SF­
83
SUPPORTING
STATEMENT:
Part
A
U.
S.
ENVIRONMENTAL
PROTECTION
AGENCY
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
(
a)
TITLE:
SOURCE
COMPLIANCE
AND
STATE
ACTION
REPORTING
(
Renwal)

(
b)
ABSTRACT:

Source
Compliance
and
State
Action
Reporting
is
an
activity
whereby
State,
District,
Local,
and
Commonwealth
governments
(
hereafter
referred
to
as
"
states/
locals"
or
"
state
and
local
agencies")
make
air
compliance
information
available
to
the
U.
S.
Environmental
Protection
Agency
(
EPA
or
the
Agency)
on
a
cyclic
basis
via
input
to
the
Air
Facility
System
(
AFS).
The
information
provided
to
EPA
includes
compliance
activities
and
determinations,
and
enforcement
activities.
EPA
uses
this
information
to
assess
progress
toward
meeting
emission
requirements
developed
under
the
authority
of
the
Clean
Air
Act
(
CAA
or
the
Act)
to
protect
and
maintain
the
atmospheric
environment
and
the
public
health.
The
EPA
and
many
of
the
state
and
local
agencies
access
the
data
in
AFS
to
assist
them
in
the
management
of
their
air
pollution
control
programs.
This
renewal
information
collection
request
(
ICR)
affects
oversight
of
approximately
41,500
stationary
sources
by
93
state
and
local
agencies
and
the
Federal
EPA,
and
is
expected
to
require
144,089
labor
hours
per
year
and
cost
approximately
$
5.5
million
annually.
State
and
local
agency
burdens
and
costs
are
estimated
as
110,809
hours
and
approximately
$
3.7
million
annually.
On
average,
this
burden
amounts
to
approximately
one­
third
of
a
full­
time
equivalent
employee
for
each
small
state
and
local
agency,
three­
fourths
of
a
full­
time
equivalent
employee
for
each
medium
sized
State
and
Local
Agency
and
one
and
one­
third
of
a
full­
time
equivalent
employee
for
each
large
sized
State
and
Local
Agency
for
national
reporting
of
compliance­
and
enforcement­
related
data
under
all
of
the
applicable
Clean
Air
Act
programs.
In
order
to
lessen
the
burden,
the
new
data
requirements
will
not
be
effective
until
October
1,
2005.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
(
a)
NEED/
AUTHORITY
FOR
THE
COLLECTION
(
i)
Authority
Unlike
other
EPA
legacy
data
systems
(
the
Permit
Compliance
System
(
PCS)
for
the
water
programs
and
the
National
Emission
Inventory
(
NEI)
for
air
emission
inventories),
there
is
no
single
statutory
requirement
for
data
entry
into
the
Air
Facility
System
(
AFS).
Much
of
this
collection
activity
is
referred
to
in
the
following
subsections
of
regulations
implementing
the
Clean
Air
Act
under
`
Subpart
Q
­
Reports'
in
40
CFR
51:
Sections
51.323(
c)(
1),
51.323(
c)(
2),
51.324
(
a)
and
(
b),
and
51.327.
Activity
also
is
authorized
by
40
CFR
70.4(
j)(
1),
which
addresses
submission
of
information
to
EPA
by
state
and
local
permit
authorities,
and
40
CFR
70.10(
c)(
1)(
iii),
which
addresses
EPA
oversight
of
state
and
local
agency
compliance
and
enforcement
efforts
for
major
sources
under
Title
V
operating
permit
programs.
Much
of
the
information
also
is
necessary
for
EPA
to
provide
adequate
oversight
for
other
Federal
programs
implemented
by
states,
such
as
the
New
Source
Performance
Standards
(
NSPS)
in
40
CFR
part
Page
2
of
36
60,
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
in
40
CFR
part
61
and
part
63,
and
New
Source
Review
(
NSR)
permitting
regulations
in
40
CFR
part
51
and
part
52.
Additionally,
all
of
the
data
is
necessary
for
the
implementation
of
the
program
at
either
the
Federal
or
state
and
local
agency
level.
Finally,
the
information
is
necessary
for
EPA
to
fulfill
its
oversight
responsibilities
to
ensure
that
State
Implementation
Plans
(
SIPs)
fulfill
the
testing,
inspection
and
enforcement
requirements
of
40
CFR
51.212
on
an
ongoing
basis.
Much
of
the
need
for
this
collection
is
outlined
in
several
EPA
guidance
documents:
the
Clean
Air
Act
Stationary
Source
Compliance
Monitoring
Strategy
(
CMS)
of
April
2001,
The
Timely
and
Appropriate
(
T&
A)
Enforcement
Response
to
High
Priority
Violations
(
HPVs)
guidance
of
December
1998,
and
the
Clean
Air
Act
National
Stack
Testing
Guidance
of
February
2004.

(
ii)
General
Need
for
the
Data
The
stationary
source
compliance
and
enforcement
air
program
promotes
effective,
cooperative,
and
coordinated
efforts
among
EPA
and
the
state
and
local
agencies.
The
program
recognizes
the
primary
role
of
the
state
and
local
agencies
in
the
prevention
and
control
of
air
pollution.
However,
under
the
Clean
Air
Act,
EPA
has
the
ultimate
responsibility
to
ensure
the
protection
of
the
health
and
welfare
of
the
American
public.
To
meet
these
responsibilities,
EPA
provides
guidance
and
oversight
to
the
state
and
local
agencies
in
two
major
areas:
compliance
surveillance
and
status
activities,
and
enforcement
activities.
The
cyclic
reporting
of
surveillance
information
and
compliance
status
is
the
subject
of
this
renewal
ICR,
and
are
identified
as
a
series
of
minimum
data
requirements
(
MDRs)
that
are
listed
in
Table
1
in
Section
4(
b).
The
MDRs
represent
the
minimum
amount
of
data
EPA
believes
is
necessary
to
manage
the
national
air
stationary
source
compliance
monitoring
and
enforcement
program.
These
data
elements
are
critical
in
prioritizing
programs
and
conducting
national
evaluations.
In
addition,
the
information
provided
by
these
data
elements
enables
the
Agency
to
respond
in
a
timely
manner
to
requests
for
information
with
accurate,
nationally
defined
and
reported
data.
The
CMS
places
an
emphasis
on
the
oversight
of
Title
V
major
sources
and
a
limited
subset
of
synthetic
minor
sources
while
providing
state/
local
agencies
with
the
flexibility
to
address
local
air
pollution
and
compliance
concerns.
CMS
established
a
framework
of
minimal
data
requirements
for
reporting
to
AFS.
This
information
collection
is
an
important
component
for
complete
implementation
of
the
CMS.

The
Clean
Air
Act
National
Stack
Testing
Guidance
is
designed
to
improve
uniformity
on
conducting
stack
tests
and
coordination
among
EPA
and
state/
local
agencies.
AFS
is
one
of
the
Agency's
vehicles
for
tracking
and
evaluating
stack
test
data.

The
HPV
Policy
is
designed
to
help
Federal,
state
and
local
agencies
prioritize
enforcement
efforts
with
respect
to
sources
of
air
pollution
in
their
jurisdictions.
The
Policy
directs
scrutiny
on
those
violations
that
are
most
important.
The
Policy
provides
definitions
for
specific
types
of
violations
and
identifies
the
procedures
to
be
used
in
violation
identification.
AFS
is
used
for
reporting
HPV
activity
in
its
entirety:
discovery,
addressing
and
resolution.

Finally,
data
from
AFS
is
provided
to
the
public
via
the
Enforcement
and
Compliance
Page
3
of
36
History
Online
(
ECHO),
a
Web
tool
developed
and
maintained
by
the
Office
of
Enforcement
and
Compliance
Assurance
(
OECA).
The
ECHO
Web
site
(
www.
epa.
gov/
echo)
provides
compliance
and
enforcement
information
for
approximately
800,000
regulated
facilities
nationwide.
Data
is
extracted
from
AFS
on
a
monthly
basis
and
provided
to
ECHO.
The
data
is
presented
as
part
of
performance
measures
satisfying
the
Government
Performance
Results
Act
(
GPRA)
requirements
for
public
outreach
and
availability
of
data.

(
iii)
Reasons
for
Need
for
New
Data
as
Part
of
this
Renewal
ICR
The
MDRs
in
this
renewal
ICR
represent
a
change
from
the
2001
ICR
for
this
collection
activity.
Also
new
in
this
information
collection
is
the
introduction
of
a
new
category
of
data
reporting­­"
Optional
Reporting".
Although
many
agencies
have
provided
more
data
than
the
required
Minimum
Data
Requirements
(
MDRs),
the
additional
data
has
provided
valuable
information
pertaining
to
compliance
activities
and
enforcement
cases.
The
creation
of
this
discretionary
category
outlines
for
state
and
local
agencies
the
types
of
data
that
the
EPA
would
like
to
use
for
analysis,
and
provides
a
standardized
way
for
data
to
be
reported.
The
changes
are
necessary
to
enable
the
Agency
to
fulfill
its
responsibility
to
protect
the
health
and
welfare
of
the
American
public
by
improving
its
compliance
oversight
and
enforcement
targeting
capabilities
as
well
as
more
fully
implementing
the
CMS,
HPV,
and
Stack
Testing
Policies.
The
new
data
provides
EPA
with
the
ability
to
completely
define
regulated
universes.
The
following
subsections
discuss
the
uses
of
data,
the
nature
of
these
policies,
and
why
the
Agency
needs
to
modify
the
information
collection
data
elements.

°
CMS
Policy
and
Data
A
review
by
the
EPA
Office
of
the
Inspector
General,
Report
No.
E1G­
AE7­
03­
0045­
8100244
dated
September
25,
1998,
Consolidated
Report
on
OECA's
Oversight
of
Regional
and
State
Air
Enforcement
Programs
identified
the
lack
of
oversight
as
a
fundamental
problem
that
adversely
affected
the
effectiveness
of
the
air
compliance
and
enforcement
program.
In
response
to
the
Office
of
Inspector
General
report,
OECA
released
the
April
2001
Compliance
Monitoring
Strategy
(
CMS).
To
implement
the
guidance,
necessary
changes
in
AFS
reporting
capabilities
were
implemented
concurrently
with
the
2001
ICR
renewal.
Specifically,
changes
were
made
to
AFS
to
enable
revised
approaches
associated
with:
identifying
facilities
to
incorporate
compliance
evaluations
frequencies;
conducting
compliance
evaluations
through
the
creation
of
Full
and
Partial
Compliance
Evaluations;
tracking
in­
depth
investigations
of
industries;
inputting
information
on
Title
V
compliance
certifications;
and
expanded
definitions
and
requirements
for
reporting
stack
tests.

These
changes
added
data
elements
not
included
in
the
2001
ICR:
Identification
of
the
pollutant
tested
during
a
stack
test
and
the
reporting
of
Partial
Compliance
Evaluations.
The
2001
ICR
did
not
include
these
two
data
elements
due
to
concerns
expressed
by
several
state
and
local
agencies
that
the
mandatory
reporting
of
this
information
possibly
could
lead
to
a
significant
increase
in
burden.
However,
EPA
continues
to
believe
that
obtaining
information
on
stack
testing
at
the
pollutant
level
and
PCEs
is
important
to
effectively
manage
a
national
air
program,
Page
4
of
36
and
for
EPA,
as
well
as
the
public,
to
be
cognizant
of
the
range
of
activities
that
is
undertaken
by
the
states
and
local
agencies
at
significant
sources.
Since
the
implementation
of
the
CMS
policy,
more
than
half
of
reporting
agencies
have
included
these
data
elements
in
their
reporting
stream.
This
ICR
renewal
includes
the
reporting
of
on­
site
PCEs
and
pollutants
on
a
stack
test
action
as
new
requirements.

