
            SUPPORTING STATEMENT  -  INFORMATION COLLECTION REQUEST
Cross-State Air Pollution Rule and Texas SO2 Trading Programs (40 CFR Part 97, Subparts AAAAA  -  FFFFF) (Renewal)

1.0  Identification of the Information Collection

   1.1  Title of the Information Collection
   
	Cross-State Air Pollution Rule and Texas SO2 Trading Programs (40 CFR part 97, subparts AAAAA  -  FFFFF), EPA ICR Number 2391.05, OMB Control Number 2060-0667.

   1.2  Short Characterization / Abstract
      
      The United States Environmental Protection Agency (EPA) is renewing an information collection request (ICR) for the Cross-State Air Pollution Rule (CSAPR) trading programs to allow for continued implementation of the programs.  There are currently five CSAPR trading programs addressing sulfur dioxide (SO2) emissions, annual nitrogen oxides (NOX) emissions, or seasonal NOX emissions in various sets of states.  The information collection requirements under all five CSAPR trading programs are reflected in the existing ICR as most recently revised in 2016.  In 2017, Texas sources were removed from two CSAPR trading programs and EPA promulgated the Texas SO2 Trading Program using the CSAPR trading programs as a model.  This ICR renewal reflects the 2017 termination of information collection requirements for Texas sources under the two CSAPR trading programs and the 2019 re-establishment of some of the same requirements for some of the same sources under the Texas trading program. 
      
      The principal information collection requirements under the CSAPR and Texas trading programs relate to the monitoring and reporting of emissions and associated data in accordance with 40 CFR part 75.  Other information collection requirements under the programs concern the submittal of information necessary to allocate and transfer emission allowances and the submittal of certificates of representation and other typically one-time registration forms.
      
      Affected sources under the CSAPR and Texas trading programs are generally stationary, fossil fuel-fired boilers and combustion turbines serving generators larger than 25 megawatts (MW) producing electricity for sale.  Most of these affected sources are also subject to the Acid Rain Program (ARP).  The information collection requirements under the CSAPR and Texas trading programs and the ARP substantially overlap and are fully integrated.  The burden and costs of overlapping requirements are accounted for in the ARP ICR (OMB Control Number 2060-0258).  This ICR accounts for information collection burden and costs under the CSAPR and Texas trading programs that are incremental to the burden and costs already accounted for in the ARP ICR.
      
      While most sources participating in the CSAPR and Texas trading programs are directly regulated under federal implementation plans (FIPs), sources in some states participate in the CSAPR trading programs under state implementation plan (SIP) revisions adopted to replace previous FIPs.  This ICR accounts for the burden and costs for sources participating under both FIPs and SIPs.
       
2.0  Need for and Use of the Collection

   2.1  Need / Authority for the Collection

      Emissions data are of vital importance to EPA for fulfilling a host of monitoring, standard-setting, rulemaking, reviewing, and reporting duties.  Allowance-related data are essential elements of regulatory approaches that use allowance trading as a mechanism to reduce the cost of achieving environmental objectives.  Certificates of representation and other registration forms are needed to ensure authoritative and timely action by sources within the deadlines essential to operation of an effective allowance trading program, to relieve retired sources of compliance requirements, and to enable non-source entities to participate in allowance trading activities. 
      
      Clean Air Act (CAA) section 110(a)(2)(D)(i)(I), 42 U.S.C. § 7410(a)(2)(D)(i)(I)  -  often referred to as the "good neighbor" provision  -  requires all states, within three years of EPA's promulgation of a new or revised national ambient air quality standard (NAAQS), to revise their SIPs to prohibit certain emissions of air pollutants because of the adverse impact those emissions would have on air quality in other states.  The first four CSAPR trading programs at 40 CFR part 97, subparts AAAAA through DDDDD, were promulgated in 2011 to fully or partially address multiple states' good neighbor obligations with respect to the 1997 ozone NAAQS and the 1997 and 2006 fine particulate matter (PM2.5) NAAQS.  The fifth CSAPR trading program at 40 CFR part 97, subpart EEEEE, was promulgated in 2016 to fully or partially address multiple states' good neighbor obligations with respect to the 2008 ozone NAAQS.  

      CAA section 169A, 42 U.S.C. § 7491, contains provisions addressing the impairment of visibility in certain areas, including requirements for certain sources to install and operate best available retrofit technology (BART).  EPA's regulations at 40 CFR 51.308(e) allow alternatives to BART under some circumstances.  The Texas SO2 Trading Program at 40 CFR part 97, subpart FFFFF, was promulgated in 2017 as a BART alternative for Texas sources.  
      
      EPA's promulgation of the CSAPR and Texas trading programs is supported by two additional statutory provisions.  First, CAA section 110(c)(1), 42 U.S.C. § 7410(c)(1), requires the EPA Administrator to promulgate a FIP at any time within two years after he or she finds that a state has failed to make a required SIP submission, finds that a SIP submission is incomplete, or disapproves a SIP submission.  Second, CAA section 301(a)(1), 42 U.S.C. § 7601(a)(1), gives the Administrator general authority to prescribe such regulations as are necessary to carry out his or her statutory functions.
   
   2.2  Practical Utility / Users of the Data

      Accurate data from emissions monitoring under 40 CFR part 75 is indispensable to successful implementation of the CSAPR and Texas trading programs for two reasons:

   ●	Accurate emissions data is integral in EPA and state assessment of the impact of the trading programs in reducing NOX and SO2 emissions, and therefore in assisting states in meeting the ozone and fine particulate matter NAAQS and addressing visibility-related requirements.   By reducing levels of NOX and SO2 emissions, the trading programs reduce the adverse effects of the transport of ozone and fine particles and their precursors from upwind states.
   
   ●	EPA enforces the trading programs (in part) by comparing emissions data measured, recorded, and reported under 40 CFR part 75 from affected sources with the number of allowances held in the respective compliance accounts of such affected sources.

      Information collected on allowance transfers is used by EPA to track allowances for the purpose of determining compliance with the NOX and SO2 trading programs.  Information on allowance transfers is also used by participants in the allowance market and the public to evaluate the activities of affected sources, and is used by EPA for program evaluation. 

