
$
0
$
0
0
0
$
0
TOTAL:
1,950,143
$
260,831,647
47
48
EXHIBIT
8
ANNUAL
AGENCY
BURDEN/
COST
ESTIMATES
FOR
EMISSIONS
REPORTING
Tasks
Quarterly
Burden
Hours
Per
Report
Quarterly
Cost
Per
Reporta,
b
Number
of
Reportsc
Total
Burden
Per
Year
(
hours)
(
2007­
2009)
Total
Cost
Process,
review,
and
evaluate
quarterly
report
and
issue
feedback
letter
2
$
54.65
14,148
28,296
$
1,546,376
a
Based
on
an
average
total
compensation
rate
of
$
54.65
per
hour
b
Updated
from
2002
dollars
using
the
same
factor
(
1.15)
as
used
to
update
the
Respondent
labor
cost.

c
Assumes
3,537
emission
data
reports
each
quarter.

6.5
Auctions
This
part
presents
estimates
of
the
burden
and
costs
to
participants
and
the
Federal
government
associated
with
the
auction
program.

Auctions
are
held
only
once
a
year.
No
restrictions
are
placed
on
the
number
of
allowances
for
which
a
participant
may
bid.
Multiple
bids
from
a
given
participant
are
permitted,
but
each
bid
is
treated
individually
and
requires
a
separate
bid
form.
Based
on
the
average
number
of
bids
in
the
past
two
auctions,
EPA
estimates
that
111
bids
will
be
received
each
year.

6.5.1
Estimate
of
Respondent
Burden
and
Costs
Exhibit
9
depicts
the
burden
and
costs
to
auction
participants.
Auction
participants
must
complete
and
submit
the
bid
form
along
with
a
certified
check,
letter
of
credit,
or
wire
transfer.
EPA
estimates
that
the
auction
bid
form
takes
approximately
30
minutes
to
prepare,
and
obtaining
a
means
of
payment
takes
approximately
one
hour.
This
estimate
includes
time
allocated
to
research
the
required
information,
fill
out
the
form,
arrange
for
a
certified
check,
letter
of
credit,
wire
transfer,
and
send
the
material
to
EPA.
The
burden
and
cost
to
auction
participants
is
estimated
to
be
166.5
hours
and
$
13,177
per
year
respectively.
49
EXHIBIT
9
ANNUAL
RESPONDENT
BURDEN/
COST
ESTIMATES
FOR
AUCTIONS
Collection
Activities
Burden
Hours
Per
Bid
Cost
Per
Bida
Burden
Hours
Per
Year
Cost
Per
Year
1.
Completing
bid
formsb
0.5
$
39.57
55.5
$
4,392.27
2.
Obtaining
means
of
paymentb
1
$
79.14
111
$
8,784.54
TOTAL:
1.5
$
118.71
166.5
$
13,176.81
a
Based
on
an
average
rate
of
$
79.14
per
hour
(
For
costing
purposes,
it
is
assumed
that
80
percent
of
the
total
hours
will
be
Managerial
($
84.43/
hr.)
and
20
percent
will
be
Technical
($
58.00/
hr.).
These
estimates
are
based
on
2006
dollars.
b
The
111
bids
represents
an
average
number
of
bids
over
the
past
four
EPA
auctions.

6.5.2
Estimate
of
Agency
Burden
and
Costs
Exhibit
10
depicts
the
burden
and
cost
to
EPA
for
the
auction
program.
Based
on
past
experience,
the
burden
and
cost
to
the
Agency
will
be
about
the
same
each
year.
Setting
up
and
revising
allowance
tracking
system
(
ATS)
accounts
for
auction
participants
is
estimated
to
take
10
hours,
the
handling
of
bids
and
checks
is
estimated
to
take
20
hours,
tabulation,
checking,
and
announcing
the
auction
results
is
estimated
to
take
15
hours,
and
transferring
allowances
and
proceeds
is
expected
to
require
40
hours
per
year.
As
Exhibit
10
shows,
the
total
burden
to
EPA
for
auction
activities
is
85
hours
at
a
cost
of
$
4,645.