°
HPV
Policy
and
Data
The
HPV
Policy
of
December
1998
provides
a
method
of
prioritizing
violations
for
enforcement
purposes.
It
provides
guidance
on
the
identification
of
violations
in
order
to
direct
scrutiny
to
those
of
most
importance.
Also
included
in
the
Policy
is
information
on
the
timeliness
and
appropriateness
of
enforcement,
penalties,
and
the
reporting
and
tracking
of
HPVs
through
AFS.
The
Policy
provides
clear
guidance
and
criteria
to
state
and
local
agency
enforcement
staff
and
managers
and
AFS
users
for
defining
the
type
of
violation
that
triggers
applicability
of
the
policy.
Although
AFS
does
contain
fields
for
the
reporting
of
the
pollutant
in
violation
and
code
values
for
violation
definition,
these
values
were
not
included
in
the
2001
request
for
data
but
were
provided
for
data
input.
The
type
of
violation
and
its
discovery
activity
have
been
topics
of
discussion
in
regularly
held
meetings
and
conference
calls
between
EPA
regional
and
state/
local
agency
staff.
However,
oversight
and
analysis
of
data
are
difficult
and
resource
intensive
without
the
reason
for
violation
and
identification
of
the
violating
pollutant
reported
in
AFS.
Therefore,
incomplete
reporting
of
such
data
is
hindering
the
Agency's
ability
to
carry
out
its
responsibilities
effectively.
Identification
of
the
violation
type
and
pollutant
will
provide
information
concerning
violation
environmental
impact.
Also
requested
is
the
identification
of
the
activity
that
discovered
the
violation
(
i.
e.,
receipt
of
information
documenting
the
violation,
such
as
source
records,
date
of
inspection,
stack
test
report,
or
continuous
emission
monitoring
system
report).
The
date
of
this
activity
is
used
in
the
calculation
of
the
"
Day
Zero",
which
is
defined
by
policy
to
be
established
30­
90
days
from
the
date
of
discovery
and
provides
information
concerning
violation
duration
and
timeliness
of
resolution
of
the
violation.
The
2001
ICR
did
not
require
the
establishment
of
this
activity
in
the
HPV
data
pathway.
The
current
MDRs
do
not
allow
EPA
to
determine
by
which
criteria
a
violation
has
triggered
a
High
Priority
Violator
status.
The
data
will
be
used
to
ensure
that
the
policy
is
being
implemented
as
intended.

(
b)
USE/
USERS
OF
THE
DATA
There
are
many
ways
in
which
EPA,
state
and
local
agencies,
and
the
public
can
use
the
AFS
compliance
and
enforcement
data.
The
Minimum
Data
Requirements
(
MDRs)
represent
the
minimum
amount
of
data
EPA
believes
is
necessary
to
manage
the
national
air
stationary
source
compliance
monitoring
and
enforcement
program.
Some
of
the
key
uses
of
the
data
are
to:

°
Provide
an
accurate
and
accessible
inventory
of
significant
sources
that
are
subject
to
federally
enforceable
emission
regulations;

°
Assess
the
compliance
status
of
sources
with
respect
to
these
regulations
(
compliance
Page
5
of
36
status
changes
are
reported
quarterly
to
ensure
progress
for
sources
that
are
out
of
compliance
and
to
continue
surveillance
for
those
which
remain
in
compliance);

°
Develop
compliance
and
enforcement
strategies;

°
Target
compliance
activities
and
track
enforcement
actions;

°
Develop
new
measures
of
regulatory
program
success;

°
Prepare
various
EPA
reports
on
a
national,
regional,
sector,
or
other
level;

°
Standardize
state
and
local
reporting
to
EPA;

°
Conduct
regulatory
analyses;

°
Support
multimedia
initiatives
which
integrate
quarterly
reports
of
air,
water,
and
land
disposal
compliance
data;

°
Provide
timely
and
accurate
response
for
information
requests
made
by
the
public,
pollution
control
vendors,
Congress
and
other
information
requesters;
and
°
Provide
a
forum
and
model
of
successful
state
and
local
compliance
programs
(
that
include
Federal
data
reporting)
which
can
be
used
by
other
agencies
in
the
development
or
expansion
of
their
existing
programs.

(
c)
ABOUT
AFS
AFS
is
a
management
information
system
designed
to
track
compliance
and
enforcement
information.
It
is
a
fully­
automated
system
which
provides
ready
access
to
historical
and
current
records
for
EPA,
and
state
and
local
agency
staff
involved
in
compliance
and
enforcement
activities.
AFS
resides
on
EPA's
Enterprise
Server
(
IBM
S/
390
G6
9672X37
computer)
at
the
National
Computer
Center
(
NCC)
in
North
Carolina
and
is
accessible
to
all
state
and
Local
Agency
users
via
a
Host
on
Demand
session
via
the
Internet
or
through
DynaComm
communications
software
available
to
Federal
users.

AFS
is
considered
to
be
an
antiquated
system.
Comments
concerning
this
collection
have
indicated
that
the
difficulties
in
using
AFS
should
negate
addition
of
any
new
data
until
modernization
of
AFS.
Modernization
of
the
system
is
underway,
but
final
conversion
to
a
stateof
the­
art
system
will
not
be
completed
until
FY2008
or
later
due
to
resource
limitations.
Oversight
of
the
program
must
continue
throughout
the
modernization
effort,
and
valuable
data
necessary
for
oversight
can
be
conveyed
via
AFS.
In
light
of
comments
received
concerning
the
antiquity
of
the
system,
several
concessions
have
been
made
in
the
consideration
and
selection
of
any
additional
data
elements
to
the
collection,
such
as
selection
of
mandatory
fields
already
Page
6
of
36
considered
reportable
by
many
agencies,
using
existing
fields
to
negate
reprogramming
of
existing
conversion
programs,
generation
of
system
utilities
to
assist
with
reporting
and
placing
more
burden
on
tools
of
analysis
used
by
EPA
instead
of
changing
data
entry
requirements.

(
d)
PROGRAM
CHANGES
The
following
data
elements
comprise
the
additions
and
changes
to
this
data
collection
request:

(
i)
Addition
of
the
Subpart
Identifier
in
the
Air
Program
Record
Specifically,
the
subpart
identifier
is
maintained
in
the
Air
Program
record
of
AFS
for
the
Maximum
Achievable
Control
Technology
(
MACT),
New
Source
Performance
Standards
(
NSPS)
and
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
air
programs.

Approximately
90
MACT
standards
have
been
promulgated
since
1990
(
40
CFR
part
63).
Compliance
dates
are
in
place
for
approximately
43
MACT
Standards.
Fifty­
five
additional
area
source
standards
are
to
be
promulgated
(
112K­
Urban
Air
Toxics
Strategy)
between
2005
and
2010.
This
significant
increase
of
Clean
Air
Act
regulations
has
underscored
the
need
for
better
targeting
of
affected
facilities
within
the
Air
Compliance/
Enforcement
Program.
Knowing
the
specific
subpart
to
which
a
facility
is
subject
will
significantly
enhance
the
Agency's
ability
to
target
limited
resources
on
the
most
environmentally
significant
sources.
Subpart
identification
will
also
help
EPA
and
state/
local
agencies
to
establish
compliance
rates.
Subpart
identification
will
provide
a
clear
definition
of
all
applicable
regulations
at
a
source
and
will
assist
the
Agency
with
performance
measurement.

Many
state
and
Local
Agencies
are
already
voluntarily
reporting
Subpart
applicability
within
Air
Programs
in
AFS,
with
24,890
subparts
reported
on
the
NSPS,
MACT
and
NESHAP
air
programs
nationwide.
In
order
to
reduce
immediate
reporting
burden
for
agencies
not
previously
reporting
this
data,
EPA
recommends
that
applicable
air
program
subpart
data
be
updated
when
a
Full
Compliance
Evaluation
is
completed.
The
CMS
Policy
requires
that
all
major
sources
be
evaluated
every
two
years,
and
a
subset
of
synthetic
minor
sources
evaluated
every
five
years,
or
as
negotiated
between
an
EPA
Regional
Office
and
delegated
Agency.
A
review
of
applicable
air
programs
and
subparts
must
be
completed
as
part
of
the
evaluation
and
subpart
applicability
can
be
updated
in
AFS
at
that
time.
Subpart
identification
would
be
required
at
the
air
program
level
only
(
AFS
acronym
SPT1)
and
not
required
at
each
air
program
pollutant,
nor
at
the
action
level
of
AFS.

(
ii)
Addition
of
the
Pollutant
Code
to
Stack
Test
Actions
The
CMS
Policy
of
April
2001
introduced
reporting
requirements
of
"
Pass"
or
"
Fail"
for
stack
tests.
Adding
the
pollutant
to
the
stack
test
action
record
provides
valuable
information
on
Page
7
of
36
which
specific
pollutants
failed
and
may
be
in
violation.
Otherwise,
"
Fail"
without
this
information
could
inaccurately
suggest
failure
for
all
pollutants.
This
does
require
a
separate
entry
for
each
pollutant
tested
in
a
particular
stack
test.
Reporting
the
stack
test
pollutant
is
consistent
with
the
requirements
contained
in
the
HPV
Policy
(
a
violation
of
an
allowable
pollutant
emission
limit
detected
during
a
reference
method
stack
test)
and
also
the
National
Stack
Testing
Guidance
of
February
2,
2004
(
pass/
fail
of
prescribed
emission
limits
of
a
pollutant).
Reporting
the
results
of
a
stack
test
at
the
pollutant
level
addresses
a
programmatic
deficiency
(
identified
by
the
EPA
Inspector
General's
"
Report
of
EPA's
Oversight
of
State
Stack
Testing
Program
(
Report
number
2000­
P­
00019)
dated
September
11,
2000)
by
removing
the
inconsistent
reporting
of
stack
tests.
Without
the
pollutant
information,
the
data
is
of
limited
utility
in
evaluating
the
level
of
activity
and
tracking
compliance
status
for
specific
pollutants
that
could
identify
a
High
Priority
Violation
or
contribute
to
non­
attainment
designation.

Regarding
the
proposed
addition
of
the
pollutant
code
to
stack
test
actions,
many
states
and
local
agencies
commented
on
the
inability
of
AFS
to
maintain
more
than
998
actions.
With
the
requirement
of
multiple
actions
for
stack
test
pollutant
reporting,
many
agencies
were
concerned
that
the
number
of
actions
reported
to
AFS
would
rapidly
approach
the
limit.
To
address
this
issue,
AFS
now
provides
a
utility
for
compressing,
renumbering,
and
archiving
actions
to
prevent
the
situation
of
"
action
overload".

(
iii)
Addition
of
the
High
Priority
Violator
(
HPV)
"
Violation
Discovered"
activity
and
date
The
HPV
Policy
sets
a
30­
90
day
window
for
HPV
determinations
from
date
of
discovery.
However,
there
is
not
an
existing
dataflow
which
documents
the
"
Violation
Determined"
or
"
first
occurrence"
date
that
initiates
the
HPV
time
line
process
and
allows
EPA
to
measure
compliance
with
the
Policy.
Incorporating
this
milestone
action
is
responsive
to
data
requests
regarding
the
need
to
better
explain
the
results
of
evaluations.
Though
violations
meeting
the
HPV
requirements
can
be
determined
by
methods
other
than
evaluation,
the
link
between
compliance
activities
and
HPV
is
critical.
Discovery
can
be
made
through
a
variety
of
ways
including
an
onsite
evaluation
(
regularly
scheduled
oversight
by
the
delegated
agency);
a
self­
disclosure
(
Title
V
Annual
Compliance
Certification);
a
report
showing
failure
of
a
stack
test;
review
of
documentation
(
e.
g.,
self­
monitoring
reports,
fuel
use
records,
production
records)
or
other
compliance
monitoring
activities.
These
action
types
are
not
new
to
AFS
and
will
pose
no
new
burden
to
the
majority
of
users
who
are
already
reporting
such
data
in
their
HPV
pathways.
In
fact,
the
action
types
are
already
included
in
the
AFS
Minimum
Data
Requirements
(
MDRs)
with
the
exception
of
on­
site
PCEs.
These
existing
action
types
will
be
coded
with
a
unique
indicator
in
the
AFS
Action
Tables.
The
user
will
have
to
link
the
"
Violation
Discovered"
action
type
in
the
violation
pathway.
Burden
for
reporting
this
activity
is
minimal,
as
in
many
cases
the
only
requirement
is
action
linkage.
Other
software
used
by
EPA
will
be
able
to
discern
and
analyze
this
data.
The
types
of
actions
that
can
be
used
to
report
the
HPV
Discovery
Date
are:

°
A
Full
Compliance
Evaluation;
Page
8
of
36
°
A
Partial
Compliance
Evaluation
(
On­
or
Off­
Site
Evaluations);
°
A
Title
V
Annual
Compliance
Certification;
°
Stack
Tests;
°
Investigations
(
iv)
Addition
of
the
High
Priority
Violator
(
HPV)
Violation
Type
Code
and
Violating
Pollutants
(
AFS
element
VTP1:
General,
Matrix
and
Discretionary
Criteria)
and
AFS
element
VPL1:
Violating
Pollutants)

As
stated
in
the
OIG
Report
No.
E1GAE7­
03­
0045­
8100244,
Consolidated
Report
on
OECA's
Oversight
of
Regional
and
State
Air
Enforcement
Programs
(
9/
25/
98),
and
the
Government
Performance
and
Results
Act
(
GPRA)
requirements
(
GPRA
Goal
5­
Compliance
and
Environmental
Stewardship;
Object
1:
Improve
Compliance),
the
Agency
must
evaluate
and
measure
priority
enforcement
in
terms
of
`
environmental
harm'.
In
addition,
the
public,
regulated
facilities,
and
environmental
advocates
have
formally
requested
this
type
of
information.
Both
the
Clean
Water
Act
(
CWA)
and
Resource
Conservation
and
Recovery
Act
(
RCRA)
programs
and
their
databases
(
Permit
Compliance
System
(
PCS)
and
RCRAInfo)
have
sophisticated
reporting
and
tracking
of
either
pollutants
violated
or
violating
types/
definitions
or
both.
Clean
Air
Act
HPV
tracking
has
only
two
methods
of
tracking
this
information
and
neither
HPV
violation
type
codes
or
violation
pollutants
were
required
to
be
reported
as
MDRs.
These
data
elements
not
only
provide
insight
to
potential
environmental
harm,
but
they
can
provide
details
about
the
extent
of
the
violations
(
e.
g.,
percentage
of
excess
emissions
above
legal
limits).
The
data
elements
also
can
provide
a
clear
connection
to
the
HPV
Policy
and,
therefore,
make
it
easier
to
evaluate
implementation.
Both
of
these
data
elements
are
entered
on
the
AFS
"
Day
Zero'
record/
menu
screen
and
would
be
entered
at
the
same
time
as
the
HPV
Day
Zero;
thereby
minimizing
burden
and
not
requiring
a
new
update
session
in
AFS.
To
phase
in
the
implementation
of
this
requirement
and
reduce
reporting
burden,
these
new
codes
would
be
required
of
new
HPVs
reported
beginning
in
FY06.
Definitions
of
these
codes
can
be
found
in
the
HPV
Policy
and
are
also
listed
in
Table
1
of
Section
4
of
this
document.