      Certificates of representation are used to identify a single individual (and optionally a single alternate individual) authorized to represent and act on behalf of all owners and operating personnel of each affected unit.  Without a designated representative, disagreements among joint owners of a unit or lack of clear authority could hamper the operation of an effective allowance trading program by impeding timely submission of quality-assured emissions data or timely decisions with respect to allowance transfers needed for program compliance.  Other one-time registration forms allow qualifying sources or non-source parties to efficiently manage their own participation in the programs, including allowance trading activities. 
      
      Together, the emissions data, allowance data, and various registration forms help to provide the accountability necessary to allow the NOX and SO2 trading programs to function, thereby avoiding the need to pursue costlier command-and-control approaches for achieving environmental objectives.

3.0  Nonduplication, Consultations, and Other Collection Criteria

   3.1  Nonduplication

      Reporting formats for affected sources for the CSAPR and Texas trading programs are integrated with existing reporting formats under 40 CFR part 75.  These reporting formats are currently used by ARP-affected units to meet reporting requirements related to SO2 and NOX under Title IV of the Act.  For a unit subject to more than one of these programs, a single quarterly submission is used to satisfy the quarterly reporting requirements for all programs. 
      
      Information collection procedures under the CSAPR and Texas trading programs for submitting and updating certificates of representation, identifying retired units, and establishing non-source general accounts in the allowance tracking system are similarly integrated with the analogous procedures under the ARP.  In each case, a representative can submit a single form to address the analogous requirements under all applicable programs.
      
   3.2  Public Notice 

      EPA provided public notice of the proposed ICR in the Federal Register on April 16, 2018 (83 FR 16357) and extended the comment period in a second Federal Register notice on June 14, 2018 (83 FR 27768). Several public submissions were made to the docket for the proposed ICR during the comment period, but none of the submissions contains any comments relating to the proposed ICR. 
      
   3.3  Consultations

      The information collection requirements for the CSAPR and Texas trading programs are largely based on the analogous requirements initially developed for the ARP and promulgated in 40 CFR parts 72, 73, and 75, as modified for use in subsequent trading programs under the NOX SIP Call and the Clean Air Interstate Rule (CAIR).  The requirements have evolved based on the trading programs' needs, EPA's experience administering those programs and a similar trading program established by the Ozone Transport Commission (OTC), and consultations with interested parties.
      
      Initial development of the ARP's reporting requirements involved a multi-stakeholder advisory committee that included representatives of states, industry, and environmental groups.  EPA conducted similar processes when modifying the reporting requirements to implement the trading program under the NOX SIP Call, and held workshops with states that participated in the NOX SIP Call or OTC programs to discuss lessons learned in those programs when formulating the emission trading requirements of CAIR.  In 2009, EPA held a series of discussions with stakeholders to identify potential options for addressing states' good neighbor obligations following the remand of CAIR.  EPA incorporated those comments from those discussions into CSAPR.  The requirements for each successive trading program have been established through notice-and-comment rulemaking.  Additionally, EPA has had frequent interaction with affected sources and states in the course of implementing the ARP, NOX SIP Call, CAIR, and CSAPR trading programs.  

      Finally, as part of updating the previous ICR for the ARP monitoring requirements and for this ICR renewal, EPA has contacted various stakeholders to gather information on CEM capital costs, CEM operation and maintenance costs, fuel flowmeter capital costs, and CEM and fuel flowmeter testing costs.  That information has been used in this ICR, as appropriate.
   
   3.4  Effects of Less Frequent Collection

      Submittal of allowance trading and emissions information on at least an annual basis (and/or on an ozone-season basis, as applicable) provides the data necessary to determine whether state budgets have been exceeded.  If this information collection were not carried out at least annually for sources subject to the CSAPR and Texas trading programs, EPA would not be able to verify that emission reductions necessary to meet each state's NOX and SO2 emission budgets were being achieved.  Meeting the annual or seasonal budgets is a central compliance requirement under each of the trading programs. 

      Quarterly collection of emissions data allows for frequent checking of data for errors and provides rapid feedback to industry of needed adjustments to data collection systems, thereby promoting more accurate and reliable emissions data.  Also, existing federal and state emission monitoring programs often require reporting on a quarterly or even monthly basis.  Less frequent collection, such as semi-annually or annually, would increase the amount of preparation and review time at the end of the reporting period both for regulated sources and for EPA, and would slow down the process of compliance determination.

   3.5  General Guidelines

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

   3.6  Confidentiality

      Emissions or allowance-related data that are submitted to EPA under this rule generally will be considered in the public domain and will not be treated as confidential.  CAA section 114(c), 42 U.S.C. § 7414(c), specifically requires that estimates or measurements of emissions must be treated as non-confidential.  Under Agency procedures, data items relating to the computation of emissions may be identified as sensitive by a state and are then treated as "state-sensitive" by EPA.  The potentially state-sensitive items include process rate, boiler design capacity, emission estimation codes, percent space heat, operating rate, and maximum operation rate/hour.  Where federal and state requirements are inconsistent, the appropriate EPA Regional Office should be consulted.
   
   3.7  Sensitive Questions

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

4.0  The Respondents and the Information Requested

   4.1  Respondents / North American Industry Classification System (NAICS) Codes
   
      The CSAPR and Texas trading programs generally apply to stationary, fossil fuel-fired boilers and combustion turbines serving generators larger than 25 MW producing electricity for sale.  In the North American Industry Classification System, these sources are generally classified as NAICS code 221112  -  Fossil Fuel-Fired Electric Power Generation.  Covered sources are subject to recurring emissions-related information collection requirements and one-time or occasional registration requirements.  
      
      Under the CSAPR and Texas trading programs' allowance trading provisions, all covered sources may engage in optional allowance trading activities. Opportunities to participate in allowance trading activities are also open to non-source entities in any industry.  Use of these opportunities is subject to trading-related information collection requirements and, in the case of non-source entities, a one-time registration requirement. 
      