EXHIBIT
10
ANNUAL
AGENCY
BURDEN/
COST
ESTIMATES
FOR
AUCTIONS
Collection
Activities
Burden
Hours
Per
Year
Cost
Per
Yeara
1.
Setup
ATS
accounts
10
$
546.50
2.
Handle
bids
and
checks
20
$
1,093.00
3.
Tabulate,
check,
and
announce
results
15
$
819.75
4.
Transfer
of
allowances
and
proceeds
40
$
2,186.00
TOTAL:
85
$
4,645.25
a
2006
dollars.

6.6
The
Opt­
in
Program
This
subsection
describes
projections
for
(
1)
the
number
and
types
of
sources
that
elect
to
participate
in
the
opt­
in
program
for
the
time
period
covered
by
this
ICR,
(
2)
the
paperwork
burden
hours
for
both
respondents
and
EPA
associated
with
the
program,
and
(
3)
the
total
costs
of
the
tasks
required
by
the
opt­
in
program.
50
Over
the
three
years
covered
by
this
ICR,
EPA
estimates
that
no
sources
will
opt
in
to
the
program.
This
figure
is
based
on
the
number
of
opt­
in
applications
EPA
has
received
over
the
past
three
years.

6.6.1
Respondent
Burden/
Cost
Estimates
for
The
Opt­
in
Program
The
tasks
under
this
program
are
divided
into
the
major
categories
of
reporting
­­
permitting,
emissions
monitoring,
and
annual
compliance
certification.
This
section
includes
only
the
burden
for
these
task
categories
for
opt­
in
sources.
Those
affected
sources
covered
by
the
mandatory
requirements
of
the
Acid
Rain
Program
are
covered
in
previous
sections.

A.
Opt­
in
Permit
Applications
EPA
estimates
that
no
sources
will
submit
a
permit
application
in
the
years
covered
by
this
ICR.
However,
if
a
source
would
chose
to
submit
an
application,
the
source
must
select
a
designated
representative,
report
operating
and
fuel
consumption
data
from
past
years,
and
report
the
actual
and
allowable
emissions
rates
for
1985
as
well
as
the
current
allowable
emission
rate.
Since
we
expect
no
applications,
there
is
no
burden
or
cost
for
this
activity.

B.
Emissions
Data
Reporting
Emissions
reporting
is
performed
only
by
operating
sources.
The
tasks
for
opt­
in
sources
are
identical
to
other
affected
sources
and
are
listed
in
Exhibit
7.
The
burden
and
costs
for
emissions
reporting
from
opt­
in
sources
are
included
in
the
total
in
Exhibit
7.

C.
Annual
Reconciliation
Annual
reconciliation
is
performed
by
all
opt­
in
sources.
Each
unit
at
an
opt­
in
source
is
required
to
submit
an
opt­
in
utilization
form.
Additionally,
if
the
source
is
covered
by
a
thermal
energy
compliance
plan,
it
must
submit
a
thermal
energy
compliance
report.
If
an
opt­
in
source
has
reduced
utilization
due
to
energy
conservation
or
improved
unit
efficiency
measures,
it
has
the
option
of
submitting
an
energy
confirmation
and
improved
unit
efficiency
confirmation
report
to
verify
the
savings
and
offset
the
corresponding
reduced
utilization.
To
date
none
of
the
opt­
in
sources
have
verified
energy
conservation
or
improved
unit
efficiency
measures,
so
EPA
is
assuming
no
sources
will
do
so
during
the
three
years
covered
by
this
ICR.
Finally,
EPA
assumes
that
half
of
the
opt­
in
units
will
submit
an
optional
allowance
deduction
form,
which
specifies
the
serial
numbered
allowances
for
deduction.

