i
Table
of
Contents
SUPPORTING
STATEMENT
for
Renewal
of
Information
Collection
Requirements
under
the
Paperwork
Reduction
Act,
44
U.
S.
C.
3501
et
seq.

Final
Rule
at
40
CFR
Part
8
Environmental
Impact
Assessment
of
Nongovernmental
Activities
in
Antarctica
Revised
Following
Public
Comment
and
Consultations
October
2004
Page
1.
Identification
of
the
Information
Collection
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1
1(
a)
Title
of
the
Information
Collection
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1
1(
b)
Abstract
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1
Environmental
Documentation
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1
Coordination
of
Review
of
Information
Received
from
Other
Parties
to
the
Treaty
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3
2.
Need
for
and
Use
of
the
Collection
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3
2(
a)
Need/
Authority
for
the
Collection
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3
2(
b)
Practical
Utility/
Users
of
the
Data
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4
Role
of
the
Information
in
Regulatory
Decisions
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4
Users
of
the
Information
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5
3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
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6
3(
a)
Nonduplication
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6
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
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7
3(
c)
Consultations
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7
3(
d)
Effects
of
Less
Frequent
Collection
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7
3(
e)
General
Guidelines
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8
3(
f)
Confidentiality
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8
3(
g)
Sensitive
Questions
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8
4.
The
Respondents
and
the
Information
Requested
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9
4(
a)
Respondents/
SIC
and
NAICS
Codes.
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9
4(
b)
Information
Requested
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9
Data
items,
including
recordkeeping
requirements
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9
Respondent
Activities
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10
5.
The
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
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13
5(
a)
Agency
Activities
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13
5(
b)
Collection
Methodology
and
Management
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14
5(
c)
Small
Entity
Flexibility
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15
5(
d)
Collection
Schedule
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17
ii
6.
Estimating
the
Hours
and
Cost
Burden
of
the
Collection
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19
6(
a)
Estimated
Annual
Respondent
Hours
and
Cost
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19
6(
b)
Estimated
Annual
Federal
Government
Hours
and
Cost
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28
6(
c)
Model
for
Federal
Government
Review
of
IEEs
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35
6(
d)
Estimated
Annual
Aggregate
Hours
and
Cost
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40
6(
e)
Reason
for
Change
in
Burden
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42
6(
f)
Burden
Statement
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42
Exhibit
1A:
PERMs
­
Estimated
Respondent
Hours
and
Cost
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44
Exhibit
1B:
IEEs
­
Estimated
Respondent
Hours
and
Cost
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45
Table
1.
IEEs
­
Total
Estimated
Hours
and
Cost
for
the
Three
IEE
Models
with
3.5%
Escalation
Rate
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47
Exhibit
1C:
CEEs
­
Estimated
Respondent
Hours
and
Cost
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48
Exhibit
1D:
Reporting
for
Emergencies
­
Estimated
Respondent
Hours
and
Cost
49
Exhibit
2A:
PERMs
­
Estimated
Federal
Government
Hours
and
Cost
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50
Exhibit
2B:
IEEs
­
Estimated
Federal
Government
Hours
and
Cost
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.
51
Table
2.
IEEs
­
Total
Estimated
Hours
and
Cost
for
the
Three
IEE
Models
with
3.5%
Escalation
Rate
.
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..
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54
Exhibit
2C:
CEEs
­
Estimated
Federal
Government
Hours
and
Cost
.
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55
Exhibit
2D:
Reporting
for
Emergencies
­
Estimated
Federal
Government
Hours
and
Cost
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56
Exhibit
2E:
Coordinating
Review
of
Information
Received
from
Other
Parties
­
Estimated
Federal
Government
Hours
and
Cost
.
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.
57
Exhibit
3:
Summary
­
Estimated
Respondent/
Federal
Government
Hours
and
Cost
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58
Chart
1.
Estimated
total
and
annual
average
hours
and
cost
for
each
type
of
environmental
document
that
is
submitted
by
a
respondent
under
the
Final
Rule
.
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.
58
Chart
2.
Estimated
total
hours
and
costs
for
Multi­
Year
IEE
as
the
anticipated
level
and
type
of
environmental
document
most
respondents
submit
under
the
Final
Rule
for
the
3­
year
ICR
renewal
.
.
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.
58
Chart
3.
Estimated
hours
and
costs
for
environmental
documentation
for
3­
year
period
of
this
ICR
renewal
.
.
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59
Exhibit
4:
Summary
for
Respondents
and
Federal
Government
­
O&
M
Costs
.
.
60
Part
B:
Statistical
Survey
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B­
1
Part
C:
Response
to
Public
Comments
on
the
Proposed
ICR
.
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.
.
C­
1
Part
D:
Summary
of
Consultations
with
Interested
Agencies
and
Affected
Respondents
.
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D­
1
1
SUPPORTING
STATEMENT
for
Renewal
of
Information
Collection
Requirements
under
the
Paperwork
Reduction
Act,
44
U.
S.
C.
3501
et
seq.

Final
Rule
at
40
CFR
Part
8
Environmental
Impact
Assessment
of
Nongovernmental
Activities
in
Antarctica
Revised
Following
Public
Comment
and
Consultations
October
2004
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
TITLE
OF
THE
INFORMATION
COLLECTION:
"
Environmental
Impact
Assessment
of
Nongovernmental
Activities
in
Antarctica
(
Renewal),
EPA
ICR
Number
1808.04,
OMB
Control
Number
2020­
0007"

1(
b)
ABSTRACT:
The
Environmental
Protection
Agency's
(
EPA's)
regulations
at
40
CFR
Part
8,
Environmental
Impact
Assessment
of
Nongovernmental
Activities
in
Antarctica
(
Final
Rule),
were
promulgated
pursuant
to
the
Antarctic
Science,
Tourism,
and
Conservation
Act
of
1996
(
Act),
16
U.
S.
C.
2401
et
seq.,
as
amended,
16
U.
S.
C.
2403a,
which
implements
the
Protocol
on
Environmental
Protection
(
Protocol)
to
the
Antarctic
Treaty
of
1959
(
Treaty).
The
Final
Rule
provides
for
assessment
of
the
environmental
impacts
of
nongovernmental
activities
in
Antarctica,
including
tourism,
for
which
the
United
States
is
required
to
give
advance
notice
under
Paragraph
5
of
Article
VII
of
the
Treaty,
and
for
coordination
of
the
review
of
information
regarding
environmental
impact
assessments
received
from
other
Parties
under
the
Protocol.
The
requirements
of
the
Final
Rule
apply
to
operators
of
nongovernmental
expeditions
organized
in
or
proceeding
from
the
territory
of
the
United
States
to
Antarctica
and
include
commercial
and
noncommercial
expeditions.
Expeditions
may
include
ship­
based
tours;
yacht,
skiing
or
mountaineering
expeditions;
privately
funded
research
expeditions;
and
other
nongovernmental
activities.
The
Final
Rule
does
not
apply
to
individual
U.
S.
citizens
or
groups
of
citizens
planning
to
travel
to
Antarctica
on
an
expedition
for
which
they
are
not
acting
as
an
operator.
(
Operators,
for
example,
typically
acquire
use
of
vessels
or
aircraft,
hire
expedition
staff,
plan
itineraries,
and
undertake
other
organizational
responsibilities.)
The
Final
Rule
provides
nongovernmental
operators
with
the
specific
requirements
they
need
to
meet
in
order
to
comply
with
the
requirements
of
Article
8
and
Annex
I
to
the
Protocol.
The
provisions
of
the
Final
Rule
are
intended
to
ensure
that
potential
environmental
effects
of
nongovernmental
activities
undertaken
in
Antarctica
are
appropriately
identified
and
considered
by
the
operator
during
the
planning
process
and
that
to
the
extent
practicable,
appropriate
environmental
safeguards
which
would
mitigate
or
prevent
adverse
impacts
on
the
Antarctic
environment
are
identified
by
the
operator.

Environmental
Documentation.
Persons
subject
to
the
Final
Rule
must
prepare
1Article
3(
4),
of
Annex
I
of
the
Protocol
requires
that
draft
CEEs
be
distributed
to
all
Parties
and
the
Committee
for
Environmental
Protection
120
days
in
advance
of
the
next
Antarctic
Treaty
Consultative
Meeting
(
ATCM)
at
which
the
CEE
may
be
addressed.

2For
example,
such
information
includes,
as
appropriate
and
to
the
best
of
the
operator's
knowledge:
identification
of
the
number
of
tourists
put
ashore
at
each
site,
the
number
and
location
of
each
landing
site,
the
total
number
of
tourists
at
each
site
per
ship
and
for
the
season;
the
number
of
times
the
site
has
been
visited
in
the
past;
the
number
of
times
the
site
is
expected
to
be
visited
in
the
forthcoming
season;
the
times
of
the
year
that
visits
are
expected
to
occur
(
e.
g.,
before,
during,
or
after
the
penguin
breeding
season);
the
number
of
visitors
expected
to
be
put
ashore
at
the
site
at
any
one
time
and
over
the
course
of
a
particular
visit;
what
visitors
are
expected
to
do
while
at
the
site;
verification
that
guidelines
for
tourists
are
followed;
description
of
any
tourist
exceptions
to
the
landing
guidelines;
and
description
of
any
activity
requiring
mitigation,
the
mitigative
actions
undertaken,
and
the
actual
or
projected
outcome
of
the
mitigation.

2
environmental
documentation
to
support
the
operator's
determination
regarding
the
level
of
environmental
impact
of
the
proposed
expedition.
Environmental
documentation
includes
a
Preliminary
Environmental
Review
Memorandum
(
PERM),
an
Initial
Environmental
Evaluation
(
IEE),
or
a
Comprehensive
Environmental
Evaluation
(
CEE).
The
environmental
document
is
submitted
to
the
Office
of
Federal
Activities
(
OFA).
If
the
operator
determines
that
an
expedition
may
have:
(
1)
less
than
a
minor
or
transitory
impact,
a
PERM
needs
to
be
submitted
no
later
than
180
days
before
the
proposed
departure
to
Antarctica;
(
2)
no
more
than
minor
or
transitory
impacts,
an
IEE
needs
to
be
submitted
no
later
than
90
days
before
the
proposed
departure;
or
(
3)
more
than
minor
or
transitory
impacts,
a
CEE
needs
to
be
submitted.
Operators
who
anticipate
such
activities
are
encouraged
to
consult
with
EPA
as
soon
as
possible
regarding
the
date
for
submittal
of
the
CEE.
1
The
Protocol
and
the
Final
Rule
also
require
an
operator
to
employ
procedures
to
assess
and
provide
a
regular
and
verifiable
record
of
the
actual
impacts
of
an
activity
which
proceeds
on
the
basis
of
an
IEE
or
CEE.
The
record
developed
through
these
measures
needs
to
be
designed
to:
(
a)
enable
assessments
to
be
made
of
the
extent
to
which
environmental
impacts
of
nongovernmental
expeditions
are
consistent
with
the
Protocol;
and
(
b)
provide
information
useful
for
minimizing
and
mitigating
those
impacts
and,
where
appropriate,
on
the
need
for
suspension,
cancellation,
or
modification
of
the
activity.
Moreover,
an
operator
needs
to
monitor
key
environmental
indicators
for
an
activity
proceeding
on
the
basis
of
a
CEE.
An
operator
may
also
need
to
carry
out
monitoring
in
order
to
assess
and
verify
the
impact
of
an
activity
for
which
an
IEE
would
be
prepared.
For
activities
that
require
an
IEE,
an
operator
should
be
able
to
use
procedures
currently
being
voluntarily
utilized
by
operators
to
provide
the
required
information.
2
Should
an
activity
require
a
CEE,
the
operator
should
consult
with
EPA
to:
(
a)
identify
the
monitoring
regime
appropriate
to
that
activity,
and
(
b)
determine
whether
and
how
the
operator
might
utilize
relevant
monitoring
data
collected
by
the
U.
S.
Antarctic
Program.
OFA
would
consult
with
the
National
Science
Foundation
and
other
interested
Federal
agencies
regarding
the
monitoring
regime.

