SUPPORTING STATEMENT
ENVIRONMENTAL PROTECTION AGENCY

Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units
 (40 CFR Part 60, Subpart UUUU) 
July 2015
Part A of the Supporting Statement
1.	Identification of the Information Collection
1(a)	Title and Number of the Information Collection
      "Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units (40 CFR Part 60, Subpart UUUU)." A new information collection request (ICR) has been prepared in support of the guidelines being promulgated. The EPA ICR tracking number is 2503.02. This ICR was developed for the 3-year period following publication of the final rule.
1(b)	Short Characterization/Abstract
Pursuant to Clean Air Act (CAA) section 111(d), the United States Environmental Protection Agency (EPA) is issuing rate-based goals for states and tribes regarding emissions of greenhouse gases, specifically carbon dioxide (CO2), from existing electric utility generating units (EGUs) burning fossil fuels, as well as emission guidelines for developing plans to attain these goals. For purposes of these guidelines, fossil fuel-fired EGUs include fossil fuel-fired steam generating units, integrated gasification combined cycle (IGCC) units, and stationary combustion turbines that generate electricity for sale and are larger than 25 megawatts (MW). Existing sources include those EGUs that commenced construction on or before January 8, 2014.
The EPA is issuing these guidelines because CO2 is a greenhouse gas (GHG), and fossil fuel-fired power plants are the country's largest stationary source emitters of GHGs. The EPA in 2009 found that by causing or contributing to climate change, GHGs endanger both the public health and the public welfare of current and future generations.
      This final action requires those states with one or more EGUs covered under this subpart to develop plans to implement the emission guidelines and submit plans to the EPA for approval. For areas of Indian country with affected sources, if the EPA determines that a plan is necessary or appropriate, the EPA has the responsibility to establish a plan, unless a tribe on whose lands an affected source is located seeks and obtains authority from the EPA to establish a plan itself. If an approvable state or other jurisdictional plan is not submitted by the deadline for that plan, the EPA will implement the emission guidelines in those states and tribal lands under a federal plan developed according to 40 CFR 60.27. Owners and operators of EGUs that are not covered by an approved jurisdictional plan must comply with the federal plan. The federal plan is an interim action and will be automatically withdrawn for a particular state or tribe when the jurisdictional plan is approved. If a federal plan is in place during the interim period beginning in 2022 or the final period beginning in 2030, and the state submits and the EPA approves a jurisdictional plan, the federal plan will not be withdrawn until the end of the performance period. Those states that have no EGUs for which construction commenced on or before January 8, 2014 would submit a negative declaration letter in place of the state plan. Tribal lands with no EGUs covered under this subpart would not be required to submit a negative declaration.
      
      The emission guidelines include required components of the state plan, provisions for working with other states to develop a combined plan, timing requirements for submitting the plan, annual goals for CO2 emission performance, compliance schedules, and affected sources (EGUs). Under the timing requirements provisions in the final guidelines, states and tribes (if they seek and obtain the authority to establish a plan) are given the option to submit their plans by the August 31, 2016 deadline or request a 2­year extension. If an extension is requested, an initial plan must be submitted in the first year that documents the reasons more time is needed and includes commitments to concrete steps that will ensure that a final plan will be submitted by the third year. In addition, a progress report must be submitted in the second year to demonstrate ongoing progress in plan preparation.
      
      This action imposes no new information collection burden on affected sources (EGUs) during the first 3 years after final rule promulgation beyond what those sources would already be subject to under the authorities of 40 CFR parts 75 and 98. The Office of Management and Budget (OMB) has previously approved the information collection requirements contained in the existing 40 CFR parts 75 and 98 regulations under the provisions of the Paperwork Reduction Act, 44 U.S.C. 3501 et seq. and has assigned OMB control numbers 2060-0626 and 2060-0629, respectively. There are no new information collection costs for these affected sources during the first 3 years, as the information required for these sources by the guidelines is already collected and reported by other regulatory programs during this period.

The only respondents expected to incur new information collection burden are those states and tribal lands with one or more EGUs covered under this subpart. Of the 48 contiguous states plus the District of Columbia, two (Vermont and the District of Columbia) have no EGUs covered under this subpart and are expected to submit negative declarations. The three tribal lands (Fort Mojave, Navajo Nation, and Ute) with EGUs covered under this subpart are expected to rely on the federal plan and not develop their own plan. One regional carbon management program, the Regional Greenhouse Gas Initiative (RGGI), is expected to submit a multi-state plan for the eight member states in their region that have EGUs covered under this subpart. Without information to the contrary, plans from 41 states and one multi-state region are assumed to be submitted by August 31, 2016, unless a 2-year extension is requested.  
2.	Need for and Use of the Collection
2(a)	Need/Authority for the Collection
      The EPA is charged under section 111(d) of the CAA to establish guidelines for existing stationary sources. Section 111(d)(1) states:

            "The Administrator shall prescribe regulations which shall establish a procedure similar to that provided by section 110 under which each State shall submit to the Administrator a plan which (A) establishes standards of performance for any existing source for any air pollutant (i) for which air quality criteria have not been issued...but (ii) to which a standard of performance under this section would apply if such existing source were a new source, and (B) provides for the implementation and enforcement of such standards of performance."

	Subpart B of 40 CFR part 60 requires the plans to include monitoring, recordkeeping, and reporting provisions consistent with the emission guidelines. In addition, section 114(a) states that the Administrator may require any owner or operator subject to any requirement of this Act to:

            "(A) Establish and maintain such records; (B) make such reports; (C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with section 114(a)(3); and (G) provide such other information as the Administrator may reasonably require."

