__

  SEQ CHAPTER \h \r 1 SUPPORTING STATEMENT

Inclusion of Delaware and New Jersey in the Clean Air Interstate Rule
(Renewal)

EPA ICR # 2184.03

  TC \l1 " 

1.	IDENTIFICATION OF THE INFORMATION COLLECTION  TC \l2 " 

	1(a) Title of the Information Collection  TC \l3 " 

	Inclusion of Delaware and New Jersey in the Clean Air Interstate Rule,
EPA ICR Number 2184.03, OMB Control Number 2060-0584

	1(b) Short Characterization/Abstract  TC \l3 " 

	The United States (U.S.) Environmental Protection Agency (EPA)
promulgated a Rule to add the States of Delaware and New Jersey to the
States that are subject to the Clean Air Interstate Rule (CAIR) because
of their PM2.5 impact on other States and to require that Delaware and
New Jersey report all of the emissions related data required by CAIR. 
(Delaware and New Jersey are already affected by ozone-related
requirements in CAIR.)  The emissions data reporting requirements
include reporting requirements and combine with existing requirements
from the Consolidated Emissions Reporting Rule (CERR), the Emission
Reporting Requirements for Ozone State Implementation Plan (SIP)
Revisions Relating to Statewide Budgets for NOX Emissions to Reduce
Regional Transport of Ozone (NOX SIP Call), the Acid Rain Program under
Title IV of the Clean Air Act Amendments of 1990, and the Rule to Reduce
Interstate Transport of Fine Particulate Matter and Ozone (Clean Air
Interstate Rule, CAIR).  Each of these four existing requirements has an
approved ICR in place.  The current ICRs are: for the CERR, ICR #
0916.12 (OMB 2060-0088), for the NOX SIP Call, ICR # 1857.04 (OMB
2060-0445), for the Acid Rain Program, ICR # 1633.14 (OMB 2060-0258),
and for CAIR, ICR  # 2152.03 (OMB 2060-0570).

	This supporting statement and ICR is being submitted to account for the
incremental burden associated with the addition of Delaware and New
Jersey to the CAIR for PM2.5.  As such, this supporting statement
references the burden analysis included in ICR #s 0916.12, 1857.04,
1633.14 and 2152.03 and estimates the change in burden resulting from
the additional requirements for Delaware and New Jersey on each of these
ICRs.  The original supporting statement for this information collection
was open for public review and comment at the same time as the proposal
to have the PM2.5 CAIR requirements apply to Delaware and New Jersey. 
There were no comments on this ICR, burden estimates, methodology, or
the Agency's authority to collect the information.

	EPA has included Delaware and New Jersey in the PM2.5 requirements
under CAIR.  This supporting statement details the additions and changes
to reporting requirements.  These changes can be divided in to two
categories: 1.  Changes to existing requirements for emission reporting
under the CERR and NOX SIP Call and 2.  The addition of reporting
requirements to support emissions trading in states using the CAIR model
cap and trade rules.  Throughout this Supporting Statement, the burden
analysis associated with these two categories will be discussed
sequentially as “Emission Reporting Requirements” and “Emission
Trading Requirements.” 

Emission Reporting Requirements

	Taken together, the existing emissions reporting requirements under the
NOX SIP Call and CERR are already rather comprehensive in terms of the
States covered and the information required.  Therefore, the practical
impact of the changes for Delaware and New Jersey is to impose only one
new requirement.

		Under the existing CERR, yearly reporting is required only for sources
whose emissions exceed specified amounts.  Under the CAIR, the 23 States
and the District of Columbia subject to the CAIR for reasons of PM2.5
must report to EPA each year a set of specified data elements for all
sources subject to new controls adopted specifically to meet the CAIR
requirements related to PM2.5, unless the sources participate in an
EPA-administered emissions trading program.  This is like the every-year
reporting requirement for controlled sources under the NOx SIP Call, but
covering SO2 in addition to NOX and covering the whole year – since
the PM2.5 NAAQS at issue is the annual NAAQS – rather than only the
ozone season.  This rule does not increase the number of sources for
which Delaware and New Jersey must submit reports each year rather than
only every third year, since both Delaware and New Jersey:  1) do not
control non-EGU sources under the CAIR; and 2) have joined the EPA
trading programs for EGUs.  This new requirement will begin with the
2009 inventory year, the report for which will be due to EPA by June 1,
2011.  After the 2009 reporting year, this new requirement will have no
effect on States that fully comply with the CAIR by requiring their EGUs
to participate in the EPA model cap-and-trade programs.  

Emission Trading Requirements

	For purposes of this ICR, it is important that the burdens and costs be
calculated only in terms of incremental impacts that have not already
been included in the existing ICRs for the ARP and CAIR programs. 
Delaware sources are subject to the CAIR Federal Implementation Plan
(FIP) for annual and ozone season NOx, and for SO2.  New Jersey sources
are subject to requirements consistent with the CAIR SO2 and annual NOx
model trading rules.  With the exception of a modification to the method
with which the NOx allowances are allocated, the requirements for New
Jersey sources are consistent with the federal trading program.  The
trading program burden includes the paperwork burden related to (1)
transferring and tracking allowances; (2) the allocation of allowances
to affected units; (3) permitting; and (4)  monitoring and  reporting. 
Many of these burdens are covered under the existing ARP ICR (1633.15)
for ARP sources and the CAIR ICR (2152.03) for non-ARP sources.  

	Like with the Acid Rain Program and the NOX SIP Call, the ability to
buy and sell (or transfer) allowances is expected to provide substantial
economic benefits by encouraging the greatest emissions reductions where
costs of reductions are lowest.  Allowance trading cannot be
implemented, however, unless regulations governing emissions monitoring
and permitting of sources are in place as well.  To ensure compliance
with the emissions reduction requirements and to provide the region-wide
consistency needed to foster the allowance market, the designated
representative of the owners and operators of each source with affected
units are required to have CAIR requirements integrated into their Title
V permits for the affected source and to certify that an approved SO2
and NOX emissions monitoring system has been installed and is properly
operated at each affected unit.  For affected units currently required
to monitor using Part 75 provisions, information for the  allocation
methodology is recorded and collected as part of the emissions
monitoring and reporting process.