In
cases
of
emergency
relating
to
the
safety
of
human
life
or
of
ships,
aircraft,
equipment
and
facilities
of
high
value,
or
the
protection
of
the
environment
which
would
require
an
activity
3During
the
time
the
Interim
Final
and
Final
Rules
have
been
in
effect,
there
were
no
emergencies
requiring
notification
by
U.
S.
operators.
An
Interim
Final
Rule
was
in
effect
from
April
30,
1997,
until
replaced
on
December
6,
2001,
by
the
Final
Rule.
The
term
Rule
in
this
document
refers
to
the
period
of
time
the
Interim
Final
and
Final
Rules
have
been
in
place
at
40
CFR
Part
8
(
e.
g.,
for
this
ICR
renewal,
the
years
1997­
2004
which
includes
the
1997­
1998
through
2003­
2004
austral
summer
seasons).

3
to
be
undertaken
without
completion
of
the
documentation
procedures
set
out
in
the
Final
Rule,
the
operator
would
need
to
notify
the
Department
of
State
within
15
days
of
any
activities
which
would
have
otherwise
required
preparation
of
a
CEE,
and
provide
a
full
explanation
of
the
activities
carried
out
within
45
days
of
those
activities.
3
Environmental
documents
(
e.
g.,
PERM,
IEE,
CEE)
are
submitted
to
OFA.
Environmental
documents
are
reviewed
by
OFA,
in
consultation
with
the
National
Science
Foundation
and
other
interested
Federal
agencies,
and
also
made
available
to
other
Parties
and
the
public
as
required
under
the
Protocol
or
otherwise
requested.
OFA
notifies
the
public
of
document
availability
via
the
World
Wide
Web
at:
http://
www.
epa.
gov/
compliance/
nepa/
international/
antarctica/
index.
html.
The
types
of
nongovernmental
activities
currently
being
carried
out
(
e.
g.,
ship­
based
tours,
land­
based
tours,
flights,
and
privately
funded
research
expeditions)
are
typically
unlikely
to
have
impacts
that
are
more
than
minor
or
transitory,
thus
an
IEE
is
the
typical
level
of
environmental
documentation
submitted.
For
the
1997­
1998
through
2003­
2004
austral
summer
seasons
during
the
time
the
Interim
Final
and
Final
Rules
have
been
in
effect,
all
respondents
submitted
IEEs
with
the
exception
of
one
PERM.
Paperwork
reduction
provisions
in
the
Final
Rule
that
are
used
by
the
operators
include:

a)
incorporation
of
material
into
the
environmental
document
by
referring
to
it
in
the
IEE;
b)
inclusion
of
all
proposed
expeditions
by
one
operator
within
one
IEE;
c)
use
of
one
IEE
to
address
expeditions
being
carried
out
by
more
than
one
operator;
and
d)
use
of
multi­
year
environmental
documentation
to
address
proposed
expeditions
for
a
period
of
up
to
five
consecutive
austral
summer
seasons.

Coordination
of
Review
of
Information
Received
from
Other
Parties
to
the
Treaty.
The
Final
Rule
also
provides
for
the
coordination
of
review
of
information
received
from
other
Parties
and
the
public
availability
of
that
information
including:
(
1)
a
description
of
national
procedures
for
considering
the
environmental
impacts
of
proposed
activities;
(
2)
an
annual
list
of
any
IEEs
and
any
decisions
taken
in
consequence
thereof;
(
3)
significant
information
obtained
and
any
action
taken
in
consequence
thereof
with
regard
to
monitoring
from
IEEs
and
CEEs;
and
(
4)
information
in
a
final
CEE.
This
provision
fulfills
the
United
States'
obligation
to
meet
the
requirements
of
Article
6
of
Annex
I
to
the
Protocol.
The
Department
of
State
is
responsible
for
coordination
of
these
reviews
of
drafts
with
interested
Federal
agencies,
and
for
public
availability
of
documents
and
information.
This
portion
of
the
Final
Rule
does
not
impose
paperwork
requirements
on
any
nongovernmental
person
subject
to
U.
S.
regulation.
4
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
NEED/
AUTHORITY
FOR
THE
COLLECTION:
The
basis
for
the
Final
Rule
is
the
United
States
Code
as
amended:
16
U.
S.
C.
2401
et
seq.,
as
amended,
16
U.
S.
C.
2403a.

The
Final
Rule,
promulgated
pursuant
to
the
Antarctic
Science,
Tourism,
and
Conservation
Act
of
1996,
provides
nongovernmental
operators
with
the
specific
requirements
they
need
to
meet
in
order
to
comply
with
the
requirements
of
Article
8
and
Annex
I
to
the
Protocol
on
Environmental
Protection
to
the
Antarctic
Treaty
of
1959
and
provides
for
the
environmental
impact
assessment
of
nongovernmental
activities,
including
tourism,
for
which
the
United
States
is
required
to
give
advance
notice
under
paragraph
5
of
Article
VII
of
the
Antarctic
Treaty
of
1959.

The
Final
Rule
also
provides
for
coordination
of
the
review
of
information
regarding
environmental
impact
assessment
received
by
the
United
States
from
other
Parties
under
the
Protocol.
This
provision
of
the
Final
Rule
includes
Federal
agency
requirements,
but
does
not
impose
paperwork
requirements
on
any
nongovernmental
person
subject
to
U.
S.
regulation.

The
procedures
in
the
Final
Rule
are
designed
to:
ensure
that
nongovernmental
operators
identify
and
assess
the
potential
impacts
of
their
proposed
activities,
including
tourism,
on
the
Antarctic
environment;
that
operators
consider
these
impacts
in
deciding
whether
or
how
to
proceed
with
proposed
activities;
and
that
operators
provide
environmental
documentation
pursuant
to
the
Act
and
Annex
I
of
the
Protocol.
These
procedures
are
consistent
with
and
implement
the
environmental
impact
assessment
provisions
of
Article
8
and
Annex
I
to
the
Protocol
on
Environmental
Protection
to
the
Antarctic
Treaty.

2(
b)
PRACTICAL
UTILITY/
USERS
OF
THE
DATA:

Role
of
the
Information
in
Regulatory
Decisions:
The
Office
of
Federal
Activities
uses
environmental
impact
assessment
information
and
any
associated
assessment
and
verification
information
to
ensure
that
nongovernmental
operators
identify
and
assess
the
potential
impacts
of
their
proposed
activities,
including
tourism,
on
the
Antarctic
environment;
that
operators
consider
these
impacts
in
deciding
whether
or
how
to
proceed
with
proposed
activities;
and
that
operators
provide
environmental
documentation
pursuant
to
the
Act
and
Annex
I
of
the
Protocol.
The
procedures
in
the
Final
Rule
are
consistent
with
and
implement
the
environmental
impact
assessment
provisions
of
Article
8
and
Annex
I
to
the
Protocol.
The
provisions
of
the
Final
Rule
are
intended
to
ensure
that
potential
environmental
effects
of
nongovernmental
activities
undertaken
in
Antarctica
are
appropriately
identified
and
considered
by
the
operator
during
the
planning
process
and
that
to
the
extent
practicable,
appropriate
environmental
safeguards
which
would
mitigate
or
prevent
adverse
impacts
on
the
Antarctic
environment
are
identified
by
the
operator.
4The
Paperwork
Reduction
Act,
44
U.
S.
C.
Section
3502,
states:

"(
13)
the
term
"
recordkeeping
requirement"
means
a
requirement
imposed
by
or
for
an
agency
on
persons
to
maintain
specified
records,
including
a
requirement
to
­
(
A)
retain
such
records;
(
B)
notify
third
parties,
the
Federal
Government,
or
the
public
of
the
existence
of
such
records;
(
C)
disclose
such
records
to
third
parties,
the
Federal
Government,
or
the
public;
or
(
D)
report
to
third
parties,
the
Federal
Government,
or
the
public
regarding
such
records;
..."

"
Burden"
is
defined
in
the
Preamble
to
the
Final
Rule,
Section
VII,
Paperwork
Reduction
Act,
as
"...
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.
..."

5
The
Final
Rule
addresses
measures
to
assess
and
verify
environmental
impacts
but
does
not
set
schedule
requirements
for
submission
of
assessment
and
verification
reports.
Under
the
Final
Rule,
all
proposed
activities
for
which
an
IEE
or
CEE
are
prepared
need
to
include
procedures
designed
to
provide
a
regular
and
verifiable
record
of
the
impacts
of
these
activities.
For
activities
requiring
an
IEE,
the
Preamble
to
the
Final
Rule
states
that
operators
should
be
able
to
use
the
annual
procedures
that
are
voluntarily
utilized
by
operators
to
provide
the
information.
Because
measures
to
assess
and
verify
environmental
impacts
for
all
proposed
activities
for
which
an
IEE
or
CEE
are
prepared
are
required
by
the
Final
Rule,
and
because
of
the
recordkeeping
requirements
of
and
burden
definition
in
the
Paperwork
Reduction
Act
(
PRA),
EPA
has
included
this
information
as
an
element
for
the
operators
for
which
hours
and
cost
were
calculated.
Because
operators
voluntarily
provide
the
information
to
the
government,
the
hours
and
cost
of
review
of
this
information
was
also
included
in
the
government's
burden
estimate.
In
this
case,
EPA
believes
the
PRA,
Section
3502(
13)
clearly
supports
the
view
that
recordkeeping
requirements
must
be
considered
inclusively
in
developing
the
ICR
budget.
4
The
purpose
of
the
Final
Rule
is
to
ensure
that
the
United
States
has
the
ability
to
implement
its
environmental
impact
assessment
obligations
for
nongovernmental
operators
under
the
Protocol.
Section
8.9(
b)
in
the
Final
Rule
requires
that
operators
have
"
procedures
designed
to
provide
a
regular
and
verifiable
record
of
the
impacts
of
these
activities."
The
EPA
believes
that
this
establishes
a
requirement
that
the
information
be
available
to
EPA.
Otherwise,
there
is
no
way
to
know
if
an
operator
was
in
compliance
with
this
requirement
in
the
regulation.
As
stated
in
the
Preamble
to
the
Final
Rule,
it
is
EPA's
view
that,
at
a
minimum,
an
IEE
is
the
appropriate
level
of
environmental
documentation
for
proposed
activities
where
multiples
of
the
activity
over
time
are
likely
and
may
create
a
cumulative
impact.
For
activities
requiring
an
IEE,
an
operator
should
be
able
to
use
procedures
that
are
voluntarily
utilized
by
operators
to
provide
the
required
information.
The
operators
currently
provide
post­
visit
reports
to
Antarctic
Treaty
Parties.
Currently,
the
National
Science
Foundation
receives
the
information
voluntarily
submitted
by
the
tour
operators
and,
in
cooperation
with
the
International
Association
of
Antarctica
Tour
Operators
(
IAATO),
uses
the
information
to
prepare
annual
summary
reports.
EPA
assumes
this
voluntary
process
of
post­
visit
reporting
will
continue.
EPA
intends
to
review
the
information
voluntarily
submitted,
and
to
maintain
files.
Because
operators
are
currently
voluntarily
providing
the
informational
reports
to
the
government
and
because
EPA
anticipates
6
that
this
practice
will
continue,
EPA
included
the
hours
and
cost
of
review
of
this
information
in
the
government's
burden
estimates.

Users
of
the
Information:
The
procedures
in
the
Final
Rule
include
procedures
for
environmental
documentation,
any
associated
assessment
and
verification
information,
and
any
reporting
in
cases
of
emergency.
This
information
would
be
used
as
follows:

°
By
operators
to
identify
and
assess
the
potential
impacts
of
their
proposed
activities,
including
tourism,
on
the
Antarctic
environment;
to
consider
these
impacts
in
deciding
whether
or
how
to
proceed
with
proposed
activities;
and
to
provide
environmental
documentation
pursuant
to
the
Act
and
Annex
I
of
the
Protocol.
For
a
CEE,
any
decision
by
the
operator
on
whether
a
proposed
activity
should
proceed
in
either
its
original
or
modified
form
must
be
based
upon
the
final
CEE
as
well
as
other
relevant
considerations,
and
the
information
provided
in
an
evaluation
should
allow
the
operator
to
make
decisions
based
on
sound
understanding
of
factors
relevant
to
the
likely
impact
of
the
proposed
activity.