As previously stated, the EPA in 2009 found that by causing or contributing to climate change, GHGs endanger both the public health and the public welfare of current and future generations. Fossil fuel-fired power plants are the country's largest stationary source emitters of GHGs. Therefore, emission guidelines for states concerning emissions of CO2 from existing sources in this category were proposed in June 2014 under 40 CFR part 60, subpart UUUU. A supplemental proposal for tribes was proposed in November 2014 under the same subpart. The emission guidelines provide guidance for developing plans to attain the CO2 emission performance goals. As noted previously, 41 states and one multi-state region are expected to develop and submit their own plans, while the three affected tribes are expected to rely on the federal plan and not develop their own plan.
2(b)	Use/Users of the Data
The data collected from respondents include the state plans expected to be developed in response to the emission guidelines. The data from states provide the foundation for identifying their emission performance levels and demonstrating how they will be achieved; identifying emission standards and compliance requirements for each affected entity; and specifying program implementation milestones. These emission performance levels, standards, compliance requirements, and milestones will be developed during the course of this ICR period.
3.	Nonduplication, Consultations, and Other Collection Criteria
3(a)	Nonduplication
As previously stated, this action imposes no new information collection burden on affected sources (EGUs) during the first 3 years after final rule promulgation, beyond what those sources would already be subject to under the authorities of 40 CFR parts 75 and 98. There are no new information collection costs; the information required by these guidelines is already collected and reported by other regulatory programs. Therefore, no duplication exists for the affected industry.
If a state plan is disapproved, the respondent (state) can respond to EPA's concerns and submit a revised plan. If an approvable plan is not submitted by the state, the EPA will implement a federal plan that applies to existing sources in the state. As noted previously, the three affected tribes are expected to rely on the federal plan and not develop their own plan. Consequently, the information would be submitted to the appropriate EPA regional office, until such time as the state or tribe is delegated this authority. Therefore, no duplication exists for states and tribes. 
3(b)	Public Notice Required Prior to ICR Submission to OMB
This section is not applicable because this is a rule-related ICR.
3(c)	Consultations
      The June 2014 proposed rule and the November 2014 supplemental proposal were developed after extensive and vigorous outreach to stakeholders and the general public. To carry out this stakeholder outreach, the EPA embarked on an unprecedented outreach effort to parties with an interest in reducing carbon pollution from existing power plants. From consumer groups to states to power plants to technology innovators, the EPA sought input from all perspectives.
      The EPA began the outreach efforts with a webinar and associated teleconferences to establish a common understanding of the basic requirements and process of CAA section 111(d). The August 27, 2013 overview presentation was offered as a webinar for state and tribal officials, "Building a Common Understanding: Clean Air Act and Upcoming Carbon Pollution Guidelines for Existing Power Plants." More than 360 people from across the country participated in the August webinar presentation--primarily from state environmental and energy offices.
      The overview presentation was also posted on the EPA website. The EPA followed up on the presentation by offering four national teleconference calls with representatives from states, tribes, industry, environmental justice organizations, community organizations and environmental representatives. The teleconferences offered a venue for stakeholders to ask questions of the EPA about the overview presentation and for the EPA to gather initial reactions from stakeholders. Stakeholders and members of the public continued to view and refer to the overview presentation throughout the outreach process. 
      The agency also provided mechanisms for anyone from the public to provide input during the pre-proposal development of this action. The EPA set up two user-friendly options to accept input during the pre-proposal period - a new email account: carbonpollutioninput@epa.gov; and a web-based form: http://www2.epa.gov/carbon-pollution-standards/forms/carbon-pollution-standards-contact-us. These links, along with policy, program, and technical information about this rulemaking effort, are available on the EPA's website at: http://www2.epa.gov/carbon-pollution-standards. The EPA has received more than 2,000 emails offering input into the development of these guidelines.  
      The agency has encouraged, organized, and participated in hundreds of meetings about CAA section 111(d) and reducing carbon pollution from existing power plants. Attendees at these various meetings have included states and tribes, members of the public, and representatives from multiple industries, labor leaders, environmental groups and other non-governmental organizations. The direct engagement has brought together a variety of states and stakeholders to discuss a wide range of issues related to the electricity sector and the development of emission guidelines under CAA section 111(d). The meetings occurred in Washington, DC, and at locations across the country. The meetings were attended by the EPA Regional Administrators, managers and staff and who will play key roles in developing and implementing the rule.
      Part of this effort included the agency's holding of 11 public listening sessions: one national listening session in Washington, DC and 10 listening sessions in locations in the EPA Regional offices across the country. Additionally, in July and August 2014, the EPA held four 2­day public hearings on the proposed emission guidelines. In November 2014, the EPA held a public hearing on the supplemental proposal in Phoenix, Arizona. All of the outreach meetings were designed to solicit policy ideas, concerns and technical information from stakeholders about using CAA section 111(d).
      Since fall 2013, the agency provided multiple opportunities for states to inform these guidelines. In addition, the EPA organized, encouraged and attended meetings to discuss multi-state planning efforts. The meetings provided state leaders, including governors, environmental commissioners, energy officers, public utility commissioners, and air directors, opportunities to engage with the EPA officials.
      Agency officials listened to ideas, concerns and details from states, including from states with a wide range of experience in reducing carbon pollution from power plants. The agency has collected policy papers from states with overarching energy goals and technical details on the states' electricity sector. The agency has engaged, and will continue to engage, with all of the 50 states throughout the rulemaking process. 
      While tribes are not required to, but may, develop or adopt Clean Air programs, the EPA conducted significant outreach to tribes. The EPA is aware of three coal-fired power plants and one natural gas plant located in Indian country but is not aware of any power plants owned or operated by tribal entities. 
      The EPA conducted outreach to tribal environmental staff and offered consultation with tribal officials in developing this action. Because the EPA is aware of tribal interest in this rule, the EPA offered consultation with tribal officials early in the process of developing the regulation to permit tribes to have meaningful and timely input into its development. The EPA sent consultation letters to 566 leaders of federally recognized tribes. The letters provided information regarding the EPA's development of emission guidelines for existing power plants and offered consultation.
      Tribes were invited to participate in the national informational webinar held August 27, 2013. In addition, a consultation/outreach meeting was held on September 9, 2013, with tribal representatives from some of the 566 tribes. The EPA representatives also met with tribal environmental staff with the National Tribal Air Association, by teleconference, on July 25, 2013; December 19, 2013; June 26, 2014; and August 4, 2014. In those teleconferences, the EPA provided background information on the GHG emission guidelines being developed and a summary of issues being explored by the agency. In addition, the EPA held a series of listening sessions prior to development of the June 2014 proposed rule and November 2014 supplemental proposal. Tribes participated in a session on September 9, 2013 with the state agencies, as well as in a separate session for tribes on September 26, 2013.
      The EPA also held a consultation with the Ute Tribe, Crow Tribe, and Mandan, Hidatsa and Arikara (MHA) Nation on July 18, 2014; a consultation with the Fort Mojave Tribe on August 22, 2014; a consultation with the Navajo Nation, Inter Tribal Council of Arizona (ITCA), Hopi Tribe, Fort Mojave Tribe, Fort McDowell Yavapai Nation, and Ak-Chin Indian Community on November 18, 2014; a consultation with the Ute Tribe on December 16, 2014; a consultation with the Gila River Indian Community on January 15, 2015; and a consultation with the Navajo Nation on April 28, 2015.
      This outreach process has produced a wealth of information. The EPA has taken information from these meetings and used it to inform the June 2014 proposed rule, November 2014 supplemental proposal, and this final rule. The outreach efforts far exceeded what is required of the agency in the normal course of a rulemaking process, and the EPA expects that a dialog with states and other stakeholders will continue even after the rule is finalized. The EPA recognizes the importance of working with all stakeholders, and in particular with the states and tribes, to ensure a clear and common understanding of the role the states and tribes will play in addressing carbon pollution from power plants.
3(d)	Effects of Less Frequent Collection
This section is not applicable because respondents for this 3-year ICR period do not include EGU facilities, and annual reports from states will be submitted after the 3-year ICR period.
3(e)	General Guidelines
None of the guidelines in 5 CFR 1320.5 are being exceeded.
3(f)	Confidentiality
All information submitted to the agency for which a claim of confidentiality is made will be safeguarded according to the agency policies set forth in Title 40, Chapter 1, part 2, subpart B - Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR 17674, March 23, 1979).
3(g)	Sensitive Questions
This section is not applicable because this ICR does not involve matters of a sensitive nature.
4.	The Respondents and the Information Requested
4(a)	Respondents/NAICS Codes
The respondents that would be expected to incur new information collection burden under subpart UUUU are those states and tribal lands with one or more EGUs covered under this subpart. As noted previously, an estimated 41 individual state plans and 1 multi-state plan are expected to be submitted by August 31, 2016, unless a 2-year extension is requested. Negative declarations are expected from one state (Vermont) and the District of Columbia. Tribes with one or more EGUs covered under this subpart (Fort Mojave, Navajo Nation, and Ute) are expected to rely on the federal plan. The applicable North American Industry Classification System (NAICS) code is 999200, "State Government, excluding schools and hospitals."
4(b)	Information Requested
 Data Items, Including Recordkeeping Requirements
There are no new information collection costs for the affected industry, as the information required by these guidelines is already collected and reported by other regulatory programs (40 CFR parts 75 and 98). The only new information collection costs are for those states with one or more EGUs covered under this subpart.
Respondents must make the following reports:
                                  Requirement
                        Guidelines Citation by Section
Plan to implement and enforce emission guidelines
60.5710 and 60.23(a)
Negative declaration letter documenting there are no affected EGUs in the state that are covered under the emission guidelines
60.5710
Request for extension to deadline for submitting a plan (as part of plan submittal)
60.5760 
Reports documenting progress towards meeting the emission performance rate/goal
60.5830
Notification of public hearing on the plan
60.23(d)
Certification that public hearing on the plan conducted according to subpart B procedures
60.23(f)