(
v)
Revised
reporting
frequency
for
state/
local
agencies
from
quarterly
to
60
days,
with
a
new
definition
of
timeliness.

This
change
in
time
standard
requires
that
all
activity
be
reported
to
AFS
within
60
days
of
the
date
the
activity
occured.
This
change
in
frequency
would
not
increase
the
amount
of
data
reported
to
AFS,
but
could
increase
burden
based
on
the
number
of
submissions
to
AFS
in
a
given
year.
This
timeliness
standard
is
considered
normal
business
practice
and
is
in
line
with
the
reporting
requirements
of
other
EPA
systems.
The
resulting
consistency
among
the
data
systems
will
remove
any
potential
confusion
among
the
users
of
the
various
data.
With
the
public
release
of
AFS
data
in
ECHO,
more
timely
reporting
requirements
placed
upon
EPA
through
GPRA,
and
an
increasing
use
of
data
for
EPA
decision­
making,
real
time
data
is
essential.
Moving
from
a
quarterly
upload
strategy
to
a
60­
day
maximum
reporting
frequency
is
an
attempt
to
move
toward
maintaining
real
time
data
in
AFS
and
meeting
public
demand.
A
quarterly
data
lag
negatively
Page
9
of
36
impacts
the
ability
to
conduct
on­
going
and
year­
end
analyses.
In
the
event
a
quarterly
update
was
not
completed,
data
would
not
be
received
until
six
months
later.
This
lag
in
data
reporting
is
misleading
because
inaccurate
(
or
at
least
old,
out
of
date)
information
ends
up
appearing
on
public
web
sites
such
as
ECHO
or
ENVIROFACTS
and
there
is
also
the
unacceptable
dely
in
error
correction.
As
a
result,
inaccurate
conclusions
can
be
made
regarding
state
and
local
compliance
monitoring
and
enforcement
program
performance.
This
new
standard
will
improve
oversight
and
management
capabilities
by
providing
data
for
analytical
purposes
on
a
consistent
and
reliable
basis.
Of
the
twelve
agencies
who
were
individually
consulted
with
regard
to
this
information
collection
renewal,
eleven
expressed
no
concerns
with
reporting
on
a
60­
day
basis.

This
new
time
standard
will
require
more
frequent
submissions
of
information
from
states
submitting
batch
files
(
a
minimum
of
6
submissions
versus
previous
4
submissions
annually).
Many
direct
users
of
AFS
(
those
entering
data
directly
on
line
without
batch
file
submission)
usually
update
the
system
on
a
monthly
basis
and
have
not
reported
any
additional
burden
with
this
new
time
standard.

(
vi)
Reporting
of
On­
Site
Partial
Compliance
Evaluations
(
PCEs)

Due
to
the
concerns
expressed
by
state
and
local
agencies
regarding
the
additional
reporting
burden
during
the
2001
ICR
renewal,
the
reporting
of
PCEs
was
optional
when
the
revised
CMS
Policy
was
initially
implemented
in
2001.
Since
that
time,
thirty­
nine
agencies
have
reported
both
on­
and
off­
site
PCEs
during
FY03,
for
a
total
of
15,459
PCE
actions,
of
which
53%
were
reported
as
on­
site
activities.
The
Agency
continues
to
believe
that
the
reporting
of
PCEs
is
essential
to
effectively
manage
a
national
program
and
adequately
portray
the
range
of
compliance
monitoring
activities
being
conducted.

The
majority
of
comments
received
from
state
and
local
agencies
indicated
that
the
reporting
of
all
PCEs
would
be
an
onerous
task
that
many
agencies
are
unwilling
to
complete.
Additionally,
comments
indicated
that
the
generic
reporting
of
PCEs
would
not
lend
any
value
to
the
data
contained
in
AFS,
nor
would
the
public
benefit
from
the
generic
listings
of
a
partial
compliance
activity
that
is
undefined.
However,
several
agencies
indicated
a
willingness
to
report
on­
site
activities
that
were
defined,
providing
EPA
and
the
general
public
with
a
better
picture
of
oversight
activity
at
any
given
source.
In
order
for
the
Agency
to
carry
out
its
oversight
responsibilities
while
taking
into
account
the
state
and
local
agency
reporting
burden,
only
on­
site
PCEs
will
be
required
as
minimum
reporting,
with
reporting
of
off­
site
PCEs
listed
as
a
highly
recommended
optional
(
discretionary)
activity.

Four
new
national
action
types
will
be
created
for
reporting
on­
site
PCEs:

°
Complaint
Evaluation:
Used
for
reporting
the
investigation
of
a
complaint
resulting
in
the
on­
site
visit
of
a
stationary
source.
°
Permit
Evaluation:
Used
for
reporting
pre­
and
post­
permit
issuance
activities,
where
an
on­
site
visit
is
necessary
to
review
individual
processes
or
installation
of
equipment.
Page
10
of
36
°
Compliance
Evaluation:
Used
for
reporting
the
review
of
one
or
more
plant
processes
for
compliance
purposes.
For
example,
Maximum
Achievable
Control
Technology
(
MACT)
notifications
and
resulting
compliance
determinations.
°
On­
Site
Observation:
Used
for
reporting
any
on­
site
review
of
source
to
include
visible
emissions
or
other
observed
activity.

The
generic
action
types
for
reporting
both
On­
and
Off­
site
PCEs
will
continue
to
be
acceptable
for
reporting.
Reporting
of
all
PCEs
(
on­
and
off­
site)
completed
by
a
Federal
Regional
Office
will
be
required.

(
vii)
Optional
Reporting
of
Permit
Program
Data
Elements
(
PPDEs):
Permit
Number,
Permit
Category,
Date
Final
Permit
Issued/
Renewal
(
Event
Types
IF/
IR
and
Date
Achieved)

The
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS)
established
the
PPDEs
in
1994
with
the
advent
of
the
new
Title
V
program.
Permit
issuance
data
greatly
assists
in
the
management
and
implementation
of
the
Title
V
program.
Knowing
when
a
facility
has
been
issued
a
Title
V
permit
is
essential
for
determining
the
universe
of
facilities
subject
to
Title
V
requirements.
The
majority
of
reporting
agencies
are
already
reporting
Title
V
issuance
to
AFS,
with
13,507
issued
permits
reported
from
43
states.
However,
there
is
no
requirement
or
standard
for
this
data
by
the
Office
of
Enforcement
and
Compliance
Assurance.
Currently
AFS
depends
on
the
reporting
of
the
Title
V
air
program
and
classification
code
for
attempting
to
establish
the
universe
of
facilities
subject
to
Title
V
requirements.
Yet,
the
air
program
code
is
not
sufficient
because
it
does
not
provide
any
information
on
the
actual
issuance
of
the
permit,
the
date
of
permit
issuance
or
category.

While
many
state
and
local
agencies
submitted
comments
supportive
of
this
data,
others
expressed
opposition
because
of
the
high
start­
up
costs
to
include
programming
to
an
AFS
data
stream
different
from
regular
compliance/
enforcement
activity
reporting.
Therefore,
in
order
to
reduce
overall
burden,
this
data
stream
will
be
considered
optional
or
discretionary
reporting
in
deference
to
the
guidance
established
by
OAQPS.
Other
PPDEs
(
other
Permit
Events
such
as
Draft
Permit
Issued,
Draft
Permit
Received
by
EPA,
etc.)
will
also
be
considered
as
optional
data
reporting.
Optional
AFS
data
elements
recommended
by
this
request
will
be:
Permit
Number
(
ASPN),
Permit
Category
(
PMTC),
Date
Final
Permit
Issued/
Reissued
(
Event
Type
(
PATY)
of
IF
or
IR,
and
Date
Achieved
(
PDEA)).

3.
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
(
a)
NON­
DUPLICATION
The
MDR
data
elements
outlined
in
Table
1
of
Section
4(
b)
represent
minimum
data
requirements
for
effective
implementation
and
management
of
a
compliance
and
enforcement
Page
11
of
36
program.
For
EPA
and
the
public,
the
AFS
data
are
the
only
source
of
national
information
on
compliance
and
enforcement
activities.
State
and
local
agency
respondents
generally
collect
the
information
as
part
of
their
customary
business
practice
to
manage
their
compliance
and
enforcement
programs,
and
thus
there
is
no
duplication
in
terms
of
collection.
AFS
has
been
designed
to
reflect
the
summary
of
core
program
data.
State
and
local
agencies
can
use
AFS
as
their
own
data
system
for
managing
the
data
elements,
but
the
majority
of
agencies
have
created
or
are
creating
their
own
integrated
data
management
system
for
a
complete
environmental
record
of
a
source's
activity.
EPA
has
also
developed
a
Universal
Interface
(
UI)
software
tool
to
improve
the
process
for
batch
uploads
of
information
from
state/
local
systems
to
AFS.
The
UI
provides
a
conversion
program
from
state/
local
systems
to
AFS,
negating
the
need
for
the
expense
of
programmers
or
additional
resources
for
transferring
data.
The
Office
of
Enforcement
and
Compliance
Assurance
(
OECA)
has
provided
$
1,714,500
in
competitive
grant
dollars
from
1999
through
2004
to
facilitate
the
use
of
the
system
and
streamline
the
reporting
process
to
AFS
using
the
UI.
Fourteen
(
14)
agencies
are
currently
using
the
Universal
Interface,
with
some
users
indicating
a
reduction
of
reporting
burden
of
30%
over
previous
reporting
efforts.
Additionally,
the
UI
will
be
able
to
convert
and
report
records
for
all
MDRs,
as
well
as
the
optional
Permit
Program
Data
Elements.
Thus
we
can
conclude
that
a
significant
percentage
of
the
increased
burden
resulting
from
this
renewal
will
be
offset
by
future
reductions
in
burden
as
a
result
of
additional
UI
users.

In
some
cases,
state
or
local
agencies
in
the
process
of
creating
a
state
system
may
manually
enter
data
into
their
system
and
AFS,
but
these
states
are
working
toward
an
automation
of
the
batch
upload
process.
EPA
encourages
these
states
to
review
the
UI
and
its
capabilities.
Additionally,
as
AFS
continues
its
modernization
efforts,
the
creation
of
streamlined
reporting
will
be
a
certainty
with
the
introduction
of
an
XML
schema
for
AFS
reporting.

(
b)
PUBLIC
NOTICE
REQUIRED
PRIOR
TO
SUBMISSION
TO
OMB
The
first
Federal
Register
notice
on
this
ICR
was
published
on
June
1,
2004
(
ICR
No.
0107.08,
OMB
Control
Number
2060­
0096,
OECA­
2004­
0024).
EPA
also
accepted
comments
through
September
2004.