°
By
OFA,
in
consultation
with
other
interested
Federal
agencies,
to
ensure
that
nongovernmental
operators
identify
and
assess
the
potential
impacts
of
their
proposed
activities,
including
tourism,
on
the
Antarctic
environment,
and
that
operators
consider
these
impacts
in
deciding
whether
or
how
to
proceed
with
proposed
activities.
OFA
also
makes
the
environmental
documentation
and
any
associated
assessment
and
verification
information
available
to
other
Parties
to
the
Treaty
and
the
public
as
required
under
the
Protocol
or
as
otherwise
requested.
OFA
uses
the
assessment
and
verification
information
for
such
things
as
tracking
Antarctic
tourism
trends
and
activities.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
NONDUPLICATION:
The
information
that
is
requested
from
respondents
under
this
ICR
is
required
by
statute
and
is
not
available
from
other
sources.
The
Act
requires
these
regulations
to
be
consistent
with
Annex
I
to
the
Protocol,
and
the
Final
Rule
provides
nongovernmental
operators
with
the
specific
requirements
they
need
to
meet
in
order
to
comply
with
the
Protocol.
Most
Antarctica
tour
operators
currently
provide,
on
an
informal
basis,
information
to
the
National
Science
Foundation
prior
to
each
Antarctic
season.
Operators
also
provide
an
advance
notice
to
the
U.
S.
Department
of
State.
This
information
is
similar
to
the
basic
information
requirements
for
preparation
of
environmental
documentation
under
the
Final
Rule.
However,
the
Final
Rule
ensures
that
nongovernmental
operators
identify
and
assess
the
potential
impacts
of
their
proposed
activities,
including
tourism,
on
the
Antarctic
environment,
and
that
operators
consider
these
impacts
in
deciding
whether
or
how
to
proceed
with
proposed
activities.
Even
the
lowest
level
of
environmental
documentation,
the
PERM,
directs
that
the
assessment
process
include
assessment
of
the
potential
direct
and
reasonably
foreseeable
indirect
impacts
on
the
Antarctic
environment
of
the
proposed
expedition
in
sufficient
detail
to
assess
5Alternately,
under
the
paperwork
reduction
provisions
of
the
Final
Rule,
operators
could
choose
to
incorporate
the
advance
notice
by
referring
to
it
since
it
is
reasonably
available
to
EPA.
Practice
has
been
that
the
operators
have
included
a
copy
in
their
environmental
assessment
documentation.

7
whether
the
proposed
activity
has
less
than
a
minor
or
transitory
impact,
a
requirement
that
leads
to
consistency
with
Article
8
and
Annex
I
of
the
Protocol.
Operators
can,
and
usually
do,
include
a
copy
of
the
advance
notice
as
part
of
their
EIA
documentation.
5
However,
simply
providing
a
copy
of
the
advance
notice
submitted
to
the
Department
of
State
as
the
environmental
documentation
would
not
meet
the
requirements
of
Article
8
and
Annex
I
of
the
Protocol
or
the
provisions
of
the
Final
Rule.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB:

The
Office
of
Federal
Activities
published
a
Notice
in
the
Federal
Register
requesting
public
comments
on
the
renewal
of
this
ICR
and
established
a
public
docket
for
this
ICR
renewal
under
Docket
ID
number
OECA­
2004­
0026.
This
docket
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
Ave.,
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)
564­
1927.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
The
public
may
use
EDOCKET
to
obtain
a
copy
of
the
draft
ICR
including
the
Supporting
Statement,
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.

The
Federal
Register
Notice
was
published
Friday,
May
14,
2004.
Comments
were
requested
to
be
submitted
on
or
before
July
13,
2004.
EPA
received
two
comments
online
through
the
EPA
Docket.
No
comments
were
received
by
mail
or
telephone.
The
two
online
comments
were
submitted
on
July
2,
2004,
by
the
same
commentor
and
are
duplicates
in
content.
Part
C
of
the
Supporting
Statement
includes
copies
of
these
two
online
comments
and
the
response
to
these
comments.

3(
c)
Consultations:

The
Final
Rule
provides
that
EPA,
in
consultation
with
other
interested
Federal
agencies,
will
review
environmental
documents.
These
other
interested
Federal
agencies
have
been
identified
and
are
included
in
the
estimate
of
burden
for
the
Federal
government.
These
agencies
include,
primarily,
the
U.
S.
Department
of
State
and
the
National
Science
Foundation.
In
addition,
the
Department
of
State
agrees
with
its
responsibilities
under
the
Final
Rule
at
Section
8.12,
Coordination
of
reviews
from
other
Parties.
Part
D
of
the
Supporting
Statement
includes
the
name,
affiliation,
contact
information,
and
a
summary
of
the
consultations
with
these
two
8
agencies.

As
part
of
the
ICR
renewal
process,
OFA
also
contacted
seven
of
the
respondents
that
operate
annually
in
Antarctica
in
order
to
gather
feedback
on
the
hours
and
cost
estimates.
Part
D
of
the
Supporting
Statement
includes
the
name,
affiliation,
and
contact
information
for
each
respondent
contacted,
and
a
summary
of
the
consultations.

3(
d)
Effects
of
Less
Frequent
Collection:
The
Final
Rule
requires
environmental
documentation
for
each
operator
for
each
nongovernmental
expedition
to
Antarctica.
Nongovernmental
activities
are
usually
limited
to
seasonal
expeditions
during
the
austral
summer
season
and
operators
report
annually
on
their
proposed
expeditions.
Operators
with
one­
time
only
expeditions
report
only
during
the
season
for
which
their
expedition
is
planned.
In
order
to
minimize
paperwork
and
to
implement
the
regulations
without
undue
burden
on
operators,
the
Final
Rule
provides
that:
(
1)
material
may
be
incorporated
by
referring
to
it
in
the
environmental
document
when
it
is
reasonably
available
to
EPA;
(
2)
more
than
one
proposed
expedition
by
an
operator
may
be
included
within
one
environmental
document;
(
3)
one
environmental
document
may
also
be
used
to
address
expeditions
being
carried
out
by
more
than
one
operator;
and
(
4)
operators
may
submit
multi­
year
environmental
documentation
to
address
proposed
expeditions
for
a
period
of
up
to
five
consecutive
austral
summer
seasons.
Once
environmental
documentation
has
been
prepared
for
a
season,
an
operator
can
resubmit
the
same
document
for
subsequent
seasons
provided
the
level
and
intensity
of
the
activities
are
not
unchanged
and
that
relevant
updates
are
submitted.
Updates
are
likely
to
include
dates
of
expeditions
and
changes
in
landing
locations.
The
operator
may
also
revise
the
document
to
address
modifications
to
the
expedition's
activities
that
could
have
environmental
consequences.
Most
operators
are
likely
to
employ
the
multi­
year
provision
thereby
further
reducing
their
annual
reporting
burden.
Under
this
paperwork
reduction
provision,
one
environmental
document
may
be
submitted
by
one
or
more
operators
for
proposed
expeditions
for
a
period
of
up
to
five
consecutive
austral
summer
seasons,
provided
that
the
conditions
of
the
multi­
year
environmental
document,
including
the
assessment
of
cumulative
impacts,
are
unchanged.
The
multi­
year
provision
allows
operators
to
update
basic
information
and
to
provide
information
on
additional
activities
to
supplement
the
multi­
year
environmental
document
without
having
to
revise
and
re­
submit
the
entire
document.

The
Protocol
and
the
Final
Rule
also
require
an
operator
to
employ
procedures
to
assess
and
provide
a
regular
and
verifiable
record
of
the
actual
impacts
of
any
activity
which
proceeds
on
the
basis
of
an
IEE
or
CEE.
For
activities
requiring
an
IEE,
an
operator
should
be
able
to
use
the
annual
procedures
currently
being
voluntarily
utilized
by
operators
to
provide
the
information.

3(
e)
General
Guidelines:
The
information
collections
associated
with
the
Final
Rule
follow
OMB's
guidelines.
Section
III.
F
of
the
Preamble,
Submission
of
Environmental
Documents,
indicates
that
an
operator
submits
five
copies
of
its
environmental
documentation,
along
with
an
electronic
copy,
if
available.
EPA
coordinates
review
of
the
document
with
other
interested
Federal
agencies
and
makes
documents
received
available
to
the
other
Parties
to
the
Treaty
and
the
public
as
required
under
the
Protocol
or
as
otherwise
requested.
EPA
believes
9
that
five
copies
(
total)
does
not
place
undue
burden
on
the
operator
and
enables
EPA
to
distribute
copies
to
the
reviewing
agencies
in
a
timely
manner,
particularly
in
light
of
the
timing
requirements
for
document
submission
and
review
prior
to
departure
for
the
expedition.

3(
f)
Confidentiality:
The
Final
Rule
does
not
require
submission
of
confidential
information,
nor
does
EPA
anticipate
that
operators
would
submit
confidential
information
as
part
of
their
environmental
documentation.

3(
g)
Sensitive
Questions:
The
Final
Rule
does
not
require
response
to
sensitive
questions
(
e.
g.,
questions
concerning
sexual
behavior
or
attitudes,
religious
beliefs,
or
other
matters
usually
considered
private).

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
RESPONDENTS/
SIC
AND
NAICS
CODES:
The
requirements
of
the
Final
Rule
apply
to
operators
of
nongovernmental
expeditions
organized
in
or
proceeding
from
the
territory
of
the
United
States
to
Antarctica
for
which
the
United
States
is
required
to
give
advance
notice
under
Paragraph
5
of
Article
VII
of
the
Treaty
and
includes
commercial
and
noncommercial
expeditions.
Expeditions
include
ship­
based
tours;
yacht,
skiing
or
mountaineering
expeditions;
flights;
privately
funded
research
expeditions;
and
other
nongovernmental
or
nongovernment­
sponsored
activities.
The
Final
Rule
does
not
apply
to
individual
U.
S.
citizens
or
groups
of
citizens
planning
to
travel
to
Antarctica
on
an
expedition
for
which
they
are
not
acting
as
an
operator.
(
Operators,
for
example,
typically
acquire
use
of
vessels
or
aircraft,
hire
expedition
staff,
plan
itineraries,
and
undertake
other
organizational
responsibilities.)
Further,
the
Act
is
specific
for
nongovernmental
activities,
thus
governmental
jurisdictions
are
not
subject
to
these
regulations.

Most
operators
are
ship­
based
or
land­
based
tour
operators.
The
SIC
Code
for
Tour
Operators
is
4725
and
the
NAICS
Code
is
561520.

4(
b)
INFORMATION
REQUESTED:

Data
items,
including
recordkeeping
requirements:
The
Final
Rule
provides
nongovernmental
operators
with
the
specific
environmental
documentation
requirements
they
need
to
meet
in
order
to
comply
with
relevant
portions
of
the
Protocol.
Nongovernmental
operators,
including
tour
operators,
conducting
expeditions
to
Antarctica
are
required
to
submit
environmental
documentation
to
EPA
that
evaluates
the
potential
environmental
impact
of
their
proposed
activities.
The
type
of
environmental
document
required
depends
upon
the
nature
and
intensity
of
the
environmental
impacts
that
could
result
from
the
activity
under
consideration.
Under
the
Final
Rule,
environmental
documentation
includes
a
Preliminary
Environmental
Review
Memorandum
(
PERM),
an
Initial
Environmental
Evaluation
(
IEE),
or
a
Comprehensive
Environmental
Evaluation
(
CEE).
If
the
operator
determines
that
an
expedition
may
have:
(
1)
less
than
a
minor
or
transitory
impact,
a
PERM
needs
to
be
submitted
no
later
than
180
days
10
before
the
proposed
departure
to
Antarctica;
(
2)
no
more
than
minor
or
transitory
impacts,
including
the
cumulative
impacts
of
the
proposed
activity
in
light
of
existing
and
known
proposed
activities,
an
IEE
needs
to
be
submitted
no
later
than
90
days
before
the
proposed
departure;
or
(
3)
more
than
minor
or
transitory
impacts,
including
the
cumulative
impacts
of
the
proposed
activity
in
light
of
existing
and
known
proposed
activities,
a
CEE
needs
to
be
submitted.

The
Protocol
and
the
Final
Rule
also
require
an
operator
to
employ
procedures
to
assess
and
provide
a
regular
and
verifiable
record
of
the
actual
impacts
of
an
activity
which
proceeds
on
the
basis
on
an
IEE
or
CEE,
including
monitoring
of
key
environmental
indicators
for
an
activity
proceeding
on
the
basis
of
a
CEE.
For
activities
that
require
an
IEE,
an
operator
should
be
able
to
use
the
annual
procedures
currently
being
voluntarily
utilized
by
operators
to
provide
the
information.
For
activities
that
require
a
CEE,
OFA
would
consult
with
the
National
Science
Foundation
and
other
interested
Federal
agencies
regarding
the
monitoring
regime
that
would
be
appropriate
to
the
activity
proposed,
and
with
regard
to
possible
utilization
of
relevant
monitoring
data
collected
by
the
U.
S.
Antarctic
Program.

