DRAFT INFORMATION COLLECTION REQUEST RENEWAL

FOR THE ACID RAIN PROGRAM

UNDER TITLE IV OF THE CLEAN AIR ACT AMENDMENTS (RENEWAL)

June 18, 2012



DRAFT INFORMATION COLLECTION REQUEST RENEWAL

FOR THE ACID RAIN PROGRAM

UNDER THE CLEAN AIR ACT AMENDMENTS TITLE IV

(June 2012)

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. 

 

	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
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●	Allowance tracking and transfers (section 403);

●	Energy conservation and renewable energy incentives (section 404);

●	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, 2009 to
June 30, 2012 (i.e., the years 2010 through 2012).  

	

1.2.1  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 Extensible Markup Language (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
required to file a one time account information application using a
paper form to establish an account in the EPA allowance tracking system.
 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.

1.2.2  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.  

1.2.3  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.  

1.2.4  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 continuous emission
monitoring systems (CEMS) exception if they certify their use of
very-low-sulfur fuel.

1.2.5  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 are 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.  

1.2.6  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 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 withdrawal notification.

1.2.7  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; or

●	Obtaining an alternative emission 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 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 2,056,946 hours each year for the years 2010 through
2012.  The burden to EPA is estimated to be 19,192.5 hours in each year
for the years 2010 through 2012.

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).

2.1.1  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.

2.1.2  Permits

	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.

2.1.3  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.

2.1.4  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).

2.1.5  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).

2.1.6  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

2.2.1  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.  

2.2.2  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.

2.2.3  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.  

2.2.4  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.  

2.2.5  Emissions Monitoring

	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.

2.2.6  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 withdrawal
notification is essential to notify EPA to discontinue the allocation of
allowances to the source and enforcement of the acid rain provisions.

2.2.7  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 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

●	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.  

	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.  

	In May 2002, EPA promulgated additional revisions to Part 75.  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 with minor reporting
changes and minimal impact on respondents' burdens and costs.  

	In September 2007, additional Part 75 revisions (such as the use of a
wall adjustment factor in determining flow rate data) resulted in minor
changes to monitoring and/or reporting requirements for some units. 
Other revisions (such as no longer requiring a hardcopy certification
application form (EPA form 7610.14) were also adopted, that could result
in time savings.  Overall, these revisions do not impose significant new
or different requirements upon sources.  

	In January 2008, EPA announced revisions to the Continuous Emissions
Monitoring Rule for the Acid Rain Program that involve a reengineered
data system for the collection and processing of emissions, monitoring
plan, quality assurance, and certification data.  These revisions do not
impose significant new requirements upon sources with regard to
monitoring or quality assurance activities.  The new reporting data
system and process, which became mandatory in 2009, uses a new XML data
format that replaced the record type/column format previously used by
EPA to collect electronic data.  With the new system, the Agency
implements and assesses the program more efficiently with streamlined
access to data and reduced redundant reporting.  These revisions do not
impose significant new requirements upon sources with regard to
monitoring or quality assurance activities.  

	In June 2009, EPA contacted eight companies subject to Acid Rain
Program (ARP) monitoring requirements, and asked for voluntary input
regarding the number of hours involved in several tasks related to Acid
Rain Program monitoring and reporting.  Six respondents offered their
estimates.  EPA reviewed these estimates and found that there was a wide
range of expected burden, but that most estimates were within the range
of results that might be expected given average the hourly burdens used
in the 2007 – 2009 renewal.  Further, with the exception of the new
data collection/reporting format, no regulatory changes are likely to
change burden levels.  Thus, while hourly rates and other costs elements
have been revised to reflect 2009 dollars and the number of units
subject to the ARP has been updated to include  projected new units and
opt-in units, the estimated hours for each task remains unchanged
consistent with the previous renewal of this ICR.  EPA anticipates that
there may be long-term savings for affected sources once they become
accustomed to using the newly re-engineered reporting system, and will
use the first few years of experience with the new system to reassess
potential cost/burden changes when preparing the next renewal of the ARP
ICR.  

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.  

3.3.1  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)
establish the sequence for allocating allowances on a first-come,
first-served basis.

3.3.2  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.  

3.3.3  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.

3.3.4  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.

3.3.5  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 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.

3.6  Public Notice

	EPA received a single comment in response to the public notice that was
published in the Federal Register.  This comment pointed out that
elements of the first published draft of this ICR supporting statement
were out-dated and required revision.  EPA has addressed these issues in
the current version of the ICR.  The comment can be found in Docket ID
No. EPA-HQ-OAR-2009-0022, which is available for   SEQ CHAPTER \h \r 1
online viewing at   HYPERLINK "http://www.regulations.gov" 
www.regulations.gov ,   SEQ CHAPTER \h \r 1 or in person viewing at the
Air and Radiation Docket in the EPA Docket Center (EPA/DC), EPA West,
Room 3334, 1301 Constitution Ave., NW, Washington, D.C.

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 and 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).

4.1.1  Emissions Monitoring

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

4.1.2  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.

4.2.1  Data Items, Including Recordkeeping Requirements

A.  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 allowance
tracking system 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.

