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Supporting Statement

Ambient Oxides of Nitrogen Monitoring Regulations: 

Revisions to Network Design Requirements

EPA ICR # 2358.02

PART A

1.  Identification of the Information Collection

     	   	 (a) Title of the Information Collection

Ambient Oxides of Nitrogen Monitoring Regulations:  Revisions to Network
Design Requirements, EPA ICR Number 2358.02, OMB Control Number 2060-NEW

 	 (b)  Short Characterization/Abstract

	This Information Collection Request (ICR) includes ambient air
monitoring data reporting and recordkeeping activities associated with
the 40 CFR part 58 Ambient Air Quality Surveillance regulations.  These
data and information are collected by State, local, and Tribal air
quality management agencies and reported to the U.S. Environmental
Protection Agency (EPA).  

	The EPA is revising the network design requirements for the oxides of
nitrogen (NOX), specifically nitrogen dioxide (NO2), to support the
proposed changes to the primary National Ambient Air Quality Standards
(NAAQS) for NO2.  Presently, States (including the District of Columbia,
Puerto Rico, and the Virgin Islands) and local agencies when delegated
by the State are required to operate minimum numbers of EPA-approved NO2
monitors based on the population of each of their Core Based Statistical
Areas (CBSA) and the traffic related metrics including Annual Average
Daily Traffic (AADT) of all the road segments in their CBSAs.  

EPA is proposing a two-tiered monitoring network design. The two tiers
are designed to: 1) monitor in areas of expected maximum 1-hour
concentrations; and 2) monitor to characterize areas with the highest
expected NO2 concentrations at the neighborhood and larger spatial
scales, or “area-wide” scales.  The proposed network design
corresponds to the revised NAAQS based on peak 1-hour daily maximum
concentrations, or 1-hour NAAQS, with a level of 100 parts per billion
(ppb), and the retention of the current annual averaged NAAQS which has
a level of 53 ppb. The introduction of the 1-hour NAAQS is intended to
protect against peak, shorter term exposure risks. These exposure risks
have been found to be of particular interest in the on-road and
near-road environments due to on-road mobile source emissions, which led
to the proposed minimum monitoring requirements to include near-road
monitors to be included in the first tier of the network design.  

In the first tier of the NO2 network design, EPA is finalizing minimum
NO2 monitoring requirements which call for monitors near major roads,
“near-road NO2 monitors,” in certain CBSAs to address on-road mobile
source emission derived exposures. Specifically, the minimum monitoring
requirements are for one near-road NO2 monitor to be placed in CBSAs of
populations greater than or equal to 500,000 persons.  A second
near-road NO2 monitor is required in CBSAs of populations greater than
or equal to 2,500,000 persons, or any CBSA with one or more roadway
segments that have 250,000 or greater AADT volumes

The first tier of the proposed NO2 network design is anticipated to
require 126 near road monitoring sites, which largely do not exist in
the current monitoring network. Therefore, we recognize that there will
likely be a need for capital funding to allow most, if not all, of the
required near-road monitoring sites to be established. The establishment
costs of monitoring sites can include property access or leasing fees,
power and telecom services, site security, a climate controlled
monitoring shelter, pollutant analyzers, supporting quality assurance
hardware and consumables, and data collection and dissemination hardware
and software.

In the second tier of the monitoring network design, we are requiring a
minimum number of monitors to characterize an area or areas within CBSAs
with highest expected NO2 concentrations at the neighborhood and larger
(area-wide) spatial scales. Specifically, we are proposing to require
one area-wide monitoring site in each CBSA with a population greater
than or equal to 1,000,000, which shall be sited to represent an area of
maximum concentration at the neighborhood or larger spatial scales. This
minimum monitoring requirement is expected to trigger 52 monitoring
sites in as many CBSAs. Many of these monitors are likely already in
place as part of the approximately 400 NO2 monitoring sites that are
currently operating across the country that serve multiple monitoring
objective aside from NAAQS comparisons, including ambient photochemical
pollutant assessment, aiding in ozone forecasting, aiding in PM
precursor analysis and PM forecasting, and to characterize point and
area sources that may be impacting certain communities. Further, the EPA
is allowing any current photochemical assessment monitoring station
(PAMS) sites that are situated to address the highest NO2 concentrations
in an urban area at neighborhood or urban scales to satisfy this
proposed area-wide monitoring requirement. Therefore, this tier of the
proposed network design is not anticipated to increase the number of
monitoring sites above what is already operating in the current network.

