                        Information Collection Request
                         Supporting Statement for the
Implementation of the Fine Particulate Matter National Ambient Air Quality Standards 
                            EPA ICR Number 2258.05
                           OMB Control No. 2060-0611
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                 Prepared by:
                                       
                 Office of Air Quality Planning and Standards 
                          Office of Air and Radiation
                     U.S. Environmental Protection Agency
                 Research Triangle Park, North Carolina 27711
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                              September 17, 2019
                                       
                                       
                                       
                                       
                                       
              EPA Information Collection Request Renewal for the
                 PM2.5 National Ambient Air Quality Standards
                  State Implementation Plan Requirements Rule
                                       
                                       
                               Table of Contents
                                       
                                       
 Identification of the Information Collection Request........................page 3



 Need for and Use of the Collection..........................................page 4



 Non-Duplication, Consultation, and other Collection Criteria......... page 7



 Respondents and the Information Requested..............................page 9



 Information Collected -- Agency Activities, Collection Methodology and Information Management....................................................................page 12



 Estimating the Burden and Cost of the Collection........................page 13
   
   
   
   
   
   
   
   
   
   
   
   
          Identification of the Information Collection Request

1(a) Title of the Information Collection

   The title of the Information Collection Request is Implementation of the PM2.5 National Ambient Air Quality Standards (NAAQS) (Renewal), ICR number 2258.05, and OMB Control Number 2060-0611.

1(b) Abstract/Executive Summary

   The EPA has established a suite of PM2.5 standards based on numerous health studies and other evidence demonstrating that serious health effects are associated with exposure to elevated levels of PM2.5. Estimates show that attainment of the PM2.5 standards would result in tens of thousands fewer premature deaths each year, tens of thousands fewer hospital admissions each year, and hundreds of thousands fewer doctor visits, absences from work and school, and respiratory illnesses in children annually. EPA initially established annual and 24-hour PM2.5 standards in 1997. The 24-hour standard was subsequently revised in 2006, and the primary annual standard was revised in 2012.
   
   The EPA finalized the PM2.5 NAAQS SIP Requirements Rule (81 FR 58010) effective October 24, 2016, to describe the Clean Air Act (CAA) requirements that must be met by states with nonattainment areas to develop plans for attaining and maintaining the NAAQS. The intended effect of the PM2.5 NAAQS SIP Requirements Rule is to provide certainty to states regarding their planning obligations related to SIP development. Only states with nonattainment areas are required to submit SIPs that meet the requirements of the rule. 
   
   On December 18, 2014, the EPA designated fourteen areas as nonattainment for the 2012 PM2.5 NAAQS (78 FR 3086). The EPA conducted an analysis for ICR Number 2258.04 using the initial fourteen nonattainment areas. The estimate also included the estimated burden associated with ongoing implementation obligations for the remaining areas designated nonattainment for the 1997 and/or 2006 PM2.5 NAAQS. The EPA requested comment on this analysis in the proposed PM2.5 NAAQS SIP Requirements Rule (80 FR 18177) and received no comments. After proposing the PM2.5 NAAQS SIP Requirements Rule, the EPA revised initial area designations for several 2012 PM2.5 NAAQS areas on March 31, 2015 (80 FR 18535). This designation action revised the count from 14 to nine nonattainment areas, while several counties in three states remained deferred. In light of the lack of comments on the initial estimate, and to ensure that the final estimate was not an underestimate in light of uncertainty, the EPA did not revise its estimate for ICR Number 2258.04. 
	
   The information collection activities in this proposed renewal have been submitted for approval to the Office of Management and Budget (OMB) under the Paperwork Reduction Act (PRA). The PRA requires the EPA to assess the administrative burden (in hours and dollars) for state air agencies to develop plans to attain the PM2.5 NAAQS, and for EPA to review and take action on such plans. This proposed ICR renewal covers the period February 1, 2020-January 31, 2023.
   
     The EPA estimates the administrative burden for states with nonattainment areas for the 1997, 2006 and 2012 PM2.5 NAAQS to be 76,500 hours. The present value of the total costs for state governments (the respondents) is estimated at $4.8 million for the 3-year period, or $1.6 million per year during the 3-year period of the ICR. 
   
   The estimated administrative burden for EPA is estimated to be 8,415 hours. The present value of the Agency administrative cost burden is estimated at $0.53 million dollars for the 3-year period, or $0.17 million per year during the 3-year period.  
   