B.  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; 

--	Unit type and category;

--	Commence commercial operation date;

--	Generator IDs of generators served by unit;

--	Nameplate capacity(s) of the generators served by the unit;

--	List of applicable programs that the unit is subject to; and

--	NAICS Code.

●	Name, address, email, telephone and facsimile number of the
designated representative;

●	Name, address, email, 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.

C.  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.

D.  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 email
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.

E.  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 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.

F.  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;

●	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.

G.  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. 
Appendix A to this ICR contains 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 added or revised some recordkeeping and
reporting terms.  Some of these were necessary for the rule requirements
to match the actual reporting practices used for the Acid Rain Program. 
Others reflected minor rule changes.  

	In 2007, additional Part 75 revisions (such as the use of a wall
adjustment factor in determining flow rate data) resulted in minor
changes to monitoring and/or reporting requirements for some units. 
Other revisions (such as no longer requiring a hardcopy certification
application form (EPA form 7610.14)) may result in time savings.  

	The January 2008 revisions required upgrades and changes to the data
acquisition and handling systems (DAHS) used by sources to record and
request emissions consistent with the new EPA data system, the Emissions
Collection and Monitoring Plan System (ECMPS).  This new system was
required as of January 1, 2009, and has helped to streamline monitoring
data management and reporting.  The January 2008 rule added some
one-time burden costs for rule review and similar activities.  It also
imposed the capital costs associated with the DAHS upgrade.  These labor
burdens do not apply to the period covered by this ICR (i.e., 2010 –
2012) but the capital costs originally shown in the proposed ICR for the
January 2008 rulemaking are now incorporated into this ICR for all ARP
facilities.  

H.  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.

I.  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 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 facsimile number of the designated
representative;

●	Name, address, telephone and facsimile 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. 
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●	Source name and location;

●	Name, mailing address, telephone and facsimile 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 Agency of their decision and provide the following
information, as required in Section 74.18:

●	Source account number;

●	Name, address, telephone and facsimile number of the designated
representative; and

●	A certification that emissions requirements will be met through
December 31 of the current year, and that all remaining allowances will
be surrendered at that time.

J.  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. 
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●	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 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 three 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;

●	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.

	

K.  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

A.  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
Allowance Management System (AMS).  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.

B.  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.

C.  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 six months prior to
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●	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.

D.  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).  ECMPS  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.  

E.  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.

●	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.

F.  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 percent 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 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

5.1.1  Allowance Transfers

	Collections associated with operating the allowance transfer system
require 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 computerized allowance tracking system 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.  

5.1.2  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
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●	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 task:

●	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.

5.1.4  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's ECMPS computer system tracks
and maintains this information.  EPA also answers respondent questions
and conducts audits of data submissions and field audits of monitoring
systems.  The use of the ECMPS software streamlines EPA's process for
conducting many of these checks.

5.1.5  Auctions

	EPA staff administering the auctions receive the sealed bids and
payments, enter the information provided on bid forms into a computer
system, and deposit 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.

5.1.6  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.

5.1.7  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
A.  

	Currently, respondents to collections for allowance transfer
information may submit the 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 XML format 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.  

	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 Online 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 four billion kilowatt-hours
per year.  Generally, although about two-thirds of the affected sources
in Phase II generate a total of less than four 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.  This is based on an analysis that was included
in the Regulatory Impact Analysis of the Final Acid Rain Implementation
Regulations, dated October 19, 1992.

	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 MW 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.

	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

5.4.1  Allowance Transactions

	There is no specific collection schedule associated with allowance
transactions.

5.4.2  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, first-served basis during the period from
January 1, 1992 to December 31, 2009.

5.4.3  Permits

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

5.4.4  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 XML format.  Only new units will have to apply
for certification during the 2010 through 2012 time period.  While some
monitors will undergo changes which will require an application for
recertification, there is no set schedule for 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).

5.4.5  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.

5.4.6  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.

5.4.7  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.  

	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:  $91.94 per
hour for managers, $63.74 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
2009.

	The labor cost to the Agency, $59.79 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.  The 2007 – 2009 ARP ICR assumed, based on an average of
three units per facility, that the number of privately submitted
allowance transfers would be about 1,700 each year (one-third of the
5,200 transfers in a typical prior year).  This assumption was made
because of the Acid Rain Program's 2006 requirement for facility-level,
rather than unit-level, compliance.  Transfers to move allowances among
the different unit accounts at a facility were no longer needed for
compliance purposes.  However, sources transfer allowances for a variety
of purposes, and the assumption that transfers would drop by two-thirds
over-estimated the impact on the number of transfers of switching to
facility-level compliance.  Based on number of transfers recorded by EPA
in 2007 and 2008, EPA now assumes that about 3,955 privately submitted
allowance transfers will be made each year, 2010 through 2012.

	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 (2010 through
2012).

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 ten hours to designate an
authorized account representative and to open a general account, about
two hours to prepare and submit information for an allowance transfer,
and about three hours to prepare and submit an optional allowance
deduction.  

	Assuming that 55 participants file new general account applications,
3,955 transfers will be made annually, and 645 deduction forms are
submitted, the burden to respondents will be about 10,395 hours
annually.  The cost to respondents will be about $796,950.30 annually.