Total
respondent
burden
and
costs
for
annual
compliance
certification
by
opt­
in
sources
are
an
estimated
280
hours
and
$
17,970,
respectively.
Exhibit
12
presents
respondent
burden
and
costs
for
annual
reconciliation
by
opt­
in
sources.
51
6.6.2.
Agency
Burden/
Cost
Estimates
for
the
Opt­
in
Program
In
2007­
2009,
the
Agency's
burden
includes;
processing
opt­
in
applications,
processing
quarterly
emissions
reports
(
which
is
included
in
Exhibit
8),
and
processing
annual
reconciliation
reports.
The
Agency's
total
annual
estimated
burden
and
cost
related
to
the
opt­
in
program
are
24
hours
and
$
1,312,
respectively.
Exhibit
13
presents
the
Agency's
burden
and
costs
for
opt­
in
program.
52
EXHIBIT
11
RESPONDENT
BURDEN/
COST
ESTIMATES
FOR
OPT­
IN
PERMIT
APPLICATIONS
Tasks
Burden
Hours
per
Occurrence
Cost
per
Occurrencea
Total
Burden
(
hours)
Total
Cost
Select
a
designated
representativeb
Managerial
Technical
Prepare
opt­
in
permit
applicationb
Managerial
Technical
Prepare
thermal
energy
compliance
planc
Managerial
Technical
Complete
withdrawal
notificationd
Managerial
Technical
20
7
20
85
15
55
2
3
$
1,688.60
$
406.00
$
1,688.60
$
4,930.00
$
1,266.45
$
3,190.00
$
168.86
$
174.00
0
0
0
0
0
0
0
0
$
0
$
0
$
0
$
0
0
0
0
0
TOTAL
0
$
0
a
2006
dollars.
b
Assumes
no
opt­
in
sources
submit
applications.
c
Assumes
no
sources
file
a
thermal
energy
compliance
plan.
d
Assumes
that
sources
that
have
made
the
investment
to
opt­
in
will
not
withdraw.
53
EXHIBIT
12
ANNUAL
RESPONDENT
BURDEN/
COST
ESTIMATES
FOR
OPT­
IN
ANNUAL
COMPLIANCE
CERTIFICATION
Tasks
Burden
Hours
Per
Occurrence
Cost
Per
Occurrencea
Total
Burden
(
Hours)
Total
Cost
Opt­
in
Utilization
formb
Managerial
Technical
2
16
$
186.86
$
928.00
16
128
$
1,494.88
$
7,424.00
Thermal
energy
compliance
report
(
shutdown
opt­
in
sources
and
replacement
units)
c
Managerial
Technical
10
21
$
844.30
$
1,218.00
40
84
$
3,377.20
$
4,872.00
Allowance
deduction
form
(
optional)
d
Managerial
Technical
Energy
conservation/
Improved
unit
efficiency
confirmation
reporte
Managerial
Technical
Excess
emissions
penalty
paymente
Managerial
Technical
1
2
5
25
4
5
$
84.43
$
116.00
$
422.15
$
1450.00
$
337.72
$
290.00
4
8
0
0
0
0
$
337.72
$
464.00
0
0
0
0
TOTAL
280
$
17,969.80
a
2006
dollars.
b
Assumes
3
opt­
in
sources
and
8
opt­
in
units.
c
Assumes
4
sources
file
reports.
d
Assumes
4
opt­
in
units
submit
allowance
deduction
forms.
e
EPA
assumes
no
sources
will
claim
savings
from
energy
conservation
or
improved
unit
efficiency
or
have
excess
emissions.
54
EXHIBIT
13
ANNUAL
AGENCY
BURDEN/
COSTS
FOR
THE
OPT­
IN
PROGRAM
Task
Burden
Hours
per
Occurrence
Cost
per
Occurrencea
Total
Burden
Hours
Total
Costs
Review
certificates
of
representation
and
record
informationb
1
$
54.65
0
$
0
Review
permit
application,
issue
proposed
and
final
permit,
and
assign
allowancesb
80
$
4,372.00
0
$
0
Review
and
process
annual
reconciliation
submissionsc
2
$
109.30
16
$
874.40
Deduct
allowances
and
send
reconciliation
reportsc
1
$
54.65
8
$
437.20
Total
24
$
1,311.60
a
2006
dollars.
b
Assumes
no
opt­
in
sources
submit
a
permit
application.
c
Assumes
3
opt­
in
sources
and
8
opt­
in
units
each
year.

6.7
NOX
Permitting
This
section
estimates
the
paperwork
burden
and
cost
of
renewing
and
revising
Phase
II
NOX
compliance
plans.

6.7.1
Estimate
of
Respondent
Burden
and
Costs
Exhibit
14
presents
the
burden
and
costs
to
applicants
for
preparing
and
submitting
NOX
Compliance
Plan
renewal
applications
and
revising
NOX
compliance
plans.
Permits,
including
NOX
Compliance
Plans
for
units
affected
for
NOX,
must
be
renewed
every
five
years.
Therefore,
EPA
assumes
20%
of
all
units
affected
for
NOX
(
i.
e.,
200
units)
will
submit
NOX
Compliance
Plan
renewal
applications
each
year.
Based
on
the
past
two
years
of
the
program,
EPA
expects
to
receive
27
NOX
compliance
plan
revisions
each
year.