(
c)
CONSULTATIONS
EPA
provided
information
to
the
states/
locals
on
potential
changes
to
AFS
reporting
as
part
of
its
overall
oversight
responsibilities.
The
Agency
encouraged
comments
and
feedback
from
state
and
local
agencies
about
these
proposed
changes
and
received
thirty
(
30)
comments
from
twenty­
eight
(
28)
agencies
(
outlined
in
Appendix
1,
Commentaries).

In
June
2004,
EPA
discussed
the
ICR
at
a
national
meeting
with
the
State
and
Territorial
Air
Pollution
Program
Administrators/
Association
of
Local
Air
Pollution
Control
Officials
(
STAPPA/
ALAPCO),
the
associations
representing
state
and
local
air
pollution
agencies.
EPA
also
presented
an
overview
of
the
ICR
proposed
requirements
at
the
National
AFS
Workshop
in
July
2004.
In
addition,
EPA
followed
up
with
several
commenting
agencies
to
clarify
their
Page
12
of
36
comments
and
confirm
estimates
of
burden.
EPA
also
discussed
this
information
request
and
collected
total
labor
estimates
for
AFS
reporting
from
a
survey
of
additional
states/
locals,
identified
in
Appendix
2,
Agencies
Directly
Contacted
for
Burden
Estimates.
This
information
was
used
to
develop
the
burden
estimates
discussed
in
Section
6
(
i.
e.,
current
burden
and
the
estimated
burden
that
will
result
from
this
renewal
ICR).

(
i)
General
Comments:

°
AFS
is
an
antiquated
system
and
too
burdensome
for
adding
workload
through
new
data
requirements.
Modernization
of
the
system
is
required
before
requesting
additional
data.
EPA
recognizes
the
age
of
the
system
(
AFS
was
operational
in
1990)
and
has
begun
a
modernization
effort.
AFS
is
scheduled
for
inclusion
into
the
Integrated
Compliance
Information
System
(
ICIS).
Several
modernization
activities
have
taken
place.
A
Needs
Analysis
was
completed
in
FY2002,
with
an
initial
comparison
to
ICIS
completed
during
FY2003.
EPA
is
now
forming
a
modernization
workgroup
to
continue
work
with
structure
and
business
rules.
While
modernization
moves
forward
toward
a
target
date
of
FY2008,
the
addition
of
essential
information
for
the
oversight
and
management
of
the
air
compliance/
enforcement
program
cannot
wait.
The
proposed
elements
will
not
require
any
structural
changes
to
AFS
and
will
utilize
already
existing
fields.
Additionally,
EPA
is
willing
to
provide
grant
assistance
for
the
facilitation
of
reporting
new
fields
during
FY2005
via
the
State/
Tribal
Assistance
Grant
(
STAG)
program
sponsored
by
OECA.
Grant
solicitations
were
published
December
16,
2004,
and
projects
utilizing
the
Universal
Interface
(
UI)
software
or
other
data
system
configurations
to
facilitate
data
migration
will
be
considered.
Agencies
with
difficulties
reporting
new
elements
are
encouraged
to
respond
to
this
solicitation.

°
Any
new
data
requirements
would
require
additional
resources
when
many
state/
local
budgets
are
frozen.
Most
new
elements
are
actually
already
being
voluntarily
reported
by
a
majority
of
agencies,
and
all
requested
elements
include
data
necessary
for
the
oversight
of
the
Clean
Air
Act.
EPA
is
ready
to
assist
state
and
local
agencies
who
currently
may
have
data
residing
in
systems
or
files
which
are
unable
to
upload
to
AFS.
Agencies
unable
to
provide
the
requested
fields
should
request
assistance
from
their
EPA
Regional
Office.

°
EPA
references
of
authority
for
AFS
reporting
are
not
adequate.
As
mentioned
in
Section
2(
a)(
i),
there
is
no
one
authority
for
AFS
reporting,
but
multiple
requirements
for
data.
These
authorities,
combined
with
EPA
guidance,
are
adequate
for
defining
the
information
needed
for
management
of
the
air
program.

°
Wait
to
implement
any
changes
until
FY06
(
October
1,
2005).
EPA
agrees
and
will
delay
implementation
of
the
new
data
elements
in
this
collection
request
until
that
time.

(
ii)
Specific
Comments
on
Proposed
Data
Elements:
Page
13
of
36
°
Subpart
Data:
Search
Time/
Startup
costs
too
onerous.
AFS
currently
houses
some
subpart
data
from
every
state.
However,
since
this
data
is
not
an
MDR,
it
cannot
be
verified
to
be
complete.
A
few
agencies
provided
comments
of
non­
support
for
this
field,
citing
the
time
needed
by
staff
to
review
permit
files
for
the
information
or
to
rework
agency
systems
to
house
the
data.
To
reduce
this
burden,
EPA
will
introduce
a
phased
approach
for
the
implementation
of
this
element
using
the
scheduling
of
Full
Compliance
Evaluations.
During
each
FCE,
a
complete
review
of
all
requirements
is
completed.
During
this
time,
subpart
fields
in
AFS
can
be
updated.
As
the
evaluation
frequencies
for
the
sources
included
under
the
CMS
Policy
are
either
2,
3,
or
5
years,
EPA
expects
that
all
subparts
for
this
universe
of
sources
will
be
updated
over
a
5
year
period.

°
Partial
Compliance
Evaluations
(
PCEs):
Wide
opposition
to
blanket
inclusion
of
all
PCEs.
The
value
of
generic
PCE
actions
are
suspect.
Advocate
optional
reporting.
Thirty­
nine
(
39)
states
are
already
reporting
both
on­
and
off­
site
PCE
activity
to
AFS.
Half
of
the
agencies
directly
consulted
report
PCEs
in
their
current
data
reporting.
However,
many
agencies
who
provided
written
comments
following
the
publication
of
the
first
Federal
Register
notice
indicated
that
reporting
all
PCEs
would
provide
no
value
to
the
public
or
EPA
without
detailed
definitions
of
actions
and
consistency
of
reporting
among
agencies.
EPA
has
addressed
the
agencies'
concerns
by
reducing
the
burden
and
requiring
only
on­
site
PCEs,
estimated
to
be
approximately
one­
fourth
of
the
burden
of
reporting
all
PCEs.
Additionally,
EPA
will
establish
four
new
specific
PCE
action
types
for
on­
site
reporting:
Compliance
Evaluations,
Permit
Evaluations,
Compliance
Evaluations,
and
On­
site
Observations.
These
newly
defined
action
types
will
provide
both
the
public
and
EPA
with
a
definition
of
significant
on­
site
activity.
Agencies
can
continue
to
report
generic
PCE
action
types,
if
desired.
EPA
will
work
with
state
and
local
agencies
to
further
define
action
types
as
requested.

°
Stack
Test
Pollutants:
Heavy
startup
costs
will
hamper
implementation.
The
limited
number
of
actions
that
AFS
can
handle
will
also
pose
a
problem,
with
multiple
actions
for
each
pollutant
tested.
AFS
can
maintain
998
actions
at
each
source.
As
the
system
has
been
functioning
for
so
many
years,
many
sources
are
rapidly
approaching
the
998
action
threshold.
EPA
has
designed
and
implemented
a
utility
to
compress,
renumber,
and
archive
actions
as
designated
by
the
owning
agency.
This
utility
will
ensure
that
the
998
action
threshold
does
not
prevent
action
reporting.
EPA
acknowledges
that
use
of
this
activity
requires
additional
time
from
the
user,
and
is
willing
to
provide
step­
by­
step
assistance
with
each
use
of
the
utility.
Users
may
indicate
the
source
identification
and
the
features
requested
(
compress,
renumber,
archive)
and
the
utility
will
be
run
for
them.
Again,
many
agencies
are
already
reporting
stack
test
pollutants.
Additionally,
the
UI
is
currently
being
enhanced
to
streamline
the
reporting
of
these
pollutants
and
is
expected
to
be
available
for
use
before
the
end
of
FY2005.

°
Permit
Program
Data
Elements
(
PPDEs):
High
startup
costs
for
agencies
not
already
reporting.
The
current
configuration
for
reporting
Title
V
PPDEs
is
awkward
and
should
Page
14
of
36
be
modernized.
Many
comments
supported
the
addition
of
this
data,
and
43
states
are
currently
reporting
some
PPDE
activity
to
AFS.
This
collection
request
would
require
the
permit
identification
and
issuance
information
only,
but
those
agencies
not
already
reporting
the
data
indicated
that
startup
would
be
time­
intensive.
To
reduce
overall
burden
resulting
from
this
ICR
renewal,
and
as
many
of
the
states
are
already
reporting
this
data
to
Regional
Offices,
it
will
continue
to
be
excluded
from
the
MDRs
but
remain
as
optional
reporting.

°
HPV
Discovery
Date:
Extrapolate
this
data
from
the
reported
Day
Zero.
This
information
could
compromise
an
enforcement
action.
The
HPV
Discovery
Date
provides
EPA
with
the
information
required
to
ascertain
timely
and
appropriate
assignment
of
the
Day
Zero
for
each
violation.
This
information
cannot
be
extrapolated
from
the
Day
Zero,
as
there
is
no
definition
of
what
activity
triggered
the
analysis
of
violation.
Many
agencies
who
commented
did
not
express
support
for
the
addition
of
this
element,
and
one
agency
directly
consulted
stated
its
intent
not
to
report
this
information
even
if
required.
EPA
believes
this
information
is
necessary
to
determine
the
Day
Zero,
and
data
in
existing
HPV
pathways
indicates
that
these
types
of
actions
are
already
being
reported
in
a
limited
fashion.
Additionally,
all
an
agency
needs
do
is
to
link
the
appropriate
action
in
the
HPV
pathway,
where
table­
driven
values
will
identify
the
action
as
an
HPV
Discovery
Date.

Analysis
of
the
Discovery
Date
will
be
completed
outside
of
the
AFS
in
the
Online
Targeting
and
Information
System
(
OTIS)
which
is
not
available
to
the
general
public.
To
reduce
reporting
burden,
EPA
will
institute
a
phased
in
approach,
where
HPV
Discovery
Date
is
not
required
for
new
HPV
pathways
until
FY2006.
The
existing
action
types
for
Discovery
Date
include:
FCEs,
PCEs,
Title
V
Annual
Compliance
Certifications
and
Stack
Tests.
EPA
does
not
believe
that
the
Discovery
Date
would
compromise
an
enforcement
action.

°
HPV
Violating
Type
Code
and
Pollutants:
Data
entry
is
onerous
and
can
compromise
enforcement
cases.
Most
consulted
agencies
provided
estimated
burden
for
these
elements,
but
many
comments
did
not
support
reporting
this
data.
EPA
cannot
adequately
analyze
the
HPV
pathways
without
knowing
what
type
of
violation
has
occurred.
This
information
provides
information
for
the
magnitude
and
duration
of
the
violation,
and
is
not
considered
to
be
an
element
that
can
compromise
an
enforcement
case.
To
reduce
reporting
burden,
EPA
will
institute
a
phased
in
approach,
where
HPV
Violation
Type
Codes
and
pollutants
are
required
entry
for
new
HPV
pathways
starting
in
FY2006.
Agencies
can
negotiate
with
their
respective
Regional
Offices
on
data
entry.

°
Time
Standard
of
30
Days:
Not
feasible
as
most
data
are
not
provided
within
agency
systems
within
30
Days.
Not
opposed
to
a
45­
or
60­
day
standard.
Many
agencies
indicated
the
inability
to
meet
a
30­
day
reporting
schedule.
Ten
of
twelve
consulted
agencies
indicated
that
a
60­
day
timeliness
standard
was
acceptable,
as
they
were
already
Page
15
of
36
reporting
on
a
monthly
schedule
or
better.
One
consulted
agency
indicated
that
they
could
not
meet
a
60­
day
standard.
Some
agencies
indicated
that
there
would
be
instances
where
some
actions
would
not
be
reported
within
60
days.
EPA
is
willing
to
accept
data
at
the
minimum
of
every
60
days,
with
the
plan
that
end­
of­
year
reports
can
be
extracted
60
days
after
the
end
of
the
Federal
fiscal
year.

(
d)
GENERAL
GUIDELINES
This
information
collection
contains
no
special
circumstances
that
would
conflict
with
the
general
guidelines
in
5
CFR
1320.5.

(
e)
CONFIDENTIALITY
AND
SENSITIVE
QUESTIONS
(
i)
Confidentiality
Any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
Agency
policies
set
forth
in
Title
40,
Chapter
1,
part
2,
subpart
B
­
Confidentiality
of
Business
Information
(
see
also
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
42251,
September
20,
1978;
and
44
FR
17674,
March
23,
1979).