EXHIBIT 1

ANNUAL RESPONDENT BURDEN/COST ESTIMATES FOR 

ALLOWANCE TRANSFERS AND DEDUCTIONS

Tasks	Burden Hours

per Occurrence	Cost per Occurrencea	Total Burdenb (hours)	Total Cost

Designate an authorized account representative and file new account
application.





Managerial.	3	$275.82	165	$15,170.10

Technical.	7	$446.18	385	$24,539.90

Prepare and submit allowance transfer information.





Managerial.	1	$91.94	3,955	$363,622.70

Technical.	1	$63.74	3,955	$252,091.70

Allowance deduction form (optional).





Managerial.	1	$91.94	645	$59,301.30

Technical.	2	$127.48	1,290	$82,224.60

TOTAL	10,395	$796,950.30



a	2009 dollars; managerial hours $91.94 per hour and technical hours
$63.74 per hour.

b	Assumes 55 participants file new account applications, 3,955 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.

A.  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.

	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.

B.  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.  

	Recent results indicate that only about one percent of all transfers
employ paper forms.  So, assuming 40 (out of the 3,955 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 90 hours.  There is no Agency burden when participants use the
electronic online transfer system (also used for the optional deduction
submission), since all EPA functions are automated.  Costs for
maintaining the online system are included in the O&M costs.  The total
cost to EPA will be about $5,381.60 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	$59.79	40	$2,391.60

Enter deduction data and deduct allowances.	0.5	$29.90	50	$2,990.00

TOTAL	90	$5,381.60



a	2009 dollars.

b	Assumes 40 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,
there have been only nine transactions involving these allowances in the
past three years, and the program will be discontinued at the close of
2009.  This analysis assumes that no applications will be submitted each
year (2010 through 2012).  This area of activity will be removed from
the supporting statement of the next ARP ICR renewal.

6.2.1  Estimate of Respondent Burden and Costs

	Exhibit 3 depicts the annual respondent burden and costs that
historically have been 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.

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
Reserve.b





Managerial.	11	$1,011.34	0	$0

Technical.	35	$2,230.90	0	$0

Assemble and submit the information required in the EPA Conservation
Verification Protocol.c





Managerial.	7	$643.58	0	$0

Technical.	25	$1,593.50	0	$0

TOTAL	0	$0



a	2009 dollars.

b	Assumes zero applications  each year (2010 through 2012).

c	Assumes zero 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 that have been
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 eleven hours to process each application and transfer
allowances (or notify applicants).  

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 completeness.b	1	$59.79	0	$0

Perform substantive review of application.b	4	$239.16	0	$0

Transfer allowances from the Reserve or notify applicants.b	1	$59.79	0
$0

Verify energy savings based upon the EPA Conservation Verification
Protocol.c	5	$298.95	0	$0

TOTAL	0	$0



a	2009 dollars.

b	Assumes zero applications each year (2010 through 2012).

c	Assumes zero 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 Permitting

	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 1,277 Certificate of Representation forms will be
submitted to appoint new designated representatives, 20 percent 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 20,686 hours. 
The costs associated with the permitting process are estimated at
$1,691,413.84 annually.

EXHIBIT 5

RESPONDENT BURDEN/COST ESTIMATES FOR PERMITS

Tasks	Burden Hours per Occurrence	Cost per Occurrencea	Total Burden
Total Cost

Change Designated Representive.b





Managerial.	10	$919.40	12,770	$1,174,073.80 

Technical.	5	$318.70	6,385	$  406,979.90 

Phase II Permit Applications.c





Managerial.	2	$183.88	500	$45,970

Technical.	3	$191.22	750	$47,805

Retired Unit Exemption.d





Managerial.	1	$91.94	33	$3,034.02

Technical.	2	$127.48	66	$4,206.84

New Unit Exemption.e





Managerial.	1	$91.94	33	$3,034.02

Technical.	3	$191.22	99	$6,310.26

TOTAL	20,636 	$1,691,413.84 



a	2009 dollars.

b	Assumes that 1,277 certificate of representation forms will be
submitted.

c	Assumes 250 sources (20 percent 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.

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 is estimated to require half
an hour.  Reviewing the permit application, notifying the public, and
issuing proposed and final permits is estimated to require nine hours
per occurrence.  The Agency's total annual effort will be 908.5 hours. 
The total cost to EPA for all permitting activities will be about
$54,313.84.  The total annual estimated burden and cost to the
Permitting Authorities is 2,132 hours and $127,472.28.  

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 information.b	0.5
$29.90	638.5	$38,182.30

Review permit application, and issue draft, proposed, and final permit.c





Permitting Authority action.	8	$478.32	2,000	$119,580

EPA review.	1	$59.79	250	$14,947.50

Receive and process retired and new unit exemptions.d





Permitting Authority action.	2	$119.58	132	$7,892.28

EPA review.	0.3	$17.94	20	$1,184.04

TOTAL	3,130.5	$181,786.12



a	2009 dollars.

b	Assumes 1,277 sources submit a certificate of representation.

c	Assumes 250 sources (20 percent 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 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, continuous
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 XML 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 XML 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 prior ICR renewals and the
Clean Air Interstate Rule (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.  In 2005, EPA promulgated Part 75 revisions that
implement the new ECMPS data system and reporting process.  