          Need For and Use of the Collection
   2(a) Need/Authority for the Collection

   The CAA, which was last amended in 1990, requires the EPA to establish National Ambient Air Quality Standards (NAAQS) for air pollutants that may reasonably be anticipated to endanger public health or welfare, and which result from numerous or diverse sources. On July 18, 1997, the EPA revised the NAAQS for particulate matter to add new standards for fine particulate matter (particles of solid and liquid material less than 2.5 microns in aerodynamic diameter, or PM2.5. The EPA established health-based (primary) annual and 24-hour standards for PM2.5 (62 FR 38652). The annual standard was set at a level of 15 micrograms per cubic meter, based on the 3-year average of annual mean PM2.5 concentrations. The 24-hour standard was set a level of 65 micrograms per cubic meter, based on the 3-year average of the 98[th] percentile of 24-hour concentrations. The welfare-based secondary standards were established identical to the primary standards.
   
   Part D of Title I of the Clean Air Act sets forth the implementation plan requirements for areas designated nonattainment for a National Ambient Air Quality Standard. The initial PM2.5 National Ambient Air Quality Standard Implementation rule was proposed November 1, 2005 (70 FR 65983) and was promulgated on April 25, 2007 (72 FR 20586). The preamble to the proposed and final regulation addressed the administrative burden associated with attainment planning in general terms. The preamble to the final rule stated that an ICR would be prepared.
   
   On October 17, 2006, the EPA revised the NAAQS for fine particles. The EPA established a new primary 24-hour standards for PM2.5 (71 FR 61144). The 24-hour standard was set at a level of 35 micrograms per cubic meter, based on the 3-year average of the 98[th] percentile of 24-hour concentrations. The annual standard remained unchanged at a level of 15 micrograms per cubic meter, based on the 3-year average of annual mean PM2.5 concentrations. The initial ICR 2258.01 covered the time period between April 5, 2008 through April 4, 2011. An extension without change of ICR 2258.02 was subsequently issued through April 30, 2012.
   
   On December 14, 2012, the EPA revised the NAAQS for fine particles. The EPA established a new primary annual standard PM2.5 (78 FR 3086). The annual standard was set at a level of 12 micrograms per cubic meter, based on the 3-year average of annual mean PM2.5 concentrations. The 24-hour standard remained unchanged at a level of 35 micrograms per cubic meter, based on the 3-year average of the 98[th] percentile of 24-hour concentrations. The time period covered in the ICR 2258.03 was a 3-year period from May 1, 2012 through April 30, 2015. ICR 2258.03 was issued a 60-day extension from April 30, 2015 through June 30, 2015. The ICR 2258.03 lapsed on July 1, 2015.
   
   Following a January 2013 decision by the U.S. Circuit Court of Appeals for the D.C. Circuit that remanded the 2007 PM2.5 Implementation Rule, on March 23, 2015, the EPA proposed the PM2.5 NAAQS SIP Requirements Rule and finalized the rule on August 24, 2016. This rule provided the framework for states to follow in developing SIPs to attain the 1997 PM2.5 NAAQS, the 2006 PM2.5 NAAQS and the 2012 PM2.5 NAAQS. 
   
   The framework in the rule reflects the applicable requirements described in the CAA part D nonattainment area provisions found in sections 172 (subpart 1) and sections 188-190 (subpart 4). A PM2.5 SIP must include rules requiring emission reductions and a demonstration showing whether the particular area can attain the standard by its attainment date. A state plan submittal for attaining the PM2.5 NAAQS is due to EPA within 18 months after the date the area is designated as nonattainment. After a state submits a SIP, the CAA requires the EPA to review the plan, and approve or disapprove it. Once an area is no longer violating the NAAQS, it may request a redesignation from "nonattainment" to "attainment." This requires the state to develop a maintenance plan to demonstrate that the area will continue to maintain the NAAQS during a 10-year maintenance period. ICR 2258.03 was included in the proposed and final regulations. This proposed ICR 2258.05 covers February 1, 2020-January 31, 2023.
   
    2(b) User/Users of the Data 
   
   The data collected from the state and local air agency respondents will include the nonattainment SIP elements and maintenance plan requirements under the CAA that are described in more detail in the PM2.5 NAAQS SIP Requirements Rule. Attainment plans for the PM2.5 NAAQS nonattainment areas must contain state rules and other requirements designed to achieve the NAAQS by the deadlines established under the CAA. Maintenance plans must contain requirements designed to maintain the NAAQS for a 10-year maintenance period.
   