(
ii)
Sensitive
Questions
This
section
is
not
applicable.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
COLLECTED
(
a)
RESPONDENTS/
SIC
CODES
The
respondents
for
the
information
collection
activity
are
state
and
local
environmental
agencies.
These
environmental
agencies
are
classified
in
SIC
9511/
NAICS
924110.
Source
compliance
data
assembled
by
the
state
and
local
agencies
covers
numerous
SIC
categories.
The
state
and
local
agencies
that
report
to
AFS
are
defined
as
delegated
grantees
of
the
Clean
Air
Act.
Most
contacts
are
identified
on
EPA's
Web
site
(
see
Contacts
List
at
http://
www.
epa.
gov/
Compliance/
contact/
planning_
afscontacts.
html
).
The
total
number
of
respondents
is
93
(
50
states,
the
District
of
Columbia,
Puerto
Rico,
the
Virgin
Islands
and
40
delegated
local
agencies).
This
is
a
change
from
the
2001
ICR
which
identified
89
respondents.
(
Appendix
3
identifies
the
list
of
respondents
reporting
to
AFS.)

(
b)
INFORMATION
REQUESTED
(
i)
Specific
Data
Reporting
and
Record
keeping
Items
Reporting:
To
manage
the
national
air
stationary
source
compliance
monitoring
and
Page
16
of
36
enforcement
programs,
EPA
provides
a
set
of
minimum
data
requirements
(
MDRs)
that
identify
the
specific
data
elements
to
be
reported
and
tracked
in
AFS
for
state
and
local
agency
compliance
and
enforcement
activities.
Table
1
provides
a
list
of
the
revised
MDRs,
and
indicates
which
MDRs
were
part
of
the
2001
ICR
for
AFS
reporting
and
which
data
elements
are
new.
The
stationary
sources
covered
by
the
MDRs
include
major
sources,
synthetic
minors,
operating
Part
61
NESHAP
sources,
any
source
with
a
violation
meeting
the
criterion
for
high
priority
violators
and
sources
receiving
Administrative
Orders
or
Civil
Referrals.

Record
keeping:
Data
submitted
to
EPA
by
respondents
are
maintained
by
EPA
in
AFS.
Respondents
are
delegated
with
the
implementation
and
management
of
the
Clean
Air
Act
and
many
of
the
data
elements
are
maintained
for
the
oversight
of
their
program
in
their
own
data
systems.
The
data
is
extracted
and
forwarded
to
EPA.
Respondents
are
not
required
to
report
these
data
elsewhere.

(
ii)
Respondent
Activities
The
respondent
activities
associated
with
reporting
of
compliance
and
enforcement
actions
are
detailed
in
Worksheet
1
in
Section
6(
a),
below.
These
activities
include:

°
Process,
compile,
and
review
information
for
accuracy
and
appropriateness;
and
°
Transmit
information
in
written
or
electronic
format
for
entry
into
AFS,
including
any
necessary
changes
to
state
and
local
data
systems
to
facilitate
the
transfer
of
the
AFS
MDRs.

These
tasks
generally
are
to
be
performed
on
a
60­
day
basis.
Section
6
of
this
Support
Statement
describes
the
cost
and
burden
of
these
respondent
activities.
Most
of
the
burdens
under
Activity
1
are
designated
as
Customary
Business
Practice
(
CBP)
because
the
state
and
local
agencies
must
collect
the
information
required
by
EPA
for
their
own
program
management.
For
MDRs
that
were
included
in
the
2001
ICR
as
well
as
this
renewal
ICR,
states/
locals
generally
agreed
with
the
CBP
designation.
For
some
of
the
new
data
elements,
not
all
agencies
necessarily
believe
each
element
is
an
element
that
they
would
voluntarily
collect
and
review
for
accuracy
in
a
manner
to
allow
reporting
to
the
AFS
database.
Because
the
states/
locals
could
not
easily
segregate
these
activities,
Worksheet
1
addresses
these
estimated
burdens
as
part
of
the
"
transmit
information"
activity.
Page
17
of
36
TABLE
1
SUMMARY
OF
NATIONAL
MINIMUM
DATA
REQUIREMENTS
(
MDRs)
FOR
CLEAN
AIR
ACT
STATIONARY
SOURCE
COMPLIANCE
Note:
Unless
otherwise
noted,
both
Regions
and
states/
locals
report
their
data.
The
reportable
universe
of
facilities
for
AFS
includes:
Major
Title
V,
Synthetic
Minor
and
NESHAP
Minor
facilities,
other
facilities
identified
within
the
CMS
Evaluation
Plan,
any
facility
with
an
enforcement
action,
any
facility
with
an
active
HPV.
Individual
regional/
state
agreements
are
not
superceded
by
this
listing.

Covered
by
the
AFS
Identification
Current
2001
ICR
Acronym
1.
Facility
Name
Yes
PNME
2.
State
Yes
STAB/
STTE
3.
County
Yes
CNTY
4.
Facility
Number
Yes
PCDS
5.
Street
Yes
STRS
6.
City
Yes
CYNM
7.
Zip
Code
Yes
ZIPC
8.
SIC
or
NAICS
Code
Yes­
SIC
SIC1/
NIC1
9.
Government
Ownership
Yes
GOVT
10.
HPV
Linkage
and
Key
Action
(
Day
Zero)
Yes
Linked
from
Action
Data
Compliance
Monitoring
Strategy
(
CMS)
11.
CMS
Source
Category1
Yes
CMSC
12.
CMS
Minimum
Frequency
Indicator1
Yes
CMSI
All
Regulated
Air
Program(
s)
2
13.
Air
Program
Yes
APC1
14.
Operating
Status
Yes
AST1
15.
Subparts
for
NSPS,
NESHAP
and
MACT3
No
SPT1
Regulated
Pollutant(
s)
within
Air
Program(
s)
16.
Pollutant(
s)
Yes
PLAP/
CAPP
17.
Classification(
s)
Yes
ECLP/
SCLP
18.
Attainment
Status
Yes
EATN/
SATN
19.
Compliance
Status
Yes
ECAP/
SCAP
Actions
Within
Air
Programs4
20.
Minimum
Reportable
Actions:
Notice
of
Violation(
s)
Yes
Administrative
Order(
s)
and
Assessed
Penalties
Yes
(
Includes
Enforcement
Orders,
Consent
Decrees
and
Consent
Agreements)
Page
18
of
36
Civil
Referrals
Yes
HPV
Violation
Discovered5
No
Examples:
FCEs,
On­
or
Off­
Site
PCEs,
Stack
Tests,
Title
V
Annual
Compliance
Certifications
HPV
Addressing
Actions6
Yes
HPV
Resolving
Actions7
Yes
Full
Compliance
Evaluations
Yes
On­
Site
Partial
Compliance
Evaluations
(
PCEs)
Defined
as:
Complaint
Evaluation,
Permit
Evaluation,
Compliance
Evaluation,
On­
Site
Observation,
Generic
On­
Site
PCE
No
Stack
Tests8
Yes
Title
V
Annual
Compliance
Certification
Received9
11
Yes
Title
V
Annual
Compliance
Certification
Reviewed10
12
Yes
Investigations13
Yes
Additional
Action
Information:
21.
Results
Code8
10
Yes
RSC1
22.
RD08
(
Certification
Deviations)
9
10
Yes
RD81
23.
Date
Scheduled11
Yes
DTS1
24.
Stack
Test
Pollutant8
No
PLC1
25.
HPV
Violation
Type
Code14
No
VTP1
26.
HPV
Violating
Pollutant(
s)
14
No
VPL1
Timeliness
Standard15
27.
Action
Reported
within
60
Days
of
Event;
No
with
minimum
of
6
uploads
to
AFS
per
year.

OPTIONAL/
DISCRETIONARY
DATA
REPORTING
TO
AFS
 
NON­
MDR
DATA
The
following
items
cover
data
that
is
not
considered
an
MDR,
but
will
be
useful
and
helpful
for
program
implementation,
evaluation
and
oversight.
State
and
local
agencies
are
encouraged
to
report
the
following
items
whenever
practicable.

°
Minor
Facility
information:
For
minor
sources
that
are
not
MDR
(
MDR
for
minor
facilities
is
defined
as:
Minor
NESHAP,
a
minor
facility
identified
within
the
CMS
plan
for
evaluation,
minor
facilities
with
an
enforcement
action
or
any
HPV
case
regardless
of
class)
reporting
is
optional
but
encouraged.
Minor
source
information
would
include
NSPS
and
MACT
subpart
applicability.

°
All
Air
Program
Reporting
at
the
Action
Level
of
AFS:
All
applicable
air
programs
at
the
source
must
be
reported
at
the
Plant
Level
of
AFS,
while
reporting
is
optional
for
all
applicable
air
programs
at
the
Action
Level
of
AFS.
It
is
acceptable
to
report
the
Title
V
air
program
(
V)
only
on
FCEs,
PCEs,
and
activities
applicable
to
Title
V.
All
applicable
Page
19
of
36
Air
Program
Codes
on
HPV
Day
Zero
and
enforcement
actions
are
required.

°
Reporting
more
frequently
than
every
60
days.

°
State
Investigations
initiated.

°
Title
V
Permit
Program
Data
Elements
(
PPDEs):
Required
for
reporting
to
AFS
by
the
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS),
used
by
the
Office
of
Enforcement
and
Compliance
Assurance
(
OECA)
for
major
source
universe
population.
To
be
established
when
the
Title
V
permit
is
issued.
AFS
will
require
the
establishment
of
an
AFS
ID,
the
individual
permit
number,
category,
and
event
type
for
permit
issued
plus
the
date
achieved.
Permit
Program
Data
Elements
(
PPDEs)
include
the
Permit
Number
(
ASPN),
Permit
Category
(
PMTC),
and
Permit
Issuance
Event
Types
(
IF­
Permit
Issued
and
IR­
Permit
Renewal)
and
the
date
(
PATY/
PDEA).

°
State
Off­
Site
Partial
Compliance
Evaluations
(
PCE):
Any
off­
site
review
of
reports
and
reviews
qualifies
as
an
off­
site
PCE.

Notes
for
Table
1:

1.
Generally
EPA
enters
this
information
into
AFS;
states/
locals
provide
this
information
per
agreement
with
the
EPA
Region.
An
EPA
Region
may
delegate
data
entry
rights
to
a
state/
local
agency.
2.
All
applicable
air
programs
should
be
reflected
at
the
plant
level
of
AFS.
3.
Any
applicable
subpart
for
the
NSPS,
NESHAP
or
MACT
air
program
at
major
and
synthetic
minor
sources,
minor
source
NESHAP
and
all
other
facilities
reported
as
MDR.
Phase­
In
approach
of
data
entry
limits
data
input
to
applicable
subparts
at
sources
receiving
FCEs
starting
in
FY06.
Reporting
of
minor
source
NSPS
and
MACT
subparts
are
optional
but
recommended
(
unless
the
minor
source
is
included
in
the
CMS
universe,
has
a
current
enforcement
action
of
<
3
years
old
and
is
listed
as
a
discretionary
HPV).
4.
Includes
action
number,
action
type,
and
date
achieved.
Penalty
amount
is
also
included
where
appropriate
and
should
reflect
assessed
penalty
(
penalty
assessed
via
a
formal
enforcement
action).
5.
Actions
for
Discovery
Date
are
defined
as:
FCEs,
PCEs,
Title
V
Annual
Compliance
Certifications
and
Stack
Tests.
These
action
types
should
be
linked
into
the
HPV
pathway.
Phased­
In
approach
for
data
entry
requires
HPV
Violation
Discovered
Date
to
be
reported
on
new
HPV
cases
starting
in
FY06.
6.
Examples
of
addressing
actions
include,
but
are
not
limited
to:
State/
EPA
Civil
Action;
State/
EPA
Administrative
Order;
State/
EPA
Consent
Decree;
Source
returned
to
compliance
by
State/
EPA
with
no
further
action
required.
HPV
Lead
Agency
responsible
for
data
entry
of
actions
into
AFS,
or
as
negotiated.
7.
Examples
of
resolving
actions
include:
Violation
Resolved
by
State/
EPA,
State/
EPA
Closeout
Memo
Issued,
Source
returned
to
compliance
by
State/
EPA
with
no
further
action
required.
Page
20
of
36
HPV
Lead
agency
responsible
for
data
entry
of
actions
into
AFS,
or
as
negotiated.
8.
Each
pollutant
tested
during
a
stack/
performance
test
should
be
reported
via
a
separate
action.
The
pollutant
code
is
reported
in
field
PLC1.
Pass/
Fail
codes
(
PP/
FF)
are
reported
in
the
results
code
field.
9.
EPA
reports
and
enters
into
AFS
unless
otherwise
negotiated.
10.
Results
codes
for
Annual
Compliance
Certification
reviews
are:
in
compliance
(
MC),
in
violation
(
MV)
and
unknown
(
MU).
11.
The
Due
Date
of
a
Title
V
Annual
Compliance
Certification
will
be
reported
as
a
date
scheduled
on
the
"
Title
V
Annual
Compliance
Certification
Due/
Received
by
EPA"
action,
and
is
not
enforcement
sensitive.
12.
Annual
Compliance
Certification
deviations(
s)
will
be
indicated
in
RD08
for
EPA
reviews
(
and
state
reviews
as
negotiated).
13.
EPA
Investigation
Initiated
(
started)
and
State/
EPA
Investigation
Conducted
(
finished).
State
Investigation
Initiated
is
added
for
optional
use.
EPA
and
State
Investigation
Initiated
(
started)
action
types
are
enforcement
sensitive.
14.
HPV
Violation
Type
Code
is
to
be
identified
when
the
Day
Zero
is
established,
values
are
listed
at
http://
www.
epa.
gov/
compliance/
planning/
data/
air/
afsmanuals.
html.
HPV
Pollutants
are
to
be
entered
with
the
Day
Zero
action
type.
Phased­
In
approach
for
data
entry
requires
HPV
Violation
Type
Code
and
Violating
Pollutants
to
be
reported
on
new
HPV
cases
starting
in
FY06.
15.
Data
is
to
be
reported
to
AFS
within
60
days
of
the
event
reported
in
the
Date
Achieved
(
DTA1)
field
of
the
action
record.
Monthly
updating
is
encouraged.
Page
21
of
36
5.
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
(
a)
AGENCY
ACTIVITIES
Activities
performed
by
EPA
personnel
involve
both
EPA
Regional
and
Headquarters
staff.
The
Regional
Offices
generally
serve
as
the
primary
liaison
with
respondents
(
and,
if
applicable,
assume
the
primary
role
of
any
EPA
reporting
of
data
to
AFS),
while
Headquarters
staff
focus
on
data
system
issues,
data
management
practices,
and
other
national
program
management
activities.
The
EPA
activities
include
(
for
purposes
of
estimating
burdens,
the
first
four
items
are
considered
the
primary
Regional
Office
activities
and
the
last
three
items
are
considered
the
primary
Headquarters
activities):