In addition, EPA has also recognized that susceptible and vulnerable
populations, which include asthmatics and disproportionately exposed
groups (as discussed in sections II.B.4 and II.F.4.d of the preamble to
the final rule) are at particular risk of NO2-related health effects. 
The Administrator is therefore requiring the Regional Administrators,
working in collaboration with states, to site 40 monitors in appropriate
locations, focusing primarily on protecting susceptible and vulnerable
communities.  Further, Regional Administrators may  also use  their 
discretionary authority to require monitoring above the minimum
requirements as necessary to address situations inside or outside of
CBSAs in which (1) the required near-road monitors do not represent all
locations of expected maximum hourly NO2 concentrations in an area and
NO2 concentrations may be approaching or exceeding the NAAQS in that
area; (2) areas that are not required to have a monitor in accordance
with the monitoring requirements and NO2 concentrations may be
approaching or exceeding the NAAQS; or (3) the minimum monitoring
requirements for area-wide monitors are not sufficient to meet
monitoring objectives.

The total number of monitors being minimally required in this rulemaking
is estimated to be 218. EPA and others (e.g., State, local, and Tribal
air quality management agencies, environmental groups, academic
institutions, and industrial groups) use the data from the monitoring
network for many purposes.  Some of the more prominent uses include
informing the public and other interested parties of an area’s air
quality, judging an area’s (e.g., county, city, neighborhood) air
quality in comparison with the established health or welfare standards
(including both nationationnal and local standards), evaluating an air
quality management agency’s progress in achieving or maintaining air
pollutant levels below the national and local standards, developing and
revising State Implementation Plans (SIPs) in accordance with 40 CFR
part 51, evaluating air pollutant control strategies, developing or
revising national control policies, providing data for air quality model
development and validation, supporting enforcement actions, documenting
episodes and initiating episode controls, air quality trends assessment,
and air pollution research.

The State, local, and Tribal air quality management agencies with
responsibility for reporting ambient air quality data and information as
requested in this ICR submit these data electronically to the EPA's Air
Quality System (AQS) and AIRNow databases.  Quality assurance/quality
control records and monitoring network documentation are also maintained
by each State, local, and Tribal agency, in AQS electronic format where
possible.

	Although the State, local, and Tribal air quality management agencies
are responsible for the operation of the air monitoring networks, the
EPA funds a portion of the total costs through federal grants.  Some of
these grants require an appropriate level of contribution, or
“match,” from the State/local air quality management agencies.  The
costs shown in this ICR are the total costs incurred for the monitoring
program regardless of the source of the funding.  

	For the purpose of this ICR, we have estimated the maximum potential
burden for the options being considered.  The ICR estimates for the
final rule will present the burden estimate based on the requirements
contained in the final rule.  The burden estimates are for the 3-year
period of 2010 2011 through 20122013.

	This Information Collection is estimated to involve 142 respondents for
a total approximate cost of $5,726,9793,261,007 (total capital, and
labor and operation and maintenance)                                    
                                                                        
                                                                        
                                                                        
                                                                        
                            and a total burden of 136,99349,474 hours.
The labor costs associated with these hours is $2,957737,174485. The
operations and maintenance costs are $349,716661,960 and equipment and
contract costs are $2,420,088289,002. In addition to the costs at the
State, local, and Tribal air quality management agencies, there is a
burden to EPA of total of 5,431 hours and $ 390,054.

2.  Need for and Use of the Collection

	(a) Need/Authority for the Collection

The information requirements included within this ICR are necessary to
provide the EPA with ambient air quality surveillance data to determine
the United States‘ air quality status, to make attainment decisions
with respect to the NAAQS, to assist in developing necessary control
strategies to ensure attainment of the NAAQS, to assess national trends
in air pollution, to inform the public of air quality, and to determine
the population’s exposure to various ambient air pollutants.  The
EPA’s goal of attaining the NAAQS in all areas of the United States is
directly dependent upon the availability of ambient air quality data
requested in this information collection.  Additionally, the EPA, State,
local, and Tribal air quality management agencies, environmental groups,
industrial groups, and academic organizations use these data to study
atmospheric chemistry, e.g., the formation and fate of NO2, to determine
the most appropriate and effective control strategies necessary to
reduce air pollution.