State respondents must also keep the following records:
                                  Requirement
                        Guidelines Citation by Section
Records of hourly values for each affected source to support the calculation of the annual emission performance goal
60.5825(c)
Records of public hearing conducted on the plan
60.23(e)
 Respondent Activities
The respondent activities required by the emission guidelines are described in the tables and footnotes in Exhibits 1a and 1b at the end of this document. Exhibits 1a and 1b include the respondent activities associated with developing and implementing the plans. Exhibit 1a accounts for states already having active energy efficiency programs in place for achieving their emission performance goals, whereas Exhibit 1b does not account for existing energy efficiency programs. The recordkeeping and reporting activities associated with documenting progress towards the annual emission performance goal would occur after the 3­year period of this ICR and, therefore, are not included in these tables.
 Summary of Requirements
      The guidelines require states covered under the emission guidelines to prepare and submit plans to implement the guidelines and conduct public hearings on the plans as necessary, according to the procedures in 40 CFR part 60, subpart B.
5.	The Information Collected: Agency Activities, Collection Methodology, and Information Management (covering the first 3 years following final rule promulgation)
5(a)	Agency Activities
The agency, specifically the EPA Headquarters and the EPA Regions, will incur burden associated with the reporting requirements for states, including: (1) providing support and outreach to states regarding the implementation of the emission guidelines and preparation of the plans, (2) reviewing and approving the plans, (3) reviewing negative declarations from states with no EGUs covered under the emission guidelines, (4) reviewing and approving extension requests, (5) reviewing notifications from states regarding public hearings on the plans, and (6) reviewing certifications from states that the public hearings were conducted according to 40 CFR part 60, subpart B procedures. 

5(b)	Collection Methodology and Management
The plans expected to be prepared by states will set forth the specifics regarding the actual collection methodology and management. The plan submittal must include the following components, which will be codified as part of the federally enforceable plan upon approval by the EPA:
 Identification of affected EGUs covered by the plan and all affected EGUs in the state that meet the applicability criteria in the emission guidelines, including an inventory of CO2 emissions from affected EGUs during the most recent calendar year for which data is available prior to the submission of the plan.
 Identification of all emission standards for each affected EGU, compliance periods for each emission standard according to the emission guidelines, and a demonstration that the emission standards are, when taken together, sufficiently protective to meet the applicable CO2 emission performance rates described in the emission guidelines.
 If the plan includes state measures, the plan must include a federally enforceable backstop that identifies emission standards for affected EGUs that will be put into place if there is an exceedance of 10 percent or greater of any interim step goal or final goal period. 
 Identification of applicable monitoring, reporting, and recordkeeping requirements for each affected EGU. These requirements must be consistent with or no less stringent than the requirements specified in the emission guidelines.
 Description of the process, contents, and schedule for state reporting to the EPA about plan implementation and progress, including information required under the emission guidelines.
 A requirement for a report to be submitted by July 1, 2021, that demonstrates that the state has met the programmatic milestone steps that it indicated it would take from the submittal of the final plan through the end of 2020, and that the state is on track to implement the plan as of January 1, 2022.