°
Interaction
(
e.
g.,
answer
respondent
questions,
including
liaison
with
state
and
local
agencies,
participate
in
National
AFS
data
management
discussions,
etc.)
°
Audit
and
review
of
data
submissions
°
Data
entry
and
verification
°
Report
preparation
°
Program
review
(
including
review
of
AFS
user
needs
and
suggestions
of
software
revisions,
or
identification
for
state
and
local
agencies
of
best/
efficient
data
management
and
quality
assurance
practices)
°
Data
interpretation
and
analysis
(
including
targeting
activities)
°
Quality
assurance
guidance
(
b)
COLLECTION
METHODOLOGY
AND
MANAGEMENT
(
i)
Overview
The
compliance
and
enforcement
information
collected
from
state
and
local
respondents
for
entry
into
AFS
is
a
well
established
process.
Compliance
and
compliance
action
reporting
to
AFS
and
its
predecessor,
the
Compliance
Data
System
(
CDS),
has
existed
for
the
past
24
years.
The
MDRs
have
been
developed
as
essential
components
of
a
compliance
tracking
program
and
have
been
adopted
into
state
and
local
systems.
Many
states
automatically
update
AFS
from
a
local
database,
while
some
enter
data
into
AFS
directly.
In
some
instances,
EPA
Regional
Offices
enter
state
and
local
agency
compliance
and
enforcement
data
into
AFS.
Several
EPA
regional
offices
enter
HPV
data
for
state/
local
agency
staff,
whereas
most
regions
have
delegated
data
entry
responsibility.

EPA
data
collection
guidance
and
technical
support
to
the
respondent
reporting
community
during
the
past
24
years
has
focused
on
supporting
these
agencies
in
their
collection
methodology
in
order
to
minimize
the
total
burden
associated
with
meeting
their
reporting
requirements,
and
the
Agency
will
continue
to
focus
on
these
efforts.
The
continued
development
of
the
Universal
Interface
(
UI)
to
allow
for
batch
upload
of
data
from
a
variety
of
state
and
local
Page
22
of
36
agency
data
systems
to
AFS
is
a
central
component
of
the
ongoing
EPA
effort
to
ease
the
burdens
on
agencies
to
report
data
to
AFS.
In
addition,
consultations
with
respondents
confirms
for
EPA
that
AFS
is
perceived
as
an
old
system
in
which
it
is
difficult
to
report,
quality
assure,
and
extract
data.
EPA
has
begun
modernization
efforts,
with
the
completion
of
a
Needs
Analysis
in
2003;
an
initial
Closeness
of
Fit
Analysis
to
OECA's
Integrated
Compliance
Information
System
in
2004;
and
a
Modernization
Workgroup
to
take
additional
steps
toward
a
modernized
AFS.
EPA
will
work
with
respondents
to
ensure
all
reporting
issues
are
dealt
with
in
a
modernized
AFS.

EPA
also
has
developed
documents
and
memoranda
to
explain
the
collection
and
reporting
of
MDRs
for
AFS,
such
as
user
manuals.
In
addition
to
these
documents,
EPA
provides
the
additional
services
in
support
of
optimizing
the
collection
and
reporting
of
AFS
MDRs
including
the
following:

°
An
AFS
telephone
help
line
providing
users
with
data
collection
transmittal
and
quality
assurance,
supplemented
by
Contractual,
Regional
and
Headquarters
staff.

°
User
training
provided
as
requested
and
as
funds
allow.

°
EPA
has
provided
a
universal
conversion
program
(
Universal
Interface)
to
facilitate
reporting
by
state/
local
agencies
to
the
AFS.
This
program
negates
the
need
for
costly
support
of
a
native
conversion
program.
Over
the
last
five
years,
EPA
has
provided
over
$
1.7
million
in
grant
dollars
to
help
state
and
local
agencies
apply
and
use
the
Universal
Interface
for
reporting
to
AFS.
There
are
currently
13
users
of
the
product,
with
6
agencies
currently
working
on
the
process
of
implementation.
Users
of
the
product
indicate
varying
levels
of
resource
savings,
with
an
average
of
30%
of
time
saved
in
routine
submissions
to
AFS.

°
A
national
AFS
user
workshop
designed
to
provide
as
much
training
as
possible,
as
well
as
provide
up­
to­
date
information
regarding
data
reporting
and
quality
assurance.

°
A
national
AFS
Compliance
Workshop
where
input
is
solicited
from
Regional
representatives
to
improve
data
collection
and
reporting.
Attendees
are
provided
with
reports
regarding
the
EPA
data
analysis
relative
to
program
progress.
The
output
of
these
meetings
include
memoranda
or
best
practices
documents
that
are
promulgated
to
state
data
collection
and
reporting
respondents.

°
A
publically­
available
EPA
AFS
Web
site
provides
all
users
as
well
as
the
general
public
with
information
on
documents,
manuals,
training
information,
updates,
etc.(
http://
www.
epa.
gov/
Compliance/
planning/
data/
air/
afssystem.
html).
Additionally,
a
User­
Only
website
is
available
with
specific
programmatic
information
(
such
as
teleconference
minutes,
planning
activities)
designed
to
keep
Page
23
of
36
AFS
users
informed
of
any
and
all
system
updates.
The
website
does
not
provide
access
to
AFS.

°
A
new
AFS
utility
designed
to
archive
historic
actions,
compress
and
renumber.
As
AFS
has
a
limit
of
998
compliance/
enforcement
actions
and
has
information
dating
back
to
the
1970s,
an
archiving
of
old
activity
was
necessary
to
make
way
for
new
actions
and
reporting.

°
During
FY2003,
respondents
collaborated
on
the
compilation
of
the
AFS
Business
Rules,
providing
a
comprehensive
compendium
of
air
compliance/
enforcement
rules
concerning
data
entry.
This
document,
used
in
tandem
with
system
documentation,
provides
the
user
with
a
complete
system
and
programmatic
guide
for
using
AFS.

EPA
presents
these
tools
in
plain
English
to
provide
novice
and
experienced
personnel
with
suggestions
as
to
how
their
reporting
burden
can
be
minimized.
More
specific
guidance
is
provided
as
each
EPA
Regional
Office
enters
into
specific
agreements
with
state
and
local
agencies
on
AFS
reporting.

(
ii)
Data
Quality
Checking
Procedures
AFS
data
are
edit
validated
by
the
system
for
range,
context,
and
appropriate
database
record
identification
and
cross
referencing
upon
submission
to
AFS.
On
a
monthly
basis,
EPA
downloads
data
from
AFS
and
loads
it
into
multiple
applications
providing
data
to
the
public:
the
Online
Tracking
and
Information
System
(
OTIS)
which
provides
powerful
analysis
capabilities
to
EPA
and
state
and
local
agencies,
the
ECHO
system
and
ENVIROFACTS.
These
systems
maintain
procedures
for
error
resolution
and
correction,
thereby
improving
the
quality
of
data
in
AFS.

Many
state
and
local
agencies
have
written
Standard
Operating
Procedures
or
have
expanded
Quality
Assurance
Project
Plans
that
define
their
reporting
process.
These
procedures
contain
a
data
correction
mechanism,
define
data
ownership,
and
outline
each
step
taken
to
report
timely,
accurate,
and
useable
data
to
AFS.
Additionally,
OECA's
Office
of
Compliance
has
a
Quality
Management
Plan
requiring
that
data
quality
requirements
are
built
into
each
legacy
application
and
required
of
each
respondent.

(
iii)
Machine
and
Processing
Technology
AFS
resides
on
EPA's
Enterprise
Server
(
IBM
S/
390
G6
9672X37
computer)
at
the
National
Computer
Center
(
NCC)
in
North
Carolina
and
is
accessible
to
all
state
and
local
agency
users
via
a
Host
on
Demand
session
via
the
Internet
or
through
DynaComm
communications
software
available
to
Federal
users.
Page
24
of
36
(
iv)
Data
Entry
and
Storage
Once
compliance
data
are
submitted
to
EPA
either
directly
online
or
via
a
batch
update,
the
data
are
managed
and
maintained
by
EPA.
EPA
policy
specifies
the
security
and
retention
requirements
for
its
databases,
in
addition
to
the
specific
program
requirements
and
archiving
protocols
associated
with
each
compliance
data
collection
program.
Additionally,
the
AFS
Business
Rules
provide
guidance
for
the
archiving
and
deletion
of
old
data.

(
v)
Public
Access
The
public
may
access
AFS
through:

°
Freedom
of
Information
Act
requests
made
to
EPA;
°
"
Browse"
(
read)
only
access
to
AFS
non­
confidential
data.
This
requires
an
NCC
user
account
and
AFS
non­
confidential
data
access
security
clearance;
and
°
Review
of
AFS
data
available
through
EPA­
supported
Web
sites
such
as
ECHO
(
http://
www.
epa.
gov/
echo/
index.
html
)
and
ENVIROFACTS
(
http://
www.
epa.
gov/
enviro/).

(
c)
SMALL
ENTITY
FLEXIBILITY
The
respondents
for
this
information
collection
activity
are
state,
local,
district,
and
Commonwealth
environmental
agencies.
The
Regulatory
Flexibility
Act
(
RFA),
incorporated
in
the
1995
Paperwork
Reduction
Act,
defines
a
"
small
governmental
jurisdiction
as
governments
of
cities,
counties,
towns,
townships,
villages,
school
districts,
or
special
districts
with
a
population
of
less
than
50,000."
The
state
and
local
agencies
covered
by
this
renewal
ICR
are
above
that
threshold,
and
therefore
no
small
entities
will
be
affected
by
this
information
collection.
Most
respondents
defined
as
local
agencies
are
recipients
of
the
Clean
Air
Act
Section
105
grants,
or
have
assumed
reporting
responsibility
from
their
respective
state
agency.

(
d)
COLLECTION
SCHEDULE
With
the
approval
of
this
ICR,
AFS
data
from
state
and
local
Agencies
are
to
be
collected
on
a
60­
day
schedule,
associated
with
the
Federal
fiscal
calendar.
Regional
and
Federal
data
is
to
be
reported
to
AFS
on
a
monthly
basis.
Each
month
data
is
extracted
and
provided
to
EPA
systems
for
use
in
analysis
and
to
provide
data
to
the
public.
On
a
routine
basis
Regional
and
HQ
EPA
program
staff
develop
trend
and
status
reports
utilizing
AFS
data
and
assess
the
completeness
of
the
data
submitted.