   The PM2.5 attainment plan submitted by the state must include the various requirements in subpart 1 and subpart 4 and guidance, including:
   
 Baseline emission inventory and projection year inventory for stationary, mobile, and area emissions sources in the nonattainment area consistent with 40 CFR 51.1008.
 For Moderate areas, an analysis of economic and technological feasibility of potential control measures (i.e., reasonably available control measures (RACM) and reasonably available control technology (RACT) and the adoption of state rules requiring emission reductions to ensure attainment of the standard "as expeditiously as practicable," consistent with 40 CFR 51.1007 and 51.1009.
 For Serious areas, an analysis of economic and technological feasibility of potential control measures (i.e., best available control measures (BACM) and best available control technology (BACT) and the adoption of state rules requiring emission reductions to ensure attainment of the standard "as expeditiously as practicable," consistent with 40 CFR 51.1010.
 For those Serious areas that fail to meet the Serious area attainment date, the state must submit a SIP revision consistent with CAA section 189(d) which provides an annual reduction in PM2.5 or its precursor emissions of not less than 5 percent of the emissions, within 12 months after the applicable attainment date.
 An attainment date consistent with 40 CFR 51.1004.
 An attainment demonstration with air quality modeling showing that existing federal and state emission reduction programs, plus any new emission reduction programs adopted by the state, will result in expeditious attainment by the attainment date, consistent with 40 CFR 51.1011. The attainment demonstration must meet the requirements of 40 CFR 51.112 and Part 51, Appendix W, and must include emission inventory data, modeling results, and emission reduction analyses on which the state has based its projected attainment date. The attainment demonstration and supporting air quality modeling should be consistent with the EPA's most current PM2.5 modeling guidance.
 An optional precursor demonstration to demonstrate out of the requirements under subpart 4 to regulate PM2.5 precursors for attainment and nonattainment new source review purposes.
 A plan showing that future emission reductions will provide for reasonable further progress (RFP) toward attainment of the standard for the period prior to the area's attainment date, consistent with 40 CFR 51.1012; and reporting every 3 years on quantitative milestones showing progress in the implementation of the attainment plan and associated control measures, consistent with 40 CFR 51.1013. 
 Contingency measures to promptly correct NAAQS violations.

   The PM2.5 maintenance plan submitted by the state must include the various requirements in subpart 1 and subpart 4, and guidance including:
 Baseline emission inventory and projection year inventory for stationary, mobile, and area emissions sources in the nonattainment area consistent with 40 CFR 51.1008.
 A demonstration that the area will continue to attain for the 10-year period following the redesignation, including air quality modeling.
 Verification of continued attainment; including tracking progress through updating the inventory, re-evaluate modeling assumptions or inputs or other methods as needed.
 Contingency measures to promptly correct NAAQS violations that occur after the redesignation.
      
   The states use this information and analysis to fulfill federal obligations under Title I, part D of the Clean Air Act and the PM2.5 NAAQS SIP Requirements Rule. 
   
   The EPA regional and headquarters offices will use the submitted information in determining the adequacy of the various elements of the PM2.5 attainment or maintenance plan. The EPA is required under the CAA to approve or disapprove a SIP revision within 12 months of the submission being found complete or within 18 months to approve a maintenance plan. Emission reduction regulations developed by the states become federally enforceable when approved by the EPA.
   
 Non-Duplication, Consultations, and Other Collection Criteria
   
   3(a) Non-Duplication
   
   	As noted in section 2(b) above, the state respondent will need to include a number of separate and unique elements for each plan submittal. For example, each Serious area attainment plan must include a unique BACM/BACT analysis, attainment demonstration, RFP plan and quantitative milestone reports. 
   
   However, there are other activities covered by existing ICRs which complement the elements required in the PM2.5 plans. For example, the existing PM2.5 monitoring network, covered under a separate ICR, provides essential data for use by states and EPA in identifying key categories of emissions and tracking progress toward attainment.
   
   EPA encourages the states to account for control measures and expected emission reductions from existing regulations and implementation planning processes, such as for the the PM2.5 NAAQS, the ozone NAAQS, or the regional haze program. Taking such steps, where appropriate, may enable states to reduce the incremental administrative burden associated with this rule and enable identification of control strategies that achieve multi-pollutant environmental progress at a lower cost.
   
   Relevant ICRs and their titles are identified below.    
   
 Requirements for Preparation, Adoption, and Submittal of Implementation Plans
 51.121-51.122  NOx SIP Call...................................2060-0445
 51.160-51.166  New Source Review................................2060-0003
 51.321-51.323  Air Quality Data Reporting..................2060-0088
 51.353-51.354  Inspection/Maintenance......................2060-0252
 51.365-51.366  Inspection/Maintenance......................2060-0252
 Approval and Promulgation of Implementation Plans
 52.21 Prevention of Significant Deterioration.................2060-0003
 Ambient Air Monitoring Reference and Equivalent Methods
 53.4 .................................................................2080-0005
 53.9(f),(h),(i).......................................................2080-0005
 53.14................................................................2080-0005
 53.15 ...............................................................2080-0005
 53.16(a)-(d),(f).....................................................2080-0005
 Outer Continental Shelf Air Regulations
 55.4-55.8 ...........................................................2060-0249
 55.11-55.14 ........................................................2060-0249
 Ambient Air Quality Surveillance
 58.11-58.14 ........................................................2060-0084
 58.20-58.23 ........................................................2060-0084
 58.25-58.28 ........................................................2060-0084
 58.30-58.31 ........................................................2060-0084
 58.33 ................................................................2060-0084
 58.35 ................................................................2060-0084
 58.40-58.41 .........................................................2060-0084
 58.43 ................................................................2060-0084
 58.45 ................................................................2060-0084
 58.50 ................................................................2060-0084
 Determining Conformity of Federal Actions to State or Federal Implementation Plans
 91.150-93.160 .....................................................2060-0279
 8-hour Ozone National Ambient Air Quality Standard Implementation Rule
 2236.02.............................................................2060  -  0594
   	