In addition to the components of the plan listed above, a final plan submittal to the EPA must include the following information, which must be submitted to the EPA but will not be codified as part of the federally enforceable plan upon approval by the EPA:
 A description of plan approach and the geographic scope of the plan (i.e., state or multi-state, geographic boundaries related to the plan elements), including, if applicable, identification of multi-state plan participants.
 Identification of CO2 emission performance rates or equivalent statewide emission goals that the affected EGUs will achieved through implementation of the plan.
 A demonstration that the affected EGUs covered by the plan are projected to achieve the CO2 emission performance rates or CO2 emission goals described in the emission guidelines.
 A demonstration that each affected EGU's emission standard is quantifiable, non-duplicative, permanent, verifiable, and enforceable according to the emission guidelines.
 If the plan includes only emission standards on the affected EGUs to meet either the CO2 emission performance rates or CO2 emission goals, the final plan submittal must include a demonstration, if necessary, that the standards will meet the CO2 emission performance rates or CO2 emission goals.
 If the plan includes state measures, in addition to or in lieu of the emission standards required in the emission guidelines, the final plan submittal must include (1) a description of the state measures, the applicable state laws or regulations, and identification of parties or entities implementing such state measures; (2) the schedule and milestones for the implementation of the state measures and a demonstration of the minimum emission, monitoring and verification requirements if the state measures rely upon renewable energy or demand-side energy efficiency programs and projects; (3) a demonstration that the federally enforceable emission standards and state measures are sufficient to attain the CO2 emission performance rates or CO2 emission goal for the interim and final periods; (4) a CO2 performance projection of the state measures that shows how the measures will achieve the future CO2 performance at affected EGUs; (5) a demonstration that the state measures will require affected EGUs to meet the CO2 emission performance rate or rate-based CO2 emission goal (if applicable); and (6) a demonstration that combined state-enforceable measures, along with any federally enforceable CO2 emission standards, will achieve the state mass-based CO2 emission goal (if applicable).
 The final plan submittal must demonstrate any regional information considered in developing the assumptions.
 The final plan submittal must include a demonstration that the reliability of the electrical grid has been thoroughly considered.
 Certification that a hearing required under §60.23(c)(1) on the plan was held, a list of witnesses and their organizational affiliations, if any, appearing at the hearing, and a brief written summary of each presentation or written submission.
 Supporting material for the plan, including (1) materials demonstrating the state's legal authority to carry out each component of its plan, including emission standards or state measures; (2) materials supporting that the CO2 emission performance rates or CO2 emission goals will be achieved by affected EGUs under the plan; (3) materials supporting any calculations for CO2 emission goals calculated under the plan; and (4) materials necessary to support evaluation of the plan by the EPA.
 5(c)	Small Entity Flexibility
      The EPA is aware that there is substantial interest in the rule among small entities (municipal and rural electric cooperatives). The EPA has conducted an unprecedented amount of stakeholder outreach on setting emission guidelines for existing EGUs. While formulating the provisions of the rule, the EPA considered the input provided over the course of the stakeholder outreach. As part of that outreach, agency officials participated in many meetings with individual utilities, as well as meetings with electric utility associations. Specifically, the EPA Administrator, Gina McCarthy, participated in separate meetings with both the National Rural Electric Cooperative Association (NRECA) and the American Public Power Association (APPA). The meetings brought together leaders of the rural cooperatives and public power utilities from across the country. The Administrator discussed and exchanged information on the unique challenges, in particular the financial structure, of NRECA and APPA member utilities. The EPA also participated in roundtable discussions with small business owners.
      In addition, the EPA conducted outreach to representatives of small entities while formulating the provisions of the standards for new sources in the electric utility industry (40 CFR part 60, subpart TTTT). Although only new EGUs are affected by those standards, the outreach regarded planned actions for new and existing sources. The EPA conducted outreach with representatives from 20 various small entities that potentially would be affected by the planned actions. The representatives included small entity municipalities, cooperatives, and private investors. We distributed outreach materials to the small entity representatives; these materials included background, an overview of affected sources and GHG emissions from the power sector, an overview of CAA section 111, an assessment of CO2 emission control technologies, potential impacts on small entities, and a summary of the listening sessions. We met with eight of the small entity representatives, as well as three participants from organizations representing power producers, on June 17, 2011, to discuss the outreach materials, potential requirements of the planned rules, and regulatory areas where the EPA has discretion and could potentially provide flexibility.
A second outreach meeting was conducted on July 13, 2011. We met with nine of the small entity representatives, as well as three participants from organizations representing power producers. During the second outreach meeting, various small entity representatives and participants from organizations representing power producers presented information regarding issues of concern with respect to development of the planned rules for GHG emissions.
5(d)	Collection Schedule
The specific frequency for each information collection activity within this request is shown in Exhibits 1a and 1b for the first 3 years following promulgation of the emission guidelines.
6.	Estimating the Burden and Cost of the Collection

Exhibits 1a and 1b document the lower and upper bounds, respectively, of individual burdens for the reporting requirements applicable to states for the first 3 years. The lower bounds account for states already having active energy efficiency programs in place for achieving their emission performance goals, while the upper bounds do not account for existing energy efficiency programs. By accounting for existing programs, the burden estimates in Exhibit 1a are lower than those in Exhibit 1b. Table 1 below presents the range of the respondent burden hours and costs (detailed in Exhibit 1c).

         Table 1. Lower to Upper Range of Respondent Burden and Costs 
               (3-year period following final rule publication)
Year
Total Annual Labor Burden (hours)
Total Annual Labor Costs ($)
                                 3-Year Total
                              1.52 - 2.46 million
                              $107 - $174 million
                                Average Annual
                               505,000 - 821,000
                             $35.8 - $58.1 million
                         Average Annual per Respondent
                                41,000 - 73,900
                             $2.90 - $5.23 million