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 2010
through 2012 was also made and included in the unit counts.  The new
unit estimates (37 new units each year, increasing the average total
number of units by 74 units/year from 2010 through 2012) were based on
the four year average of new units coming on line in the 2006 – 2009
period plus a one percent annual increase in the number of units (per
the Energy Information Administration (EIA) projected approximately one
percent annual increase in electricity generating capacity in the  
HYPERLINK "http://www.eia.doe.gov/oiaf/aeo/"  Annual Energy Outlook 2009
).  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 projects the total number of reporting units
within the following model categories:

●	Model A (units with SO2, flow, NOx, and CO2 CEMS):  1,046 total
units.

●	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):
 2,107 total units.

●	Model D (units using both Appendix D and Appendix E for SO2 and
NOx):  438 total units.

●	Model E (units using the LME methodology):  145 total units

●	Model F (units with moisture monitors necessary for moisture
correction):  32 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
sources estimates included in the prior ICR renewal for labor hour
estimates of each activity.  O&M and capital costs were updated from
estimates included in the 2006 – 2009 ICR renewal, using a factor
(1.024) based on the BLM Producer Price Index.  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 2009 dollars
using the BLM 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) installing
and 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.
 

A.  Regulatory Review

The estimate for time to review instructions and requirements remains
consistent with the labor estimates used in previous ICRs (four manager
hours and four technician hours) where no substantial changes have been
made to the Rule.  These estimates apply at the facility level.  The
estimates for burden in 2008 – 2009 to review the Part 75 rule
revision in January 2008 were addressed in the proposed ICR for that
rule, and are not expected to be included in the period covered by this
ICR (2010 – 2012).  These hours cover reviews independent of the
reviews that may occur as part of the reviewing task areas listed below.
 EPA continues to make available a   HYPERLINK
"http://www.epa.gov/airmarkt/emissions/monitoring.html"  Part 75
Emissions Monitoring Policy Manual , as well as tutorials, questions and
answers, and other guidance documents for using ECMPS.  Part 75 is
available online through the electronic   HYPERLINK
"http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=%2Findex.tpl" 
Code of Federal Regulations  (  HYPERLINK
"http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=%2Findex.tpl" 
e-CFR ).  In addition, EPA in 2005 posted online a text version of its  
HYPERLINK
"http://www.epa.gov/airmarkt/emissions/docs/plain_english_guide_part75_r
ule.pdf"  Plain English Guide to Part 75 .  

B.  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
ECMPS software, this occurs before formal data submission because the
ECMPS client tool checks all data with more than 1,000 QA checks, prior
to the data being submitted.  Thus, EPA believes that the burdens for
this activity will decrease over time.  At the same time, however, EPA
has increased its audit oversight and expects to continue to conduct a
number of electronic and field audits of facilities over the next few
years.  In particular, EPA makes significant use of electronic audits as
a means to provide continuous data quality improvement.  This effort has
already been factored into respondent burden.  In addition, if EPA
conducts a field audit, the burden to a source could 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 ten 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.

C.  DAHS Upgrade and Debugging

During the years immediately preceding the 2010 – 2012 ICR, sources
installed computer software designed to implement updated electronic
data reporting using XML formats required under the Acid Rain Program. 
EPA promulgated revisions to Part 75 in late 2006 to accommodate changes
in EPA's data systems that manage the data submitted by respondents. 
These data system changes were necessary to modernize EPA's data
systems, and to streamline reporting.  The costs of the required DAHS
upgrade were analyzed in a separate, but closely related ICR (see EPA
Docket EPA-HQ-OAR-2005-0132).  The capital costs for ARP facilities
associated with that DAHS upgrade are accounted for in this ICR.  Use of
XML format data systems became mandatory in January 2009, and updated
values in this section reflect estimated changes in respondents' burden,
some of which may be related to this upgrade.  Upon the next renewal of
this ICR, EPA will continue to examine this issue 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, 2010
through 2012, no other changes would require a DAHS upgrade and
therefore the burden hours for this activity remain zero.

D.  Monitoring Plans

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 2010 through 2012. 
The burden associated with revising the monitoring plan is included in
the time for preparing and submitting each quarterly emissions report.

Based on EIA's projected one percent per year increase in electricity
generating capacity, EPA projects that the number of new units in 2010
through 2012 will increase approximately one percent per year over the
number of units reporting in 2009.  These units have a separate line
item for initial monitoring plan preparation.

E.  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 2010 through 2012.  The Agency estimates a
labor burden of 50 hours and a contractor cost of $3,482 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 costs are incorporated within the annual QA costs for previously
certified monitoring systems.  

Under Part 75, sources are required to recertify the monitoring systems
whenever the source makes a replacement, modification, or change in a
certified CEMS or continuous opacity monitoring system that may
significantly affect the ability of the system to accurately measure or
record the SO2 or CO2 concentration, stack gas volumetric flow rate, NOx
emission rate, percent moisture, or to meet the QA and QC requirements. 
Recertification is also necessary whenever the source makes a
replacement, modification, or change to the flue gas handling system or
the unit operation that may significantly change the flow or
concentration profile.  Examples of changes which require
recertification include:  replacement of the analyzer, change in
location or orientation of the sampling probe or site; and complete
replacement of an existing CEMS or continuous opacity monitoring system.