	While many sources have already installed necessary emissions
monitoring equipment due to requirements under other regulations, some
sources may need to install new monitors or upgrade existing monitors. 
Capital costs also usually include the cost of initial certification of
new or upgraded monitors and are included as part of start-up costs.

	Emissions monitoring and reporting by sources in the cap and trade
program is fundamental to the allowance trading system.  EPA uses the
data contained in the reports to verify actual emissions.  Without
accurate monitoring and reporting of emissions, the integrity of the
allowance system would be undermined, and there would be no assurance
that the cap is achieved and emissions had been reduced.  To meet the
emissions monitoring, recordkeeping and reporting requirements, affected
units are required to (1) submit a monitoring plan and certification
reports for each monitoring system, (2) record hourly emissions data,
and (3) submit reports of their emissions and operating data to EPA. 
Sources with monitors already certified under Part 75 may be exempt from
initial certification requirements.

	All participants in the allowance transfer system are required either
to complete and submit an allowance transfer form for each allowance
transfer or to perform the transfer on-line.  Participants in the
transfer system that are not affected sources, such as allowance
brokers, fuel suppliers and environmental groups are also required to
file a one-time account information application to establish accounts in
the allowance tracking systems.  For sources affected by the CAIR,
allowance transfers previously conducted under the NOx SIP Call Program
occur in the context of the CAIR Trading Program.

2.	NEED FOR AND USE OF THE COLLECTION

	2(a) Need/Authority for the Collection  TC \l3 " 

	While the Clean Air Act does not provide a specific authorization for a
national emissions database, the Clean Air Act provides the EPA ample
legislative authority for acquiring such data.  Emissions data are of
vital importance to the EPA for fulfilling a host of monitoring,
standard-setting, rulemaking, reviewing, and reporting duties.  Section
110 and 301(a) of the Clean Air Act provide a primary authority for a
national emissions database.  Section 110 requires each State to prepare
a plan which provides for implementation, maintenance, and enforcement
of the primary standard for each pollutant for which air quality
criteria have been issued.  This plan must include provisions for
periodic reports identifying sources and listing amounts of emissions. 
Section 301(a) authorizes the Administrator to promulgate necessary
regulations.

	Congressional support for collecting and reporting emissions data is
demonstrated in three sections of the Clean Air Act.  Section
110(a)(2)(F) requires that each State provide for periodic reports on
the nature and amounts of emissions of criteria pollutants from
stationary sources.

	Sections 182(a)(3)(A) and 187(a)(5) of the Clean Air Act specify
periodic inventory requirements for ozone and CO nonattainment areas,
respectively.  Section 182(a)(3)(A) requires States with ozone
nonattainment areas to submit a current inventory of actual emissions of
VOC, NOX, and CO every 3 years.  Section 187(a)(5) requires a similar
inventory of actual CO emissions for CO nonattainment areas.  Periodic
inventories include emission estimates for all point, nonpoint, onroad
mobile, nonroad mobile, and biogenic sources.  Section 172(c)(3) also
provides the Administrator with discretionary authority to require other
emissions data as deemed necessary for State Implementation Plan (SIP)
development in nonattainment areas to meet the NAAQS.  In 1998, EPA
promulgated the NOX SIP Call which requires the affected States and the
District of Columbia to submit SIP revisions providing for NOX
reductions to reduce their adverse impact on downwind ozone
nonattainment areas.  (63 FR 57356, October 27, 1998).  As part of that
rule, codified in 40 CFR 51.122, EPA established emissions reporting
requirements to be included in the SIP revisions required under that
action.  Another set of emissions reporting requirements, termed the
Consolidated Emissions Reporting Rule (CERR), was promulgated by EPA in
2002, and is codified at 40 CFR part 51 subpart A.  (67 FR 39602, June
10, 2002).  These requirements replaced the requirements previously
contained in subpart Q, expanding their geographic and pollutant
coverages while simplifying them in other ways.

	

	As noted above, at present, two sections of title 40 of the CFR contain
emissions reporting requirements applicable to States: subpart A of part
51 (the CERR) and section 51.122 in subpart G of part 51 (the NOX SIP
Call reporting requirements).  The rulemaking consolidates these for
Delaware and New Jersey, with modifications.  The modifications are
intended to achieve the additional reporting needed to verify the
reductions required by the CAIR. 

	2(b) Practical Utility/Users of the Data  TC \l3 " 

Emission Reporting Requirements

	Emissions data and related information on stationary point and nonpoint
sources, as well as nonroad mobile and onroad mobile sources, are
routinely used by the OAQPS and the EPA Regional Offices in carrying out
a variety of activities.  These activities support regulatory functions
as well as functions that are more programmatic in nature such as trends
analyses.  Such projects include:

	•	Evaluation of existing control strategies, such as the NOX SIP
Call, for States and larger areas;

•	Evaluation of control strategies for States and larger areas,
including applications of regional scale models;

•	Development of national control strategies and preparation of
Regulatory Impact Analyses (RIA);

•	Preparation and publication of national summaries of emissions
including trend analyses;

•	As a data base to assist in the identification of important source
categories for future regulation; and

•	Preparation of the stationary source portion of a report to Congress
on SO2 emissions.  This report is required by Section 406 of the Clean
Air Act and is due on a 5-year cycle that began on January 1, 1995.  The
report must contain an inventory of national annual SO2 emissions from
industrial sources (as defined in Title IV of the Clean Air Act).

	EPA’s Office of Research and Development (ORD) uses emissions source
data in determining priorities for control technology research and as a
key data component in the application of regional scale models.  The
EPA’s Regional Offices use emissions and other source parameters to
support source inspections and in the analyses of the impact of new or
modified sources within an area.  EPA’s Emission Inventory and
Analysis Group (EIAG) use the data to assess and analyze trends in
criteria pollutant emissions over time.

	In addition to supporting projects and initiatives internal to EPA,
both the OAQPS and the Regional Offices respond to numerous requests for
reports on emission sources.  Typically this is done under the Freedom
of Information Act.  Most requests come from contractors and consultants
involved in special studies; a smaller number come from the press and
universities and others involved in research.