      The CSAPR and Texas trading programs do not impose any information collection obligations on states and do not establish any program-specific permitting requirements that would implicate state and local permitting authorities.  However, a state whose sources participate in a CSAPR trading program under either a FIP or a SIP has certain options to determine how CSAPR emission allowances are allocated each year among the state's affected sources.  Use of this opportunity triggers requirements to submit allowance allocation information.  
      
   4.2  Information Requested

      This section describes the data items requested from affected sources for the collections described in this ICR and defines the activities in which respondents must engage to assemble, submit, or store these data items.  

      (i)  Data Items, Including Recordkeeping Requirements

         (a)  Certificates of Representation and Other One-Time Registration Forms

      For each affected source under each of the CSAPR trading programs and the Texas SO2 trading program, the designated representative must submit a certificate of representation.  The certificate must be updated as needed to reflect any changes in the units at the source or in the identities of owners, operators, or the designated representative or alternate.  A complete certificate of representation for a source includes:

   ●	Identification of the source and the units at the source;
   ●	Dates on which the units commenced commercial operation;
   ●	Name and contact information for the designated representative and alternate (if applicable);
   ●	A list of the owners and operators of each unit; and
   ●	A certification statement and signature of the designated representative and alternate (if applicable).

      Certification applications are to be kept for a period of five years pursuant to the general requirements imposed for Title V permitted facilities.
      
      The CSAPR and Texas trading programs exempt a retired unit from emission monitoring and reporting requirements following receipt of appropriate notification from the designated representative.  A complete retired unit exemption form includes:
      
   ●	Identification of the source and unit;
   ●	Date on which the unit was or will be permanently retired;
   ●	A certification statement and signature of the designated representative or alternate.
      
      The Texas trading program allows certain units not otherwise subject to the Texas trading program to opt in.  Eligible units must already be subject to a CSAPR trading program.  A complete opt-in form includes:
      
   ●	Identification of the source and unit;
   ●	Year in which the unit seeks to enter the program;
   ●	A certification statement and signature of the designated representative or alternate.
      
      Non-source entities participating in allowance trading activities under the CSAPR and Texas trading programs must submit an application to establish a general account in the allowance tracking system.  For purposes of this ICR, it is assumed that the burden and costs of all general account applications are accounted for in the ARP ICR.
      
         (b)  Allowance Tracking

	Sources and other trading program participants must submit allowance transfer, allowance deduction, and compliance assurance information, as necessary. 

 	The authorized account representative for an allowance tracking system account is required to provide the following information for each transfer of allowances to another account:
 
●	Allowance tracking system account number;
●	Name, phone number, and facsimile number of the authorized account representative, along with the representative's signature and date of submission; and
●	Serial numbers of allowances to be transferred.
 
 	In addition, if the designated representative for a source chooses to identify the specific serialized allowances to be deducted from the source's allowance tracking system account for annual reconciliation, then the following information is required:
 
●	Allowance tracking system account number;
●	Type of deduction;
●	Serial numbers of the allowance blocks to be deducted; and
●	Dated signature of the designated representative.
 
 	In the event that total emissions in a state during a control period ever exceeded the state's emission budget by more than a specified variability limit, some sources in the state would be required to submit additional information for compliance assurance.  For purposes of this ICR, it is assumed that no such exceedances will occur.
 
 	Where a state has elected to determine allowance allocations, the state must submit a list identifying the units or other entities to which allowances are being allocated and the numbers of allowances being allocated to each unit or entity. 
 
         (c)  Emissions Monitoring and Reporting

      Sources affected under the CSAPR and Texas trading programs are required to monitor NOX and/or SO2 mass emissions and record and report emissions data following the procedures of 40 CFR part 75.  The emissions monitoring requirements specify that affected sources must (1) submit a monitoring plan for each affected unit at a source, (2) submit data for certification of each monitor, (3) record hourly operational, pollutant monitor, and flow monitor data for each affected unit, and (4) submit quarterly reports of their emissions data to EPA.

      Respondents are required under 40 CFR 75.64 to submit the quarterly NOX and SO2 mass emissions data via direct electronic submission to EPA.  Such data must include a certification statement by the designated representative of the facility attesting to the accuracy, truthfulness, and completeness of the submission.  Generally, all monitoring records are required to be kept for three years.

      (ii)  Respondent Activities

      Industry respondents' tasks to meet the certificate of representation requirement are to submit the certificate when a source first becomes subject to a particular trading program and to submit an updated certificate whenever there are changes in the units at the source or changes in the source's owners, operators, or designated representative.  The task to meet the retired unit exemption notification requirement is to submit a one-time form.  These forms may be submitted on paper or electronically through the CAMD Business System.
      
      Industry respondents' only required task for allowance tracking is occasional submission of allowance transfer forms as necessary to ensure that sufficient allowances are in a source's compliance account as of each compliance deadline.  Additional allowance transfer forms may be submitted by industry or non-source entity respondents as desired, and industry respondents may submit optional allowance deduction forms as desired. These forms may be submitted on paper or electronically through the CAMD Business System.
      
      Industry respondents' primary tasks to meet the emissions monitoring and reporting requirements are:  (1) completing and submitting appropriate monitoring plans; (2) conducting tests to certify monitors and submitting test results to EPA; (3) recording hourly emissions and operational data (this activity is generally performed electronically); (4) performing operation and maintenance activities associated with monitoring, including quality assurance activities; (5) assuring data quality, preparing quarterly reports of emissions data, and submitting these reports to EPA; and (6) responding to error messages generated by such submissions.  In addition, respondents must purchase the necessary monitoring hardware and electronic data reporting software (or software upgrades).
      
      A state respondent that has elected to submit state-determined CSAPR allowance allocations must calculate the allocations according to the state's procedures and periodically submit the allocation information to EPA by specified deadlines.
      
5.0	The Information Collected  -  Agency Activities, Collection Methods, 
and Information Management

   5.1  Agency Activities

      EPA activities related to the CSAPR and Texas trading programs include:  (1) reviewing and processing certificates of representation, retired unit exemptions, and opt-in forms; (2) allocating allowances to affected units, or reviewing states' allocations, and recording the allocations; (3) reviewing and recording allowance transfers and deductions; (4) reviewing monitoring plans and monitor certification applications; (5) processing, reviewing, and evaluating reports of quarterly emissions data from affected units, providing feedback, and storing the data; (6) calculating/reviewing annual emissions from affected sources, and aggregating such annual emissions for compliance assurance purposes; and (7) reviewing total annual emissions data submitted to track each state's progress toward meeting its budgets and creating a summary report of emissions.  EPA also answers respondents' questions and conducts audits of data submissions.