The principal legal authority for this information collection is the
Clean Air Act 42 U.S.C.A. Sections 7403, 7410, and 7511a, from which the
40 CFR part 58 regulations were promulgated.

Under Section 7403 (c), the Administrator is required to conduct a
program of research, testing, and development of methods for sampling,
measurement, monitoring, analysis, and modeling of air pollutants,
specifically including a requirement to establish a national network to
monitor, collect, and compile data with quantification of certainty in
the status and trends of air emissions and air quality.  This program
will also include the development of improved methods and technologies
to increase understanding of the sources of nitrogen oxides, its
formation, transport, regional influences and trends, and interactions
with other pollutants.  

Section 7410 (a) contains the SIP requirements, which include a
requirement that each State submit a SIP that provides for the
establishment and operation of appropriate devices, methods, systems,
and procedures necessary to monitor, compile, analyze, and make
available to the Administrator data on ambient air quality.  

Section 7511a (c)(1) states that the Administrator will promulgate rules
requiring that State, local, and Tribal air quality management agencies
conduct enhanced monitoring of ozone and its precursors (oxides of
nitrogen and volatile organic compounds) in serious, severe, or extreme
ozone nonattainment areas. 

2(b) Practical Utility/Users of the Data

The EPA Office of Air Quality Planning and Standards (OAQPS) uses the
ambient air quality data included within this collection to make
attainment decisions with respect to each air pollutant subject to
NAAQS.  For those areas that do not attain the NAAQS for one or more
pollutants, the OAQPS, the affected EPA Regional Office, and the
affected State or local air quality management agency will work to
develop an appropriate SIP to address how the area(s air quality can be
improved to meet the applicable NAAQS.

To identify how the nation is progressing in improving air quality, the
OAQPS prepares annually the National Air Quality and Emissions Trends
report (http://www.epa.gov/airtrends) using the ambient air quality data
collected through this ICR.  The State, local, and Tribal air quality
management agencies use these data for multiple purposes including
tracking their progress toward achieving and maintaining air quality
within the established NAAQS and any statewide standards they have
established.  For example, the State of California has established a
separate statewide ozone air quality standard that is more stringent
than the NAAQS for ozone; therefore, they use ambient air data to
determine compliance with both standards.  

3.  NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a) Non-duplication

This collection is not unnecessarily duplicative of information
otherwise reasonably accessible to the agency.  The AQS and AIRNow
systems, which contain information based solely on this collection, are
the only national air quality data repositories available to the EPA. 
The ambient air quality surveillance data and related information
collected through this information collection are not otherwise
reasonably accessible to the EPA.

A few State and local air quality management agencies have their own
data storage systems (e.g., the California Air Resources Board);
however, most State, local, and Tribal air quality management agencies
use the AQS and AIRNow as their primary repositories for all air quality
data.

3(b) Public Notice Required Prior to ICR Submission to OMB

The 1995 Paperwork Reduction Act requires that any agency developing a
non-rule related ICR must solicit public comments for a 60-day period
prior to submitting the ICR to OMB.    SEQ CHAPTER \h \r 1 This section
is not applicable to this ICR because this is a rule-related ICR.

3(c) Consultations

	Through the course of planning, monitoring, and improving upon this
collection and its associated regulation, the EPA regularly consults
with affected State, local, and Tribal air quality management agencies
through various methods including the regulatory process, regular
meetings, and training courses.  The EPA conducts annual work shops and
training on the AQS reporting system, e.g., the annual AQS Conference. 
The EPA Regional Offices conduct annual ambient air monitoring meetings
with their affected State, local, and Tribal air quality management
agencies to assist these affected agencies with this collection and its
associated regulation.  The EPA’s OAQPS also meets regularly with
leading State and local air monitoring managers to discuss the
Nation’s ambient air monitoring program and this collection, via large
monthly phone calls and smaller in person meeting two or three times per
year.  Starting in 1999, the Clean Air Scientific Advisory Committee
(CASAC) established the subcommittee on fine particle monitoring to
provide advice to EPA on various implementation aspects of the PM
monitoring networks.  In addition, CASAC also has established a
monitoring strategy subcommittee to extend consultation to the entire
network.