	 The collection of emissions data specific to nonattainment areas for
certain criteria air pollutants is necessary to comply with requirements
specified in Title I of the Clean Air Act.  States with nonattainment
areas rely on current information for point, nonpoint, and mobile
sources to revise their SIPs and to plan for emission reductions
mandated by the Clean Air Act.  In addition, a statewide inventory
compiled at least every 3 years for all point, nonpoint, and mobile
sources is considered to be a key tool to assist States in meeting Clean
Air Act requirements that address emissions tracking, compliance issues,
and mid-course adjustments.  Statewide emission inventories can be used
by States affected by pollution transport from upwind areas to develop
more efficient control strategies to meet the NAAQS.  Statewide emission
inventories that were developed by EPA (the NEI) are being used by the
Regional Planning Organizations (RPOs) as the starting point for the
development of statewide emission inventories used in the regional haze
program to define control strategies.

Emission Trading Requirements

 

	Data from emissions monitoring is indispensable to successful
implementation of the trading programs for two reasons:

•	The primary purpose of the trading programs is to assist States in
the attainment of the fine particulate matter national ambient air
quality standard (NAAQS) by reducing the adverse effects of the
transport of fine particles from upwind States by reducing annual
emissions of sulfur dioxide and nitrogen oxides; and

•	EPA can only enforce the program by comparing, for each affected
unit, emissions data and the number of allowances held.

	Information collected on allowance transfers is used by EPA or its
designated agent to track allowances for the purpose of determining
compliance with the CAIR annual NOX and SO2 Trading Programs. 
Information on allowance transfers is also used by participants in the
allowance market and the public to evaluate the activities of affected
sources, and by EPA for program evaluation.

	Together, the allowance trading system, operating permits, and
emissions data help to provide the accountability to allow the NOX and
SO2 Trading Programs to function without more stringent command and
control approaches.

3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA  TC \l2
" 

	3(a) Nonduplication  TC \l3 " 

Emission Reporting Requirements

	The EPA allows the direct reporting of point source data from sources
to EPA to satisfy this requirement if the sources are subject to the
monitoring and reporting requirements of 40 CFR Part 75.  The direct
reporting of data from sources to EPA minimizes the reporting burden on
Delaware and New Jersey.  Also, direct reporting avoids duplication of
effort for sources subject to the Part 75 requirements.  

Emission Trading Requirements

	Reporting requirements for affected sources for the CAIR NOX and SO2
Trading Programs are integrated with existing Part 75 reporting.  The
reporting formats are currently used by Acid Rain Program units under
Title IV of the Clean Air Act and were previously used by units subject
to the NOX SIP Call Trading Program implemented under Title I of the
Clean Air Act.  Thus, for units subject to Acid Rain or the CAIR
quarterly reporting requirements, or both, only one submission will need
to be made on a quarterly basis.

	3(b) Public Notice Required Prior to ICR Submission to OMB  TC \l3 " 

	On May 11, 2009, EPA published a Federal Register notice (74 FR 21802)
soliciting public comment on this ICR.  EPA received no comments.  EPA
will publish a second notice concurrent with the submission of this ICR
to OMB.

	3(c) Consultations  TC \l3 " 

						

Emission Reporting Requirements

	Prior to the publication of the final rule on April 28, 2006 (71 FR
25288), discussions were held with STAPPA/ALAPCO to clarify EPA’s
logic in developing the rule and to answer questions. 

Emission Trading Requirements

	The requirements for the CAIR Trading Programs have been developed
using both the methodology found in existing trading programs as well as
consultations with interested parties. EPA built on the cap and trade
strategy used in the Acid Rain Program, Ozone Transport Commission's NOX
Budget Program, and the NOX SIP Call.

	EPA held two workshops with states in the NOX SIP Call or OTC programs
to discuss lessons learned in those programs.  Additionally, EPA has
frequent interaction with affected sources and states in the course of
implementing the Acid Rain and NOX SIP Call Trading Programs.  EPA has
received comments following the workshops and through these less formal
interactions and considered and incorporated those comments into the
rule and ICR.

									

	Finally, as part of updating the ICR for the Acid Rain Program (Part
75) monitoring requirements, EPA contacted various affected parties to
gather information on CEM capital costs, CEM operation and maintenance
costs, fuel meter capital costs, and CEM/fuel meter testing costs.  That
information has been used in this ICR where appropriate.

	

	3(d) Effects of Less Frequent Collection  TC \l3 " 

Emission Reporting Requirements	

	

	The submittal dates required for reporting of emissions data to EPA
have been established to minimize the burden on Delaware and New Jersey,
but also to ensure that Delaware and New Jersey are collecting timely
and sufficient emissions inventory data to support their air pollution
control efforts.  A statewide inventory compiled at least every 3 years
for all point, nonpoint, and mobile sources is considered important to
assist Delaware and New Jersey in meeting various Clean Air Act
requirements.

	If the information collection were not carried out every 3 years for
all sources and annually for major point sources, the EPA would not be
able to maintain a central, national repository of emissions data from
which to extract updated information needed to fulfill EPA mandates.

	If this information collection were not carried out annually for
sources being controlled to meet the SO2 and NOX budgets, EPA would not
be able to verify that emission reductions necessary to meet Delaware
and New Jersey’s SO2 and NOX emission budgets were being achieved.

	In addition, a triennial report of all NOX sources statewide is vital
in enabling EPA to track Delaware and New Jersey’s progress towards
meeting the NOX budgets.  Because the SO2 and NOX budgets prescribed
have been deemed essential in order for downwind States to attain the
NAAQS in a timely manner, data collected less frequently would be of
little or no use.  

Emission Trading Requirements

 	Submittal of allowance trading information and emissions information
on an annual basis provides necessary feedback on the requirements of
the program, especially whether the program caps have been maintained. 
If this information collection were not carried out annually for sources
being controlled to meet the SO2 and NOX budgets, EPA would not be able
to verify that emission reductions necessary to meet each State’s SO2
and NOX emission budgets were being achieved.  Because the SO2 and NOX
budgets prescribed have been deemed essential in order to aid downwind
States in attaining the NAAQS in a timely manner, data collected less
frequently would be of little or no use.

	Quarterly collections of emissions data 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 reporting period both for regulated sources and for EPA.  This would
slow down the process for the verification of compliance.