   5.2  Collection Methodology and Management
   
      To ensure consistency across sources and to expedite data entry, EPA requires that standard formats used for reporting under 40 CFR part 75 be used to submit the information collected for the CSAPR and Texas trading programs.

      Several computer systems and associated databases have been developed to (1) track allowance activity, (2) record quarterly emissions monitoring data, and (3) calculate the number of allowances to be deducted each year.  These systems and databases are designed to provide easy access to information for use by the Agency, states, the regulated community, and the general public.  EPA provides access to the data on emissions and allowance activity in both detailed and summary formats on the Clean Air Markets Division website. 

   5.3  Small Entity Flexibility

      CSAPR applies to fossil fuel-fired units (stationary boilers and combustion turbines) that serve an electrical generator with nameplate capacity greater than 25 MWe.  Some cogeneration units and solid waste incinerators are exempt from CSAPR if they meet certain criteria.  The Texas SO2 Trading Program applies to a subset of CSAPR-affected units.

      The low mass emissions provisions under 40 CFR 75.19 provide for optional reduced monitoring, quality assurance, and reporting requirements for certain units that combust natural gas and/or fuel oil.  Such units must emit no more than 100 tons of NOX annually, 50 tons of NOX during the May-September ozone season, and 25 tons of SO2 annually, and must calculate no more than these same amounts based on specified procedures for calculating and reporting emissions.  Units that qualify are exempted from certain requirements to install and operate monitoring equipment, conduct fuel sampling, and perform quality assurance or quality control tests.  Moreover, emissions reporting requirements are significantly simplified for these units.

      Gas- or oil-fired units that do not qualify for the low mass emissions unit provisions under 40 CFR part 75 may still meet criteria that allow for the use of alternative methods to measure emissions.  As discussed in the Regulatory Impact Analysis of the final ARP regulations (October 19, 1992), smaller utilities are more likely to be dependent on these oil- and gas-fired units, especially very small utilities.
   
   5.4  Collection Schedule
      
      Collection frequency under the CSAPR and Texas trading programs is on a quarterly basis.  All affected industry sources must use the Emission Collection and Monitoring Plan System (ECMPS) to submit monitoring plan, quality assurance, certification test, and emissions data to EPA quarterly.  In addition, the programs require the collection of allowance trading information as transfers are submitted, as well as information regarding other "event" submissions made on a one-time or annual basis.  

6.0  Estimating the Burden and Cost of the Collection

   6.1  Estimating Respondent Burden

      This section estimates respondents' burden and cost to meet the information collection requirements described above.  To estimate the burden and/or cost of each requirement, EPA utilized prior estimates of the costs of activities, estimates provided by affected utilities in comments to the Agency, and/or estimates based on the Agency's experience in implementing existing trading programs.
      
      For purposes of this ICR, emissions-related burdens and costs are calculated only for units not subject to the ARP.  Units subject to the ARP already have all of the monitoring and reporting capability required under CSAPR, and EPA believes that the associated ongoing burdens and costs are entirely accounted for under the ARP ICR.  Most CSAPR-affected units are subject to the ARP, and all units required to participate in the Texas trading program (and almost all units eligible to opt into that program) are also subject to the ARP.  Relatedly, this ICR does not address burden and costs for any new units.  EPA expects that any new CSAPR-affected units will also be subject to the ARP, and the burden and costs for those units are therefore covered under the ARP ICR.  The Texas trading program does not apply to new units.  
      
      Burden and costs associated with allowance-related activities and submittal of certificates of representation and other registration forms are calculated based on the estimated numbers of transactions.  The estimates reflect transactions by all sources subject to the CSAPR and Texas trading programs as well as non-source entities participating in allowance trading activities.
      
      Table 2 summarizes the annual industry respondent burden for registration-related, allowance-related, and emissions-related activities.  Table 3 summarizes the annual state respondent burden.  The following discussion describes how the burden estimates were derived.  
      
      (i)  Respondent Burden Related to Certificates of Representation and Other One-Time Registration Forms
      
      Under the CSAPR and Texas trading programs, the designated representative for each affected source must submit a certificate of representation to EPA.  The previous ICR for the CSAPR trading programs accounted for the one-time certificate updates required to reflect commencement of the CSAPR trading programs.  For purposes of this ICR, EPA estimates that certificates of representation covering 10% of non-ARP-affected units will need to be updated annually.  This ICR also includes a one-time burden for sources subject to the Texas SO2 Trading Program to update their certificates of representation to reflect the commencement of participation in that program.  EPA believes that all such revisions are routine and estimates that, on a per unit basis, about one half hour of managerial time and one half hour of technical time will be required for each revision.
      
      Under the CSAPR and Texas trading programs, the designated representative for each retired unit must submit a retired unit exemption form.  EPA estimates that retired unit exemption forms will be filed for approximately 3% of non-ARP units annually, and estimates that each revision will require about one half hour of managerial time and one half hour of technical time.
      
      Under the Texas trading program, a unit seeking to opt into the program must submit a one-time application form.  EPA estimates that such forms would require about one half hour of managerial time and one half hour of technical time.  For purposes of this ICR, it is estimated that one unit will opt in.  

      (ii)  Respondent Burden Related to Allowance Tracking

      Based on the number of allowance transfers recorded by EPA for all CSAPR trading programs for the 2015, 2016, and 2017 control periods, EPA estimates that approximately 2,200 privately submitted allowance transfers will be made each year by sources and non-source entities combined.  The Agency estimates that each transaction submitted will involve about one hour each of managerial and technician time.
      
      Because compliance under the CSAPR and Texas trading programs is determined on a facility basis rather than a unit basis, allowance deduction forms are also generally submitted for facilities rather than individual units.  From experience, EPA estimates that these optional forms will be submitted for approximately one half of all affected facilities, and that each transaction submitted will involve about one hour of managerial time and two hours of technician time.  