   3(b) Public Notice Required Prior to ICR Submission to the Office of Management and Budget (OMB)
   	This is a renewal of a rule-related ICR. 
   
   3(c) Consultations
   
   	The EPA will solicit comment.
   
   3(d) Effects of Less Frequent Collection
   
   	The collections under this rule (as reviewed in section 2(b)) are necessary to comply with Clean Air Act requirements and provide assurances that identified levels of emission reductions are adequate to ensure timely attainment and maintenance of the PM2.5 NAAQS. 
   
   3(c) General Guidelines 
   
   The reporting and recordkeeping requirements for the PM2.5 NAAQS SIP Requirements Rule do not violate any of the regulations promulgated by OMB under 5 CFR part 1320, section 1320.5. This submission meets the current Paperwork Reduction Act guidelines set forth by OMB. Those guidelines reflect the requirements of 5 CFR 1320.6. The PM2.5 SIP Requirements Rule does not require:
 reporting more than once a year;
 respondents to participate in a statistical survey;  
 responses to Agency inquiries in less than 30 days;
 respondents to receive remuneration for preparation of reports; 
 records to be kept more than 3 years;
 manual methods of reporting.
   
   3(f)	 Confidentiality
     
   	The information requested from the states to fulfill CAA requirements as described in section 2(b) will rely on emissions levels and control efficiency data provided by certain facilities in the private and public sectors. This information is available from a variety of sources and states should already have information from emission sources, as facilities should have provided this information to meet other NAAQS SIP requirements, operating permits, and/or emissions reporting requirements. It is the assimilation and analysis of that data (e.g., for BACM/BACT control measure determinations, the attainment demonstration, etc.) that is required by the PM2.5 NAAQS SIP Requirements Rule. 
   
   	Emissions and control technology information from emissions sources generally do not reveal the details of production processes. But, to the extent that it may, the affected facilities are protected. Specifically, the provision of the emissions and control efficiency information that is confidential, proprietary, and trade secret is protected from disclosure under the requirements of subsections 503(e) and 114(c) of the Clean Air Act.
   
   3(g) Sensitive Information
   
   	The anticipated submissions are not expected to include sensitive information.
   
    The Respondents and the Information Requested
   
   4(a) Respondents and Nonattainment areas
   
   State and local air agencies are the primary respondents under this ICR. Table 1 lists all 18 area or parts of areas that are currently nonattainment for one or more of the PM2.5 NAAQS and the potential submissions that one might reasonably expect from their respective states during the 3-year period covered by this ICR.
   
   Table 1 also includes estimated burden hours for each nonattainment area and an estimated total weighted direct and indirect hourly equivalent salary cost of $67.96 per hour. For those areas that are expected not to attain by their applicable PM2.5 NAAQS attainment date, we estimate 18,000 hours to develop and submit SIP revisions in the form of a new attainment plan. For those areas that will have attained by their applicable attainment dates, we estimate 300 hours for states to develop and submit maintenance plans and requests to redesignate those nonattainment areas back to attainment.


   Table 1. Areas Designated Nonattainment for 1997, 2006 and/or 2012 PM2.5 NAAQS: Estimated Burden for Meeting PM2.5 NAAQS Attainment Plan or Maintenance Plan Requirements
   