Environmental
documentation
is
submitted
to
EPA
by
an
operator
prior
to
an
expedition.
For
most
respondents,
including
tour
operators,
EPA
assumes
this
will
be
an
IEE
and,
as
provided
in
the
Final
Rule
at
Section
8.4,
an
operator
may:
(
1)
include
more
than
one
proposed
expedition
within
one
environmental
document,
and
(
2)
one
environmental
document
may
also
be
used
to
address
expeditions
being
carried
out
by
more
than
one
operator.
An
operator
can
also
submit
multi­
year
documentation
to
address
proposed
expeditions
for
a
period
of
up
to
five
consecutive
austral
summer
seasons
thus
eliminating
the
need
for
annual
submission
of
environmental
documentation.
The
multi­
year
provision
also
allows
operators
to
update
basic
information
and
to
provide
information
on
additional
activities
to
supplement
the
multi­
year
environmental
document
without
having
to
revise
and
re­
submit
the
entire
document.
Operators
are
not
required
to
retain
the
environmental
documentation
submitted
to
EPA.
There
is
nothing
in
the
Final
Rule,
however,
that
precludes
an
operator
from
submitting
a
previous
year's
documentation,
with
appropriate
updates,
for
a
subsequent
year's
expedition(
s).

In
cases
of
emergency
relating
to
the
safety
of
human
life
or
of
ships,
aircraft,
equipment
and
facilities
of
high
value,
or
the
protection
of
the
environment
which
requires
an
activity
to
be
undertaken
without
completion
of
the
documentation
procedures
set
out
in
the
Final
Rule,
the
operator
must
notify
the
Department
of
State
within
15
days
of
any
activities
which
would
have
otherwise
required
preparation
of
a
CEE,
and
provide
a
full
explanation
of
the
activities
carried
out
within
45
days
of
those
activities.

Enforcement
action
can
proceed,
pursuant
to
Section
8.11
of
the
Final
Rule,
against
an
operator
who
violates
any
provision
of
the
Final
Rule.
Enforcement
actions
are
not,
however,
subject
to
the
requirements
of
the
Paperwork
Reduction
Act.

Respondent
Activities:
The
EPA
considered
the
definition
of
"
burden"
developed
for
the
PRA
and
the
Office
of
Management
and
Budget's
(
OMB's)
final
rules
on
implementing
the
PRA.
6For
the
1997­
1998
through
2003­
2004
austral
summer
seasons
(
e.
g.,
during
the
time
the
Interim
Final
and
Final
Rules
have
been
in
effect),
EPA
found
that
the
IEEs
for
expeditions
that
were
not
ship­
based
(
e.
g.,
landbased
non­
governmental
research,
and
flight
expeditions)
were
usually
similar
to
ship­
based
IEEs
in
terms
of
complexity;
thus,
the
IEEs
for
these
expeditions
are
similar
in
detail
and
length.

11
For
purposes
of
renewing
this
ICR,
EPA
estimated
the
hours
and
costs
to
respondents
under
the
Interim
Final
Rule
and
the
first
three
years
of
the
Final
Rule.
These
are
the
operators
(
e.
g.,
respondents)
for
which
the
United
States
provided
advance
notice
under
Paragraph
5
of
Article
VII
of
the
Treaty
for
proposed
nongovernmental
expeditions
organized
in
or
proceeding
from
the
U.
S.
to
the
Antarctic
Treaty
area.
EPA
used
a
ship­
based
tour
operator
as
its
model
respondent
since
most
U.
S.­
based
nongovernmental
activities
covered
by
the
Final
Rule
are
for
operators
and
activities
associated
with
ship­
based
tourism
as
summarized
in
Figure
1.6
7The
term
Rule
in
this
document
refers
to
the
period
of
time
the
Interim
Final
Rule
and
Final
Rule
have
been
in
place
at
40
CFR
Part
8
(
e.
g.,
for
this
ICR
renewal,
the
years
from
1997­
2004
which
includes
the
1997­
1998
through
2003­
2004
austral
summer
seasons).

8Nine
IAATO­
member
operators
submitted
one
IEE
for
their
Peninsula
area
expeditions
but
one
of
the
operators
did
not
proceed
with
its
planned
tours
during
the
season;
this
operator
plans
to
continue
its
operations
in
the
out­
years.

12
Figure
1.
Numbers
of
Operators
Submitting
Environmental
Documentation
Under
the
Rule7
and
the
Level
of
Documentation
Submitted
Season
Operators
Documentation
Submitted
1997­
1998
9
4
total
IEEs
submitted
including:
°
1
IEE
submitted
on
behalf
of
five
IAATO­
member
operators
for
expeditions
to
the
Peninsula
area
°
1
IEE
submitted
by
two
IAATO­
member
operators
for
their
expeditions
to
the
Ross
Sea
area
°
2
IEEs
submitted
by
two
non­
IAATO
operators
1998­
1999
10
4
total
IEEs
submitted
including:
°
1
IEE
submitted
on
behalf
of
seven
IAATO­
member
operators
for
expeditions
to
the
Peninsula
area
°
1
IEE
submitted
by
one
IAATO­
member
operator
for
its
expeditions
to
the
Ross
Sea
area
°
2
IEEs
submitted
by
two
non­
IAATO
operators
1999­
2000
13
6
total
IEEs
submitted
including:
°
1
IEE
submitted
on
behalf
of
eight
IAATO­
member
operators
for
expeditions
to
the
Peninsula
area
°
1
IEE
submitted
by
one
IAATO­
member
operator
for
its
expeditions
to
the
Ross
Sea
area
°
4
IEEs
submitted
by
four
non­
IAATO
operators
including
a
one­
time
only
filming
expedition
and
a
one­
time
only
cruise­
only
expedition
2000­
2001
13
8
5
total
IEEs
submitted
including:
°
1
IEE
submitted
on
behalf
of
nine
IAATO­
member
operators
for
expeditions
to
the
Peninsula
area
°
1
IEE
submitted
by
one
IAATO­
member
operator
for
its
expeditions
to
the
Ross
Sea
area
°
3
IEEs
submitted
by
three
non­
IAATO
operators
including
a
one­
time
only
trekking
expedition
9Seven
IAATO
member
operators
submitted
one
IEE
for
their
Peninsula
area
expeditions
but
one
of
the
operators
did
not
proceed
with
its
planned
tours
during
the
season;
it
is
unknown
whether
this
operator
will
pursue
operations
during
the
3­
year
life
of
this
ICR.

13
2001­
2002
129
7
total
IEEs
submitted
including:
°
1
IEE
submitted
on
behalf
of
seven
IAATO­
member
operators
for
expeditions
to
the
Peninsula
area
°
1
IEE
submitted
by
one
IAATO­
member
operator
for
its
expeditions
to
the
Ross
Sea
area
°
5
IEEs
submitted
by
five
non­
IAATO
operators
including
a
one­
time
sailor
training
expedition
2002­
2003
14
8
total
IEEs
submitted
including:
°
1
IEE
submitted
on
behalf
of
seven
IAATO­
member
operators
for
expeditions
to
the
Peninsula
area
°
1
IEE
submitted
by
one
IAATO­
member
operator
for
its
expeditions
to
the
Ross
Sea
area
°
6
IEEs
submitted
by
six
non­
IAATO
operators
2003­
2004
22
1
PERM
submitted
for
a
one­
time
only
flight
13
total
IEEs
submitted
including:
°
1
IEE
submitted
on
behalf
of
nine
IAATO­
member
operators
for
expeditions
to
the
Peninsula
area
°
1
IEE
submitted
by
one
IAATO­
member
operator
for
its
expeditions
to
the
Ross
Sea
area
°
11
IEEs
submitted
by
eleven
non­
IAATO
operators
including
two
one­
time
only
flights
The
EPA
hours
and
cost
estimates
are
based
on
the
following
activities
which
EPA
assumes
a
respondent
would
carry
out
to
prepare
and
submit
the
environmental
documentation
and
undertake
as
assessment
and
verification
procedures.

Assumed
Operator
Activities
Associated
With:

1.
Preparing
and
Submitting
Environmental
Documentation:
1.
Read
the
regulations
and
evaluate
business
operations
and
the
expedition(
s)
activities
relative
to
the
regulatory
provisions
of
the
Final
Rule
and
determine
the
level
of
environmental
documentation
needed;
2.
Search
reference
sources
for
existing
information
on
environmental
conditions
at
proposed
expedition
site(
s)
and
compile
basic
information
from
company
records
for
use
in
preparation
of
the
environmental
document
for
the
proposed
expedition(
s);
3.
Prepare
the
environmental
impact
assessment
(
EIA)
document
(
e.
g.,
PERM,
IEE
or
CEE),
or
review
a
contractor­
prepared
document,
and
submit
to
EPA;
and
4.
Revise
document
if
necessary,
or
operator
decides
to
prepare
higher
level
EIA
document,
in
response
to
EPA's
comments
and
submit
to
EPA.

2.
Post­
Expedition
Assessment
and
Verification
Procedures:
10EPA
routinely
consults
with
the
Department
of
State
(
DOS)
and
the
National
Science
Foundation
(
NSF).
EPA
may
consult
with
other
agencies
when
appropriate
for
specific
activities.
These
may
include:
U.
S.
Coast
Guard
(
USCG),
Marine
Mammal
Commission
(
MMC),
National
Oceanic
and
Atmospheric
Administration
(
NOAA,
including
National
Marine
Fisheries
Service),
and
the
Department
of
Justice
(
DOJ).

14
1.
Prepare
assessment
and
verification
information.

3.
Reporting
for
Cases
of
Emergency,
if
necessary:
1.
Notify
the
Department
of
State
of
any
activities
which
would
have
otherwise
required
preparation
of
a
CEE
within
15
days.
2.
Provide
a
full
report
to
the
Department
of
State
within
45
days.

The
Final
Rule
does
NOT
require
or
contemplate
the
need
for
respondents
to:

1.
Acquire,
install,
or
utilize
technology
and
systems
for
the
purpose
of
collecting,
validating,
and
verifying
information;
2.
Develop,
acquire,
install,
or
utilize
technology
and
systems
for
the
purpose
of
processing
and
maintaining
information;
3.
Develop,
acquire,
install,
or
utilize
technology
and
systems
for
the
purpose
of
disclosing
and
providing
information;
or
4.
Adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements.

5.
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
AGENCY
ACTIVITIES:
The
EPA
consults
with
the
Department
of
State,
the
National
Science
Foundation,
and
other
interested
Federal
agencies10
for
activities
associated
with
the
Final
Rule.
This
enables
appropriate
government
agencies
with
specific
Antarctic
interests
and
expertise
to
be
involved
with
the
review
of
the
environmental
documentation
for
proposed
nongovernmental
expeditions
including
coordination
of
appropriate
information
relative
to
the
U.
S.
Antarctic
Program.
Further,
violation
of
the
provisions
of
the
Final
Rule
could
result
in
enforcement
and
penalties
pursuant
to
the
Antarctic
Conservation
Act,
as
amended,
as
undertaken
by
the
National
Science
Foundation
and/
or
the
Department
of
Justice.
Finally,
the
Department
of
State
has
specific
responsibilities
under
the
Final
Rule,
Section
8.12,
Coordination
of
reviews
from
other
Parties,
and
for
circulating
a
CEE
that
is
prepared
in
accordance
with
the
Final
Rule
at
Section
8.8,
along
with
any
decisions
by
the
operator
relating
thereto,
to
all
Parties.
Activities
associated
with
the
Final
Rule
for
the
EPA
and
other
Federal
agencies
consist
of
the
following.

EPA
and
Other
Federal
Agencies
Activities
Associated
With:

1.
Processing
and
Reviewing
Environmental
Documentation
Received
from
Operators:
1.
Post
receipt
of
environmental
documents
on
OFA's
World
Wide
Website,
and
provide
15
copies
to
other
Federal
agencies
and
the
public,
if
requested.
2.
Prepare
and
publish
Federal
Register
notice
of
receipt
of
draft
CEEs
and
notice
of
availability
for
Final
CEEs.
3.
Review
environmental
documents,
including
any
appropriate
public
comments,
and
provide
comments
to
the
operator.
4.
Consult
with
operators
on
the
comments,
or
any
other
elements
associated
with
the
environmental
documentation
requirements.
5.
Circulate
to
interested
Federal
agencies
and
review
the
revised
or
final
document
submitted
by
the
operator,
and
notify
the
operator,
if
necessary,
if
the
environmental
documentation
does
not
meet
the
requirements
of
the
Protocol
and
the
provisions
of
the
Final
Rule.
6.
Notify
the
Parties
and
provide
copies
to
the
Committee
for
Environmental
Protection
of
the
annual
list
of
IEEs,
draft
CEEs
and
final
CEEs.
7.
Maintain
files.