      As noted above, under the CSAPR trading programs, states have certain options to submit state-determined allowance allocations.  EPA estimates that where a state has elected to submit such allocations, the activities to prepare the submissions will require 100 hours per year, comprising 25 hours of managerial time and 75 hours of technician time. To date, two states have revised their SIPs to provide for periodic submissions of CSAPR allowance allocation information.  For purposes of this ICR, EPA assumes that three additional states will make similar SIP revisions requiring periodic submissions of allowance allocation information.

      (iii)  Respondent Burden Related to Emissions Monitoring and Reporting

      For emissions monitoring and reporting, the respondent burden varies depending on the monitoring approach followed by the unit and the trading programs in which the unit participates.  The burden and costs in Table 2 are broken out for various groups of respondents to reflect these differences.  As noted above, EPA believes that the emissions-related information collection burden and costs of the CSAPR and Texas trading programs are fully accounted for in the ARP ICR, and this ICR therefore accounts for emissions-related burden and costs for only non-ARP units.
      
      The CSAPR and Texas trading programs generally require all affected sources to monitor their NOX and/or SO2 emission rate and heat input in order to determine NOX mass emissions and/or SO2 mass emissions.  Coal-fired units use NOX, SO2, and stack flow CEMS to meet those requirements.  Oil and gas-fired units have alternatives.  For SO2, these units can use fuel sampling and analysis (or an SO2 default factor for pipeline natural gas) combined with a fuel flowmeter.  In addition, peaking units that burn natural gas and/or fuel oil may use an alternative method for calculating NOX emission rates.  The regulations also allow certain low mass emissions units to use assumed emissions factors together with operational data to calculate emissions.  

      Non-ARP units in 22 states are subject to CSAPR trading programs for both NOX and SO2 and therefore must monitor or calculate and report emissions data for both pollutants.  Non-ARP units in these states must submit quarterly reports for all four quarters of each year.
      
      Non-ARP units in five states including Texas are subject to CSAPR trading programs for NOX, but not SO2, and therefore must monitor or calculate and report emissions data only for NOX.  (While certain Texas units must also monitor and report emissions data for SO2 under the Texas SO2 trading program, all units required to participate in that program  -  and most units eligible to opt into that program  -  are ARP units.)  Non-ARP units in these states may elect to submit quarterly reports for only the two quarters of each year that encompass the May-September ozone season.
      
Start-up Activities
      
      For many sources, a large part of the overall emissions monitoring burden consists of start-up costs for the acquisition, installation, and testing of monitoring equipment.  For units subject to the ARP, the burden and costs for both NOX and SO2 monitoring equipment are accounted for in the ARP ICR.  For non-ARP units, this ICR includes ongoing annualized start-up/capital costs as well as ongoing O&M burden and costs for any monitoring equipment needed by the unit to meet the applicable monitoring and reporting requirements of the CSAPR trading programs, whether the equipment was initially installed to address the requirements of the trading programs under CSAPR, CAIR, or the NOX SIP Call.  No one-time start-up burden is included in this ICR renewal because any such burden was accounted for in previous ICRs, and start-up burdens for any new units are assumed to be covered under the ARP ICR.

Regulatory Review
      
      The ICR includes an allocation of time for the managerial and technical staff to review the CSAPR regulatory requirements as well as the XML formats and instructions associated with electronic emissions data submissions.  Burden for an initial review was covered in the previous ICR.  For purposes of ongoing review after the initial review, the estimated annual burden for each non-ARP source is four hours each for managerial and technician time.

Response to Error Messages
      
      The Agency provides feedback for errors that are found in monitoring plans or other reports.  The Agency estimates that for each non-ARP unit, an owner or operator will spend approximately six hours of managerial time and eighteen hours of technician time responding to these error messages each year.

DAHS Debugging
      
      An estimated burden to fix initial problems with the DAHS software used to report in the 40 CFR part 75 formats was included in the previous ICR.  For the years covered by this ICR renewal, EPA estimates that for each non-ARP unit, one managerial and four technician hours will be required annually for occasional further debugging. 

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

Monitor Certification/Recertification

	Initial certification burdens and costs for new monitoring equipment are considered part of start-up activities since these costs are often part of the overall purchase expense for the equipment.  Sources occasionally experience burdens for recertification to the extent a change in a monitoring system requires recertification.  Based on the previous CSAPR ICR, EPA estimates that approximately ten percent of all non-ARP units will have to recertify each year following the year in which the initial certification occurs.  The ICR incorporates a labor burden estimate generally consistent with existing Agency models for the labor burdens associated with certification.  However, note that the ICR reduces the labor hours for this activity to avoid double counting hours that are already accounted for in the quality assurance activity area (see the following subsection).  The double counting would occur because a portion of the labor incurred for the certification or recertification event replaces the labor burden that is generally allocated to the annual relative accuracy test audit (RATA) in the year in which the certification event occurs.

Quality Assurance

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

Quarterly Reports

	Tasks performed by utilities in preparing quarterly reports include: (1) assuring the quality of the data, (2) preparing the quarterly report, (3) revising the monitoring plan, if necessary, (4) preparation of hard copy documentation accompanying the quarterly reports, and (5) managerial review.  The existing ARP ICR was used as the basis for these estimates.

   6.2  Estimating Respondent Costs

      Table 2 summarizes the annual industry respondent costs for registration-related, allowance-related, and emissions-related activities.  Table 3 summarizes the annual state respondent costs.  The following discussion describes how the costs were derived.

      (i)  Estimating Respondent Labor Costs
      
      In estimating labor costs for industry, EPA used the following amounts: $101.86 per hour for managers and $72.17 per hour for technicians.  These rates are consistent with the Current Employment Cost Index year 2017.
      
      The labor rate used for technical staff at state agencies is $48.78 per hour, and the labor rate for managerial employees at state agencies is $58.76.  These labor rates include benefits and overhead, and are derived from data shown on the Bureau of Labor Statistics website at http://stats.bls.gov/news.release/ecec.toc.htm.  Wage and salary rates are shown at the link "Table 3:  State and local government, by major occupation and industry group (December 2017)."  The wage and salary rates from this table account for benefits provided to workers.  
      