The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and major assumptions have been identified; responses to this information collection are mandatory.
The 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.
6(a)	Estimating Respondent Burden
The average annual burden over the 3-year period of this ICR from these reporting requirements is estimated to range from approximately 505,000 to 821,000 hours per year (detailed in Exhibit 1c). These hours are based on agency studies and background documents from the development of the regulation, agency knowledge and experience with part 60 and other regulations, the previously approved ICR for subpart TTTT, and other sources.
6(b)	Estimating Respondent Costs
Respondent costs are typically divided into three categories. These categories include labor costs, operation and maintenance (O&M) costs, and annualized capital costs. Labor costs and O&M costs are the only respondent costs associated with this ICR. 
(i)	Estimating Labor Costs
The average annual labor costs over the 3-year period of this ICR from these reporting requirements are estimated to range from approximately $35.8 to $58.1 million per year (detailed in Exhibit 1c). Labor rates and associated costs are based on Bureau of Labor Statistics (BLS) data. Technical, managerial, and clerical average hourly rates for state government workers were based on the Bureau of Labor Statistics, Occupational Employment Statistics, May 2013 National Industry-Specific Occupational Employment and Wage Estimates for state government (NAICS code 999200). The state government labor rates from BLS were multiplied by an overhead multiplier of 110 percent to estimate loaded labor rates of $74.05 per hour for technical, $89.67 per hour for managerial, and $35.09 per hour for clerical.
(ii)	Estimating Annualized Capital Costs
There are no annualized capital costs associated with this ICR.
(iii)	Estimating Operations and Maintenance (O&M) Costs
      The annual O&M costs associated with this ICR are the costs associated with the paperwork requirements incurred continuously over the life of the ICR (e.g., storing hard copy records, electronic data storage, and miscellaneous annual supplies) (see Exhibits 1a and 1b). The average annual O&M costs associated with this ICR are approximately $58,000 (detailed in Exhibit 1c).
 6(c)	Estimating Agency Burden and Cost
Because the information collection requirements were developed as an incidental part of standards development, no costs can be attributed to the development of the information collection requirements. Because reporting and recordkeeping requirements on the part of the respondents are required under section 111 of the CAA, no operational costs will be incurred by the federal government. Publication and distribution of the information are part of the Compliance Data System, with the result that no federal costs can be directly attributed to the ICR. Examination of records to be maintained by the respondents will occur incidentally as part of EPA's overall compliance and enforcement program, and, therefore, is not attributable to the ICR. The only costs to the federal government, specifically the EPA Headquarters and the EPA Regions, under this ICR are those costs associated with the support and outreach to states; the review of the plans, negative declarations, extension requests for plan submittals, progress reports and public hearing notifications/certifications; and miscellaneous administrative charges. Exhibit 2a presents the average annual agency burden and cost estimates for the first 3 years after promulgation of the emission guidelines. Table 2 below contains a summary of the 3-year total and average annual agency burden hours and costs (detailed in Exhibit 2b).

                  Table 2. Summary of Agency Burden and Costs
               (3-year period following final rule publication)
Year
Total Annual Labor Burden (hours)
Total Annual Labor Costs ($)
                                 3-Year Total
                                    162,000
                                 $8.99 million
                                Average Annual
                                    54,000
                                 $3.00 million

Technical, managerial, and clerical average hourly rates for EPA Headquarters staff and EPA Regional staff were selected from the U.S. Office of Personnel Management Salary Table 2012-GS (accessed at http://www.opm.gov/oca/12tables/pdf/gs_h.pdf). These rates were increased by 60 percent to include fringe benefits and overhead. For EPA Headquarters staff, the loaded labor rates are $62.27 per hour for technical (GS-13, Step 5), $86.56 per hour for managerial (GS-15, Step 5), and $36.11 per hour for clerical (GS-9, Step 5). For EPA Regional staff, the loaded labor rates are $52.37 per hour for technical (GS-12, Step 5), $86.56 per hour for managerial (GS-15, Step 5), and $29.52 per hour for clerical (GS-7, Step 5).  

The agency cost estimates also include annual costs of $1,000 for miscellaneous administrative charges (e.g., telephone, photocopies, and postage) incurred during the first 3 years after promulgation.
6(d)	 Estimating the Respondent Universe and Total Burden and Costs.
Forty-eight states, three areas of Indian country and the District of Columbia will be subject to the requirements of the emission guidelines. Two (Vermont and the District of Columbia) have no EGUs covered under this subpart, and thus are expected to submit negative declarations. Thirty-nine states are expected to submit their own individual plans, while the three tribes are expected to rely on the federal plan. One regional carbon management program (RGGI) is expected to submit a multi-state plan for the eight member states in that region that have EGUs covered under this subpart.
The total number of responses for the monitoring, recordkeeping, and reporting guidelines in subpart UUUU over the 3-year ICR period is estimated to be 136. The average number of annual responses over the 3-year ICR period is 45.3 per year. The total labor burden over the 3-year ICR period is estimated to range from approximately 1.52 to 2.46 million person-hours. The total labor costs over the 3-year ICR period are estimated to range from approximately $107 to $174 million.
6(e)	Bottom Line Burden Hours and Cost Tables
The bottom line labor hours and costs are shown in Exhibits 1a and 1b for respondents and Exhibit 2a for EPA. The labor hours and costs are summarized in Exhibit 1c for respondents and Exhibit 2b for EPA.
6(f)	Reasons for Change in Burden
The increase in burden is due to this being a new ICR associated with a new subpart.
6(g)	Burden Statement
The annual public reporting and recordkeeping burden (as listed in Section 5(b) above) for this collection of information is estimated to range from approximately 11,100 to 18,100 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 in 40 CFR part 60 are listed in 40 CFR part 9.
PART B
This section is not applicable because statistical methods are not used in data collection associated with these guidelines.
                                  ATTACHMENTS


Exhibit 1a. Lower Bound Respondent Burden and Cost of Reporting and Recordkeeping Requirements, Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units (40 CFR Part 60, Subpart UUUU)

Exhibit 1b. Upper Bound Respondent Burden and Cost of Reporting and Recordkeeping Requirements, Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units (40 CFR Part 60, Subpart UUUU)

Exhibit 1c. Summary of Respondent Burden and Cost of Reporting and Recordkeeping Requirements, Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units (40 CFR Part 60, Subpart UUUU)

Exhibit 2a. Burden and Cost to the Agency, Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units (40 CFR Part 60, Subpart UUUU)

Exhibit 2b. Summary of Agency Burden and Cost, Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units (40 CFR Part 60, Subpart UUUU)
Exhibit 1a. Lower Bound Respondent Burden and Cost of Reporting and Recordkeeping Requirements, Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units (40 CFR Part 60, Subpart UUUU)
                                  Burden Item
                             (A)
Hours/ Occurrence
                         (B)
Occurrences/ Respondent/ 
                                     Year
                      (C)
Hours/ Respond-ent/Year
(A x B)
                                      (D)
                               Respond-ents/Year
                         (E)
Total Hours/ Year
(C x D)
                      (F)
Technical Hours/Year
(E x 0.79)
                     (G)
Managerial Hours/Year
(E x 0.09)
                      (H)
Clerical Hours/Year
(E x 0.12)
                                 (I)
Cost/Year
1. REPORTING REQUIREMENTS
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       

A. Read and Understand Rule Requirements [a][,b]
                                      50
                                       1
                                      50
                                     16.3
                                      817
                                      408
                                      408
                                       0
                                    $66,851

B. Required Activities
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       


Develop initial submittal/progress report [c,d]
                                    12,480
                                       1
                                    12,480
                                     15.7
                                    195,520
                                    154,461
                                    17,597
                                    23,462
                                  $13,838,429


Develop final plan
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       


    Individual plan [e][,f]
                                    11,440
                                       1
                                    11,440
                                      26
                                    297,440
                                    234,978
                                    26,770
                                    35,693
                                  $21,052,077