For
each
compliance
plan
renewal,
EPA
estimates
that
the
applicant
will
require
about
5
hours,
while
compliance
plan
revisions
will
require
about
10
hours.
The
total
respondent
burden
for
NOX
permitting,
as
shown
in
Exhibit
14,
is
estimated
to
be
1,270
hours
each
year.
The
costs
associated
with
NOX
permitting
are
estimated
at
$
87,800
per
year.
55
EXHIBIT
14
RESPONDENT
BURDEN/
COST
ESTIMATES
FOR
NOX
PERMITTING
Tasks
Burden
Hours
per
Occurrence
Cost
per
Occurrencea
Total
Burden
Hours
Total
Cost
Prepare
NOX
Compliance
Plan
renewal
applicationsb
Managerial
Technical
2
3
$
168.86
$
174.00
400
600
$
33,772.00
$
34,800.00
Revise
NOX
Compliance
Plan
(
e.
g.,
emissions
averaging
plans)
c
Managerial
Technical
5
5
$
422.15
$
290.00
135
135
$
11,398.05
$
7,830.00
Total
1,270
$
87,800.05
a
2006
dollars.
b
Assumes
200
units
(
20%
of
all
NOX
affected
units)
submit
NOX
compliance
plan
renewals
each
year.
c
Assumes
27
respondents
revise
emissions
averaging
plans
each
year.

6.7.2.
Estimate
of
Agency/
Permitting
Authority
Burden
and
Costs
for
NOX
Exhibit
15
presents
the
paperwork
burden
and
costs
to
EPA
for
NOX
permitting.
The
total
annual
burden
and
cost
for
renewing
and
revising
NOX
compliance
plans
is
estimated
at
127
hours
and
$
6,942,
respectively.

The
tasks
involved
in
reviewing
applications
will
include
reviewing
forms
for
completeness
and
entering
the
revised
data
from
the
plans
into
a
NOX
compliance
database.
56
EXHIBIT
15
AGENCY
BURDEN/
COST
ESTIMATES
FOR
NOX
PERMITTING
Tasks
Burden
Hours
Per
Occurrence
Cost
Per
Occurrencea
Total
Burden
Hours
Total
Cost
Renew
NOX
compliance
plansb
0.5
$
27.33
100
$
5,466.00
Revise
NOX
compliance
plansc
1
$
54.65
27
$
1,475.55
Total
127
$
6,941.55
a
2006
dollars.
b
Assumes
200
units
(
20%
of
all
NOX
affected
units)
submit
NOX
compliance
plan
renewals
each
year.
c
Assumes
27
respondents
revise
emissions
averaging
plans
each
year.

6.8
Summary
of
Burden
Hours
and
Costs
Exhibit
16
summarizes
the
annual
aggregate
burden
and
cost
estimates
to
respondents
for
the
period
of
July
1,
2006
through
June
30,
2009
for
collections
associated
with
allowance
transfers,
energy
conservation
and
renewable
energy
allowances,
permits,
emissions
reporting,
auctions,
the
opt­
in
program,
and
NOX
permitting.
Exhibit
17
summarizes
the
aggregate
burden
and
cost
estimates
to
EPA
and
permitting
authorities
for
these
collections.

6.9
Reasons
for
Change
in
Burden
This
ICR
renewal
reflects
a
few
differences
from
the
previous
ICR.
This
section
discusses
the
changes
in
burden
since
the
last
clearance.

Overall,
the
estimated
annual
burden
in
2003
from
the
last
clearance
was
1,600,807
hours.
This
ICR
estimates
the
annual
burden
in
2007
will
be
1,971,276
hours,
which
increases
the
burden
by
370,469
hours.
The
reasons
for
this
burden
increase
are
explained
below.

Most
of
the
change
in
burden
for
this
collection
is
due
to
adjustments.
Adjustments
stem
from
actions
outside
the
Agency's
control.
It
includes
changes
to
the
number
of
responses
and
the
time
it
takes
to
respond
to
a
particular
activity.
The
adjustments
and
corresponding
change
in
burden
are
as
follows.