      (ii)  Estimating Capital and Operations and Maintenance Costs

      Capital/start-up costs include the cost of installing required CEMS or alternatives.  Operation and maintenance costs (exclusive of labor costs) reflect ongoing costs to a unit and include both contractor costs for the required recertification, diagnostic, and quality assurance (QA) testing, and other direct maintenance-related expenses (e.g., spare parts and calibration gases).  These cost estimates have been derived from EPA CEM cost models, existing ICRs, Agency staff experience under the ARP, NOX SIP Call, CAIR, and CSAPR programs, and supplemental estimates provided by affected utilities and others related to the various cost items.  These costs are assumed to include incremental calibration gas costs consistent with the former ICR for the Protocol Gas Verification Program (OMB Control Number 2060-0626).
      
      Note that testing contractor costs for certification, recertification and annual relative accuracy test audits (RATAs) are presented as other direct costs and are not converted to equivalent source labor hours.  This approach is consistent with the common business practice of obtaining outside contractors to conduct certification/recertification tests and annual RATAs.  For initial certification, the certification test costs are commonly bundled with equipment purchase contracts, according to information provided by a range of CEMS equipment vendors.  For RATAs that are conducted either as part of the annual quality assurance requirements or as part of recertification, industry contacts have indicated that RATA testing is usually performed under a fixed price contract basis, except for travel costs that may be billed on an hourly basis beyond the basic contract cost.
      
      As noted above, for non-ARP units this ICR includes ongoing annualized start-up/capital costs as well as ongoing O&M costs for any monitoring equipment needed by the unit to meet the applicable monitoring and reporting requirements of the CSAPR trading programs, whether the equipment was initially installed to address the requirements of the trading programs under CSAPR, CAIR, or the NOX SIP Call.  

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

      Capital costs reflect one-time costs for purchase of equipment which will be used over a period of years.  Conversely, operating and maintenance costs are those costs which are incurred on an annual or other scheduled basis.  For instance, costs associated with quality assurance activities, such as spare parts or contractor costs for work, will be incurred on an annual basis.
      
      (iv)  Annualizing Capital Costs

      The relevant capital costs for this ICR were annualized at a rate of seven percent, (i.e., the annualized capital cost was calculated assuming money to purchase the capital equipment was borrowed at a seven percent annual interest rate).  The cost of the loan was amortized over the life of the loan to repay the borrowed amount plus interest.  The result is the annualized capital cost reported.)  The annualized cost of the necessary capital purchases varies from $600 to $29,572 per year per unit, depending on the type of monitoring methodology.  Table 2 contains a breakdown of annualized capital costs by monitoring methodology.

   6.3  Estimating Agency Burden and Costs

      Table 4 summarizes estimated Agency burden and costs.  The following discussion describes how the estimates were derived.

      (i)  Agency Burden Related to Certificates of Representation and Other One-Time Registration Forms
      
      The Agency must review and process each updated certificate of representation and retired exemption form submitted by industry respondents.  EPA estimates that the time required is 0.5 hours per updated certificate of representation, 0.3 hours per retired unit exemption, and 0.3 hours per Texas SO2 opt-in form.  
      
      (ii)  Agency Burden Related to Allowance Tracking

      The Agency must review all state-determined allowance allocations submitted by states and record annual allocations to all existing units according to either the state-determined allocations or EPA's default allocations.  In addition, the Agency must annually calculate allocations to new units according to procedures in the regulations and record those allocations.  EPA estimates that these activities will require 200 hours annually.
      
      Most allowance transfer and deduction forms are submitted electronically using the CAMD Business System.  These transactions are verified and processed automatically at no incremental cost to the Agency.  EPA estimates that approximately 1% of the submissions each year will be submitted on paper, and that review and processing of paper submissions will require one hour per allowance transfer form and one half hour per allowance deduction form. 
      
      The costs of the computer systems used by the Agency in allowance tracking activities are accounted for under the ARP ICR.
      
      (iii)  Agency Burden Related to Emissions Monitoring and Reporting
      
      Agency activities related to the monitoring and reporting of emissions data include reviewing monitoring plans and monitor certification applications; processing, reviewing, and evaluating reports of quarterly emissions data from affected units, providing feedback, and storing the data; calculating/reviewing annual emissions from affected sources, and aggregating such annual emissions for compliance assurance purposes; and reviewing total annual emissions data submitted to track each state's progress toward meeting its budgets and creating a summary report of emissions.  The Agency estimates that these activities will require one hour per quarterly report submitted.
      
      The costs of the computer systems used by the Agency in emissions-related activities are accounted for under the ARP ICR.
      
      (iv)  Agency Labor Costs
      
	Federal Agency labor rates were assumed to be $85.00 per hour.  This labor rate was derived from the federal government's 2017 U.S. Office of Personnel Management General Schedule "Salary Table 2017-GS" (http:/www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2017/GS.pdf) using the factors in Table 1 below.  
                                       
                 Table 1:  Determination of Federal Wage Rates
                                       
                                Labor category 
                                    Factors
                                     Total
Annual salary of technical staff, GS 13, Step 8 
                                                                               
                                                                        $98,986
Annual cost of supervisory staff, GS 15, Step 8 
                                                                       $127,864
                                                                               
Factor (1/11) 
                                                                           0.09
                                                                               
 
                                                                               
                                                                       $11,508 
Benefits
                                                                            1.6
                                                                               
Total cost per FTE 
                                                                               
                                                                      $176,790 
Total hourly cost (total cost per FTE divided by 2,080 hours per year)
                                                                               
                                                                        $85.00 

   6.4  Estimating the Respondent Universe and Total Burden and Costs

      EPA estimates that there are approximately 1,028 industry respondents potentially subject to one or more of the information collections covered by this ICR.  The industry respondents consist of 978 source facilities with 3,152 units subject to at least one of the CSAPR or Texas trading programs, including sources and units that are also subject to the ARP, plus approximately 50 non-source entities participating in allowance trading activities.  This ICR includes estimated allowance-related burden and costs for all industry respondents.  However, EPA believes that the emissions-related information collection burden and costs for sources and units also subject to the ARP are fully accounted for in the ARP ICR (OMB Control Number 2060-0258).  Accordingly, this ICR includes estimated emissions-related burden and costs only for sources that are not subject to the ARP.  EPA estimates that there are approximately 168 sources with 541 non-ARP-affected units subject to emissions-related information collection requirements covered by this ICR.  Table 2 provides estimates of industry respondent burden and costs for registration-related, allowance-related, and emissions-related activities.  
      