	3(e) General Guidelines  TC \l3 " 

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

	3(f) Confidentiality  TC \l3 " 

	 Any data that is submitted to EPA under this rule will be considered
in the public domain and cannot be treated as confidential. 

	As required by Section 114 of the Clean Air Act, estimates or
measurements of emissions must be treated as non-confidential.  Under
Agency procedures, data items relating to the computation of emissions
may be identified as sensitive by a State and are then treated as
“State-sensitive” by EPA.  The potentially State-sensitive items
include the following: process rate, boiler design capacity, emission
estimation codes, percent space heat, operating rate, and maximum
operation rate/hour.  Where Federal and State requirements are
inconsistent, the appropriate EPA Regional Office should be consulted
for final reconciliation.

	3(g) Sensitive Questions

	This information collection does not ask any questions concerning
sexual behavior or attitudes, religious beliefs, or other matters
usually considered private.  

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED

	4(a) Respondents/Standard Industrial Classification (SIC) Codes  TC \l3
" 

	The emissions data required by the rule will be submitted by Delaware
and New Jersey’s air pollution control agencies.  Delaware and New
Jersey must report to EPA each year a set of specified data elements for
all sources subject to new controls adopted specifically to meet the
CAIR requirements related to PM2.5, unless the sources participate in an
EPA-administered emissions trading program.  The affected SIC code would
be 9511 - Air and Water Resource and Solid Waste Management [NAICS 92411
Administration of Air and Water Resource and Solid Waste Management
Programs], which includes governmental environmental protection and
control agencies, and pollution control agencies. 

	This ICR also estimates a burden for affected industry sources to
monitor SO2 and NOx mass emissions and demonstrate compliance with SO2
and NOx control measures.  Sources may report data directly to EPA if a
source is required to meet the monitoring and reporting requirements of
Part 75.  Delaware and New Jersey control large electric utility sources
to ensure compliance with their SO2 and NOx emissions budgets.  Electric
utility combustion sources are generally classified as either SIC 4911 -
Electric Services, or 4931 - Electric and Other Services Combined [NAICS
221112 Electric Power Distribution].

	4(b) Information Requested  TC \l3 " 

Emission Reporting Requirements

	The CERR and NOX SIP Call established the basic emission reporting
requirements, and the associated burden is covered under ICRs 0916.13
and 1857.04, respectively.  The CAIR changes some of these requirements
such that the previously accounted for reporting burden also changes. 
Only the changes to the CERR and NOX SIP Call reporting requirements
that change reporting burden are discussed here.

	 Respondent activities

	For the emission inventory reporting requirements of the CAIR,
respondent activities are very similar to what has been required to
satisfy reporting under CERR and the NOX SIP Call.  The previous
iteration of this ICR, which preceded the final rule, covered a one-time
state burden item of reading the reporting requirements of the rule. 
For this ICR, there are no specific State respondent activities
associated with the CAIR that differ from the existing CERR and NOX SIP
Call requirements.

Emission Trading Requirements

	This section describes 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.

		(i)  Data Items, Including Recordkeeping Requirements

			(a) Allowance Tracking

	There are several data items required for allowance tracking
activities.  First, the affected source must submit account certificates
of representation for the CAIR designated representative and (if
desired) alternate CAIR designated representative.  This documentation,
found in 40 CFR §§ 96.113 and .213, must include:

Identification of the source and unit,

Dates on which the unit commenced operation and commenced commercial
operation,

Name and contact information for the CAIR designated representative and
alternate,

A list of the owners and operators of each source and unit, and

A certification statement and signature of the CAIR designated
representative and alternate.

	Certification applications are to be kept for a period of 5 years
pursuant to the general requirements imposed for Title V permitted
facilities.

			(b) Permitting

	The basic requirement for permitting will be an application for a
permit revision to a source's operating permit issued under Title V of
the Act.  Although there is some possibility that a non-Title V source
could be affected under the CAIR Trading Program, all affected sources
are assumed to be Title V sources for purposes of this ICR.  Except for
the permit revision application, all of the other monitoring, reporting
or recordkeeping requirements associated with Title V permitting are
either part of the baseline Title V requirements or are covered
separately under section 4(c).  Title V permit applications must be kept
for 5 years pursuant to Title V recordkeeping requirements.  In
addition, coal-fired units that are not part of the Acid Rain Program
are expected to have to apply for a permit to construct under Title I of
the Clean Air Act. 

			(c) Monitoring and Reporting

	Affected trading program sources are required to monitor annual SO2 and
NOX mass emissions, and record and report emissions data using the
requirements of 40 CFR Part 75.  The 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.

	Respondents are required by 40 CFR 75.64 to submit the quarterly SO2
and NOX mass emissions data electronically, by direct electronic
submission to EPA, and must also include a certification statement by
the designated representative of the unit.  All monitoring records are
to be kept for three years, with one possible exception under a
voluntary option for fuel flowmeter calibration testing.

	(ii)  Respondent Activities

	The primary tasks that will be performed by trading program respondents
to meet the emissions monitoring requirements are (1) completing and
submitting appropriate monitoring plan information 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.  In addition, respondents will have to
purchase the necessary monitoring hardware and purchase the electronic
data reporting software (or software upgrades).  For nearly all units in
Delaware and New Jersey that are affected by CAIR, the burden associated
with these activities, including the allowance tracking, permitting and
monitoring and reporting requirements, is already covered in the
existing CAIR ICR (i.e., ICR 2152.03).  The only additional activities
that need to be accounted for in this ICR renewal are the additional
allowance transfer, SO2 monitoring, and annual reporting requirements
for those sources that were previously only affected by ozone-season NOx
requirements (i.e., NBP units in Delaware and New Jersey that are not
affected by the ARP).     

		

THE INFORMATION COLLECTED–AGENCY ACTIVITIES, COLLECTION METHODS, AND
INFORMATION MANAGEMENT

	

	5(a) Agency Activities  TC \l3 " 

Emission Reporting Requirements

	The EPA activities associated with the rule include:

•	Receiving, reviewing, and storing emission inventory data submitted
by each State;

•	Processing and updating data submitted by States, including
performing quality assurance of data, and coordination of efforts to
resolve errors and anomalies; and

•	Fulfilling information requests.