2.
Processing
and
Reviewing
Post­
Expedition
Assessment
and
Verification
Information:
1.
Review
assessment
and
verification
information
submitted
by
operators.
2.
Maintain
files.

3.
Processing
and
Reviewing
Reports
for
Cases
of
Emergency,
if
necessary:
1.
Notify
Parties
to
the
Protocol
when
activities
taken
in
cases
of
emergency
are
reported
by
operators
which
required
the
operator
to
undertake
any
activities
which
would
have
otherwise
required
preparation
of
a
CEE.
2.
Forward
the
operator's
full
explanation
of
the
activities
carried
out
to
the
Parties.
3.
Review
assessment
and
verification
information
submitted
by
operator.
4.
Maintain
files.

4.
Processing
and
Reviewing
Environmental
Documentation
Received
from
Other
Parties:
1.
Prepare
and
publish
Federal
Register
notice
of
receipt
of
a
draft
CEE
from
another
Party
and
provide
copies
to
other
interested
Federal
agencies
and
the
public,
if
requested.
2.
Review
draft
CEE
and
transmit
inter­
agency
response
to
the
Party
that
circulated
the
CEE.
3.
Provide
copies
of
other
environmental
documents
to
interested
Federal
agencies
and
the
public,
if
requested.
Other
environmental
documents
may
include:
a)
a
description
of
national
procedures
for
considering
the
environmental
impacts
of
proposed
activities;
b)
an
annual
list
of
any
IEEs
and
any
decisions
taken
in
consequence
thereof;
c)
significant
information
obtained
and
any
action
taken
in
consequence
thereof
with
regard
to
monitoring
from
IEEs
and
CEEs;
and
d)
information
on
a
final
CEE.
4.
Post
receipt
of
significant
monitoring
information
on
OFA's
World
Wide
Website.
5.
Maintain
files.
11For
example,
Sweden
has
a
specific
form,
and
the
United
Kingdom
has
a
permit
system.
For
purposes
of
the
Final
Rule,
an
operator
could
submit
environmental
documentation
prepared
for
another
country
as
long
as
all
the
elements
required
by
the
regulations
are
addressed.

16
5(
b)
COLLECTION
METHODOLOGY
AND
MANAGEMENT:
The
environmental
documentation
that
is
required
by
the
Final
Rule
is
submitted
by
operators
in
accordance
with
the
deadlines
in
the
regulations.
These
documents
can
be
submitted
in
hard
copy
and
can
also
be
submitted
electronically.
The
Final
Rule
mandates
specific
information
to
be
included
in
the
document,
but
does
not
require
a
specific
format.
Since
the
information
requirement
is
the
same
as
that
in
the
Protocol,
this
allows
flexibility
for
operators
who
have
multiple
international
documentation
requirements.
11
EPA,
in
consultation
with
other
interested
Federal
agencies,
reviews
the
environmental
documentation
relative
to
the
general
requirements
(
e.
g.,
Final
Rule,
Section
8.4)
and
the
specific
requirements
for
each
level
of
documentation
(
e.
g.,
Final
Rule,
Section
8.6
for
PERMs;
Section
8.7
for
IEEs;
and
Section
8.8
for
CEEs).
EPA
provides
its
comments
to
the
operator,
and
the
operator
then
prepares
revised
documentation
or
responses
to
EPA's
questions
or
comments.
Following
the
final
response
from
the
operator,
if
appropriate,
EPA,
with
the
concurrence
of
the
National
Science
Foundation,
makes
a
finding
that
the
documentation
submitted
does
not
meet
the
requirements
of
Article
8
and
Annex
I
of
the
Protocol
and
the
provisions
of
the
regulations.
EPA
provides
copies
of
environmental
documents
to
all
interested
Federal
agencies,
and
the
public
is
informed
of
receipt
of
environmental
documents
through
notice
on
OFA's
Homepage
on
the
World
Wide
Web,
and
through
the
Federal
Register
for
CEEs.

5(
c)
SMALL
ENTITY
FLEXIBILITY:
The
PRA
incorporated
the
Regulatory
Flexibility
Act
into
it.
The
Regulatory
Flexibility
Act
(
RFA),
as
amended
by
the
Small
Business
Regulatory
Enforcement
Act
of
1996
(
SBREFA,
5
U.
S.
C.
601
et
seq.),
generally
requires
an
agency
to
prepare
a
regulatory
flexibility
analysis
of
any
rule
subject
to
notice
and
comment
rulemaking
requirements
under
the
Administrative
Procedure
Act
or
any
other
statute
unless
the
agency
certifies
that
the
rule
will
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities.
Small
entities
include
small
businesses,
small
organizations,
and
small
governmental
jurisdictions.

The
purpose
of
the
RFA/
SBREFA
is
"
to
fit
regulatory
and
informational
requirements
to
the
scale
of
the
business,
organizations
and
governmental
jurisdictions
subject
to
the
regulation."
To
achieve
this
principle,
agencies
are
required
to
"
solicit
and
consider
flexible
regulatory
proposals
and
to
explain
the
rationale
for
their
actions
to
assure
that
such
proposals
are
given
serious
consideration."
The
RFA/
SBREFA
does
not
require
an
agency
to
minimize
a
rule's
impact
on
small
entities
if
there
are
legal,
policy,
factual
or
other
reasons
for
not
doing
so.
The
RFA/
SBREFA
requires
only
that
agencies:
determine,
to
the
extent
feasible,
the
rule's
economic
impact
on
small
entities;
explore
regulatory
options
for
reducing
any
significant
economic
impact
on
a
substantial
number
of
such
entities;
and
explain
the
Agency's
ultimate
choice
of
regulatory
approach.
1216
U.
S.
C.
2401
et
seq.,
as
amended,
16
U.
S.
C.
2403a.

17
The
RFA/
SBREFA
requirements
to
prepare
a
regulatory
flexibility
analysis
or
a
certification
of
no
significant
economic
impact
on
a
substantial
number
of
small
entities
applies
to
proposed
rules
subject
to
notice­
and­
comment
rulemaking
requirements
under
the
Administrative
Procedure
Act
or
any
other
statute,
and
final
rules
promulgated
under
the
notice­
and­
comment
rulemaking
requirements
of
the
Administrative
Procedure
Act.
Further,
the
RFA
requires
that
an
agency
identify
the
types,
and
estimate
the
numbers,
of
small
entities
"
to
which
the
final
[
or
proposed]
rule
will
apply,"
and
describe
the
rule
"
requirements"
to
which
small
entities
"
will
be
subject"
and
any
regulatory
alternatives,
including
exemptions
and
deferrals,
which
would
lessen
the
rule's
burden
on
small
entities.
It
is
EPA's
policy
to
make
an
assessment
of
the
rule's
impact
on
any
small
entities,
to
engage
the
potentially
regulated
entities
in
a
dialog
regarding
the
rule,
and
minimize
the
impact
to
the
extent
feasible.
However,
in
view
of
the
requirements
of
SBREFA,
a
regulatory
flexibility
analysis
as
specified
by
the
RFA
is
not
required
simply
because
the
rule
has
some
impact
on
some
number
of
small
entities.
Instead,
such
analyses
is
required
only
in
cases
where
the
Agency
cannot
certify
that
the
rule
will
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities.

For
purposes
of
assessing
the
impacts
of
the
Final
Rule
on
small
entities,
small
entity
is
defined
as:

(
1)
a
small
business
as
defined
by
the
Small
Business
Administration
with
the
North
American
Industry
Classification
System
(
NAICS)
code
for
"
Tour
Operators,"
code
561520,
with
annual
maximum
receipts
of
$
5.0
million
(
13
CFR
Part
121);
and
(
2)
a
small
organization
that
is
any
not­
for­
profit
enterprise
which
is
independently
owned
and
operated
and
is
not
dominant
in
its
field.

In
accordance
with
section
2403a
of
the
Act,
governmental
jurisdictions
are
not
subject
to
this
rulemaking.
12
In
determining
whether
a
rule
has
a
significant
economic
impact
on
a
substantial
number
of
small
entities,
the
impact
of
concern
is
any
significant
adverse
economic
impact
on
small
entities,
since
the
primary
purpose
of
the
regulatory
flexibility
analyses
is
to
identify
and
address
regulatory
alternatives
"
which
minimize
any
significant
economic
impact
of
the
proposed
rule
on
small
entities."
5
U.
S.
C.
Sections
603
and
604.
Thus,
an
agency
may
certify
that
a
rule
will
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities
if
the
rule
relieves
regulatory
burden,
or
otherwise
has
a
positive
economic
effect
on
all
of
the
small
entities
subject
to
the
rule.
The
EPA
believes
that
because
the
Final
Rule
only
requires
assessment
of
environmental
impacts
the
effects
on
any
small
entities
will
be
limited
primarily
to
the
cost
of
preparing
such
an
analysis
and
that
the
requirements
are
no
greater
than
necessary
to
ensure
that
the
United
States
will
be
in
compliance
with
its
international
obligations
under
the
Protocol
and
the
Treaty.
The
costs
are
minimal
because
the
types
of
activities
currently
being
carried
out
typically
are
unlikely
to
have
impacts
that
are
more
than
minor
or
transitory
assuming
that
activities
will
be
carried
out
in
13For
the
austral
seasons
the
Final
Rule
has
been
in
effect,
operators
have
used
all
of
the
available
paperwork
provisions
available
under
the
Final
Rule.

18
accordance
with
the
guidelines
set
forth
in
the
ATCM
Recommendation
XVIII­
1,
Tourism
and
Non­
Governmental
Activities,
the
relevant
provisions
of
other
U.
S.
statutes,
and
Annexes
II­
V
to
the
Protocol.
Therefore,
most
activities
are
likely
to
need
only
IEE
documentation,
the
cost
of
which
is
minimal
as
shown
in
Section
6
of
this
Supporting
Statement
and
as
presented
in
the
Preamble
to
the
Final
Rule,
Section
V.
D,
Paperwork
Reduction
Act.
Further,
EPA
has
included
provisions
in
the
Final
Rule
which
are
available
to
all
respondents,
including
small
entities,
which
will
have
a
positive
effect
by
minimizing
the
cost,
and
reducing
the
paperwork
burden,
of
such
an
analysis.

It
has
been
EPA's
experience
that
respondents
used
the
cost
reduction
provisions
in
the
final
regulations.
The
cost
and
paperwork
reduction
provisions
in
the
Final
Rule
include:
(
1)
material
may
be
incorporated
by
referring
to
it
in
the
environmental
document
with
its
content
briefly
described
when
the
cited
material
is
reasonably
available
to
the
EPA;
(
2)
more
than
one
proposed
expedition
by
an
operator
may
be
included
within
one
environmental
document
and
may,
if
appropriate,
include
a
single
discussion
of
components
of
the
environmental
analysis
which
are
applicable
to
some
or
all
of
the
proposed
expeditions;
(
3)
one
environmental
document
may
also
be
used
to
address
expeditions
being
carried
out
by
more
than
one
operator,
provided
that
the
environmental
documentation
includes
the
names
of
each
operator
for
which
the
environmental
documentation
is
being
submitted
pursuant
to
obligations
under
these
regulations;
and
(
4)
one
environmental
document
may
be
submitted
by
one
or
more
operators
for
proposed
expeditions
for
a
period
of
up
to
five
consecutive
austral
summer
seasons,
provided
that
the
conditions
of
the
multi­
year
environmental
document,
including
the
assessment
of
cumulative
impacts,
are
unchanged.
The
multi­
year
provision
also
allows
operators
to
update
basic
information
and
to
provide
information
on
additional
activities
to
supplement
the
multi­
year
environmental
document
without
having
to
revise
and
re­
submit
the
entire
document.
13
In
consideration
of
the
timing
requirements
associated
with
the
need
to
assist
new
operators
who
are
unfamiliar
with
the
regulations
and
its
schedules,
or
to
assist
operators
who
have
unanticipated
amendments
to
their
EIA
documentation
for
a
particular
year,
the
Final
Rule
at
Section
8.5(
b)
provides
that
EPA
may
waive
or
modify
the
deadlines
of
the
Final
Rule
if
EPA
determines
that
an
operator
is
acting
in
good
faith
and
that
circumstances
outside
the
control
of
the
operator
created
delays,
provided
that
environmental
documentation
fully
meets
deadlines
under
the
Protocol.