For new units, the monitor certification costs are included in the
capital/startup costs.

F.  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 were 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.

G.  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 percent reduction from the 1999
ICR).  This burden estimate was used in the prior ICR renewal as well. 
For this renewal, consultations with affected sources continued to show
a wide range of estimates for this activity.  EPA will use the existing
estimate for 2010 – 2012, and they seek input from reporters as ECMPS
reporting matures during the period.  In the next renewal, EPA will
reassess this estimate.  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.

A.  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 were originally
drawn from CAIR EPA ICR #2152.02 (OMB Control Number 2060-0570), and
have been updated for this ICR using a factor based on the rate of
inflation shown for 2006 through 2009 in Industrial Commodities Producer
Price Index (PPI) maintained by the Bureau of Labor Statistics.  The
annualized costs ranged from $29,572 for units with a full set of CEMS
(Model A), to $19,200 for a unit that uses NOx CEMS and Appendix D
methods (Model C), to $2,304 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 C. 
Annualizing Capital Costs.  As noted earlier, this ICR includes
annualized capital costs for recent DAHS upgrades at all ARP facilities.
 

In addition to capital/start-up costs, respondents incur operation and
maintenance (O&M) 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 CAIR EPA ICR #2152.02, and were
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).  These O&M costs have also
been updated to 2009 dollars based on the PPI.  The total cost for these
operation and maintenance cost items (other than fuel sampling) is
estimated at $31,949 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 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.

B.  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.  

C.  Annualizing Capital Costs

The relevant capital costs for the emissions trading portion of this ICR
were annualized at a rate of seven percent (i.e., the annualized capital
cost was calculated assuming money to purchase the capital equipment was
borrowed at a seven percent 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 monitoring equipment
capital purchases varies from $2,304 to $29,572, per year, per unit,
depending on the type of monitoring methodology.  Exhibit 7 contains a
breakdown of annual costs by monitoring methodology.  The capital costs
are from the CAIR EPA ICR #2152.02, updated from 2006 dollars to 2009
dollars by a factor (1.024) based on the PPI for industrial commodities.

D.  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
CAIR 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 burden has been reduced from two hours,
in the 2007 – 2009 ICR, to one hour in the 2010 – 2012 ICR on a per
report basis.  EPA's increased audit oversight efforts are more than
offset by burden reductions from increasing familiarity with the program
and improved automated tools.  Assuming that affected sources will
submit 3,736 emissions reports to EPA per quarter, the total annual
burden incurred by the Agency will be 15,072 hours.  The total annual
cost to EPA for processing, reviewing, and evaluating these quarterly
emissions reports will be approximately $901,155.  Exhibit 8 summarizes
the Agency burden and costs associated with emissions reporting.

6.4.4  Estimating the Respondent Universe and Total Burden and Costs

Based on the number of units reporting in 2009 and the EIA projection
that electricity generation capacity will increase by about one percent
per year, EPA estimates that, during the 2010 – 2012 time period:  (a)
1,249 sources will review instructions and requirements; (b) 1,201
sources (this number excludes sources with only low mass emissions units
and new units) will reprogram and debug DAHS computer software; (c)
3,736 units will submit quarterly reports; and (d) 3,591 units will
respond to EPA generated error messages (of which about ten 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, from 2006 through 2008, an average of 913
units recorded recertification events annually.  Applying a one percent
annual increase, based on EIA capacity projections, EPA estimates that
approximately 922 units will recertify annually.  This is significantly
more than the estimate (294 units) used in the 2007 – 2009 ICR, and
some of these recertifications may have been related to changes made for
compliance with CAIR.  EPA is using the larger number as a conservative
estimate for recertifications from 2010 through 2012, and will again
revisit the data when preparing the next (2013 – 2015) renewal of the
ARP ICR.  Exhibit 7 shows the total burden and total cost based on this
respondent universe. 

 EXHIBIT 7

ANNUAL RESPONDENT BURDEN/COST ESTIMATES FOR EMISSIONS MONITORING

INFORMATION 

COLLECTION ACTIVITY	Mgr. $91.94/Hour	Tech. $63.74/Hour	Respondent
Hours/Year	Labor Cost/Year	Cont./O&M Cost	Capital/Start-up Cost	No. of
Respondents	Total Hours/Year	Total Cost/Year

1.  Review Instructions and Requirements.	4 	4 	8 	$623 	$	-	$	-	1,249 
9,992 	$777,777

2.  Respond to EPA Generated Error Messages, Field Audits.	6 	18 	24 
$1,699 	$	-	$	-	3,591 	86,184 	$6,100,965

3a.  DAHS Upgrade.