Emission Trading Requirements

		

	The major EPA activities related to the CAIR Trading Program include
(1) maintenance and administration of the SO2 and NOX allowance tracking
systems, (2) reviewing permit applications, (3) reviewing monitoring
plans and certification applications, (4) processing, reviewing and
evaluating reports of quarterly emissions data from affected units, (5)
calculating/reviewing annual emissions from affected sources, and (6)
reviewing total annual emissions data submitted to track each State’s
progress toward meeting its budgets and creating a summary report of
emissions.  EPA will use a computer system to track and maintain
monitoring and emissions information.  EPA will also answer respondent
questions and conduct audits of data submissions.

	5(b) Collection Methodology and Management  TC \l3 " 

Emission Reporting Requirements

	The EPA has establishing a central repository of inventory data for all
States termed the National Emissions Inventory (NEI) database. 
Emissions inventory data reported electronically will be stored in the
NEI database and used by the EPA and by other States for air modeling,
tracking progress in meeting Clean Air Act requirements, setting policy
and answering questions from the public. 

	The EPA has created and maintains the NEI database as a central
repository of inventory data for all States, but the data must be
supplied by the States in electronic form.  The EPA currently requires
that States use the NEI Input Format (NIF) for electronic data
reporting.

Emission Trading Requirements

		

	To ensure consistency region-wide and to expedite data entry, EPA will
require that standard formats used for Part 75 reporting be used to
submit the information collected for the CAIR SO2 and NOX Trading
Programs.

	Several computer systems and associated databases have been developed
to (1) track allowances, (2) record quarterly emissions monitoring data,
and (3) calculate the number of allowances to be deducted each year. 
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 EPA also has established a Clean Air Markets Page on the Internet,
which includes detailed information collected from emissions reports. 
Those without access to the Internet may use the Clean Air Markets
Hotline to request information, including summary reports.  The Agency
expects to rely on these electronic means to disseminate information
about the CAIR Trading Program as the program is developed and
implemented.

	5(c) Small Entity Flexibility  TC \l3 " 

Emission Reporting Requirements

	State and Territorial control agencies are not considered to be small
entities.  According to EPA’s ICR Handbook, OMB’s definition for a
small entity includes small governmental jurisdictions with populations
of less than 50,000.  According to 1999 population data from the U.S.
Census Bureau, no State or Territory has a population below this
threshold.  However, certain local air pollution agencies may be in
charge of individual counties or multi-county areas whose population is
less than 50,000.

	These local agencies have had experience compiling their 2002
inventories that were submitted to EPA in June 2004 as required by the
CERR. The emission reporting requirements in CAIR are estimated to
result in a net burden reduction for the reporting agencies.

Emission Trading Requirements

	The CAIR Trading Program includes fossil fuel-fired units (stationary
boilers, combustion turbines, and combined cycle systems) that serve an
electrical generator of capacity greater than 25 MWe.  Units with a
lower capacity are not included because of the high cost of monitoring
emissions from these sources and the de minimis nature of their
emissions.

	There is one small unit provision applicable to the CAIR Trading
Program which provides for reduced monitoring.  The low mass emissions
provisions (40 CFR 75.19) allows optional reduced monitoring, quality
assurance, and reporting requirements for units that combust natural gas
and/or fuel oil and that emit no more than 100 tons of NOX annually
provided that no more than 50 tons of NOX is emitted in the ozone season
(May 1 – September 30) and no more than 25 tons of SO2 annually and
that calculate no more than the same amount based on specified
procedures for calculating and reporting emissions.  Utilities that
qualify are not required to keep monitoring equipment installed on (or
conduct 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 "low mass
emissions unit" provisions, the monitoring provisions of Part 75 do
allow for the use of alternative methods to determine emissions.  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 gas or oil-fired units, especially
very small utilities (see p. 5-14 of that RIA document).  This analysis
remains relevant to this rulemaking.

	5(d) Collection Schedule  TC \l3 " 

	There are no requirements in the CAIR that will impact the reporting
schedule for Delaware and New Jersey.

6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

	6(a) Estimating Respondent Burden  TC \l3 " 

Emission Reporting Requirements

	The respondent burden for complying with the reporting requirements of
the rule is estimated incremental to the burden associated with existing
annual inventory and periodic inventory reporting requirements. 

	In general, States already have mechanisms in place for reporting
emissions data to EPA under the existing CERR and NOX SIP Call inventory
requirements.  As specified in Section 4(b)(i) of this supporting
statement, there are no significant changes that Delaware and New Jersey
will face in existing reporting to EPA. 

	

Emission Trading Requirements

	This section estimates the paperwork burden and cost of submitting
permit applications, allowance tracking and transfer materials
(including applications for early reduction credits), submittal of
monitoring plans, obtaining certification of each monitoring system,
conducting monitor quality assurance activities, and recording and
reporting data from CEM systems (or approved alternatives).  The burden
associated with many of these activities is already included in the
existing ARP and CAIR ICRs for the affected units in Delaware and New
Jersey.  

	To estimate the burden and/or cost of each incidence of the various
rule revisions, EPA had available prior estimates of the costs of
various activities, estimates provided by affected utilities in comments
to the Agency, and estimates based on the Agency's experience in
implementing the existing trading programs. 

	All units in Delaware and New Jersey that are likely to be affected by
this rule have already been regulated by the Acid Rain Program or the
NOX SIP Call trading program or both.

	The CAIR Trading Program requires all affected sources to monitor a NOX
emission rate, SO2 emission rate and heat input in order to determine
NOX mass emissions and SO2 mass emissions.  Affected gas and oil-fired
units may elect to use a SO2 emissions rate CEM and a fuel flowmeter. 
In addition, peaking units that burn natural gas and/or fuel oil may use
an alternative method for calculating NOX emission rates.  EPA will also
allow certain low mass emissions units to use assumed emissions factors
together with operational data to calculate emissions.

	For purposes of this ICR, burdens and costs are calculated only in
terms of incremental impacts resulting from this rule.  It should be
noted that the labor hour and cost estimates per unit identified in this
document, represent the weighted average burden and cost for all units
and do not represent the actual burden and cost for a particular unit.