    Multi-state plan [g][,h]
                                    17,056
                                       1
                                    17,056
                                      0.7
                                    11,371
                                     8,983
                                     1,023
                                     1,364
                                   $804,788

C. Create Information
                                  Incl. in 1B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       

D. Gather Information
                                  Incl. in 1B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       

E. Report Preparation
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       


Initial/final plan
                                  Incl. in 1B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       


Negative declaration [i]
                                       1
                                       1
                                      1.0
                                      0.7
                                      0.7
                                      0.5
                                     0.06
                                     0.08
                                      $47
AVERAGE ANNUAL LABOR BURDEN
AND COST
                                       
                                       
                                       
                                       
                                    505,148
                                    417,470
                                    45,798
                                    60,520
                                  $35,762,192
AVERAGE ANNUALIZED COSTS (O&M) (Reporting/recordkeeping supplies)
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                    $58,045
[a] Assumes one-time burden of 50 hours (based on an average reading rate of 100 words/minute) to read and understand rule requirements, divided equally among technical and managerial staff.
[b] Respondents include all 48 contiguous states, plus the District of Columbia, averaged over the 3-year ICR period (49/3=16.3).
[c] Assumes 6 FTEs per state per year for team leadership, political outreach, general coordination of plans, energy and policy analysis, coordination between energy office and air office, energy efficiency programs liaison, modeling, data analysis, extension requests, and 2017 progress reports.
[d] Respondents include 47 states with EGUs expected to develop an initial submittal over the first year and progress report over the second year, averaged over the 3-year ICR period (47*1/3=15.7).
[e] Assumes 5.5 FTEs per state per year for team leadership, political outreach, general coordination of plans, energy and policy analysis, coordination between energy office and air office, energy efficiency programs liaison, modeling, and data analysis.
[f] Respondents include those 39 states with EGUs expected to develop a final individual plan over the remaining 2 years, averaged over the 3-year ICR period (39*2/3=26).
[g] Assumes 1 FTE per year for multi-state plan staff providing team leadership, political outreach, outreach to participating states, modeling, and data analysis, and 0.9 FTE for each participating state in the region.
[h] Respondent is the regional carbon management program (RGGI) expected to develop a final multi-state plan for its 8 member states with EGUs over the remaining 2 years, averaged over the 3-year ICR period (1*2/3=0.7).
[i] Respondents include the 1 state and District of Columbia without EGUs expected to submit a one-time negative declaration, averaged over the 3-year ICR period (2/3=0.7).


Nationwide Respondent Assumptions
                           Breakdown of Respondents
                                   No. Resp.
                                     Notes
Total no. respondents
                                      49
48 states, DC
No. expected to submit negative declaration
                                       2
VT, DC
No. expected to submit plan [a]
                                      47
47 states
No. expected to submit individual plan [a]
                                      39
39 states
No. expected to submit multi-state plan
                                       1
Regional Greenhouse Gas Initiative (RGGI)
No. states included in multi-state plan
                                       8
Includes the 8 states in RGGI with EGUs
[a] Tribes expected to rely on federal plan.

Respondent Labor Rates
                                Labor Category
                       Respondent Labor Rates (May 2013)

                                  Unloaded[a]
                          Overhead Multiplier (110%)
                                    Loaded
Technical
                                    $35.26
                                      2.1
                                    $74.05
Managerial
                                    $42.70
                                      2.1
                                    $89.67
Clerical
                                    $16.71
                                      2.1
                                    $35.09
[a] Unloaded labor rates from U.S. Department of Labor, Bureau of Labor Statistics,
Occupational Employment Statistics, May 2013 National Industry-Specific Occupational
Employment and Wage Estimates, NAICS 999200 - State Government, excluding schools
and hospitals (OES Designation) <http://www.bls.gov/oes/2013/may/naics4_999200.htm>

Recordkeeping/Reporting Supplies (Annual O&M Costs) [a]
                                  Supply Item
                                  Price/ Item
                                  No./ Resp.
                                 No. of Resp.
                                     Total
File cabinet to store hard copy records 
                                     $235
                                       1
                                      47
                                    $11,045
Electronic data storage device
                                     $500
                                       1
                                      47
                                    $23,500
Miscellaneous annual supplies
                                     $500
                                       1
                                      47
                                    $23,500
                                                            Average Annual Cost
                                       
                                       
                                       
                                    $58,045
[a] Costs based on estimates initially prepared for 40 CFR part 60, subpart TTTT.




Exhibit 1b. Upper Bound Respondent Burden and Cost of Reporting and Recordkeeping Requirements, Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units (40 CFR Part 60, Subpart UUUU)
                                  Burden Item
                             (A)
Hours/ Occurrence
                         (B)
Occurrences/ Respondent/ 
                                     Year
                      (C)
Hours/ Respond-ent/Year
(A x B)
                                      (D)
                               Respond-ents/Year
                         (E)
Total Hours/ Year
(C x D)
                      (F)
Technical Hours/Year
(E x 0.79)
                     (G)
Managerial Hours/Year
(E x 0.09)
                      (H)
Clerical Hours/Year
(E x 0.12)
                                 (I)
Cost/Year
1. REPORTING REQUIREMENTS
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       

A. Read and Understand Rule Requirements [a][,b]
                                      50
                                       1
                                      50
                                     16.3
                                      817
                                      408
                                      408
                                       0
                                    $66,851

B. Required Activities
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       


Develop initial submittal/progress report [c,d]
                                    19,760
                                       1
                                    19,760
                                     15.7
                                    309,573
                                    244,563
                                    27,862
                                    37,149
                                  $21,910,845


Develop final plan
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       


    Individual plan [e][,f]
                                    18,720
                                       1
                                    18,720
                                      26
                                    486,720
                                    384,509
                                    43,805
                                    58,406
                                  $34,448,854


    Multi-state plan [g][,h]
                                    35,360
                                       1
                                    35,360
                                      0.7
                                    23,573
                                    18,623
                                     2,122
                                     2,829
                                  $1,668,463

C. Create Information
                                  Incl. in 1B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       

D. Gather Information
                                  Incl. in 1B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       

E. Report Preparation
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       


Initial/final plan
                                  Incl. in 1B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       


Negative declaration [i]
                                       1
                                       1
                                      1.0
                                      0.7
                                      0.7
                                      0.5
                                     0.06
                                     0.08
                                      $47
AVERAGE ANNUAL LABOR BURDEN
AND COST
                                       
                                       
                                       