°
The
annual
number
of
allowance
transfer
submissions
decreased
from
4,800
to
1,700.
This
changed
the
annual
burden
hours
for
allowance
transfer
activities
from
10,640
to
5,885.
57
°
The
annual
number
of
conservation
and
renewable
energy
reserve
applications
dropped
from
7
to
0,
while
the
number
of
applicants
using
EPA's
conservation
verification
protocol
decreased
from
1
to
0.
These
changes
decreased
the
net
burden
from
418
to
0
hours.

°
Permitting
activities
were
estimated
to
require
15,410
burden
hours
in
2003.
The
estimated
annual
burden
hours
for
permitting
under
this
ICR
are
13,531.
This
burden
change
reflects
a
decrease
in
the
number
of
units
submitting
new
and
retired
unit
exemptions.

°
Adjustments
increased
the
annual
average
burden
for
monitoring
and
reporting
activities
from
1,564,000
hours
in
the
previous
ICR
to
approximately
1,950,000
hours.
This
reflects
an
increase
in
the
respondent
universe
because
of
the
number
of
new
units
that
came
on­
line
in
the
last
four
years.

°
The
estimated
number
of
sources
applying
to
opt­
in
to
the
Acid
Rain
Program
was
reduced
from
1
to
0.
This
results
in
the
estimated
burden
dropping
from
388
hours
in
2003
to
0
in
the
current
collection.

°
The
burden
for
NOX
permitting
increased
from
1,060
hours
to
1,270
hours.
This
burden
change
reflects
an
increase
in
the
number
of
NOX
compliance
plan
revisions
submitted
each
year,
from
6
to
27.

While
most
of
the
change
in
burden
is
due
to
adjustments,
there
is
a
smaller
burden
reduction
due
to
program
changes.

°
The
burden
for
reporting
annual
compliance
certification
information
decreased
from
8,575
hours
to
0
due
to
the
elimination
of
the
annual
compliance
certification
reports
and
the
change
from
unit
level
to
facility
or
plant
level
compliance.

6.10
Burden
Statement
The
respondent
reporting
burden
for
this
collection
of
information
is
estimated
to
be
1,971,276
hours
each
year
for
the
years
2007
through
2009.
The
burden
to
EPA
is
estimated
to
be
31,974
hours
in
2003
each
year
for
the
years
2007
through
2009.
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
110
hours
per
response.
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.
58
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
0509,
which
is
available
for
online
viewing
at
www.
regulations.
gov,
or
in
person
viewing
at
the
Air
and
Radiation
docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
NW,
Washington,
D.
C.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Air
and
Radiation
docket
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
0509
and
OMB
Control
Number
2060­
0258
any
correspondence.
59
EXHIBIT
16
AGGREGATE
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
COLLECTIONS
(
2007­
2009)

Program
Total
Burden
(
Hours)
Total
Costsa
Allowance
transfers
and
deductions
5,885
$
407,669.30
Energy
conservation
and
renewable
energy
allowances
0
$
0
Permits
13,531
$
1,011,726.00
Emissions
reporting
1,950,143
$
260,831,647
Auctions
166.5
$
13,176.81
Opt­
inb
280
$
17,969.80
NOx
permitting
1,270
$
87,800.05
TOTAL
1,971,275.5
$
262,369,988.96
a
2006
dollars.

b
Includes
permitting
and
annual
reconciliation
burdens
for
opt­
in
sources.
60
EXHIBIT
17
AGGREGATE
ANNUAL
AGENCY
BURDEN
AND
COST
OF
COLLECTIONS
Program
Total
Burden
(
Hours)
Total
Costsa
Allowance
transfers
and
deductions
550
$
30,058.00
Energy
conservation
and
renewable
energy
allowances
0
$
0
Permits
Permitting
Authority
EPA
2,212
680
$
120,885
$
37,156
Emissions
reporting
Auctions
Opt­
in
NOx
permitting
Operation
&
Maintenance
of
data
systemsb
28,296
85
24
127
NA
$
1,546,376
$
4,645.25
$
1,311.60
$
6,941.55
$
1,500,000
TOTAL
31,974
$
3,247,373.40
a
2006
dollars.

b
Average
annual
operation
and
maintenance
costs
associated
with
running
electronic
data
systems
are
assumed
to
be
incurred
by
an
EPA
contractor.
Therefore,
EPA
will
not
incur
any
labor
burden
for
these
activities.
61
62
Appendix
A:
Acid
Rain
Program
Forms
and
Instructions