A
normal
data
submission
to
AFS
is
composed
primarily
of
action
items
(
reference
Table
1
of
Section
4,
Summary
of
National
Minimum
Data
Requirements
(
MDRs).
State
and
local
agencies
would
be
including
new
sources,
changes
in
classification
or
compliance
status
to
existing
sources
and
any
other
changes
to
the
basic
identification
of
the
reportable
universe.
The
Page
25
of
36
inventory
of
sources
may
change
(
for
example,
many
sources
change
processes
and
thus
lower
their
emission
levels
resulting
in
a
classification
change
from
major
to
synthetic
minor
(
or
even
minor)
periodically,
but
is
usually
not
a
significant
increase
to
data
uploads.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
(
a)
ESTIMATING
RESPONDENT
BURDEN
Worksheet
1
reports
the
annual
respondent
burden
estimates
by
burden
activity.
Worksheet
1
is
derived
from
Appendix
1,
Commentaries;
Appendix
2,
Agencies
Directly
Contacted
for
Burden
Estimates;
and
Appendix
3,
State
and
Local
Agency
Classification
by
Size;
plus
activity
assumptions
discussed
in
Section
4(
b)(
ii)
of
this
collection
request.
The
respondent
hour
burden
presented
in
this
renewal
ICR
reflects
the
current
and
proposed
MDRs,
which
differ
from
the
2001
ICR,
as
listed
in
Table
1
in
Section
4(
b)
of
this
document.
Based
on
the
consultations
identified
in
Section
3(
c)
and
other
data
analyses,
the
burden
estimates
incorporate
the
following
assumptions
and
findings:

°
There
are
93
respondents.
This
is
a
change
from
the
2001
ICR
which
identified
89
respondents.
All
delegated
grantees
of
the
Clean
Air
Act
program
plus
reporting
local
agencies
are
included.
(
Appendix
3
identifies
the
list
of
respondents
reporting
to
AFS.)

°
Each
respondent
will
provide
some
information
at
least
six
times
per
year
versus
4
times
per
year.

°
The
basis
of
the
reportable
universe
is
21,085
Title
V
major
sources
and
20,352
synthetic
minor
sources
(
sources
with
the
potential
to
emit
at
the
major
threshold,
but
emit
under
this
threshold
due
to
process
or
operating
restrictions).
Also
reportable
are
minor
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
sources
(
1,284
sources
nationwide),
any
source
included
in
the
CMS
universe
for
evaluation
(
opted­
in
sources
used
as
a
replacement
for
other
sources)
regardless
of
class,
any
minor
source
with
an
enforcement
action
or
any
source
with
a
High
Priority
Violation.

°
The
average
respondent
hours
per
response
for
reporting
activities
will
depend
on
the
number
of
sources
for
which
a
state
or
local
agency
must
collect
and
report
compliance
and
enforcement
data.
To
reflect
these
differences
EPA
has
grouped
the
agencies
in
three
categories
for
purposes
of
this
ICR
based
on
the
number
of
Title
V
major
sources
that
are
in
each
state
and
local
agency's
jurisdiction,
as
defined
in
the
following
table:
Page
26
of
36
Respondent
Size
Category
Number
of
Facilities
Number
of
Agencies
Large

500
14
13
States,
1
Local
Agency
Medium
151­
499
23
22
States,
1
Local
Agency
Small

150
56
15
States,
38
Local
Agencies,
DC,
PR,
VI
°
Three
states
have
reduced
their
major
source
universe
in
size
since
the
2001
ICR,
becoming
medium­
sized
agencies
(
NC,
TN
and
VA).
South
Carolina
has
reported
a
reclassification
effort
to
begin
in
FY05
which
will
result
in
a
source
universe
changed
from
approximately
800
major
sources
to
400,
effecting
another
change
to
the
number
of
large
source
agencies
in
the
nation.

°
Within
each
category,
consultations
with
states/
local
agencies
reveal
significant
differences
in
estimated
burdens.
The
burden
estimated
from
one
large
state
was
less
than
some
Local
Agencies
with
one
tenth
of
the
major
source
universe.
Burdens
were
built
on
universe
size
and
method
of
update
to
AFS:
direct
user,
batch
user,
or
a
Universal
Interface
batch
user.

°
Estimations
of
burden
from
direct
users
of
AFS
were
done
using
the
universe
of
sources,
the
level
of
activity
from
FY03,
comments
received
on
the
Federal
Register
announcement
and
input
from
consultations.
Actual
evaluations,
notices
of
violation,
enforcement
actions,
compliance
activities,
and
High
Priority
Violator
pathways
were
taken
into
account
in
order
to
establish
current
reporting
burden.
Proposed
data
elements
were
estimated
by
type
of
activity
and
number
expected
to
be
reported.
Also
taken
into
consideration
was
startup
time
and
any
other
costs.
Data
entry
time
was
figured
into
the
burden
estimate.

°
Estimations
of
burden
from
batch
users
were
completed
using
the
universe
of
sources,
the
level
of
activity
from
FY03,
comments
received
on
the
Federal
Register
announcement,
and
on
input
from
consultations.
Time
necessary
to
create
the
batch
file
from
a
state
system
will
vary
on
the
complexity
of
a
system.
Universal
Interface
users
have
a
streamlined
effort
of
time
with
no
maintenance
costs
and
thus
have
a
lower
level
of
effort
than
states
or
local
agencies
that
maintain
their
own
conversion
program.
Data
entry
for
those
items
not
included
in
the
state
or
local
system
was
figured
into
the
burden
estimate.
Page
27
of
36
(
b)
ESTIMATING
RESPONDENT
COSTS
The
last
column
in
Worksheet
1
reports
the
total
costs
of
respondent
burden
activities.
The
costs
reflect
the
use
of
appropriately
skilled
labor
at
$
33.39
per
hour.
This
hourly
rate
is
in
2003
dollars
reflecting
average
state
and
local
government
wages
and
salaries
(
ftp://
ftp.
bls.
gov/
pub/
special.
requests/
ocwc/
ect/
ececqrt.
txt)
for
management,
professional,
and
related
occupational
groups
taken
from
the
Department
of
Labor
Employment
Compensation
and
Costs
(
ECEC)
web
site.
These
figures
provide
total
compensation
with
wages
and
total
benefits,
and
include
overhead.
The
2001
ICR
used
a
rate
of
$
31.22/
hour.
The
burden
cost
by
activity
is
computed
as
the
product
of
burden
hours
and
cost
per
hour.
Total
annual
burden
cost
for
state
and
local
agencies
is
estimated
to
be
approximately
$
3.7
million.

(
c)
ESTIMATING
RESPONDENT
CAPITAL
AND
MAINTENANCE
COSTS
There
are
no
capital
and
maintenance
costs
associated
with
this
reporting
activity.
State
and
local
agencies
maintain
computers
for
their
own
tracking
needs
and
this
reporting
activity
only
involves
reformatting
and
transmission
of
that
data.
As
necessary,
EPA
provided
the
equipment
necessary
for
electronic
transmission
of
data
from
state
and
local
systems
to
AFS
as
part
of
an
AIRS
Connectivity
Project
prior
to
1991.

There
were
reports
of
costs
for
reprogramming
existing
data
systems
to
facilitate
batch
uploading
of
data
from
state
and
local
systems
to
AFS.
Based
on
the
information
gathered
from
consultations
with
state
and
local
agencies,
these
activities
reflect
internal
state
and
local
agency
labor
burdens
(
using
state
and
local
agency
programming
staff)
working
with
Information
Technology
staff,
which
are
treated
as
labor
hours
and
not
capital
or
maintenance
costs.
Although
some
agencies
may
use
external,
contracted
services
(
a
capital
or
maintenance
cost),
EPA
has
assumed
for
purposes
of
this
renewal
ICR
that
all
reprogramming
efforts
will
use
inhouse
labor.

(
d)
ESTIMATING
AGENCY
BURDEN
AND
COST
Section
5(
a)
identifies
several
Agency
activities
for
this
information
collection.
Worksheet
2
presents
the
Federal
EPA
burden
and
cost
estimates
for
each
of
these
activity
categories.
Hours
are
allocated
to
individual
tasks
on
the
basis
of
1.5
full­
time
equivalent
positions
dedicated
to
AFS
activities
in
each
Regional
Office
and
1.0
full­
time
equivalent
at
the
Headquarters
level.
The
estimates
are
based
on
information
from
Regional
Offices
and
on
prior
experience
with
the
program.
Estimates
are
formulated
on
a
monthly
basis
versus
bi­
monthly
basis
(
every
60
days)
required
of
state
and
local
agencies.
Cost
estimates
for
Regional
activities
assume
GS­
12
(
Step
5)
staff
with
an
annual
salary
of
$
59,951
in
2004.
An
overhead
factor
of
1.6
is
applied,
and
an
average
locality
adjustment
of
16.39%
(
based
on
the
average
for
EPA
Regional
office
locations)
to
determine
a
fully
loaded
hourly
rate
for
Regional
activities
of
$
53.50,
or
$
1,669,267
annually
across
the
nation.
Page
28
of
36
The
bottom
half
of
Worksheet
2
shows
the
burden
and
costs
for
EPA
Headquarters
staff.
Direct
labor
costs
are
based
on
the
assignment
of
a
GS­
14
(
Step
5)
to
AFS
activities.
In
2001,
the
listed
annual
pay
scale
for
this
grade
in
Washington,
DC
is
$
96,572.
The
fully
loaded
hourly
wage
rate,
using
the
1.6
benefit
factor
is
$
74.27,
or
$
154,486
annually.
Page
29
of
36
WORKSHEET
1
ANNUAL
STATE
RESPONDENT
BURDEN
Respondent
Activities:
Process,
compile
and
review
information;
transmit
information
to
AFS.
Maintain
records
for
AFS
reporting
compatibility
Number
of
States/
Locals
Annual
Responses
(
6X
per
year)
Hours
per
Response
Total
Hours
Total
Cost
Respondent
Activities:
Process,
compile
and
review
information;
transmit
information
to
AFS.
Maintain
records
for
AFS
reporting
compatibility
Number
of
States/
Locals
Annual
Responses
(
6X
per
year)
Hours
per
Response
Total
Hours
Total
Cost
Small
States/
Locals
(
less
than
or
equal
to
150
Major
Sources)
56
336
5,990
35,941
$
1,199,931
Medium
States/
Locals
(
151­
499
Major
Sources)
23
138
6,018
36,110
$
1,205,572
Large
States/
Locals
(
greater
than
or
equal
to
500
Major
Sources)
14
84
6,460
38,758
$
1,293,978
Totals1
93
558
18,468
110,809
$
3,699,481
1May
not
total
due
to
rounding
of
hours
and
dollars.

[
Note:
A
small
state/
local
agency
having
150
major
sources
or
less
spends
an
average
of
107
hours
per
60
days
reporting
to
AFS.
A
medium
state/
local
area
spends
an
average
of
262
hours
and
a
large
state/
local
area
spends
an
average
of
461
hours
per
60
days
reporting
to
AFS.
On
a
yearly
basis,
a
small
state/
local
agency
with
150
major
sources
or
less
will
spend
642
hours
per
year,
a
medium
state/
local
agency
will
spend
1,570
hours
per
year
and
a
large
state/
local
agency
will
spend
2,768
hours
per
year
reporting
to
AFS,
for
a
total
of
110,809
hours
per
year
for
the
transmittal,
management
and
quality
assurance
of
their
data.]
Page
30
of
36
WORKSHEET
2
ANNUAL
AGENCY
BURDEN
ESTIMATES
EPA
Region
Activities
#
of
Responses1
Hours
per
Response
Total
Hours
Total
Cost2
Monthly
Effort
for:
1.
Interactions
2.
Audit
and
Review
3.
Data
Entry
and
Verification
4.
Report
Preparation
12
33
65
130
33
3,900
7,800
15,600
3,900
$
208,658
$
417,317
$
834,634
$
208,658
Total
120
261
31,200
$
1,669,267
1Ten
Regions,
each
with
a
monthly
response,
for
a
total
of
120
responses.
Hours
per
response
are
approximate
based
on
total
effort
estimates
per
Regional
Office
and
EPA
experience
on
allocation
of
effort
amongst
applicable
tasks.
2Fully
loaded
wage
for
GS­
12
(
Step
5)
in
2004
dollars
is
$
53.50
EPA
Headquarters
Activities
#
of
Responses
Hours
per
Response
Total
Hours
Total
Cost3
Monthly
Effort
for:
1.
Program
Review
2.
Data
Interpretation/
Analysis
3.
Quality
Assurance
12
22
130
22
260
1,560
260
$
19,311
$
115,864
$
19,311
Total
12
174
2,080
$
154,486
3Fully
loaded
wage
rate
for
GS­
14
(
Step
5)
in
2004
dollars
is
$
74.27
Page
31
of
36
(
e)
BOTTOM
LINE
BURDEN
HOURS
AND
COSTS
Worksheet
3
summarizes
the
total
annual
burden
hours
and
costs
for
AFS
collection
activity.
The
data
for
Worksheet
3
represents
totals
computed
across
activities
identified
in
Worksheets
1
and
2.