                                       
                                    820,684
                                    648,104
                                    74,196
                                    98,384
                                  $58,095,060
AVERAGE ANNUALIZED COSTS (O&M) (Reporting/recordkeeping supplies)
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                    $58,045
[a] Assumes one-time burden of 50 hours (based on an average reading rate of 100 words/minute) to read and understand rule requirements, divided equally among technical and managerial staff.
[b] Respondents include all 48 contiguous states, plus the District of Columbia, averaged over the 3-year ICR period (49/3=16.3).
[c] Assumes 9.5 FTEs per state per year for team leadership, political outreach, general coordination of plans, energy and policy analysis, coordination between energy office and air office, energy efficiency programs liaison, modeling, data analysis, extension requests, and 2017 progress reports.
[d] Respondents include 47 states with EGUs expected to develop an initial submittal over the first year and progress report over the second year, averaged over the 3-year ICR period (47*1/3=15.7).
[e] Assumes 9 FTEs per state per year for team leadership, political outreach, general coordination of plans, energy and policy analysis, coordination between energy office and air office, energy efficiency programs liaison, modeling, and data analysis.
[f] Respondents include those 39 states with EGUs expected to develop a final individual plan over the remaining 2 years, averaged over the 3-year ICR period (39*2/3=26).
[g] Assumes 1 FTE per year for multi-state plan staff providing team leadership, political outreach, outreach to participating states, modeling, and data analysis, and 0.9 FTE for each participating state in the region.
[h] Respondent is the regional carbon management program (RGGI) expected to develop a final multi-state plan for its 8 member states with EGUs over the remaining 2 years, averaged over the 3-year ICR period (1*2/3=0.7).
[i] Respondents include the 1 state and District of Columbia without EGUs expected to submit a one-time negative declaration, averaged over the 3-year ICR period (2/3=0.7).

Nationwide Respondent Assumptions
                           Breakdown of Respondents
                                   No. Resp.
                                     Notes
Total no. respondents
                                      49
48 states, DC
No. expected to submit negative declaration
                                       2
VT, DC
No. expected to submit plan [a]
                                      47
47 states
No. expected to submit individual plan [a]
                                      39
39 states
No. expected to submit multi-state plan
                                       1
Regional Greenhouse Gas Initiative (RGGI)
No. states included in multi-state plan
                                       8
Includes the 8 states in RGGI with EGUs
[a] Tribes expected to rely on federal plan.

Respondent Labor Rates
                                Labor Category
                       Respondent Labor Rates (May 2013)

                                  Unloaded[a]
                          Overhead Multiplier (110%)
                                    Loaded
Technical
                                    $35.26
                                      2.1
                                    $74.05
Managerial
                                    $42.70
                                      2.1
                                    $89.67
Clerical
                                    $16.71
                                      2.1
                                    $35.09
[a] Unloaded labor rates from U.S. Department of Labor, Bureau of Labor Statistics,
Occupational Employment Statistics, May 2013 National Industry-Specific Occupational
Employment and Wage Estimates, NAICS 999200 - State Government, excluding schools
and hospitals (OES Designation) <http://www.bls.gov/oes/2013/may/naics4_999200.htm>

Recordkeeping/Reporting Supplies (Annual O&M Costs) [a]
                                  Supply Item
                                  Price/ Item
                                  No./ Resp.
                                 No. of Resp.
                                     Total
File cabinet to store hard copy records 
                                     $235
                                       1
                                      47
                                    $11,045
Electronic data storage device
                                     $500
                                       1
                                      47
                                    $23,500
Miscellaneous annual supplies
                                     $500
                                       1
                                      47
                                    $23,500
                                                            Average Annual Cost
                                       
                                       
                                       
                                    $58,045
[a] Costs based on estimates initially prepared for 40 CFR part 60, subpart TTTT.


Exhibit 1c. Summary of Respondent Burden and Cost of Reporting and Recordkeeping Requirements,
Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units
(40 CFR Part 60, Subpart UUUU)

Summary of Respondent Burden and Cost
                                    Totals
                          Annual Labor Burden (Hours)
                              Annual
Labor Costs
                           Annualized
Capital Costs
                             Annual
O&M Costs
                            Total Annualized Costs
                         Total Annual Respondent Costs
                             Lower Bound Estimates
                                 3-Year Total
                                   1,515,444
                                 $107,286,576
                                      $0
                                   $174,135
                                   $174,135
                                 $107,460,711
                                Average Annual
                                    505,148
                                  $35,762,192
                                      $0
                                    $58,045
                                    $58,045
                                  $35,820,237
                       Average Annual per Respondent [a]
                                    41,027
                                  $2,904,345
                                      $0
                                    $1,235
                                    $1,235
                                  $2,905,580
                             Upper Bound Estimates
                                 3-Year Total
                                   2,462,052
                                 $174,285,180
                                      $0
                                   $174,135
                                   $174,135
                                 $174,459,315
                                Average Annual
                                    820,684
                                  $58,095,060
                                      $0
                                    $58,045
                                    $58,045
                                  $58,153,105
                       Average Annual per Respondent [b]
                                    73,891
                                  $5,230,379
                                      $0
                                    $1,235
                                    $1,235
                                  $5,231,614
[a] Equal to average annual estimate for each burden item in Exhibit 1a divided by the number of respondents in Exhibit 1a for that burden item, summed for all burden items.
[b] Equal to average annual estimate for each burden item in Exhibit 1b divided by the number of respondents in Exhibit 1b for that burden item, summed for all burden items.

Summary of Responses
                        Information Collection Activity
                           Occurrence per Respondent
                                  Respondents
                                Total
Responses
                                Average Annual
                             Lower Bound Estimates
 REPORT REQUIREMENTS
 
                                       
                                       
 
    Initial submittal
                                       1
                                      47
                                      47

    Progress report
                                       1
                                      47
                                      47

    Final individual plan
                                       1
                                      39
                                      39
 
    Final multi-state plan
                                       1
                                       1
                                       1
 
    Negative declaration
                                       1
                                       2
                                       2
 
3-Year Total Responses
                                       
                                       
                                      136
 
                                          Average Annual Number of Responses = 
                                     45.3
                                     Average Annual Responses per Respondent = 
                                      0.9
                                           Average Annual Hours per Response = 
                                    11,143
                             Upper Bound Estimates
 REPORT REQUIREMENTS
 
                                       
                                       
 
    Initial submittal
                                       1
                                      47
                                      47

    Progress report
                                       1
                                      47
                                      47

    Final individual plan
                                       1
                                      39
                                      39
 
    Final multi-state plan
                                       1
                                       1
                                       1
 