                      Nonattainment Area for  PM2.5 NAAQS
                                     State
                                  EPA Region 
             Potential Actions during ICR period 1/2020 to 2/2023
                        3-year Burden Estimate (Hours)
                       3-year Burden Estimate (Dollars)
                                   Fairbanks
                                      AK
                                      10
                              2006 SIP Revision 
                                    18,000
                                  $1,223,280
                                    Nogales
                                      AZ
                                       9
                             2006 Maintenance Plan
                                      300
                                    $20,388
                              West Central Pinal
                                      AZ
                                       9
                             2006 Maintenance Plan
                                      300
                                    $20,388
                                   Imperial
                                      CA
                                       9
                             2006 Maintenance Plan
                                      300
                                    $20,388
                       Los Angeles-South Coast Air Basin
                                      CA
                                       9
                2006/2012 SIP Revisions; 1997 Maintenance Plan
                                    18,300
                                  $1,243,668
                                 Plumas County
                                      CA
                                       9
                               2012 SIP Revision
                                    18,000
                                  $1,223,280
                                  Sacramento
                                      CA
                                       9
                             2006 Maintenance Plan
                                      300
                                    $20,388
                                 San Francisco
                                      CA
                                       9
                             2006 Maintenance Plan
                                      300
                                    $20,388
                              San Joaquin Valley
                                      CA
                                       9
                         1997/2006/2012 SIP Revisions 
                                    18,000
                                  $1,223,280
                                     Logan
                                      ID
                                      10
                             2006 Maintenance Plan
                                      300
                                    $20,388
                              West Silver Valley
                                      ID
                                      10
                             2012 Maintenance Plan
                                      300
                                    $20,388
                                     Libby
                                      MT
                                       8
                             1997 Maintenance Plan
                                      300
                                    $20,388
                                 Klamath Falls
                                      OR
                                      10
                             2006 Maintenance Plan
                                      300
                                    $20,388
                                   Oakridge
                                      OR
                                      10
                             2006 Maintenance Plan
                                      300
                                    $20,388
                                   Allegheny
                                      PA
                                       3
                        1997/2006/2012Maintenance Plan
                                      300
                                    $20,388
                                     Logan
                                      UT
                                       8
                             2006 Maintenance Plan
                                      300
                                    $20,388
                                     Provo
                                      UT
                                       8
                             2006 Maintenance Plan
                                      300
                                    $20,388
                                Salt Lake City
                                      UT
                                       8
                             2006 Maintenance Plan
                                      300
                                    $20,388
                                     TOTAL
                                       
                                       
                                       
                                    76,500
                                  $5,198,940
   
   
     4(b)	 	Information Requested

   The information requested, as described in section 2(b) of this ICR, is required to meet the requirements of the CAA. The implementation framework set forth in the PM2.5 SIP Requirements Rule does not adopt a "one-size-fits all" approach to meeting these requirements.  This additional flexibility enables the states to customize, to the extent allowed by the Clean Air Act, their approach to attaining and maintaining the PM2.5 NAAQS.

   Data Items.  The emissions and control efficiency data required for the attainment demonstration, RFP, BACT, BACM, and quantitative milestone reporting is assumed to have been collected as a result of reporting activities required by other OMB approved ICRs. For example, the collection of emissions information for many stationary sources is required under other program requirements, such as the Air Emissions Reporting Rule (AERR) Rule (see https://www.epa.gov/air-emissions-inventories/air-emissions-reporting-requirements-aerr). In developing PM2.5 SIPs, air agencies are expected to use a range of other readily available data sources, such as existing federal rules that are expected to reduce future emissions of particulate matter precursors, and economic and population growth rates.
   
   Respondents' Activities. The states will compile and reference the data, set forth the analytical methodology, analyze and assess control technology, conduct emission reduction and air quality modeling analyses, develop initial drafts, hold public hearings, adopt rules, regulations, and programs, have discussions with EPA staff as appropriate, refine the draft demonstrations as appropriate, adopt the plan, and formally submit to the EPA.
   
   Agency Activities. The EPA staff in the regional offices will facilitate receipt of the draft and final submissions by reviewing materials and answering questions from the states regarding regulatory requirements, potential data sources, analytical tools, the draft demonstrations, and other draft SIP or maintenance plan elements. The EPA regional offices will evaluate the formal plan submissions and take rulemaking actions to approve or disapprove the plan revisions. The EPA headquarters staff will facilitate policy coordination and national consistency in the timely review and evaluation of plans from states around the country. They will also facilitate information flow among the regions and states to promote the development of nationally consistent attainment plan and/or maintenance plan submissions.
   
   Reporting Protocols. The dates for plan submissions and milestone reports are as set forth in subpart 4 of Part D of the CAA (sections 188-190), and in the PM2.5 NAAQS SIP Requirements Rule.
   
 The Information Collected -- Agency Activities, Collection Methodology, and Information Management
     
     5(a)	States, EPA Regional Offices, and EPA Headquarters Offices

	States.  The state agencies' activities include:

 Develop baseline emissions inventory and projection year inventory.
 Conduct analyses of economic and technological feasibility of potential control measures and adopt state rules requiring emission reductions to ensure attainment of the standard "as expeditiously as practicable" or maintenance of the NAAQS during the 10-year maintenance period.
 Develop and evaluate emission reduction strategies, and conduct air quality modeling showing that existing federal and state emission reduction programs, plus any new emission reduction programs adopted by the state, will result in expeditious attainment by the attainment date or maintenance of the NAAQS.
 Develop plans to ensure that future emission reductions will provide for reasonable further progress toward attainment of the standard for the period prior to the area's attainment date. 
 Submit quantitative milestone report within 90 days of a quantitative milestone date that demonstrates the area met its implementation milestones.
   