The
Final
Rule
does
not
provide
an
exemption
from
coverage
of
the
collection
of
information,
or
any
part
thereof.
This
is
because
the
Final
Rule
only
requires
assessment
of
environmental
impacts.
This
assessment
is
limited
to
the
cost
of
preparing
such
an
analysis
and
the
requirements
would
be
no
greater
than
necessary
to
ensure
that
the
United
States
will
be
in
compliance
with
its
international
obligations
under
the
Protocol
and
the
Treaty.
14See:
Final
Rule,
Preamble,
Section
III.
D.
3(
c).
Article
3(
4),
of
Annex
I
of
the
Protocol
requires
that
draft
CEEs
be
distributed
to
all
Parties
and
the
Committee
for
Environmental
Protection
120
days
in
advance
of
the
next
Antarctic
Treaty
Consultative
Meeting
(
ATCM)
at
which
the
CEE
may
be
addressed.
Operators
who
anticipate
such
activities
are
encouraged
to
consult
with
EPA
as
soon
as
possible
regarding
the
date
for
submitting
the
CEE.
In
fact,
there
were
no
CEEs
submitted
during
the
seven
austral
seasons
the
Rule
has
been
in
effect.

19
5(
d)
COLLECTION
SCHEDULE:
The
schedule
for
submittal
of
environmental
documentation
depends
on
the
document
to
be
submitted
as
described
below.
An
operator
could
submit
environmental
documentation
prior
to
these
deadlines.
In
all
cases,
however,
documents
need
to
be
submitted
such
that
the
schedule
requirements
for
submitting
draft
CEEs
to
the
Parties
can
be
met
by
the
United
States.

Preliminary
Environmental
Review
Memorandum
(
PERM):
In
accordance
with
the
Final
Rule
at
Section
8.6,
a
PERM
needs
to
be
submitted
to
EPA
no
less
than
180
days
before
the
proposed
departure
of
the
expedition.
°
EPA,
in
consultation
with
other
interested
Federal
agencies,
provides
its
comments
to
the
operator
within
15
days
of
receipt.
°
The
operator
then
has
75
days
to
revise
the
PERM
or
prepare
an
IEE,
if
necessary.
If
an
IEE
is
prepared
and
submitted
within
the
75
day
response
period,
it
is
reviewed
under
the
time
frames
for
an
IEE
(
see
below).
If
a
CEE
is
prepared,
it
is
reviewed
under
the
time
frames
for
a
CEE
(
see
below.)
°
Within
30
days,
if
appropriate,
EPA,
with
the
concurrence
of
the
National
Science
Foundation,
provides
notice
to
the
operator
that
the
environmental
documentation
does
not
meet
the
requirements
of
the
Protocol
and
the
provisions
of
the
Final
Rule.

Initial
Environmental
Evaluation
(
IEE):
In
accordance
with
the
Final
Rule
at
Section
8.7,
an
IEE
needs
to
be
submitted
no
fewer
than
90
days
before
the
proposed
departure
of
the
expedition.
°
EPA,
in
consultation
with
other
interested
Federal
agencies,
provides
its
comments
to
the
operator
within
30
days
of
receipt.
°
The
operator
then
has
45
days
to
revise
the
IEE
or
prepare
a
CEE,
if
necessary.
If
a
CEE
is
prepared,
it
would
be
reviewed
under
the
time
frames
for
a
CEE
(
see
below).
°
Within
15
days
of
receiving
the
final
IEE
from
the
operator
or,
if
the
operator
does
not
provide
a
final
IEE,
within
60
days
following
EPA's
comments
on
the
original
IEE,
if
appropriate,
EPA,
with
the
concurrence
of
the
National
Science
Foundation,
provides
notice
to
the
operator
that
the
environmental
documentation
does
not
meet
the
requirements
of
the
Protocol
and
the
provisions
of
the
Final
Rule.

Comprehensive
Environmental
Evaluation
(
CEE):
In
accordance
with
the
Final
Rule
at
Section
8.8(
b),
operators
need
to
submit
a
CEE.
14
°
Within
15
days
of
receipt,
EPA
would:
(
1)
send
it
to
the
Department
of
State
for
circulation
to
the
Parties
and
Committee
for
Environmental
Protection;
and
(
2)
publish
notice
of
receipt
and
request
for
comments
in
the
Federal
Register.
20
°
EPA
accepts
public
comments
for
90
days
following
the
published
notice.
°
EPA,
in
consultation
with
other
interested
Federal
agencies,
provides
its
comments
to
the
operator
within
120
days
following
the
Federal
Register
notice.
°
The
operator
then
needs
to
submit
a
final
CEE
75
days
before
commencement
of
the
proposed
activity
in
the
Antarctic
Treaty
area.
°
Within
15
days
of
receiving
the
final
CEE
from
the
operator
or,
if
the
operator
does
not
provide
a
final
CEE,
within
60
days
prior
to
departure
of
the
expedition,
if
appropriate,
EPA,
with
the
concurrence
of
the
National
Science
Foundation,
provides
notice
to
the
operator
that
the
environmental
documentation
does
not
meet
the
requirements
of
the
Protocol
and
the
provisions
of
the
Final
Rule.
°
If
EPA
does
not
provide
such
notice,
the
operator
would
have
met
all
requirements
provided
that
procedures,
which
may
include
appropriate
monitoring,
are
put
in
place
to
assess
and
verify
the
impact
of
the
activity.
°
No
later
than
60
days
before
commencement
of
the
proposed
activity
in
the
Antarctic
Treaty
area,
EPA:
(
1)
transmits
the
CEE,
along
with
notice
of
any
decisions
by
the
operator,
to
the
Department
of
State
for
circulation
to
the
Parties,
and
(
2)
publishes
notice
of
availability
of
the
final
CEE
in
the
Federal
Register.

Information
to
Assess
and
Verify
Impacts:
There
is
no
set
schedule
requirements
in
the
Final
Rule
for
submitting
information
on
measures
to
assess
and
verify
environmental
impacts.
Operators
provide
the
information
to
the
National
Science
Foundation
on
a
voluntary
basis.
Operators
often
specify
this
schedule
within
the
environmental
document
for
the
expedition.

Reporting
for
Cases
of
Emergency:
In
accordance
with
the
Final
Rule
at
Section
8.10,
within
15
days
in
cases
of
emergency,
an
operator
needs
to
report
notice
of
any
activities
which
would
have
otherwise
required
preparation
of
a
CEE
to
the
Department
of
State,
and
a
full
explanation
of
the
activities
carried
out
must
be
provided
within
45
days
of
those
activities.

6.
ESTIMATING
THE
HOURS
AND
COST
BURDEN
OF
THE
COLLECTION
6(
a)
ESTIMATED
ANNUAL
RESPONDENT
HOURS
AND
COST
Exhibits
1A,
1B
(
including
Table
1),
and
1C
present
the
estimated
respondent
(
e.
g.,
operator)
hours
and
cost
for
the
three
possible
levels
of
environmental
documentation
(
e.
g.,
PERM,
IEE,
CEE)
and
associated
post­
expedition
assessment
and
verification
procedures.
Exhibit
1D
presents
the
estimated
respondent
hours
and
cost
for
reporting
for
cases
of
emergency.
Respondent
burden
tables
were
prepared
for
each
type
of
environmental
documentation
since
the
effort
should
increase
as
an
increasing
level
of
environmental
documentation
is
required;
e.
g.,
from
PERM
to
IEE
to
CEE.

The
model
respondent
used
in
the
estimates
is
a
nongovernmental,
U.
S.­
based
Antarctic
15For
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect,
environmental
documentation
has
been
submitted
primarily
by
ship­
based
tour
operators
and
one
privately
funded
researcher.
Many
of
the
U.
S.­
based
tour
operators
(
both
ship­
based
and
land­
based)
are
members
of
IAATO
and
are
experienced
for­
profit
companies
that
organize
and/
or
operate
travel
programs
to
the
Antarctic.

21
tour
ship
operator.
15
The
estimated
hours
and
cost
for
operators
is
based
on
the
assumption
that
most
environmental
documentation
submitted
by
operators
will
be
IEEs.
As
stated
in
the
Preamble
to
the
Final
Rule
(
Section
III.
D.
3(
b)),
at
a
minimum,
an
IEE
is
typically
the
appropriate
level
of
environmental
documentation
for
proposed
activities.
The
types
of
nongovernmental
activities
that
are
currently
being
carried
out
typically
are
unlikely
to
have
impacts
that
are
more
than
minor
or
transitory
assuming
that
activities
are
carried
out
in
accordance
with
the
guidelines
set
forth
in
the
ATCM,
Recommendation
XVIII­
1,
Tourism
and
Non­
Governmental
Activities,
the
relevant
provisions
of
other
U.
S.
statutes,
and
Annexes
II­
V
to
the
Protocol.
During
the
austral
summer
seasons
the
Rule
has
been
in
effect,
IEEs
have
been
submitted
by
operators
as
summarized
in
Figure
1.
The
following
elements
further
discuss
the
assumptions
factored
into
the
estimated
respondent
hours
and
cost.

1.
Number
of
Respondents:
Based
on
EPA's
experience
during
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect
(
see
Figure
1),
for
purposes
of
this
ICR
renewal,
the
total
number
of
respondents
is
estimated
as
twenty­
two
as
delineated
in
Figure
2.
This
estimate
includes
17
repeat
operators
who
are
expected
to
submit
new
or
revised
or
multi­
year
IEE
documentation,
and
five
new
operators
who
are
expected
to
submit
new
IEEs.

FIGURE
2.
Estimated
Respondents
and
Anticipated
Level
of
EIA
Documentation
Considering
EPA's
Experience
Under
the
Rule
Operators
Number
of
Operators
U.
S.­
based
IAATO­
member
tour
operators
9
Peninsular
Area
U.
S.­
based
IAATO­
member
tour
operators
1
Ross
Sea
Area
U.
S.­
based
IAATO­
member
tour
operators
1
Continental
Area
U.
S.­
based
non­
IAATO
member
tour
operators
4
Peninsular
Area
U.
S.­
based
non­
IAATO
member
tour
operators
1
Continental
Area
U.
S.­
based
privately
funded
researcher
1
U.
S.­
based
possible
new
respondents
5
TOTAL
ESTIMATED
22
2.
Basis
for
Cost
Estimates:
The
cost
estimates
are
based
on
industry
labor
rates
obtained
during
informal
consultations
with
industry
representatives
and
include
overhead
and
fringe
benefits.
The
three
rates
used
in
the
calculations
represent
the
rates
provided
by
the
industry
representatives
including
$
65/
hour
as
a
low,
$
75/
hour
as
an
intermediate,
and
$
100/
hour
as
a
high.
The
$
75/
hour
intermediate
rate
is
used
for
summary
purposes.
See
Part
D
for
additional
information
on
the
consultations
with
affected
respondents.
16For
the
four
IEEs
submitted
in
1997­
1998,
the
approximate
number
of
pages,
including
the
"
core"
document
plus
supplemental
documentation,
was:
215
(
5­
operator
Peninsular
Area),
208
(
2­
operator
non­
PA),
43
(
non­
IAATO
member
operator),
and
20
(
privately­
funded
researcher).
The
supplemental
information
submitted
by
the
5
operators
for
the
Peninsular
Area
IEE,
which
included
tour
brochures,
averaged
about
23
pages
per
operator.
The
privately­
funded
researcher
incorporated
by
reference
selected
information
from
three
previously
published
reports.
During
the
subsequent
three
years
the
Interim
Final
Rule
was
in
effect,
the
annual
submissions
averaged
closer
to
50
pages
due,
in
large
part,
to
the
use
of
the
paperwork
reduction
provisions
of
the
Interim
Final
Rule.
This
"
preparation"
burden
is
actually
less
when
the
fact
that
tour
brochures
for
the
current
season
prepared
for
commercial
purposes
and
a
copy
of
the
advance
notice
submitted
to
the
Department
of
State
were
submitted
by
the
tour
operators
as
part
of
the
IEE
documentation.
However,
for
purposes
of
maximum
burden
estimates,
the
1997­
1998
figures
are
used
in
the
burden
calculations.
Experience
under
the
Final
Rule
indicates
these
assumptions
are
still
generally
accurate.