	$	-	$570 	1,201 

$684,570

3b.  DAHS Debugging.	4 	12 	16 	$1,133 	$	-	$	-	1,201 	19,216 
$1,360,301

4.  New Unit Monitoring Plans.	10 	10 	20 	$1,557 	$	-	$	-	37 	740 
$57,602

5.  Recertify Monitors.	38 	12 	50 	$4,259 	$3,482 	$	-	922 	46,100 
$7,136,464

6.  Startup/Capital Items and Perform QA Testing and Maintenance.









	(a) Model A (CEMS).	50 	480 	530 	$35,192	$31,949	$29,572 	1,046 
554,380 	$101,161,898

(b) Model B (COMS).	-	171 	171 	$10,900	$295 	$3,645 	500 	85,500 
$7,419,946

(c) Model C (App D -- NOx CEM).	20 	375 	395 	$25,741	$17,818 	$19,200
2,107 	832,265 	$132,233,002

(d) Model D (App D and E).	5 	30 	35 	$2,372 	$1,843 	$2,304 	438 
15,330 	$2,855,366

(e) Model E (LME).	-	-	-	$	-	$1,991 	$	-	145 	-	$288,645

(f) Model F (H2O).	-	40	40 	$2,550 	$8,192 	$874 	32	1,280 	$371,715

7a.  Assure Data Quality, Prepare Reports (inc. monitor plan update),
Submit Reports.	20 	82 	102 	$7,065 	$	-	$	-	3,591 	366,282 	$25,372,139

7b.  LME Reporting.	4 	12 	16 	$1,133 	$	-	$	-	145 	2,320 	$164,233

8.  Annual Fuel Sampling.	-	-	-	$	-	$	-	$	-	-	-	$	-

Total	2,019,589	$285,984,623



Capital cost and O&M cost increase factor equal to 1.024 based on the
2006 to 2009 increase in PPI for industrial commodities.

Adding one percent per year for each of three years, an average of 74
additional units will report each year.  These additional units were
apportioned to the various models based on the percent change in each
model from 2006 to 2009.

Annualized capital costs for DAHS upgrades were drawn from the proposed
DAHS upgrade ICR (EPA Docket EPA-HQ-OAR-2005-0132).

Capital cost and O&M cost increase factor equal to 1.024 based on the
2006 to 2009 increase in PPI for industrial commodities.

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) 

(2010 – 2012)	Total Cost

Process, review, and evaluate quarterly report and issue feedback
letter.	1	$59.79	15,072	15,072	$901,155



a	Based on an average total compensation rate of $59.79 per hour.

b	Updated from 2006 dollars using the average factor (1.09) used to
update the Respondent labor cost.  

c	Assumes 3,768 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 four auctions, EPA estimates that 130 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 195 hours and $16,809 per year
respectively.

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 forms.b	0.5	$43.10	65	$5,603.00

2.  Obtaining means of payment.b	1	$86.20	130	$11,206.00

TOTAL	1.5	$129.30	195	$16,809.00



a	Based on an average rate of $86.20 per hour (for costing purposes, it
is assumed that 80 percent of the total hours will be Managerial ($91.94
per hour) and 20 percent will be Technical ($63.74 per hour).  These
estimates are based on 2009 dollars.

b	The 130 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 accounts for auction participants is estimated to take ten hours,
the handling of bids and checks is estimated to take 20 hours,
tabulation, checking, and announcing the auction results is estimated to
take fifteen 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 $5,082.

EXHIBIT 10

ANNUAL AGENCY BURDEN/COST ESTIMATES FOR AUCTIONS

Collection Activities	Burden Hours Per Year	Cost Per Yeara

1.  Setup allowance tracking system accounts.	10	$597.90

2.  Handle bids and checks.	20	$1,195.80

3.  Tabulate, check, and announce results.	15	$896.85

4.  Transfer of allowances and proceeds.	40	$2,391.60

TOTAL	85	$5,082.15



a	2009 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.

	There were three sources with a total of eight units listed as opt-in
units in the ARP program in 2006.  Two additional sources with a total
of twelve units opted into the ARP in 2008.  Twenty-eight applications
were undergoing processing in early 2009, as sources prepared to comply
with the CAIR SO2 trading.  The final form of SO2 regulation under CAIR
remains in flux.  EPA currently estimates that sources could submit up
to four additional applications per year from 2010 through 2012, and
will revisit this estimate in the next renewal of this ICR.  

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:	Currently, there are five opt-in facilities, with 20 units.  Adding
the 28 applications received in early 2009, plus four facilities per
year with an average of four units per facility, the projected number of
facilities involved in annual reconciliation processes is 37, and the
number of units is 148.  

	Over the three years covered by this ICR, EPA estimates that up to four
sources will opt into the program annually.  This figure is based on the
number of opt-in applications EPA has received over the past four 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 up to four sources per year will submit opt-in
permit applications in the years covered by this ICR.  Sources that file
an application must select a designated representative, report operating
and fuel consumption data from past years, and report the actual and
allowable emissions rates for 1985 (or their first year of operations,
if after 1985) as well as the current allowable emission rate.  As shown
below in Exhibit 11, EPA estimates a burden of 828 hours and a cost of
$59,206 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 4,033 hours and $277,931,
respectively.  Exhibit 12 presents respondent burden and costs for
annual reconciliation by opt-in sources.

6.6.2  Agency Burden/Cost Estimates for the Opt-in Program

	In 2010 through 2012, 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 768 hours and $45,918.72, respectively.  Exhibit 13 presents
the Agency's burden and costs for opt-in program.

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 representative.b





Managerial.	20	$1,838.80	80	$7,355.20

Technical.	7	$446.18	28	$11,784.72

Prepare opt-in permit application.b





Managerial.	20	$1,838.80	80	$7,355.20

Technical.	85	$5,417.90	340	$21,671.60

Prepare thermal energy compliance plan.