   	EPA Regional Offices. The regional office activities include:
 Respond to inquiries from the air agencies and providing guidance on plan development.
 Review technical data, analyses, and draft plan elements developed by the air agencies. 
 Evaluate the formal plan submissions and conduct rulemaking actions approving or disapproving the submissions.
   
   	EPA Headquarters.  The EPA headquarters office activities include:
 Answer questions regarding application and interpretation of rule provisions.
 Facilitate policy coordination and national consistency in the timely review and evaluation of plans from states around the country. 
 Coordinate information flow between the regions and states to promote the development of acceptable demonstrations plan submissions.

   5(b) Collection Methodology and Management
   
   	The PM2.5 plans submitted by air agencies will set forth the data sources, analytical methods, and emission reduction and air quality improvement verification procedures used in its development and implementation. 

     5(c)	Small Entity Flexibility

		For an approved ICR, the Agency must demonstrate that it has taken all practical steps to develop separate and simplified requirements for small businesses and other small entities. See 5 CFR 1320.6(h). The PM2.5 NAAQS SIP Requirement Rule does not provide a direct administrative burden on small entities.  

      5(d) Collection Schedule 

		The deadlines for implementing the PM2.5 NAAQS under subpart 4 were approved consistent with CAA requirements. BACM/BACT requirements for Serious area SIPs are due within 18 months of the date an area is reclassified as Serious. For an area reclassified to Serious by operation of law under CAA section 188(b)(2), a state must submit a new attainment demonstration no later than 18 months after reclassification. For an area reclassified to Serious pursuant to the agency's discretionary authority provided under CAA section 188(b)(1), a state must submit a new attainment demonstration no later than 4 years after the reclassification. 189(d) plan revisions are due within 12 months after the applicable Serious area attainment date. Quantitative milestone reports, as required under the CAA, are due every 3 years. To receive a redesignation from "nonattainment" to "attainment," a state must submit a maintenance plan with its redesignation request. However, there is no requirement for a state to submit a redesignation request or maintenance plan.

 Estimating the Burden of the Collection
      
   	This section provides information on the hours and costs associated with the information collection for the respondents (the affected state and local air agencies) and the EPA (regional and headquarters offices).  Hours and costs are presented for the activities associated with each collection item for a nonattainment area (or portion thereof) in a given state, as well as the equivalent annual and present value cost estimates.
   
   6(a) Estimating Respondent Burden
      
   	The estimated respondent burden represents the estimated staff time associated with the activities required to develop the relevant PM2.5 attainment plan or maintenance plan and redesignation request. 
      
   	The estimated burden in this ICR is incremental to the estimated burden of other EPA environmental reporting obligations. The actual incremental burden is expected to vary across areas for a number of reasons, such as the severity of the nonattainment problem and whether existing federal and state emission reduction programs are projected to attain or maintain the NAAQS.
   	
   6(b) Remaining Nonattainment Areas for 1997, 2006 and 2012 PM2.5 NAAQS 
   
   Table 1 provides the list of areas and states that remain nonattainment for the 1997, 2006 and 2012 PM2.5 NAAQS that potentially may need to develop Serious area SIP revisions or 189(d) SIP revisions, or could qualify for and choose to develop redesignation requests with a maintenance plan during the ICR period. The bulk of the anticipated work for the majority of the nonattainment areas consists of developing maintenance plans. The estimated burden hours for each of the areas to develop and submit maintenance plans and redesignation requests is 300 hours. 
   
   However, the Fairbanks, AK; LA-South Coast, CA; Plumas, CA; and San Joaquin, CA, areas could be determined to have missed applicable Serious area attainment dates during the ICR period, and could have one or more Serious area 189(d) SIPs (or portions thereof) due within 12 months of the applicable attainment date (also within the period for this ICR renewal). For the purposes of this analysis, the estimated burden for development of the SIP revisions to address the Serious area requirements is 18,000 hours. 
   
   Table 2 below summarizes the number of collection items (e.g. Serious area attainment plans and redesignation requests) that states may be anticipated to develop, and it provides a 3-year breakdown of expected burden hours by state.
   
   	As a starting point for developing burden estimates for this analysis, the Agency looked at the total hours expended in related EPA level of effort work assignments for meeting the 1997 ozone NAAQS, exclusive of the air quality modeling. The total estimate for ozone areas classified as Marginal was about 2,000 hours in level of technical effort.  The estimated burden for a subpart 4 PM2.5 SIP revision was considered similar to the burden for ozone areas classified as Moderate, and estimated at 9,000 hours. The estimated burden for a subpart 4 PM2.5 SIP revision after an area was reclassified to Serious was considered similar to ozone areas with higher classifications and estimated at 18,000 hours. 
   