	Units subject to Acid Rain and NOX SIP Call requirements will incur
only labor burdens associated with permit applications and certain
allowance transactions.  These units will not incur additional burdens
(or capital and operating and maintenance costs) as a result of the rule
since they have already installed and are operating a CEMS (or approved
alternative) and meet Part 75 requirements for both SO2 and NOX.

	Units subject only to NOX SIP Call requirements are already required to
meet the monitoring and reporting requirements in Part 75 for NOX. 
These units have been required to calculate and report hourly, quarterly
and ozone season or annual NOX mass emissions.  These sources will
continue monitoring and reporting NOX mass emissions.  These sources
will need to monitor and report NOX mass emissions year round; therefore
needing to modify operational practices but not purchase any equipment. 
However, the existing ICRs do not assume any difference in burden
between NOx SIP Call/CAIR units that opt to report on an ozone season
versus annual basis, because the difference is expected to be slight. 
Thus, the existing CAIR ICR already assumes year-round reporting for
sources subject only to the CAIR ozone season program.  There will also
be labor burdens associated with permit applications, certain allowance
transactions, and some additional emission collection and reporting, and
the installation of systems to measure SO2 in accordance with Part 75. 
These sources will need to make some additions to their existing
monitoring systems to account for SO2 mass emissions, but will not need
to install a full monitoring and reporting system in order to comply
with the monitoring and reporting requirements in the CAIR SO2 Trading
Program.  As a result, these units will incur additional capital and
other operating costs.  Finally, these units are expected to incur some
costs associated with upgrading the data acquisition and handling system
(DAHS) to collect the new SO2 and additional NOX data for this program.

	In 2009, sources in Delaware and New Jersey are subject to the CAIR
Trading Programs NOX monitoring and reporting requirements as well as
the SO2 monitoring and reporting requirements.  The current CAIR ICR
(2152.03) covers the burden associated with meeting the CAIR NOx ozone
season program.  This ICR only includes the incremental burden for
meeting the CAIR annual trading program for NOx and SO2.  Compliance
with the emissions caps (with allowance holding requirements) began in
2009 for NOX and will start in 2010 for SO2.  Table 6-2 shows the
incremental burden associated with monitoring SO2 and NOX under CAIR
trading programs at the sources in Delaware and New Jersey.

	The primary tasks performed by owners and operators of affected units
are (1) permitting, (2) monitoring, recording, and reporting emissions
data, (3) allowance trading activities and (4) submittal of the year end
compliance certification.

	(i)  Permitting.

	Each affected entity had to submit a permit revision application to
include in the source's Title V permit the necessary conditions related
to compliance with the CAIR Trading Programs.  The Agency believes that
this application should be relatively routine, and that a standard
method of incorporating the requirements by reference or a standard set
of permit conditions is available.  The Agency estimated that, on a per
unit basis, about 4 managerial hours will be required to revise the
Title V permit.  No burden for this activity is expected in 2009 and
subsequent years because the activity should be complete.  For new units
or facilities, the CAIR ICR adequately accounts for these burdens, with
no additional burdens to include the annual trading program
requirements.

	Some sources may also construct additional facilities to meet the CAIR
requirements, and therefore must complete a permit to construct
application.  For the initial ICR, the Agency estimated that this
requirement would be necessary for all coal-fired units that are not in
the Acid Rain Program and that the task would take 20 hours of
managerial and 20 hours of technician time, per permit.  This activity
is expected to be completed by 2009, and thus no ongoing burden in this
area should occur. 

	(ii)  Monitoring.

	For monitoring, the burdens differ greatly based on the amount and type
of monitoring the unit is already subject to and the particular subtask
of monitoring being conducted.  The specific elements of burden are:

		Start-up Activities.  A large part of start-up activities involves
capital and test contractor costs.  However, the owner or operator will
incur some labor burden for these activities, as applicable.  For Acid
Rain units, the rule imposes no start-up burdens beyond existing
programs. For non-Acid Rain units, the burdens reflect arranging for SO2
CEMS purchase (as required) and oversight of the certification process.

		Regulatory Review.  The ICR includes an allocation of time for the
managerial and technical staff to review the regulatory requirements and
the electronic data reporting formats and instructions (using EPA’s
Emissions Collection and Monitoring Plan System or ECMPS).  Affected
units in Delaware and New Jersey are expected to be relatively familiar
with the trading program requirements because of similar Acid Rain and
NOX SIP Call requirements and therefore the incremental burden is
expected to be 1 hour of managerial and technician time each year.

		DAHS Debugging.  Based on experience with the Acid Rain Program, some
effort will be involved to fix problems with the DAHS software used to
report using ECMPS.  This burden is assumed to fall primarily on units
that are not affected under either the Acid Rain or NOX SIP Call
programs.  Since all units in Delaware and New Jersey will be familiar
with this process it is estimated that 1 managerial and 4 technician
hours will be required each year for this activity.

		Monitoring Plans.  The regulations require submittal of monitoring
plans.  Because most of the monitoring plan elements are now submitted
electronically through ECMPS, the effort involved in developing and
maintaining the plans are incorporated into the overall reporting burden
estimate.

		Monitor Certification/Recertification.  Initial certification burdens
and costs for new monitoring equipment are addressed above under
start-up activities since these costs are often part of the overall
purchase expense for the equipment.  For some non-Acid Rain units,
however, there will be burdens associated with certifying existing
monitors used under other programs for this program, as well as burdens
for recertification to the extent a change in a monitoring system
requires recertification.  EPA estimates that approximately 10% of all
units will have to recertify each year following the year in which the
initial certification occurs.  The ICR incorporates a labor burden
estimate generally consistent with existing Agency models for the labor
burdens associated with certification.  However, note that the ICR
reduces the labor hours for this activity to avoid double counting hours
that are already accounted for in the quality assurance activity area
(see the following subsection).  The double counting would occur because
a portion of the labor incurred for the certification or recertification
event replaces the labor burden that is generally allocated to the
annual relative accuracy test audit (RATA) in the year in which the
certification event occurs.  