      The CSAPR and Texas trading programs apply to sources in 27 states.  States have no mandatory activities under these programs, but states have options to submit state-determined allowance allocations for their sources that are subject to the CSAPR programs.  To date, two states have revised their SIPs to provide for periodic submissions of CSAPR allowance allocation information.  For purposes of this ICR, EPA assumes that three additional states will make similar SIP revisions, resulting in an estimate of five annual responses from the 27 potential state respondents.  Table 3 provides estimates of state respondent burden and costs for this activity.

      Estimates of the Agency's burden and costs are provided in Table 4.
  
                                       
       Table 2:  Annual Industry Respondent Burden and Cost by Activity
                                       
                                       
                           Manager  $101.86 per hour
                         Technician   $72.17 per hour
                           Respondent hours per year
                        Respondent  labor cost per year
                          Cont. O&M cost per year
                       Start-up / capital cost per year
                     Number of respondents / transactions
                             Total hours per year
                              Total cost per year
                     Registration-related burden and costs
Certificate of representation updates[1]
                                                                           0.50
                                                                           0.50
                                                                              1
                                                                            $87
                                                                               
                                                                               
                                                                             54
                                                                             54
                                                                         $4,698
Retired unit exemption forms[2]
                                                                           0.50
                                                                           0.50
                                                                              1
                                                                            $87
                                                                               
                                                                               
                                                                             16
                                                                             16
                                                                         $1,392
Certificate of representation updates for Texas SO2 sources (one-time)[3]
                                                                           0.17
                                                                           0.17
                                                                           0.33
                                                                            $29
                                                                               
                                                                               
                                                                             18
                                                                              6
                                                                           $522
Texas SO2 opt-in form (one-time)[4]
                                                                           0.17
                                                                           0.17
                                                                           0.33
                                                                            $29
                                                                               
                                                                               
                                                                              1
                                                                           0.33
                                                                            $29
                      Allowance-related burden and costs
Allowance transfer form submissions[5]
                                                                              1
                                                                              1
                                                                              2
                                                                           $174
                                                                               
                                                                               
                                                                          2,200
                                                                          4,400
                                                                       $382,800
Allowance deduction form submissions[6]
                                                                              1
                                                                              2
                                                                              3
                                                                           $246
                                                                               
                                                                               
                                                                            489
                                                                          1,467
                                                                       $120,294
                      Emissions-related burden and costs
Review of regulations[7]
                                                                              4
                                                                              4
                                                                              8
                                                                           $696
                                                                               
                                                                               
                                                                            168
                                                                          1,344
                                                                       $116,928
Response to error messages[8]
                                                                              6
                                                                             18
                                                                             24
                                                                         $1,910
                                                                               
                                                                               
                                                                            541
                                                                         12,984
                                                                     $1,033,310
DAHS debugging[8]
                                                                              1
                                                                              4
                                                                              5
                                                                           $391
                                                                               
                                                                               
                                                                            541
                                                                          2,705
                                                                       $211,531
Recertification of monitors, by monitoring approach:[9] 
Solid fuel units: SO2 CEMS (where needed), NOX CEMS, and stack flow CEMS
                                                                             15
                                                                             48
                                                                             63
                                                                         $4,992
                                                                        $2,800 
                                                                               
                                                                              6
                                                                            378
                                                                        $46,752
Gas/oil units: NOX CEMS and Appendix D fuel monitoring
                                                                             10
                                                                             32
                                                                             42
                                                                         $3,328
                                                                        $2,800 
                                                                               
                                                                              7
                                                                            294
                                                                        $42,896
Gas/oil peaking units: Appendix D fuel monitoring, Appendix E, or LME methods
                                                                              8
                                                                             24
                                                                             32
                                                                         $2,547
                                                                       $10,000 
                                                                               
                                                                             42
                                                                          1,344
                                                                       $526,974
                                                                                                (Continued)
                                       
 Table 2:  Annual Industry Respondent Burden and Cost by Activity (continued)
                                       
                                       
                           Manager  $101.86 per hour
                          Technician  $72.17 per hour
                           Respondent hours per year
                        Respondent  labor cost per year
                          Cont. O&M cost per year
                       Start-up / capital cost per year
                     Number of respondents / transactions
                             Total hours per year
                              Total cost per year
Start-up/capital items and performance of QA testing and maintenance, by monitoring approach:[10]
Solid fuel units: SO2 CEMS (where needed), NOX CEMS, and stack flow CEMS
                                                                             50
                                                                            600
                                                                            650
                                                                        $48,395
                                                                       $31,949 
                                                                        $29,752
                                                                             58
                                                                         37,700
                                                                     $6,385,568
Gas/oil units: NOX CEMS and Appendix D fuel monitoring
                                                                             20
                                                                            375
                                                                            395
                                                                        $29,101
                                                                       $17,818 
                                                                        $19,200
                                                                             66
                                                                         26,070
                                                                     $4,363,854
Gas/oil peaking units: Appendix D fuel monitoring, Appendix E, or LME methods
                                                                              5
                                                                             30
                                                                             35
                                                                         $2,674
                                                                        $1,843 
                                                                         $2,304
                                                                            417
                                                                         14,595
                                                                     $2,844,357
Data quality assurance and preparation and submittal of quarterly reports, by reporting frequency:[11]
Annual reporters (four quarterly reports/year)
                                                                             16
                                                                             42
                                                                             58
                                                                         $4,661
                                                                               
                                                                               
                                                                            513
                                                                         29,754
                                                                     $2,391,093
Ozone season-only reporters (two quarterly reports/year)
                                                                              8
                                                                             21
                                                                             29
                                                                         $2,330
                                                                               