Managerial.	15	$1,379.10	60	$5,516.40

Technical.	55	$3,505.70	220	$14,022.80

Complete withdrawal notification.d





Managerial.	2	$183.88	8	$735.52

Technical.	3	$191.22	12	$764.88

TOTAL	828	$59,206.32



a	2009 dollars.

b	Assumes four 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.

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 form.b





Managerial.	2	$183.88	296	$27,214.24

Technical.	16	$1,019.84	2,368	$150,936.32

Thermal energy compliance report (shutdown opt-in sources and
replacement units).c





Managerial.	10	$919.40	370	$34,017.80

Technical.	21	$1,338.54	777	$49,525.98

Allowance deduction form (optional).d





Managerial.	1	$91.94	74	$6,803.56

Technical.	2	$127.48	148	$9,433.52

Energy conservation/improved unit efficiency confirmation report.e





Managerial.	5	$459.70	0	0

Technical.	25	$1,593.50	0	0

Excess emissions penalty payment.e





Managerial.	4	$367.76	0	0

Technical.	5	$318.70	0	0

TOTAL

	4,033	$277,931.42



a	2009 dollars.

b	Assumes 37 opt-in sources (five currently listed, plus 28 current
applications, plus four new opt-in sources) and 148 opt-in units (37
sources with an average of four units each).

c	Assumes 37 sources file reports.

d	Assumes 74 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.

EXHIBIT 13

ANNUAL AGENCY BURDEN/COSTS FOR THE OPT-IN PROGRAM

Tasks	Burden Hours per Occurrence	Cost per Occurrencea	Total Burden
(hours)	Total Cost

Review certificates of representation and record information.b	1	$59.79
4	$239.16

Review permit application, issue proposed and final permit, and assign
allowances.b	80	$4,783.20	320	$19,132.80

Review and process annual reconciliation submissions.c	2	$119.58	296
$17,697.84

Deduct allowances and send reconciliation reports.c	1	$59.79	148
$8,848.92

TOTAL	768	$45,918.72



a	2009 dollars.

b	Assumes four opt-in sources submit a permit application.

c	Assumes 37 opt-in sources and 148 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 percent of all units affected for NOx  (i.e., 200 units) will
submit NOx Compliance Plan renewal applications each year.  Based on
previous 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 five hours, while compliance plan revisions will require
about ten 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 $96,037 per year.

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 applications.b





Managerial.	2	$183.88	400	$36,776.00

Technical.	3	$191.22	600	$38,244.00

Revise NOx Compliance Plan (e.g., emissions averaging plans).c





Managerial.	5	$459.70	135	$12,411.90

Technical.	5	$318.7	135	$8,604.90

TOTAL	1,270	$96,036.80



a	2009 dollars.

b	Assumes 200 units (20 percent 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 $7,593.33,
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.

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 plans.b	0.5	$29.90	100	$5,979.00

Revise NOx emissions averaging plans.c	1 	$59.79 	27	$1,614.33 

TOTAL	127	$7,593.33



a	2009 dollars.

b	Assumes 200 units (20 percent 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, 2009 through June 30, 2012 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 2007 from the last clearance
was 1,971,276 hours.  This ICR estimates the annual burden in 2010 will
be 2,056,946 hours, which increases the burden by 85,670 hours, about
four percent.  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. 
Adjustments include changes to the number of responses and the time it
takes to respond to a particular activity.  Some new estimates for the
number of responses are based on queries of EPA databases for activities
reported in recent years.  At this time, EPA does not believe any
changes in burden are warranted as a result of the change to ECMPS. 
Although the process may impact average burden, the basic information
being requested remain basically the same, and it is too early at this
juncture to determine if the new process
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●	Based on a query of allowance transfers in 2009, the estimated
annual number of allowance transfer submissions increased from 1,700 to
3,995.  This, along with re-estimated time requirements for designating
an authorized account representative, filing new account application,
and preparing an optional allowance deduction form, changed the annual
burden hours for allowance transfer activities from 5,885 to 10,395.  

●	Permitting activities were estimated to require 13,531 burden hours
in 2007.  The estimated annual burden hours for permitting under this
ICR are 20,636.  This burden change reflects an increase in the number
of units submitting Certificate of Representation forms.  

●	Adjustments increased the annual average burden for monitoring and
reporting activities from approximately 1,950,000 hours in the previous
ICR renewal to approximately 2,019,589 hours.  This reflects an increase
in the respondent universe because of the number of new units that came
online in the last four years and hours
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●	The estimated annual average burden for auction activities increased
from 166.5 hours in the previous ICR renewal to 195 hours in the present
renewal.  This reflects an increase in the number of bids received.  

●	The estimated number of sources applying to opt-in to the ARP was
increased from zero to four.  This increase, along with two opt-in
sources (adding a total of twelve units) in 2008 and 28 applications
received in early 2009, results in the estimated burden for applications
and annual compliance certification increasing from 280 hours in 2007 to
4,861 hours in the current collection.  