		Quality Assurance.  Quality assurance (QA) activities and other
routine maintenance for monitoring systems are the largest burden items
under the CAIR Trading Programs.  These requirements generally include
daily, quarterly and annual QA requirements, depending on the monitoring
approach being used.  For reporting units that use a CEMS, the Agency
has assumed a per unit labor burden based on a variety of sources,
including the existing Acid Rain Program ICR, the existing NOX SIP Call
ICR, information provided by Acid Rain Program sources, a CEM cost model
developed by EPA, and comments submitted in response to the section 110
SIP Call for ozone transport.  For units that rely on alternative
methodologies, reduced labor burden estimates apply because the quality
assurance activities for the excepted methods are less than for a CEMS. 
Consistent with the existing Acid Rain Program ICR, the labor burden is
expected to be almost entirely technician labor. 

		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 managerial review.  The existing Acid Rain
Program ICR was used as the basis for these estimates.

		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 is 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.

Allowance transaction activities. 	

The Agency anticipates the average number of additional allowance
transactions will be approximately 100 per year beginning in 2008.  A
portion of all units will likely conduct transactions in each year
solely as a result of this program.  The Agency believes that each
transaction will involve about 1 hour each of managerial and technician
time.

	6(b) Estimating Respondent Costs  TC \l3 " 

	

	Table 6-1 presents the burden associated with the activities covered
under this ICR for state and local respondents.  Table 6-2 summarizes
the annual industry respondent costs for those units for which the
additional incremental burden associated with the inclusion of Delaware
and New Jersey applies.  The following discussion describes how the
costs were derived.

		(i) Estimating Labor Costs

	For this ICR, the labor rate used for technical staff at State agencies
is $39.51 per hour, and the labor rate for managerial employees at State
agencies is $48.32.  These labor rates include benefits and overhead. 
These labor rates are derived from data shown on the U. S. Department of
Labor, Bureau of Labor Statistics, web site at
http://stats.bls.gov/news.release/ecec.t03.htm.  Wage and salary rates
are given in Employee Costs for Employee Compensation “Table 3.  State
and local government, by major occupation and industry group (March
2009).”  The wage and salary rates from this table account for
benefits provided to workers.  As shown in Table 6-1, when considering
both technical and managerial hours, labor costs for State and
Territorial agencies are estimated to be $8,868 per year per respondent.
  As shown in Table 6-2, EPA used the following labor rates for industry
respondents:  $83.43 per hour for managers and $58.00 per hour for
technicians.  These rates are consistent with those used in the existing
CAIR ICR.

		(ii) Estimating Capital and Operations and Maintenance Costs  TC \l4 "


Emission Reporting Requirements

	EPA has concluded that the Capital and Operations and Maintenance Costs
estimated under the CERR and the NOX SIP Call are sufficient to
accommodate the modest changes in reporting burden for CAIR.  Therefore,
no estimate of Capital and Operations and Maintenance Costs were made
for this ICR.  

Emission Trading Requirements

	Capital/start-up costs include the cost of installing required CEMS or
alternatives.  Operation and maintenance costs (exclusive of labor
costs) reflect ongoing costs to a unit and 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).  These cost estimates have been derived
from EPA CEM cost models, existing ICRs, Agency staff experience under
the Acid Rain and NOX SIP Call programs, and supplemental estimates
provided by affected utilities and others related to the various cost
items.  

	Acid Rain affected units are not expected to incur any non-labor costs
associated with this program.  They are already monitoring and reporting
SO2 and NOX year round.  Non-Acid Rain units will need a DAHS upgrade,
estimated at $4,000 per unit and an SO2 analyzer for $42,525.

	Note that testing contractor costs for certification, recertification
and annual relative accuracy test audits (RATAs) 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 RATAs.  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.

	The Agency also notes that this ICR does not include a cost for the
purchase of monitoring equipment for all affected units.  Many sources
covered by the CAIR Trading Programs are already required to have CEMS
under other regulatory programs.  Therefore, to the extent that no new
equipment is needed by these sources, capital costs are not included
because those costs were included in the ICRs of those other programs. 
Thus, the capital and other costs included in Table 6-2, represent
weighted average costs for each respondent, not the total individual
cost for any particular respondent.

		(iii)  Capital/Start-up vs. Operating and Maintenance (O & M) Costs

	Capital costs for emissions trading reflect one-time costs for purchase
of equipment that will be used over a period of years.  Conversely,
operating and maintenance costs are those costs that 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.

		(iv)  Annualizing Capital Costs

	The relevant capital costs for the emissions trading portion of this
ICR were annualized at a rate of 7%, (i.e., the annualized capital cost
was calculated assuming money to purchase the capital equipment was
borrowed at a 7% annual interest rate).  The cost of the loan was
amortized over the life of the loan to repay original borrowed amount
plus interest.  The result is the annualized capital cost reported.  

	(6)(c) Estimating Agency Burden and Costs

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.  However, it is assumed that there is little burden to Agency
staff in addition to the burden already estimated and included in ICR
2152.03 because the CAIR ICR assumes all sources submit reports on an
annual basis, even for the CAIR NOx ozone season program.  With
additional SO2 data, EPA estimates that the Agency burden would be one
hour per report.  Assuming that affected sources will submit 126
emissions reports to EPA per quarter, the total annual burden incurred
by the Agency will be 504 hours. The total annual cost to EPA to
process, review, and evaluate these quarterly emissions reports will be
approximately $24,575. 

Federal Agency labor rates were assumed to be $48.76 per hour. This
labor rate was derived from the federal government’s 2009 General
Schedule published by the U.S. Office of Personnel Management using the
factors in the following table.

Determination of Federal Wage Rates

Annual Salary, Technical Staff, GS 11 Step 3

$52,846

Annual Salary, Supervisory Staff, GS 13 Step 3	$75,323

	Factor (1/11)	0.09	$  6,779

Annual Cost of Support Staff, GS 6 Step 6	$35,145

	Factor (1/8)	0.13	$  4,569

Annual Applicable Salary of Permit Staff

$64,194

Benefits (16%)

$  10,271

Sick Leave/Vacation (10%)

$  6,419

General Overhead (32%)

$20,542

Total Cost per FTE

$101,426

Total Hourly Cost (total per FTE dividend / 2,080 hours per year)

$  48.76

 

	6(d) Estimating the Respondent Universe and Total Burden and Costs  TC
\l3 " 

Emission Reporting Requirements

	The number of respondents is 2 States.  The burden associated with the
emission reporting requirements for these states is already covered in
the ICRs for CERR and other programs.   