3(d) Effects of Less Frequent Collection

	State, local, and Tribal air quality management agencies would collect
and report ambient air quality data without the 40 CFR 58 regulations
associated with this collection.  Sanctions do not automatically accrue
to State or local air quality management agencies that fail to meet
these requirements.  The 40 CFR part 58 regulations and this associated
collection do provide for a consistent system for reporting and record
keeping that would not exist without these requirements.  The effects of
less frequent collection include:

• 	A national database that is not consistently updated and available
for public consumption;

• 	Less timely attainment designations with respect to the NAAQS;

• 	More difficultly in identifying and repairing problems with an
ambient air monitor--i.e., data are used as to check a monitor’s
operating condition, and reporting data less frequently would delay a
State or local agency’s ability to recognize a problem with a monitor
or a laboratory procedure; and

• 	The EPA would not be able to consistently answer questions from the
public in a timely fashion regarding air quality in various areas of the
country.

3(e) General Guidelines

  SEQ CHAPTER \h \r 1 All of the OMB’s general guidelines for
information collections in 5 CFR 1320.6 are met by this ICR.  None of
the guidelines are exceeded.

• 	Data reporting on a quarterly basis is the requirement.  Nearly all
respondents voluntarily report on a monthly basis.

•	Record retention is for no more than 3 years (most records are kept
by the EPA data repository, not the affected State, local, and Tribal
air quality management agencies)

•	Information is maintained and reported in the standardized
electronic AQS format.

3(f) Confidentiality

Information that is considered personal, private, proprietary, or
confidential is not required for this collection.  One purpose of
collecting ambient air data through AQS and AIRNow is to inform the
public of general air quality in ambient air (air considered generally
accessible to the public), and as such, does not present a need for
maintaining a confidential nature.  Security measures are taken to
prevent tampering with the AQS electronic database by limiting the
access to the AQS mainframe only to authorized users

3(g) Sensitive Questions

	  SEQ CHAPTER \h \r 1 This section is not applicable to this ICR
because no information involving matters of a sensitive nature is
collected.

4.  THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents/SIC Codes

This ICR affects State, local, and Tribal governments (SIC code 951,
Administration of Environmental Quality Program) that are currently
operating and maintaining established ambient air quality networks.  The
40 CFR part 58 regulations associated with this request require that
State, local, and Tribal air quality management agencies conduct the
ambient air quality surveillance and report the data to the EPA’s AQS.
 Although industrial, environmental, and research organizations may use
the data available through the AQS, they are not required to report any
information for this information collection.  Data submittal to AIRNow
is voluntary for all organizations, but most State and local agencies
reporting to AQS also report to AIRNow.

4(b) Information Requested

(i)  Data items, including record keeping requirements

	These data items are submitted electronically to EPA’s AQS as
required by 40 CFR part 58.   These data are stored electronically
within the EPA’s AQS, and separate records kept by the State or local
air quality management agency are not required.

•	Hourly ambient air pollutant concentrations of NO, NO2, and total
NOX collected at SLAMS/PAMS and tribal sites.

•	Precision and accuracy data for all SLAMS sites, PAMS, and Special
Purpose Monitors (SPM).

•	SLAMS monitoring network description information, including the site
AQS identification number, site location, sampling and analysis method,
operating schedule, monitoring objective, site’s scale of
representation, identity of the urban area represented, and quality
assurance plan.

•	Results of the annual ambient air monitoring network and quality
assurance plan review.

•	Annual SLAMS summary report which includes the location, date,
pollution source, and duration of each incident of air pollution during
which ambient levels of a pollutant reached or exceeded the significant
harm levels as defined in 40 CFR 51.151, the certification of the
report’s accuracy by a designated State air pollution control officer,
and various other summary statistics as provided by the AQS system.

(ii)  Respondent Activities

A model respondent would engage in the following activities to comply
with this information request:

•	Read the 40 CFR part 58 regulatory provisions and other EPA guidance
(for example, please reference our Internet site at
www.epa.gov/ttn/amtic.)

•	Plan ambient air monitoring activities, such as developing a quality
assurance plan for the network operation and maintenance, developing and
reviewing the ambient air quality surveillance network design, planning
where to locate sites, plan how to maintain and operate each site,
develop a data reporting and validation plan.