    Negative declaration
                                       1
                                       2
                                       2
 
3-Year Total Responses
                                       
                                       
                                      136
 
                                          Average Annual Number of Responses = 
                                     45.3
                                     Average Annual Responses per Respondent = 
                                      0.9
                                           Average Annual Hours per Response = 
                                    18,103

Exhibit 2a. Burden and Cost to the Agency, Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units (40 CFR Part 60, Subpart UUUU)
                                   Activity
                            (A)
Hours/
Occur-rence
                       (B) 
Occur-rences/
Facility/ Year
                      (C)
Hours/ Facility/ Year 
(A x B)
                             (D)
Facili-ties/ Year
                      (E)
EPA Total 
Hours/ Year
 (C x D)
                  (F)
EPA Technical 
Hours/ Year
 (E x 0.79)
                   (G)
EPA
Managerial
Hours/Year
 (E x 0.09)
                   (H)
EPA
Clerical
Hours/ Year
 (E x 0.12)
                                  (I)
Cost, $
1. SUPPORT/OUTREACH
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       

EPA Headquarters [a,b]
                                      434
                                       1
                                      414
                                      40
                                    17,368
                                    13,721
                                     1,563
                                     2,084
                                  $1,064,984 

EPA Regions [b,c]
                                     475 
                                       1
                                      452
                                      40
                                    18,980
                                    14,994
                                     1,708
                                     2,278
                                  $1,000,313 
2. REPORT REVIEW [g]
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       

Review negative declarations [h]
                                       1
                                       1
                                      1.0
                                      0.7
                                      0.7
                                      0.5
                                      0.1
                                      0.1
                                     $35 

Review progress reports [i]
                                      100
                                       1
                                      100
                                     15.7
                                     1,567
                                     1,238
                                      141
                                      188
                                    $82,569

Coordination on submitting individual plans [j]
                                      160
                                       1
                                      160
                                      13
                                     2,080
                                     1,643
                                      187
                                      250
                                   $109,623

Coordination on submitting multi-state plan [k]
                                      320
                                       1
                                      320
                                      0.3
                                      107
                                      84
                                      10
                                      13
                                    $5,622 

Review notifications of public hearings on plans [l]
                                       2
                                       1
                                      2.0
                                     15.7
                                      31
                                      25
                                      2.8
                                      3.8
                                    $1,651

Review certifications that public hearings on plans
conducted according to subpart B procedures [l]
                                       2
                                       1
                                      2.0
                                     15.7
                                      31
                                      25
                                      2.8
                                      3.8
                                    $1,651

Review/approve plans [b,][m]
                                     1,040
                                       1
                                     1,040
                                     13.3
                                    13,867
                                    10,955
                                     1,248
                                     1,664
                                   $730,822
AVERAGE ANNUAL LABOR BURDEN AND COST
                                       
                                       
                                       
                                       
                                    54,031
                                    42,685
                                     4,863
                                     6,484
                                  $2,997,270
AVERAGE ANNUAL OTHER DIRECT COSTS
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
  Miscellaneous cost (e.g., telephone, photocopies, postage)
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                    $1,000
TOTAL AVERAGE ANNUAL COST (Average Annual Labor Cost + Average Annual Other Direct Costs)
                                  $2,998,270
[a] Assumes 8.35 FTEs per year to oversee the entire program and help with outreach/state/enforceability questions and regional assistance, divided by the total number of respondents.
[b] Includes those 39 states expected to develop individual state plans and 1 multi-state carbon management program expected to develop a multi-state plan for 8 states, for a total of 40.
[c] Assumes 36.5 hours per week of outreach per EPA Region, divided by the total number of respondents.
[d] One-time activities, averaged over the 3-year ICR period.
[e] Includes the 1 state and District of Columbia without EGUs expected to submit a negative declaration, averaged over the 3-year ICR period (2/3=0.7).
[f] Assumes 2.5 weeks to review each 2017 progress report; respondents include all 47 states submitting 2017 progress reports, averaged over the 3-year ICR period (47/3=15.7).
[g] Assumes 4 weeks to coordinate with states to advise on their development of individual plans and extension requests; respondents include these 39 states, averaged over the 3-year ICR period (39/3=13).
[k] Assumes 8 weeks to coordinate with RGGI representatives to advise on their development of a multi-state plan and extension request; respondent includes RGGI, averaged over the 3-year ICR period (1/3=0.3).
[l] Includes all 47 states for which a state plan was developed (including individual RGGI states), averaged over the 3-year ICR period (47/3=15.7).
[m] Assumes 6 full months for EPA Regions to review each state plan, with some coordination with EPA Headquarters; respondents for this one-time activity averaged over the 3-year period (40/3=13.3).

EPA Staff Labor Rates
                                Labor Category
                              Labor Rates (2013)

                                  Unloaded[a]
                           Overhead Multiplier (60%)
                                    Loaded
EPA Headquarters
                                       
                                       
                                       
Technical (Grade 13, Step 5)
                                    $38.92
                                      1.6
                                    $62.27
Managerial (Grade 15, Step 5)
                                    $54.10
                                      1.6
                                    $86.56
Clerical (Grade 9, Step 5)
                                    $22.57
                                      1.6
                                    $36.11
EPA Regions
                                       
                                       
                                       
Technical (Grade 12, Step 5)
                                    $32.73
                                      1.6
                                    $52.37
Managerial (Grade 15, Step 5)
                                    $54.10
                                      1.6
                                    $86.56
Clerical (Grade 7, Step 5)
                                    $18.45
                                      1.6
                                    $29.52
[a] Unloaded labor rates from U.S. Office of Personnel Management < http://www.opm.gov/oca/13tables/pdf/gs_h.pdf>

Other Direct Costs
                                 Expense Item
                                   Cost [a]
Miscellaneous cost (e.g., telephone, photocopies, postage)
                                    $1,000
[a] Cost based on estimate initially prepared for 40 CFR part 60, subpart TTTT.


Exhibit 2b.  Summary of Agency Burden and Cost, Carbon
Pollution Emission Guidelines for Existing Stationary Sources:
Electric Utility Generating Units (40 CFR Part 60, Subpart UUUU)
                                    Totals
                          Annual Labor Burden (Hours)
                                 Annual Costs
                                 3-Year Total
                                    162,094
                                  $8,994,811
                                Average Annual
                                    54,031
                                  $2,998,270

Average Annual Agency Hour Burden per Response = 1,192
Average Annual Agency Cost Burden per Response = $66,138