22
3.
PERM
Model
for
Respondent
Submittals:
For
PERMs,
the
estimated
hours
and
cost
is
based
on
the
estimated
time
to
comply
with
the
Final
Rule
at
Section
8.4,
preparation
of
environmental
documents,
generally,
and
Section
8.6,
preliminary
environmental
review.
The
estimate
assumes
one
week
at
40
hours
per
week
including
revisions
in
response
to
any
EPA
comments.
Assessment
and
verification
procedures
are
not
required
at
the
PERM
level
of
activity
and
documentation.
Although
one
respondent
per
year
is
estimated
for
purposes
of
the
cost
calculations
in
Exhibit
1A,
EPA
anticipates
that
the
actual
number
of
nongovernmental
expeditions
with
activities
that
will
likely
proceed
with
less
than
minor
or
transitory
impacts
may
well
be
reduced
to
less
than
one
respondent
per
year.
In
fact,
during
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect,
only
one
PERM
has
been
submitted
as
the
final
document
for
an
expedition.

4.
IEE
Model
for
Respondent
Submittals:
EPA
has
developed
three
models
for
IEEs
that
incorporate
the
estimated
time
to
comply
with
the
Final
Rule
at
Section
8.4,
preparation
of
environmental
documents,
generally,
and
Section
8.7,
initial
environmental
evaluation.
The
model
also
considers
the
experience
with
IEE
documents
received
during
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect
and
burden
estimates
in
the
previous
Supporting
Statements
for
the
ICRs
for
the
Interim
Final
and
Final
Rules.
The
assumptions
for
EPA's
IEE
model
include
the
following:

°
Figure
2
lists
the
potential
respondents.
°
The
maximum
length
for
an
IEE
is
about
200
pages
including
supplemental
information.
16
°
IEEs
consist
of
"
core"
information
with
supplemental
expedition­
specific
or
other
project­
specific
information
(
e.
g.,
dates,
landing
sites,
number
of
tours,
etc.)
attached
or
referenced.
°
For
initial
preparation
of
the
"
core"
IEE,
the
estimate
assumes
four
weeks,
on
average,
at
40
hours/
week,
or
about
160
hours,
including
revisions
in
response
to
EPA
comments.
This
estimate
assumes
a
full
time
effort
during
the
four
weeks,
and
that
information
will
be
incorporated
by
reference
when
appropriate.
°
The
estimate
assumes
5
hours
for
an
operator
to
prepare
and/
or
compile
supplemental
17The
estimate
for
preparation
of
supplemental
information
excludes
any
time
associated
with
preparing
travel
brochures
and/
or
major
reports
referenced
in,
and
submitted
along
with,
an
IEE
(
e.
g.,
researcher
reports
such
as
those
prepared
by
Oceanites,
Inc.,
and
submitted
as
referenced
attachments
with
the
IEE).

18For
activities
requiring
an
IEE,
an
operator
should
be
able
to
use
procedures
currently
being
voluntarily
utilized
by
operators
to
provide
the
required
information.

19For
an
IEE
that
covers
multiple
operators,
the
cost
per
operator
is
further
reduced;
specific
examples
are
listed
as
a
footnote
for
each
model
calculation.

20If,
for
example,
the
"
Core"
IEEs
cover
six
operators
(
e.
g.,
four
of
the
IEEs
cover
one
operator
each
and
one
of
the
IEEs
covers
2
operators),
the
cost
per
operator
is
reduced
from
185
hours
to
154
hours.

23
information.
17
°
If
appropriate,
EPA
anticipates
operators
will
submit
the
"
core"
IEE
in
subsequent
years
with
any
necessary
revisions
(
discussed
below).
An
estimated
one
week
at
40
hours/
week
is
estimated
to
prepare
this
"
revised"
IEE
for
submittal
in
subsequent
years.
The
estimate
of
5
hours
for
preparation
and/
or
compilation
of
supplemental
information
remains
the
same.
°
If
appropriate,
EPA
anticipates
operators
will
submit
"
multi­
year"
IEE
documentation.
In
the
initial
year,
this
is
anticipated
to
consist
of
a
"
revised"
IEE
with
an
estimated
40
hours
associated
preparation
time
and
5
hours
for
preparation
and/
or
compilation
of
supplemental
information.
For
the
subsequent
four
consecutive
years
the
"
multi­
year"
IEE
can
be
submitted
by
an
operator,
for
purposes
of
maximum
burden
estimation,
5
hours
are
estimated
for
preparation
and/
or
compilation
of
the
supplemental
information.
°
The
IEE
level
of
documentation
requires
assessment
and
verification
(
A/
V)
procedures;
20
hours
are
estimated
for
preparation
and/
or
compilation
of
this
information.
18
°
For
an
IEE
that
covers
multiple
operators,
the
hours
and
costs
per
operator
are
spread
among
the
total
number
of
operators;
e.
g.,
the
more
operators
under
one
document,
the
lower
the
hours
and
costs
to
each
individual
operator.
19
IEE
Model
1
­
"
Core"
IEE:
The
following
estimate
is
based
on
EPA's
experience
for
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect
and
considers
the
paperwork
reduction
options
utilized
by
the
operators.
EPA
anticipates
five
one­
time
"
core"
IEEs
will
be
prepared
for
the
three
austral
summer
seasons
this
ICR
renewal
will
be
in
effect.
The
operator
hourly
burden
for
preparation
of
a
"
Core"
IEE
is
estimated
as
follows:

Prepare
"
core"
IEE:
160
hrs/
IEE
x
5
IEEs
=
800
hours
Prepare
supplemental
information:
5
hrs/
operator
x
5
operators
=
25
hours
A/
V
procedures:
20
hrs/
operator
x
5
operators
=
100
hours
TOTAL
HOURS
=
925
hours
TOTAL
HOURS
PER
IEE
(
5
IEEs)
=
185
hours
TOTAL
HOURS
PER
OPERATOR
(
5
operators)
=
185
hrs20
IEE
Model
2
­
"
Revised"
IEE:
For
purposes
of
maximum
burden
assessment,
EPA
21If,
for
example,
the
three
"
Revised"
IEEs
cover
four
operators
(
e.
g.,
two
IEEs
cover
one
operator
each
and
the
other
covers
two
operators),
the
burden
per
operator
is
reduced
from
65
hours
to
49
hours.

22For
purposes
of
demonstrating
the
hourly
burden
for
an
operator
submitting
a
"
Multi­
Year"
IEE,
EPA
assumed
two
operators
would
submit
multi­
year
IEEs
during
the
time
covered
by
this
ICR
renewal.
It
is
possible
that
two
of
the
operators
listed
under
the
"
Revised"
IEE
model
may
submit
"
multi­
year"
rather
than
"
revised"
IEEs.
However,
since
the
intent
of
these
operators
is
unknown,
EPA
assumed
these
two
operators
would
submit
"
revised"
IEEs,
an
assumption
that
provides
the
maximum
hours
and
cost
estimates
for
the
three
year
period
of
this
ICR
renewal
since
the
hours
and
costs
per
operator
are
more
for
a
"
Revised"
IEE
than
for
a
"
Multi­
Year"
IEE.

24
anticipates
that
three
present
ship
based
tour
operators
will
remain
the
same,
and
that
these
operators
will
continue
to
submit
revised
IEEs
for
the
three
austral
summer
seasons
this
ICR
will
be
in
effect.
Updates
are
likely
to
include
such
items
as
dates
of
expeditions
and
changes
in
landing
locations.
Revisions
could
address
items
such
as
assessment
of
the
potential
impacts,
including
cumulative
impacts,
of
modifications
to
the
planned
activities
and
any
associated
mitigation
measures,
or
a
reassessment
of
overall
impacts
for
the
expedition.
Thus,
for
subsequent
seasons,
EPA
assumes
a
reduced
number
of
hours
would
be
required
for
revision
of
the
"
core"
IEE,
and
the
hours
for
preparation
of
supplemental
information
will
remain
the
same.
The
model
for
estimating
respondent
hourly
burden
for
a
"
Revised"
IEE
is
based
on
EPA's
experience
for
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect
and
considers
the
paperwork
reduction
options
utilized
by
the
operators.
The
operator
hourly
burden
for
preparation
of
a
"
Revised"
IEE
is
estimated
as
follows:

Prepare
"
Revised"
IEE:
40
hrs/
IEE
x
3
IEEs
=
120
hours
Prepare
supplemental
information:
5
hrs/
operator
x
3
operators
=
15
hours
A/
V
procedures:
20
hrs/
operator
x
3
operators
=
60
hours
TOTAL
HOURS
=
195
hours
TOTAL
HOURS
PER
IEE
(
3
IEEs)
=
65
hours
TOTAL
HOURS
PER
OPERATOR
(
3
operators)
=
65
hours21
Model
3
­
"
Multi­
Year"
IEE:
Under
the
Final
Rule,
operators
may
choose
to
submit
multi­
year
IEE
documentation.
Under
this
model,
EPA
assumes
the
operators
will
submit
a
"
Revised"
IEE
in
the
initial
year.
The
multi­
year
provision
then
allows
operators
to
supplement
the
multi­
year
environmental
document
without
having
to
revise
and
re­
submit
the
entire
document
in
order
to
update
basic
information
as
necessary,
and
to
provide
information
on
any
new
activities
or
revisions
to
the
documented
activities.

For
purposes
of
demonstrating
the
full
model
for
a
"
multi­
year"
IEE,
EPA
assumes
two
operators
may
submit
"
multi­
year"
IEEs,
and
the
operator
hourly
burden
for
preparation
of
a
"
Multi­
Year"
IEE
is
estimated
as
follows:
22
Initial
Year:
Prepare
"
Revised"
IEE:
40
hrs/
IEE
x
2
IEEs
=
80
hours
23If,
for
example,
the
two
"
Multi­
Year"
IEEs
cover
three
operators
(
e.
g.,
one
IEE
covers
one
operator
and
the
other
covers
two
operators),
the
burden
per
operator
is
reduced
from
33
hours
to
25
hours
(
e.
g.,
the
hours
for
the
annual
supplemental
information
and
A/
V
procedures)
as
the
initial
cost
of
the
"
Revised"
IEE
is
spread
among
the
operators.

24The
number
of
operators
covered
by
the
IAATO
Multi­
Year
IEE
varies
from
year
to
year;
for
purposes
of
this
ICR
renewal,
EPA
estimated
there
would
be
seven
IAATO
members
covered
under
the
IAATO
Multi­
Year
IEE.