•	Write the quality assurance plan for network operation and
maintenance, the ambient air quality surveillance network plan, and the
data reporting and validation plan.  Submit these plans to the EPA
Regional or Headquarters office for review, and approval if appropriate.

•	Obtain on-site leases or agreements to locate ambient air quality
surveillance equipment.

•	Investigate vendors, and procure equipment necessary to meet the
ambient air quality network plan.

•	Receive training for site operation and maintenance, quality
assurance procedures, and data processing and reporting.

•	Make arrangements for appropriate utility hookups for each ambient
air quality surveillance site, i.e., electricity, telephones, data lines
for electronic submission of concentrations from automated analyzers.

•	Install ambient air quality surveillance equipment and equipment
shelter.  Ensure security of the site.

•	Conduct ambient air quality monitoring, incorporating all
appropriate quality assurance procedures such as calibrations, precision
and accuracy checks, and, if necessary, concurrent monitoring.

•	Validate the ambient air data for quality assurance considerations.

•	Electronically submit the complete and validated ambient air data to
the AQS and/or AIRNow data repositories.

•	Prepare and submit to EPA annually the SLAMS sites summary report.  

Each of these activities are conducted using existing reporting and
recordkeeping practices, including electronic submittal to the AQS and
to AIRNow .  If the 40 CFR part 58 regulations did not exist, and
presumably the related AQS and AIRNow, the quality assurance procedures,
and the siting guidance did not exist, the State, local, and Tribal air
quality management agencies would in a majority of cases conduct
monitoring; however, methods used by each agency would vary and data
would not be readily available to EPA and the public.  The influence of
the 40 CFR part 58 regulations has been to provide a nationally
consistent mechanism for collecting ambient air quality data including
uniform quality assurance procedures, data collection and storage
mediums (AQS), and uniform methodology.  Without this regulations and
associated ICR, managing and maintaining a national air quality program
would be extremely difficult, if possible.

 

 

5.  THE INFORMATION COLLECTED--AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

The EPA conducts the following activities to implement this ICR and
associated regulation:

•	Periodically review the 40 CFR part 58 regulations to update the
information collection and monitoring requirements in light of new
technological developments or new air pollutant standards.  Develop
revisions to the regulations in response to legislative action and
program changes.

•	Establish, maintain, and support the AQS and AIRNow as the national
repositories for all State, local, and Tribal air quality management
agency ambient air quality data and monitoring information. 
Periodically evaluate and improve upon this system as new technologies,
and new regulatory requirements would dictate.

•	Answer respondent (generally State, local, and Tribal air quality
management agencies, but also industrial organizations, environmental
groups, and others) questions about ambient air monitoring, the 40 CFR
part 58 regulatory requirements, and the AQS and AIRNow.  This includes
the establishment of the Ambient Monitoring Technology Information
Center bulletin board, the AQS toll-free hotline, and other written or
verbal communication.

•	Support the quality assurance program by working within the EPA and
with the respondents to evaluate precision and accuracy data, oversee
the National Performance Audit Program, participate in systems audits,
and conduct data validation checks on the AQS data submittal.

•	Provide within the AQS mechanisms for statistical calculations, such
as the number of times a particular ambient air quality monitoring site
exceeds the NAAQS.  Distribute the AQS data in various ways including
upon written request, by Freedom of Information Act request, by press
release, and in the annual National Air Quality and Emissions Trends
Report. 

•	Provide adequate electronic storage space within the AQS for all
ambient air quality surveillance data and information.

•	Provide various reports and graphics for users of AIRNow.

5(b) Collection Methodology and Management

All State, local, and Tribal ambient air monitoring networks have access
to and use well-established quality assurance procedures as defined in
the Quality Assurance Handbook for Air Pollution Measurement Systems,
Volumes I and II, EPA/600/R-94/038a & b.  These documents ensure that
all ambient air quality data are accurate and reliable.  

The EPA has provided and will continue to provide resources for the
maintenance and operation of the AQS and AIRNow national data
repositories.  All data required by this collection are submitted
electronically to reduce the burden of the collection and to improve
data quality, agency efficiency, and responsiveness to the public. 
Various statistical and graphical summaries are also provided by the AQS
and AIRNow systems which enhance the utility of the information for
consumption by the public and all affected State, local, and Tribal air
quality management agencies.  In submitting ambient air data into the
AQS and AIRNow national repositories, we ensure that the data are
publicly available, electronically stored, and electronically
retrievable.  State, local, and Tribal air quality management agencies
and the EPA have been submitting data to the AQS since its inception in
1987.