   For the purposes of this analysis, the assumed allocation of total incremental burden across the 3 years is divided evenly. Table 2 provides a 3-year breakdown of expected burden hours by state and by year.
   
Table 2.  Nonattainment Areas for 1997, 2006 and 2012 PM2.5 NAAQS: Estimated Incremental Burden Hours by State and Year
      
State
                                  EPA Region
                        No. of Areas or Parts of Areas
                                       
                            Additional hours Year 1
                            Additional hours Year 2
                            Additional hours Year 3
                                      AK
                                      10
                                       1
                                                                          6,000
                                                                          6,000
                                                                          6,000
                                      AZ
                                       9
                                       2
                                                                            200
                                                                            200
                                                                            200
                                      CA
                                       9
                                       6
                                                                         18,400
                                                                         18,400
                                                                         18,400
                                      ID
                                      10
                                       2
                                                                            200
                                                                            200
                                                                            200
                                      MT
                                       8
                                       1
                                                                            100
                                                                            100
                                                                            100
                                      OR
                                      10
                                       2
                                                                            200
                                                                            200
                                                                            200
                                      PA
                                       3
                                       1
                                                                            100
                                                                            100
                                                                            100
                                      UT
                                       8
                                       3
                                                                            300
                                                                            300
                                                                            300
                                     Total
                                        
                                      18
                                                                         25,500
                                                                         25,500
                                                                         25,500
   
       	
6(c)	Estimating Respondent Cost
      
   	Labor costs are estimated for state and local governments using the total of projected burden hours for the current nonattainment for the 1997, 2006, and 2012 PM2.5 NAAQS areas. These estimates do not reflect staff experience and economies of scale. The hourly rates are the result of estimated direct and indirect cost per employee. The main source of the information is http://www.opm.gov/oca/payrates/index.htm.
      
   	The estimated weighted direct salary cost per employee is $43.02 per hour. This results from a summation of the professional, managerial, and support staff components.  
      
 Hourly equivalent 2019 salary of permanent professional staff at GS 11, Step 3 is $35.47.  This is the average of hourly equivalent rates for the San Francisco, CA and Washington, D.C. areas.
 To account for permanent managerial staff, 1/11 or 9.1% of the hourly rate for GS 13, Step 3 is added to the professional staff hourly rates.  The average hourly equivalent rate for GS-13 using rates for San Francisco, CA and Washington, D.C. is $50.46.   The 9.1 percent estimate of that is $4.60.
 To account for permanent support staff at GS-6, Step 6, 1/8 or 12.5% of the hourly rate is added to the professional staff hourly rates. The average hourly equivalent rate for GS-6, Step 6 using rates for San Francisco, CA and Washington, D.C. is $23.60.  The 12.5 percent estimate of that is $2.95. 
      
   	The estimated hourly indirect cost per employee is $24.95.  This amount is the sum of the following:
   
 Benefits at 16% of the weighted direct hourly equivalent salary cost per employee, or $6.88.
 Sick and annual leave at 10% of the weighted direct hourly equivalent salary cost per employee, or $4.30.
 General overhead at 32% of the weighed direct hourly equivalent salary cost per employee, or $13.77.
   	
   	The estimated total weighted direct and indirect hourly equivalent salary cost per employee is therefore $67.96. The estimated annual incremental respondent burden for the state respondents to make the anticipated plan submissions in current year dollars is provided in Table 3.
      
Table 3.  Estimated Annual Incremental Hour and Cost Burden for the States (Respondents) to Fulfill the PM2.5 SIP Submittal Requirements including Maintenance Plans
      
                        No. of Areas or Parts of Areas
                                       
                       Burden for the 3-year ICR period
                                Cost for Year 1
                                Cost for Year 2
                                Cost for Year 3
                                      18
                                 76,500 hours
                                 $1.73 million
                                 $1.73 million
                                 $1.73 million
      
6(d)	Estimating Agency Burden and Cost
      
   The estimated agency burden is derived from the same estimates used for estimating respondent costs in section 6(c). 
      
   The respondent burden was summed for each EPA regional office and a percentage factor was applied to the yearly respondent burden estimate to reflect the burden associated with EPA regional office actions for each SIP submission actions taken. Once yearly burdens were estimated for the Agency's regional offices, a percentage of those amounts was used to derive estimates for the Agency's headquarters office burden. 
      
      Agency Regional Office Burden. The Agency regional office burden is presumed to be 10% of the estimated total incremental burden for respondent by the EPA regional office. The total incremental burden allocation for the Agency regional offices is divided evenly over the 3-year period.

      Agency Headquarters Burden.  The regional office burden estimates for years 1, 2, and 3 are multiplied by 10% to arrive at an estimate for headquarters burden for the same 3 years.    
      