Emission Trading Requirements

	The number of industry respondents varies depending on the activity in
question.  Activities such as title V permit application or processing
allowance transfers can involve approximately sixty sources.  The number
of units which will be required to install a particular type of
monitoring equipment will be less since many sources already have
monitoring equipment especially since they are in the NOX SIP Call
region.  Table 6-1 provides estimates of State burden.  These burdens
include activities associated with participating in an emissions trading
program.  Table 6-2 provides estimates of the industry burden starting
in 2009.  This burden includes monitoring, reporting and other
activities involved in participating in an emissions trading program. 
The total number of respondents is estimated to be 60 facilities. 

	6(e) Bottom Line Burden Hours and Cost Tables   TC \l3 " 

	Total Estimated Respondent Burden and Cost Summary

	Number of

Respondents	Total Hours

Per Year for all Respondents	Total

Costs Per Year for all Respondents

State Respondents	2	440	$17,737

Industry Respondents	~ 60	1,894	$218,188



	6(f) Reasons for Change in Burden  TC \l3 " 

Emission Reporting Requirements

	There is no emission reporting burden in addition to the burden already
incorporated in the existing CERR and NOx SIP Call ICRs.  The prior ICR
included a one-time estimate of 1 hour per state to read the rule
requirements.  

Emission Trading Requirements

	The burden associated with this rule is a result of the costs of
monitoring, certifying, quality assuring and reporting emissions data
from large electric generating units regulated under the rule.  This
burden is reduced as a result of the integration of these monitoring and
reporting requirements with those already required under the Acid Rain
and NOX SIP Call trading programs.  Otherwise, the burden would be
significantly higher and the number of sources would be greater.  In
addition, most of the burden associated with Delaware and New Jersey
sources affected by CAIR is covered under the existing CAIR ICR.  The
change in burden from the previous ICR primarily reflects removal of
certain one-time burdens. 

	6(g) Burden Statement  TC \l3 " 

	For purposes of this ICR, reporting of emissions data required by the
CAIR is estimated to be small for State air pollution control agencies
in DE and NJ given the burden already incorporated in the existing ICRs
for the CERR, NOx SIP Call and CAIR. Monitoring and reporting emissions
under the CAIR Trading Programs is estimated to involve up to 32 hours
per year for industrial sources and most of this burden is also covered
under existing ICRs.  This estimate considers the most hours expected
for a source.  With acceptable variations in monitoring methodologies,
many sources will spend much less time each year meeting these
requirements.

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 4 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-2009-0295, which is available for online viewing at
www.regulations.gov, or in person viewing at the Air and Radiation
Docket and Information Center in the EPA Docket Center (EPA/DC), EPA
West, 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 and Information Center is (202) 566-1742.  An
electronic version of the public docket is available at
www.regulations.gov.  This site can be used to submit or view public
comments, access the index listing of the contents of the public docket,
and to access those documents in the public docket that are available
electronically.  When in the system, select “search,” then key in
the Docket ID Number identified above.  Also, you can send comments to
the Office of Information and Regulatory Affairs, Office of Management
and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk
Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OAR-2009-0295 and OMB Control Number 2060-0584 in any
correspondence.



Table 6-1.  Annual State Respondent Burden and Cost by Activity

	Hours and Costs Per Respondent	          Total Hours and Costs

Information Collection or Trading Rule Activity	Mgr.

$48.32/Hr1	Tech.

$39.51/Hr1	Respondent

Hours/Year	Labor

Cost/Year	Number of

Respondents	Total

Hours/Year	Total

Cost/Year

Annual







	Trading Program related (monitoring certifications, audits)	20	200	220
$8,868.40	2	440	$17,736.80



1   See Section 6 (b) (i) for labor and overhead rates. 

															

Table 6-2.  Annual Industry Respondent Burden and Cost by Activity,
2009 and subsequent years

	Mgr.	Tech.

Respondent	 Annual Capital 

Total



$83.43 	$58.00 	Respondent	Labor	 Startup 	 O & M 	Number of	Hours/	
Total 

	/Hour	/Hour	Hours/Year	Cost/Year	 Costs 	 Cost 	Respondents	Year	
Cost/Year 

Information Collection Activity	2009	2009	2009	2009	2009	2009	2009	2009
2009











	Title V permit application	0	0	0	$     0 	                             
-   	                   -   	0	0	$ 0.00

Permit to Construct	0	0	0	$  0 

		                              -   	                   -   	0	0	 $  
0.00











	Startup/ Capital Items









	~ nonAR Sources in PM States in SIP Call region









	    a. add SO2 monitoring	13	3	16	$  1,258.59 	 $ 6,417.00 	           
       -   	2	32	 $ 15,351.18

    b. DAHS modification

				2	4	6	$     398.86 	 $    604.00 	                   -   	92	552	 $
92,263.12











	Review Instructions and Requirements















                              -   	                   -   



	~ nonAR Sources in PM States in SIP Call region	1	1	2	$     141.43 	   
                          -   	                   -   	92	184	 $
13,011.56























Debug Computer Software









	~ nonAR Sources in PM States in SIP Call region	1	4	5	$     315.43	    
                         -   	                   -   	92	460	 $
29,019.56 











	Certify Monitors









	~ nonAR Sources in PM States in SIP Call region









	    a. SO2 monitor	5	16	21	$  1,345.15 	                              -
  	 $  2,817.00 	2	42	 $   8,324.30











	Perform QA Testing and Maintenance









	~ nonAR Sources in PM States in SIP Call region









	    a. SO2 monitor	10	200	210	$12,434.30 	                             
-   	 $10,462.00 	2	420	 $ 45,792.60











	Year-End Compliance Activities 

~ Assure Data Quality, Prepare Reports, Submit Reports	1	1	2	141.43

	2	4	282.86











	~ Allowance Transfers	1	1	2	$    141.43 	                             
-   	                   -   	100	200	 $  14,143.00























TOTAL







1,894	 $218,188.18



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