5(c) Small Entity Flexibility 

This collection contains a minimum amount of information in order to
manage the air quality program for the United States.  The smallest
entities affected by this collection are local air quality management
agencies, typically consisting of the governing agencies for a county or
group of counties, or a smaller metropolitan area (e.g., cities with a
population of 350,000).  This collection reduces to the extent
practicable and appropriate the burden on entities that provide ambient
air quality data and information to or for the EPA, including with
respect to small entities, as defined in the Regulatory Flexibility Act
(5 U.S.C. 601(6)), the use of such techniques as:

•	Establishing differing compliance or reporting requirements or
timetables that account for the resources available to those who are to
respond (e.g., the monitoring and reporting requirements decrease as the
population of an area decreases, and various timetables for deploying
ambient air monitoring stations are negotiated between the affected
State or local air quality management agency and the EPA with
consideration of the respondent’s resources);  

•	Clarification, consolidation, or simplification of compliance and
reporting requirements (e.g., by establishing, maintaining, and
improving as needed the AQS and AIRNow national repositories for ambient
air quality data and information);

•	Exemption from coverage of the collection of information, or any
part thereof (e.g., the EPA negotiates with State, local, and Tribal air
quality management agencies to determine the most effective and most
efficient ambient air quality networks with respect to the monitoring
needs, technical abilities, and resources available to each affected
agency).

5(d) Collection Schedule

Ambient air quality surveillance data and precision and accuracy data
for criteria air pollutants are submitted according to the schedule
defined in 40 CFR 58.16.  These current regulations require that State
and local air quality management agencies report their data within 90
days after the end of the quarter during which the data were collected. 


The annual SLAMS report is submitted by July 1 of each year for data
collected from January 1 through December 31 of the previous year in
accordance with 40 CFR 58.15.  This certification applies to all SLAMS
and all SPM monitoring data that have been submitted by July 1.  

The annual air quality surveillance network reviews are conducted and
reports are submitted to the EPA on a schedule that is determined by the
affected State or local air quality management agency and the EPA
Regional Office.  

Ambient air quality data and information are made available to the
public at any time in various ways, including:

•	Upon request to the appropriate EPA Regional office, or to the
OAQPS;

•	By Freedom of Information Act Request to the appropriate EPA
Regional Office or the OAQPS;

•	From the State or local air quality management agency responsible
for collecting the ambient air quality data and information; 

•	By obtaining access, through appropriate EPA channels, to the AQS
and AIRNow to obtain the data electronically; 

•	Through EPA public reports, such as the annual “National Air
Quality and Emissions Trends Report”; or

•	Through the AIRNow data base and the AQI reporting mechanisms which
include newspaper, television, Internet and other publicly available
notices (see www.epa.gov/airnow).

6.  ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden

All activities listed with section 4 (b) (ii) of this ICR Supporting
Statement are presented in  Worksheet 1.  The detailed burden and cost
estimates for the different types of monitors are based on information
provided in the updated version of Guidance for Estimating Ambient Air
Monitoring Costs for Criteria Pollutants and Selected Air Toxic
Pollutants (prepared by Desert Research Institute for the EPA Office of
Air Quality Planning and Standards, Air Quality Assessment Division,
Ambient Air Monitoring Group, January 2005).  The cost estimates
presented in this guidance document are based on existing literature and
direct monitoring experience.  The costs for equipment and supplies were
verified with vendors.  The monitoring costs are based on vendor quotes
for the monitor type that EPA expects respondents to use to comply with
the requirements.  Costs for level of effort estimates are verified with
selected State and local agencies.  All cost values presented in the
guidance document are adjusted to 2004 dollars, based on the average of
the first two quarters.  

	For use in preparing the burden estimates for this ICR, costs for the
monitoring requirements were inflated to 20101, 20112012, and 20122013. 
The cost escalation factors were estimated based on the appropriate
Gross Domestic Product (GDP) price indices as reported in the report
available at   HYPERLINK "http://www.jsc."  http://www.jsc.
nasa.gov/bu2/inflateGDP.html .  Tables showing the detailed burden
estimate calculations are presented below.  A summary of the average
annual respondent burden costs follows.