6.10  Burden Statement

	The respondent reporting burden for this collection of information is
estimated to be 2,056,946 hours each year for the years 2010 through
2012.  The burden to EPA is estimated to be 19,182.5 hours in each year
for the years 2010 through 2012.

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 90 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 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-2009-0022, which is available for online viewing at 
HYPERLINK "C:\\Documents and Settings\\WorleyC\\Local
Settings\\Temp\\notesFCBCEE\\www.regulations.gov" www.regulations.gov ,
or in person viewing at the Air and Radiation docket in the EPA Docket
Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW,
Washington, D.C.  The EPA Docket Center Public Reading Room is open from
8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays.
 The telephone number for the Reading Room is (202) 566-1744, and the
telephone number for the Air and Radiation docket is (202) 566-1742.  An
electronic version of the public docket is available at  HYPERLINK
"C:\\Documents and Settings\\WorleyC\\Local
Settings\\Temp\\notesFCBCEE\\www.regulations.gov" 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-2009-0022 and
OMB Control Number 2060-0258 any correspondence.

EXHIBIT 16

AGGREGATE ANNUAL RESPONDENT BURDEN AND 

COST OF COLLECTIONS (2010 through 2012)

Program	Total Burden (hours)	Total Costsa

Allowance transfers and deductions.	10,395	$796,950.00 

Energy conservation and renewable energy allowances.	0	$0.00

Permits.	20,636	$1,691,413.89

Emissions reporting.	2,019,589	$285,984,623

Auctions.	195	$16,809.00 

Opt-in.b	4,861	$337,137.74 

NOx permitting.	1,270	$96,036.80 

TOTAL	2,056,946	$288,922,970.38



a	2009 dollars.

b	Includes permitting and annual reconciliation burdens for opt-in
sources.

EXHIBIT 17

AGGREGATE ANNUAL AGENCY BURDEN AND COST OF COLLECTIONS

Program	Total Burden (hours)	Total Costsa

Allowance transfers and deductions.	90	$5,382.00

Energy conservation and renewable energy allowances.	0	$0.00

Permits.



Permitting Authority.	2,132	$127,472.28

EPA.	908.5	$54,313.84

Emissions reporting.	15,072	$901,155.00

Auctions.	85	$5,082.15

Opt-in.	768	$45,918.72

NOx permitting.	127	$7,593.33

Operation & Maintenance of data systems.b	N/A	$1,500,000.00

TOTAL	19,182.5	$2,646,917.32



a	2009 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.



Appendix A

Acid Rain Program Forms and Instructions

	EPA Acid Rain Program Forms and Instructions are shown below, and can
be downloaded from the Forms for Clean Air Markets Programs website,  
HYPERLINK "http://www.epa.gov/airmarkt/business/forms.html" 
http://www.epa.gov/airmarkt/business/forms.html .

Acid Rain Program and CAIR Forms	

Certificate of Representation Form	

Certificate of Representation data can also be submitted online using
the   HYPERLINK "https://camd.epa.gov/cbs/"  CAMD Business System (CBS) 


Allowance Transfer Form (see also:    HYPERLINK
"http://www.epa.gov/airmarkt/business/allowance.html"  single signature
requirement )

General Account Form	

Retired Unit Exemption Form	 

Acid Rain Program

EPA SO2 Allowance Auction 

  HYPERLINK
"http://www.epa.gov/airmarkt/business/docs/forms/2009HowtoBid.pdf"  2009
How to Bid Factsheet   

  HYPERLINK
"http://www.epa.gov/airmarkt/business/docs/forms/2009BidForm.pdf"  2009
Bid Form and Instructions  

  HYPERLINK
"http://www.epa.gov/airmarkt/business/docs/forms/2009OfferForm.pdf" 
2009 Offer Form and Instructions  

  HYPERLINK
"http://www.epa.gov/airmarkt/business/docs/forms/proceed.pdf" 
Notification for Distribution of Proceeds from EPA Auctions  

	(This document is used for changing a recipient name on proceeds
checks.) 

  HYPERLINK
"http://www.epa.gov/airmarkt/business/docs/forms/2009LetterofCreditForm.
pdf"  2009 Letter of Credit Form and Instructions  

For more information, see the   HYPERLINK
"http://www.epa.gov/airmarkt/trading/factsheet-auction.html"  Acid Rain
Program Allowance Auction Fact Sheet 

Acid Rain Permitting 

Acid Rain Permit Application 

Acid Rain NOx Compliance Plan

Acid Rain NOx Averaging Plan 

Acid Rain New Unit Exemption

For more information, see   HYPERLINK
"http://www.epa.gov/airmarkt/progsregs/arp/permits.html"  Acid Rain
Permits and Applicability 

Monitoring 

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EPA form 7610-14, Certification Application, is no longer required.  For
information on monitoring, see   HYPERLINK
"http://www.epa.gov/airmarkt/emissions/index.html"  Emissions Monitoring
 and   HYPERLINK
"http://www.epa.gov/airmarkt/business/report-emissions.html"  Report
Emissions 

Phase II Annual Reconciliation

Allowance Deduction Form 

For more information, see the   HYPERLINK
"http://www.epa.gov/airmarkt/progsregs/arp/reconciliation-factsheet.html
"  Acid Rain Program Annual Reconciliation Fact Sheet 

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