                                                                               
                                                                             28
                                                                            812
                                                                        $65,240
Totals
                                                                        133,923
                                                                    $18,538,238
            [1] Assumes updated certificates of representation are required for 10% of non-ARP units each year.
            [2] Assumes 3% of non-ARP units retire each year.
            [3] Reflects one-time required update for each source with units subject to the Texas SO2 Trading Program.
            [4] Assumes for purposes of this ICR that one unit opts into the Texas SO2 Trading Program.
            [5] Estimate reflects 2015-2017 annual average number of allowance transfers submitted for all CSAPR programs by both sources and non-source entities.
            [6] Assumes half of all affected sources under the CSAPR and Texas trading programs submit optional allowance deduction forms each year.
            [7] Applies to all non-ARP sources.
            [8] Applies to all non-ARP units. 
            [9] Assumes 10% of non-ARP units recertify monitoring systems each year.
            [10] Applies to all non-ARP units.  Reflects annualized start-up/capital costs whether monitoring began under CSAPR, CAIR, or the NOX SIP Call.
      [11] Applies to all non-ARP units.  Assumes 40% of non-ARP units eligible to report on an ozone season-only basis elect to do so. 
            
                                                                               
        
                                       
               Table 3:  Annual State Respondent Burden and Cost
                                       
                                       
                            Manager $58.76 per hour
                          Technician $48.78 per hour
                           Respondent hours per year
                        Respondent labor cost per year
                              Responses per year
                             Total hours per year
                              Total cost per year
State allowance allocation[1]
                                                                             25
                                                                             75
                                                                            100
                                                                         $5,128
                                                                              5
                                                                            500
                                                                        $25,640
Totals
                                                                            500
                                                                        $25,640
  [1] Assumes five of 27 CSAPR-affected states submit optional state-determined allowance allocations.
   
                                       
              Table 4:  Annual Agency Burden and Cost by Activity
                                       
                                       
                             Hours per occurrence
                             Cost per occurrence 
                             Occurrences per year
                             Total hours per year
                              Total cost per year
Review and processing of updated certificates of representation.
                                                                            0.5
                                                                           $43 
                                                                             54
                                                                             27
                                                                         $2,295
Review and processing of retired unit exemptions.
                                                                            0.3
                                                                            $26
                                                                             16
                                                                              5
                                                                           $416
Review and processing of opt-in form.
                                                                            0.3
                                                                            $26
                                                                              1
                                                                            0.3
                                                                            $26
Annual allocation and recordation of allowances.
                                                                            200
                                                                        $17,000
                                                                              1
                                                                            200
                                                                        $17,000
Review and recordation of allowance transfers and notification of transfer participants.[1]
                                                                              1
                                                                            $85
                                                                             22
                                                                             22
                                                                         $1,870
Review and recordation of allowance deductions.[2]
                                                                            0.5
                                                                            $43
                                                                              5
                                                                              3
                                                                           $255
Review and processing of quarterly reports and issuance of feedback letters.[3]
                                                                              1
                                                                            $85
                                                                          2,108
                                                                          2,108
                                                                       $179,180
Totals
                                                                          2,365
                                                                       $201,042
     [1]	Assumes 1% of all allowance transfers each year are submitted on paper rather than electronically.
     [2]	Assumes 1% of all allowance deductions each year are submitted on paper rather than electronically.
     [3]	Assumes 513 annual reporters (4 reports/year) and 28 ozone season-only reporters (2 reports/year).


   6.5  Bottom Line Burden Hours and Cost Table

	Table 5 summarizes the bottom line burden and costs for state and industry respondents and the Agency.

               Table 5:  Total Estimated Burden and Cost Summary

                                       
                             Number of Respondents
                    Total Hours Per Year (All Respondents)
                     Total Cost Per Year (All Respondents)
Industry Respondents 
                                                                          1,028
                                                                        133,923
                                                                    $18,538,238
State Respondents
                                                                             27
                                                                            500
                                                                        $25,640
Agency
                                                                              1
                                                                          2,365
                                                                       $201,042

   6.6  Reasons for Change in Burden

      Relative to the burden and costs approved under the existing ICR, the estimated combined burden for industry and state respondents in this ICR renewal has decreased by 40,699 hours and the estimated costs have increased by $5,446,992.  The main causes of the changes in both burden and costs are adjustments reflecting updated estimates for the numbers of respondents and transactions, the time required for certain activities, and current year labor costs.  In addition, small portions of the overall changes in burden and costs are attributable to the termination of information collection requirements for Texas sources under the CSAPR trading programs for SO2 and annual NOX and the reestablishment of similar information collection requirements for a subset of those sources under the new Texas SO2 Trading Program.  Specifically, EPA estimates that the program changes for Texas sources are responsible for a net burden reduction of approximately 574 hours and a net reduction in labor-related costs of $46,048, mostly because of an increase in the number of units eligible to submit quarterly reports for only two instead of all four quarters per year.  Adjustments are responsible for the remainder of the overall changes in burden and costs. 
      
   6.7  Burden Statement

      The annual public reporting and recordkeeping burden for this collection of information is estimated to be 134,423 hours per year for industry and state respondents, or approximately 20 hours per response.  Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, 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, maintaining, disclosing, and providing information; adjusting the existing ways to comply with any previously applicable instructions and requirements; training personnel to be able to respond to a collection of information; searching data sources; completing and reviewing the collection of information; and transmitting or otherwise disclosing the information.  An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.  The OMB control numbers for EPA's regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.

      To facilitate comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID No. EPA-HQ-OAR-2018-0209, which is available for public viewing at the Air and Radiation Docket and Information Center in the EPA Docket Center, Room 3334, 1301 Constitution Avenue NW, Washington, DC.  The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays.  The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the Air and Radiation Docket and Information Center is (202) 566-1742.   An electronic version of the public docket is available at www.regulations.gov.  This site can be used to submit or view public comments, to access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically.  When in the system, select "search," then key in the Docket ID Number identified above.  Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street NW, Washington, DC 20503, Attention: Desk Officer for EPA.  Please include EPA Docket ID No. EPA-HQ-OAR-2018-0209 and OMB Control Number 2060-0667 in any correspondence.