Worksheet 1:  Annual Average Respondent Burden Estimates

Collection

Activities	Total Labor Hours

Per Respondent Per Year

(142 respondents)

1.  Network design	4

2.  Site installation	3

3.  Sampling & analysis	94

4.  Maintenance & repairs	67

5.  Data management	38

6.  Quality assurance	108

7.  Supervision	33

TOTAL	 347                                                              
                                                                        
                                                                        
    



6(b) Estimating Respondent Costs

All activities listed with section 4 (b) (ii) of this ICR Supporting
Statement are included in the Worksheet 2. A summary of the average
annual respondent burden costs follows.

Worksheet 2:  Annual Average Respondent Cost Estimates

Collection

Activities	Total Labor Cost 

Per Respondent Per Year 

(142 respondents)

1.  Network design	$278

2.  Site installation	$2180

3.  Sampling & analysis	$4874

4.  Maintenance & repairs	$4662

5.  Data management	$2223

6.  Quality assurance	$6776

7.  Supervision	$1961

TOTAL	$22,954



6(c) Estimating Agency Burden and Cost

We estimated the Agency burden and cost by using current burden and cost
of the ambient air monitoring program related to this collection.  We
included burden and cost for the OAQPS, the ten Regional Offices, and
associated contract activities.  The in-house activities for this
collection are completed by a variety of individuals with a variety of
salaries; therefore, we used the actual salary as an average for
computing the program costs.  Actual contractor expenses were used for
those activities completed using extramural resources.  We estimated a
total of 5,431 hours and $390,054 total agency burden.

6(d)	Estimating the Respondent Universe and Total Burden and Costs 

Worksheet 3 shows the total respondent hourly burdens and costs which
was taken from section 6(b) above for the estimated 142 respondents. 
The total labor burden for the respondents was estimated to be 49,474
hours at a total cost of $2,737,485.

Worksheet 3:  Annual Total Respondent Labor Burden/Cost Estimates

Collection

 Activities	Total Labor Hours

Per Year	Total Labor Cost

Per Year

1.  Network design	642	$40,932

2.  Site installation	477	$20,540

3.  Sampling & analysis	13,340	$587,876

4.  Maintenance & repairs	9,560	$531,671

5.  Data management	5,447	$315,730

6.  Quality assurance	15,339	$962,205

7.  Supervision	4,669	$278,532

TOTAL	49,474	$2,737,485



6(e) Bottom Line Burden Hours and Cost Tables

 (i)  Respondent Tally 

Respondent Total Annual Burden = 49,474 hours

Respondent Total Annual Labor Cost = $2,737,485

Respondent Total Annual Cost for O & M = $234,520

Respondent Total Equipment/Contract Dollars = $289,002

Total Respondent Tally = $3,261,007	

(ii) The Agency Tally		

Agency Total Annual Burden = 5,431 hours

Agency Total Annual Cost = $390,054

(iii) Variations In The Annual Bottom Line.

We do not expect any significant variations in the annual bottom line
for the ambient air monitoring networks for the clearance period
requested.

	

6(f) Reasons for Change in Burden

	

	EPA is proposing to revise the network design requirements for NO2 to
support changes to the primary national ambient air quality standards
(NAAQS) for NO2 that are being proposed.  For the purpose of this, ICR
we have estimated the maximum potential burden for the options being
considered in the proposed rule.  The ICR burden estimates are
associated with the current NO2 monitoring portion of the approved ICR
2060-0084 – “Ambient Air Quality Surveillance.”

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 22 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.  

To allow 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 established a public docket for this ICR under Docket ID
No. OAR-2008-0338 which has been available for public viewing at the Air
and Radiation Docket and Information Center Docket in the EPA Docket
Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW,
Washington, DC.  The EPA Docket Center Public Reading Room is open from
8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays.
 The telephone number for the Reading Room is (202) 566-1744, and the
telephone number for the Air and Radiation Docket and Information Center
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.  The public was also
advised to send comments to the Office of Information and Regulatory
Affairs, Office of Management and Budget, 725 17th Street, NW,
Washington, DC 20503, Attention: Desk Office for EPA.

PART B OF SUPPORTING STATEMENT

	

This section is not applicable to this ICR because statistical methods
are not used in the data collection associated with the rule amendments.
	

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