      Total Incremental Burden for the Agency.  The EPA regional and headquarters office burden estimate for each year is 2,805 hours. 
      
      Total Cost for the Agency. Using the weighted direct and indirect salary equivalent hour rate derived in section 6(c), the total incremental burden hours are multiplied by that rate.  
      
6(e)	Estimating the Respondent Universe and Total Additional Burden and Costs

	The total incremental respondent universe burden and cost estimates are presented in Table 4. 

      
Table 4.  PM2.5 NAAQS Total Incremental Respondent & Agency Universe Burden and Cost Estimates 
      
Entity
                         Average Yearly Burden (hours)
                              3-Year Burden (hrs)
                   Present Value of Costs for 3-Year Burden
States
                                    25,500
                                    76,500
                                 $4.8 million
Agency
                                     2,805
                                     8,415
                                 $0.53 million
Total
                                    28,305
                                    84,915
                                 $5.33 million
      
      
      *The estimates are in current year (2019) dollars.  Costs for years 2 and 3 are calculated using the equation Present Value = Future Value/ (1 + interest rate)[t] , where "t" is the number of years hence (i.e., 0 for year 1, 1 for year 2, 2 for year 3).  The adjusted values for years 1, 2, and 3 are then summed.
      

6(f)	Reason for Change in Burden

   We are estimating a total burden of 84,915 hours due to the implementation of the remaining requirements for the 1997 PM25, 2006 PM25 and 2012 PM25 NAAQS. This burden estimate is lower than the estimate for the previous PM2.5 NAAQS SIP Requirements Rule ICR primarily because the number of designated nonattainment areas covered by this ICR is estimated to be lower than it was for the prior 3-year period. The estimates have been calculated using 2019 dollars and some assumptions regarding overhead, O&M costs, and capital costs have been adjusted to meet current guidelines and common procedures for preparing ICRs.

6(g)	Burden Statement

   The annual public reporting and recordkeeping burden for this collection of information is estimated to average 4,250 hours per state respondent for this reporting period. This estimate is derived by taking 76,500 hours, the average yearly burden for the states identified in Table 1, and dividing by 8, the number of affected state respondents. 
      
   The annual burden to the state respondents for this information collection averaged over the 3 years of this ICR is estimated to be a total of 76,500 labor hours at an average of 25,500 labor hours per year at an annual labor cost of $1.6 million (present value) over the 3-year period or approximately $199 thousand per state for the 8 state respondents. The average annual reporting burden is 4,250 hours per response, with approximately 2.25 responses per state for 18 state responses. There are no capital and operating and maintenance costs associated with the PM2.5 NAAQS SIP Requirements Rule.  Burden is defined at 5 CFR 1320.3(b).
      
   Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, disclose, or provide information or for a Federal agency other than the EPA to do so.  This estimate includes the time and burden needed to conduct the tasks associated each state submitting plans required for each PM2.5 nonattainment area. The plan submissions anticipated during this ICR reporting period may include several elements, including emissons inventories, attainment demonstration, RFP plan, BACT and BACM, and quantitative milestones, or redesignation requests and maintenance plans. In meeting these elements, such incremental efforts may include reviewing instructions as well as verifying, processing, maintaining, and disclosing information. Such efforts may require incremental development, acquisition, installation, and/or utilization of technological systems for several purposes. These purposes include collecting, verifying, validating, processing, maintaining and disclosing information associated with the each milestone. The incremental efforts may result from adjusting the ways to comply with the previously applicable instructions associated with other NAAQS such as for 8-hr ozone and PM10.  Consequently, in meeting the milestones, there could be some incremental burden associated with learning/training, searching data sources, and transmitting the deliverables.

   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 the EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.  When this ICR is approved by OMB, the Agency will publish a technical amendment to 40 CFR part 9 in the Federal Register to display the OMB control number for the approved information collection requirements contained in the final implementation rule. However, as was stated in the April 2007 Federal Register Notice for the PM2.5 Implementation Rule, ".. the failure to have an approved ICR for this rule does not affect the statutory obligation for the states to submit SIPs as required under part D of the CAA."

   The Agency established a docket for the PM2.5 NAAQS SIP Requirements Rule under Docket ID No. EPA-HQ-OAR-2013-0691. All documents in the docket are listed at http://www.regulations. gov. Although listed in the docket index, some information may not be publicly available, e.g.,  Confidential Business Information (CBI)  or other information which disclosure is restricted by statue. Certain other material, such as copyrighted materials, is not placed on the internet and will be publicly available in hard copy form. The docket can be viewed online at www.regulations.gov or in person at the EPA Docket Center, WJC West, Room 3334,  1301 Constitution Ave., NW, Washington, DC. The telephone number for the Public Reading Room is (202) 566-1744. For additional information about EPA's public docket, visit http://www.epa.gov/dockets. 
   