WORKSHEET
3
TOTAL
BURDEN
HOURS
AND
COST
Respondent
Type
Total
Hours
Total
Costs
1.
States/
Locals
2.
EPA
Regions
3.
EPA
Headquarters
110,809
31,200
2,080
$
3,699,481
$
1,669,267
$
154,486
Totals
144,089
$
5,523,234
(
f)
REASONS
FOR
CHANGE
Under
this
renewal
ICR,
total
annual
state
and
local
agency
respondent
burden
is
110,809
hours,
while
the
2001
ICR
estimated
a
total
annual
respondent
burden
of
85,496
hours.
Thus,
the
total
estimated
annual
increase
in
respondent
burden
is
25,313
hours.
This
increase
in
hours
was
attributable
to
the
new
MDRs
in
this
renewal
ICR,
with
an
adjustment
to
the
baseline
count
of
hours.

°
Per
Respondent
Baseline
Adjustment
(­
2,762
unadjusted
current
hours,
)

Current
burden
hours
were
compiled
via
consultations
with
agencies
agreeing
to
provide
estimates
or
through
submitted
comments.
Unadjusted
current
burden
hours
were
estimated
at
82,734,
providing
a
difference
of
­
2,762
burden
hours
from
the
2001
ICR.
However,
many
consulted
agencies
indicated
that
some
of
the
requested
data
elements
are
already
being
reported
in
the
current
burden
hours.
In
order
to
accurately
estimate
the
hours
of
burden
necessary
for
each
proposed
element,
burden
hours
for
the
proposed
elements
were
extracted
from
the
current
reporting
burden.

An
adjusted
burden
estimate
of
74,767
hours
represents
the
current
burden
without
the
proposed
new
elements,
indicating
that
approximately
7,967
hours
is
spent
reporting
new
elements
outlined
in
this
proposal.

Reductions
in
current
burden
hours
are
attributed
to
changes
in
the
respondent
population
(
reduction
in
the
number
of
large
reporting
agencies),
reduction
in
the
number
of
major
sources,
streamlined
reporting
of
data
using
the
Universal
Interface
program
to
facilitate
batch
uploading
from
state/
local
systems,
an
overall
reduction
in
the
reported
number
of
hours
required
for
transferring
data,
and
overestimation
of
reporting
hours.
Large
reporting
agencies
declined
by
Page
32
of
36
three
as
NC,
TN
and
VA
reclassified
their
universes
and
are
now
numbered
among
the
medium
universe
states.
The
number
of
agencies
is
key
in
the
calculation
of
median
burden
estimates.
The
2001
ICR
estimates
were
based
on
a
major
source
universe
of
23,272
sources,
while
the
2004
universe
is
21,085,
causing
a
9%
reduction
in
the
major
source
universe.
Since
reporting
activities
at
major
sources
encompasses
the
bulk
of
AFS
reporting,
estimates
for
burden
are
lower
for
current
universe
numbers.
Users
of
the
Universal
Interface
are
experiencing
a
reduction
in
burden
through
reduced
time
in
batch
file
processing
and
also
the
maintenance
of
a
conversion
program.
Estimates
of
reduction
vary
by
agency,
but
an
average
reduction
of
30%
of
total
reporting
time
is
saved
through
the
use
of
the
Universal
Interface.
There
are
currently
thirteen
agencies
using
the
Universal
Interface,
with
six
agencies
in
the
process
of
implementing
this
tool
for
facilitating
data
entry.
Seven
agencies
have
begun
use
of
the
Universal
Interface
since
the
2001
ICR
was
released.
Continued
use
of
the
Universal
Interface
is
expected
to
further
reduce
state
and
local
agency
burden
costs
through
the
streamlining
of
data
submissions
and
reduction
of
costs
for
maintaining
conversion
programs.
Total
burden
hours
were
also
reduced
by
several
agencies
reporting
a
lower
burden
estimate
than
in
previous
years.

°
Increase
from
Program
Changes
(
28,074
hours
current
base
hours,
36,042
adjusted
current
base
hours)

The
consultations
with
state
and
local
agencies
indicated
addition
of
the
subparts,
On­
Site
Partial
Compliance
Evaluations,
Stack
Test
Pollutants,
HPV
Discovery
Date,
Violation
Type
Code
and
Pollutants,
and
a
60­
day
timeliness
standard
will
increase
the
current
burden
estimate
by
28,074
hours,
or
36,042
hours
using
an
adjusted
current
burden.

(
g)
BURDEN
STATEMENT
Reporting
by
state
and
local
Environmental
Agencies
on
Source
Compliance
and
Enforcement
Actions
is
estimated
based
on
the
number
of
major
sources
in
the
state/
local
area.
A
small
state/
local
agency
having
150
major
sources
or
less
spends
an
average
of
107
hours
per
60
days
reporting
to
AFS.
A
medium
state/
local
area
spends
an
average
of
262
hours
and
a
large
state/
local
area
spends
an
average
of
461
hours
per
60
days
reporting
to
AFS.
On
a
yearly
basis,
a
small
state/
local
agency
with
150
major
sources
or
less
will
spend
642
hours
per
year,
a
medium
state/
local
agency
will
spend
1,570
hours
per
year
and
a
large
state/
local
agency
will
spend
2,768
hours
per
year
reporting
to
AFS,
for
a
total
of
110,809
hours
per
year
for
the
transmittal,
management
and
quality
assurance
of
their
data.
The
EPA
will
require
a
total
of
33,280
hours
per
year
for
EPA
oversight,
data
quality
assurance,
reporting,
and
other
Agency
activities,
for
an
overall
total
of
144,089
hours
for
both
Federal
and
state/
local
Agency
effort.

Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
Page
33
of
36
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.

An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
valid
OMB
Control
Number.
The
OMB
Control
Numbers
for
EPA's
regulations
are
listed
at
40
CFR
part
9
and
48
CFR
Chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
OECA­
2004­
0024,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
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
Enforcement
and
Compliance
Docket
and
Information
Center
is
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
When
in
the
system,
select
"
search,"
then
key
in
the
Docket
ID
Number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
2004­
0024
and
OMB
Control
Number
2060­
0096
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
Page
34
of
36
APPENDIX
1
COMMENTORS
TO
OECA­
2004­
0024
COMMENTS
RECEIVED
FROM:

Allegheny
County
Health
Department
Bay
Area
Air
Quality
Management
District
California
Air
Resources
Board
California
Air
Pollution
Control
Officer's
Association
Cleveland
Division
of
Air
Quality
Dayton
Regional
Air
Pollution
Acontrol
Agency
Delaware
Department
of
Natural
Resources
and
Environmental
Control
Georgia
Department
of
Natural
Resources
Indiana
Department
of
Environmental
Management
Iowa
Department
of
Natural
Resources
Louisiana
Department
of
Environmental
Quality
Maine
Department
of
Environmental
Protection
Michigan
Department
of
Environmental
Quality
Minnesota
Pollution
Control
Agency
Mojave
Desert
Air
Quality
Management
District
New
York
State
Department
of
Environmental
Conservation
Ohio
Environmental
Protection
Agency
Oregon
Department
of
Environmental
Quality
Pennsylvania
Department
of
Environmental
Protection
Sacramento
Metropolitan
Air
Quality
Management
District
San
Diego
County
Air
Pollution
Control
District
Santa
Barbara
County
Air
Pollution
Control
District
South
Coast
Air
Quality
Management
District
South
Carolina
Department
of
Health
and
Environmental
Control
Spokane
County
Air
Pollution
Control
Authority
State
and
Territorial
Air
Pollution
Program
Administrators/
Association
of
Local
Air
Pollution
Control
Officials
Ventura
County
Air
Pollution
Control
District
Western
States
Air
Resources
Council
Page
35
of
36
APPENDIX
2
CONSULTATIONS
WITH
STATE/
LOCAL
AGENCIES
TO
CONTACT
FOR
ICR
RENEWAL
Contact
Organization
Telephone
#
of
Major
Sources
Method
of
Reporting
to
AFS
Contact
Email
Tony
Gambardella
CA
Bay
Area
Air
Quality
Management
District
(
415)
749­
4765
99
(
small)
Local
System­
Direct
tgambarbella@
baaqmd.
gov
Lisa
Young
HI
Department
of
Health
(
808)
586­
420079
79
(
small)
Direct
lyyoung@
emd.
health.
hi.
us
Mary
Ruel
NH
Department
of
Environmental
Services
(
603)
271­
0882
53
(
small)
ST
System­

Universal
Interface
mruel@
des.
state.
nh.
us
Mike
Lohmeyer
Clark
County
Department
of
Air
Quality
Management
(
NV)
(
702)
385­
1291
25­
30
(
small)
ST
System­

Direct
lohmeyer@
co.
clark.
nv.
us
Dianne
Spingler
FL
Department
of
Environmental
Protection
(
850)
488­
1344
417
(
medium)
ST
System­

Conversion
dianne.
spingler@
dep.
state.
fl.
us
Arch
Crouse
CO
Department
of
Health
(
303)
692­
3172
238
(
medium)
ST
System­

Conversion
arch.
crouse@
state.
co.
us
Lou
Musgrove
GA
Department
of
Natural
Resources
(
403)
363­
7115
441
(
medium)
ST
System­

Conversion
lou_
musgrove@
mail.
dnr.
state.
ga.
us
Keith
Duncan
OK
Department
of
Environmental
Quality
(
405)
271­
5220
413
(
medium)
ST
System­

Universal
Interface
keith.
duncan@
deq.
state.
ok.
us
Cherity
Gabrielle
IA
Department
of
Natural
Resources
(
515)
242­
5154
950
(
large)
ST
System­

Direct
cherity.
gabrielle@
dnr.
state.
ia.
us
William
Thompson
CA
South
Coast
Air
Quality
Management
District
(
909)
396­
2398
753
(
large)
ST
System­

Direct
wthompson@
aqmd.
ca
John
Hulsberg
PA
Department
of
Environmental
Protection
(
717)
772­
3426
1871
(
large)
ST
System­

Conversion
jhulsberg@
state.
pa.
us
Dick
Sharpe
SC
Department
of
Health
and
Environmental
Control
(
803)
898­
4108
838
(
large)
ST
System­

Direct
SHARPERD@
dhec.
sc.
gov
Page
36
of
36
APPENDIX
3
STATE
&
LOCAL
AGENCY
CLASSIFICATION
BY
SIZE
Small
=

150
Major
Sources
Medium
=
151­
499
Major
Sources
Large
=

500
Major
Sources
SMALL
SMALL
MEDIUM
LARGE
AL­
Huntsville
NC­
Mecklenburg
County
AK
CA
AL­
Jefferson
City
NC­
Western
AL
CA­
South
Coast
AZ­
Maricopa
County
ND
AR
IA
AZ­
Pima
County
NE
AZ
IL
AZ­
Pinal
County
NE­
Lincoln­
Lancaster
CA­
San
Joaquin
Valley
IN
CA­
Antelope
Valley
NH
CO
LA
CA­
Bay
Area
NM­
Albuquerque
FL
MI
CA­
Colusa
NV
GA
MO
CA­
Feather
River
NV­
Clark
County
KS
NY
CA­
Imperial
County
NV­
Washoe
County
KY
OH
CA­
Mojave
Desert
OR
MA
PA
CA­
Monterey
Bay
PR
MD
SC
CA­
Placer
County
RI
MN
TX
CA­
Sacramento
SD
MS
WI
CA­
San
Diego
TN­
Chattanooga
NC
CA­
Santa
Barbara
TN­
Knox
County
NJ
CA­
Ventura
County
TN­
Memphis
NM
CT
TN­
Nashville
OK
DC
UT
TN
DE
VI
VA
HI
VT
WA
IA­
Linn
County
WA­
Benton
WV
IA­
Polk
County
WA­
Northwest
WY
ID
WA­
Olympic
KY­
Jefferson
County
WA­
Puget
Sound
ME
WA­
Southwest
MT
WA­
Spokane
NC­
Forsyth
County
WA­
Yakima