25
Prepare
supplemental
information:
5
hrs/
operator
x
2
ops
x
1
year
=
10
hours
A/
V
procedures:
20
hrs/
operator
x
2
ops
x
1
year
=
40
hours
Four
Subsequent
Years
for
a
Total
of
Five
Consecutive
Years:
Prepare
supplemental
information:
5
hrs/
operator
x
2
ops
x
4
years
=
40
hours
A/
V
procedures:
20
hrs/
operator
x
2
ops
x
4
years
=
160
hours
TOTAL
HOURS
for
5­
Year
Period
of
"
Multi­
Year"
IEE
=
330
hours
TOTAL
HOURS
PER
YEAR
(
5
Years)
PER
IEE
(
2
IEEs)
=
33
hours
TOTAL
HOURS
PER
YEAR
(
5
Years)
PER
OPERATOR
(
2
operators)
=
33
hours23
Under
the
Final
Rule,
eight
"
multi­
year"
IEEs
have
been
submitted
for
an
estimated
14
of
the
anticipated
22
operators.
24
During
the
three
austral
seasons
covered
by
the
three­
year
life
of
this
ICR
renewal,
these
eight
IEEs
will
be
in
the
"
subsequent"
years
of
their
documentation
requirements.
The
operator
hourly
burden
for
preparation
of
the
"
subsequent"
years
for
these
eight
"
Multi­
Year"
IEEs
is
estimated
as
follows:

Three
Subsequent
Years
(
life
of
ICR
renewal)
for
the
Current
"
Multi­
Year"
IEEs:
Prepare
supplemental
information:
5
hrs/
operator
x
14
ops
x
3
years
=
210
hours
A/
V
procedures:
20
hrs/
operator
x
14
ops
x
3
years
=
840
hours
TOTAL
HOURS
for
3­
Year
Period
of
this
ICR
Renewal
for
"
Multi­
Year"
IEE
=
1,050
hours
TOTAL
HOURS
PER
YEAR
(
3
Years)
PER
IEE
(
8
IEEs)
=
44
hours
TOTAL
HOURS
PER
YEAR
(
3
Years)
PER
OPERATOR
(
14
operators)
=
25
hours
5.
CEE
Model
for
Respondent
Submittals:
For
CEEs,
the
estimated
hours
and
cost
is
based
on
the
estimated
time
to
comply
with
the
Final
Rule
at
Section
8.4,
preparation
of
environmental
documents,
generally,
and
Section
8.8,
comprehensive
environmental
evaluation,
and
assumes
an
increased
effort
from
that
required
for
an
IEE.
The
estimate
assumes
six
(
6)
weeks
at
40
hours
per
week,
or
240
hours,
including
time
for
revisions
in
response
to
EPA's
comments.
The
estimate
assumes
60
hours
to
prepare
assessment
and
verification
information
associated
with
the
CEE
level
of
activity
and
documentation.
Further,
although
one
respondent
per
year
is
estimated
for
purposes
of
the
cost
calculations
in
Exhibit
1C,
EPA
anticipates
that
the
actual
number
of
nongovernmental
expeditions
with
activities
that
will
likely
proceed
with
more
than
minor
or
transitory
impacts
may
well
be
reduced
to
less
than
one
respondent
per
year.
In
fact,
there
were
no
CEEs
submitted
during
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect.
25One­
time
capital/
start­
up
costs
usually
include
any
produced
physical
good
needed
to
provide
the
necessary
information.
Start­
up
capital
must
be
purchased
for
the
specific
purpose
of
satisfying
EPA's
reporting
or
recordkeeping
requirements.
Capital
goods
include
computers,
machinery,
or
equipment.
Start­
up
capital
costs
are
usually
incurred
at
the
beginning
of
an
information
collection
period
and
are
usually
incurred
only
once.

26O&
M
costs
are
the
recurring
dollar
amount
of
cost
associated
with
O&
M
or
purchasing
services.
For
example,
when
respondents
are
required
to
submit
reports
or
information,
O&
M
costs
may
include
costs
for
file
storage,
photocopying,
and
postage.

27For
Exhibits
1
and
2,
costs
are
rounded
down
to
the
nearest
dollar
for
$
0.01
to
$
0.49,
and
rounded
up
to
the
nearest
dollar
for
$
0.50
to
$
0.99.

26
6.
Emergency
Reporting
Model:
Reporting
for
Cases
of
Emergency
is
based
on
the
Final
Rule
at
Section
8.10,
Cases
of
emergency,
which
requires
notice
and
reporting
for
activities
taken
in
cases
of
emergency
which
would
have
otherwise
required
the
preparation
of
a
CEE.
The
estimate
is
based
on
reporting
requirements
only,
not
the
actual
cost
of
the
emergency
response
action.
The
hours
and
cost
estimate
assumes
one
such
emergency
per
10
years.
In
fact,
there
were
no
such
incidents
during
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect.

7.
Capital/
Start
Up
Costs:
The
EPA
does
not
anticipate
any
capital
or
start
up
costs
on
the
part
of
respondents
to
comply
with
the
provisions
of
the
Final
Rule.
25
8.
O&
M
Costs:
The
EPA
estimates
the
following
operating
and
maintenance
(
O&
M)
costs
associated
with
the
paperwork
requirements
for
respondents
to
comply
with
the
provisions
of
the
Final
Rule.
26
Assumptions
and
calculations
used
in
EPA's
O&
M
estimate
for
the
three
levels
of
environmental
documentation
are
as
follows:

PERMs.
The
assumptions
used
for
the
O&
M
estimates
include:

°
PERMs
are
estimated
to
average
25
pages
including
any
supplemental
information.
°
One
PERM
submitted
per
year
by
one
operator.
In
fact,
during
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect,
only
one
PERM
has
been
submited
as
the
final
documentation
for
an
expedition.
°
Five
copies
of
each
PERM
should
be
submitted.
°
Although
not
required,
the
model
assumes
operators
will
use
express
mail
to
submit
PERM
packages
(
e.
g.,
original
PERM
and
5
copies).
°
PERMs
do
not
require
assessment/
verification
procedures.
°
The
Final
Rule
does
not
require
file
storage
or
audits.
°
Mailing
charges
have
been
increased
to
reflect
inflation.

The
estimated
O&
M
costs
for
a
PERM
are
calculated
as
follows:
27
(
1)
Copying:
25
pages/
PERM
x
5
copies
x
$
0.10/
page
=
$
12.50
(
2)
Mailing:
1
PERM
package
x
$
27/
package
=
27.00
28Three
years
are
used
in
these
calculations
because
that
is
the
period
of
time
the
ICR
is
in
effect
before
it
must
be
renewed.

27
Exhibit
1A
incorporates
double
these
estimated
O&
M
costs
in
the
estimated
respondent
burden
and
costs
for
PERMs
for
a
three
year
period28
based
on
the
assumption,
for
purposes
of
maximum
cost
calculation,
the
initial
submittal
will
be
revised
and
resubmitted.

IEEs.
The
assumptions
used
for
the
O&
M
estimates
include:

°
Figure
2
lists
the
potential
respondents.
°
The
maximum
length
for
an
IEE
is
200
pages
including
supplemental
information.
(
See
above:
"
IEE
Model
for
Respondent
Submittals")
°
Five
copies
of
each
IEE,
including
supplementary
information,
should
be
submitted.
°
Although
not
required,
the
model
assumes
operators
will
use
express
mail
to
submit
IEE
packages
(
e.
g.,
original
IEE
and
5
copies).
°
Assessment/
verification
(
A/
V)
information
is
estimated
as
25
pages
per
operator.
°
Five
copies
of
each
A/
V
information
package
may
be
submitted.
°
Although
not
required,
the
model
assumes
operators
will
use
express
mail
to
submit
A/
V
information
packages
(
e.
g.,
original
and
5
copies).
°
The
Final
Rule
does
not
require
file
storage
or
audits.
°
Mailing
charges
have
been
increased
to
reflect
inflation.

The
estimated
O&
M
costs
for
the
three
IEE
models
are
calculated
as
follows:

"
Core"
IEE:
(
1)
Copying:
200
pages/
Core
IEE
x
5
copies/
IEE
x
$
0.10/
page
=
$
100.00
10
pages/
Supplemental
Info.
x
5
copies
x
$
0.10/
page
=
5.00
25
pages/
A/
V
information
x
5
copies
x
$
0.10/
page
=
12.50
(
2)
Mailing:
1
"
Core"
IEE
package
x
$
27/
package
=
27.00
1
Supplemental
Information
package
x
$
12/
package
=
12.00
1
A/
V
information
package
x
$
17/
package
=
17.00
"
Revised"
IEE:
(
1)
Copying:
200
pages/
Revised
IEE
x
5
copies/
IEE
x
$
0.10/
page
=
100.00
10
pages/
Supplemental
Info.
x
5
copies
x
$
0.10/
page
=
5.00
25
pages/
A/
V
information
x
5
copies
x
$
0.10/
page
=
12.50
(
2)
Mailing:
1
"
Revised"
IEE
package
x
$
27/
package
=
27.00
1
Supplemental
Information
package
x
$
12/
package
=
12.00
1
A/
V
information
package
x
$
17/
package
=
17.00
"
Model
Multi­
Year"
IEE:
(
1)
Copying:
200
pages/
Revised
IEE
x
5
copies/
IEE
x
$
0.10/
page
=
$
100.00
10
pages/
Supplemental
Info.
x
5
copies
x
$
0.10/
page
=
5.00
28
25
pages/
A/
V
information
x
5
copies
x
$
0.10/
page
=
12.50
(
2)
Mailing:
1
Revised
IEE
package
x
$
27/
package
=
27.00
1
Supplemental
Information
package
x
$
12/
package
=
12.00
1
A/
V
information
package
x
$
17/
package
=
17.00
"
Subsequent
Year,
Multi­
Year"
IEE:
(
1)
Copying:
10
pages/
Supplemental
Info.
x
5
copies
x
$
0.10/
page
=
5.00
25
pages/
A/
V
information
x
5
copies
x
$
0.10/
page
=
12.50
(
2)
Mailing:
1
Supplemental
Information
package
x
$
12/
package
=
12.00
1
A/
V
information
package
x
$
17/
package
=
17.00
Exhibit
1B,
including
Table
1B,
incorporates
the
"
Subsequent
Year,
Multi­
Year"
IEE
estimated
O&
M
costs
in
the
estimated
respondent
hours
and
costs
for
IEEs
per
year.
The
costs
for
the
"
Model
Multi­
Year"
IEE
are
listed
only
to
maintain
information
for
purposes
of
the
full
Model.
The
O&
M
costs
are
doubled
for
the
"
Core"
and
"
Revised"
IEE
submittals
based
on
the
assumption,
for
purposes
of
maximum
cost
calculation,
the
initial
submission
will
be
revised
and
resubmitted.

Table
3.
Summary
of
the
3­
Year
Average
O&
M
Costs
for
a
PERM,
the
Three
IEE
Models,
and
a
CEE
PERM
"
Core"
IEE
"
Revised"
IEE
"
Subsequent
Year,
Multi­
Year"
IEE
CEE
Copying:
$
25
Mailing:
$
54
TOTAL
$
79
Copying:
$
218
Mailing:
$
83
TOTAL
$
301
Copying:
$
218
Mailing
$
83
TOTAL
$
301
Copying:
$
18
Mailing:
$
29
TOTAL
$
47
Copying:
$
325
Mailing:
$
81
TOTAL
$
406
NOTE:
The
O&
M
costs
for
the
"
Multi­
Year"
IEE
include
the
"
Subsequent
Year,
Multi­
Year"
IEE
costs
for
purposes
of
this
three­
year
ICR
renewal.

CEEs.
The
assumptions
used
for
the
O&
M
estimates
include:

°
CEEs
are
estimated
to
average
300
pages
including
any
supplemental
information.
°
One
CEE
submitted
per
year
by
one
operator.
In
fact,
there
were
no
CEEs
submitted
during
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect.
°
Five
copies
of
each
CEE
should
be
submitted.
°
Although
not
required,
the
model
assumes
operators
will
use
express
mail
to
submit
CEE
packages
(
e.
g.,
original
CEE
and
5
copies).
°
Assessment/
verification
(
A/
V)
information
is
estimated
as
50
pages
per
operator.
°
Five
copies
of
each
A/
V
information
package
should
be
submitted.
°
Although
not
required,
the
model
assumes
operators
will
use
express
mail
to
submit
A/
V
information
packages
(
e.
g.,
original
and
5
copies).
°
The
Final
Rule
does
not
require
file
storage
or
audits.
°
Mailing
charges
have
been
increased
to
reflect
inflation.
29Three
years
are
used
in
these
calculations
because
that
is
the
period
of
time
the
ICR
is
in
effect
before
it
must
be
renewed.

29
The
estimated
O&
M
costs
for
a
CEE
are
calculated
as
follows:

(
1)
Copying:
300
pages/
CEE
x
5
copies
x
$
0.10/
page
=
$
150.00
50
pages/
A/
V
information
x
5
copies
x
$
0.10/
page
=
25.00
(
2)
Mailing:
1
CEE
package
x
$
32/
package
=
32.00
1
A/
V
information
package
x
$
17/
package
=
17.00
Exhibit
1C
incorporates
these
estimated
O&
M
costs
in
the
estimated
respondent
hours
and
cost
for
CEEs
for
a
three
year
period.
29
The
O&
M
costs
are
doubled
for
the
CEE
submission
based
on
the
assumption,
for
purposes
of
maximum
cost
calculation,
the
initial
submission
will
be
revised
and
resubmitted.

Reporting
for
Cases
of
Emergency.
The
assumptions
used
for
the
O&
M
estimate
include:

°
Emergency
Reports
are
estimated
to
average
300
pages
including
supplemental
information.
°
The
model
assumes
assessment
and
verification
procedures
will
be
undertaken
with
50
pages
submitted.
°
Five
copies
of
the
assessment
and
verification
information
should
be
submitted.
°
Although
not
required,
the
model
assumes
operators
will
use
express
mail
to
submit
Emergency
Reports
and
assessment
and
verification
information.
°
The
O&
M
costs
are
first
calculated
to
indicate
the
annual
cost
assuming
one
such
emergency
per
10
years.
(
See:
Item
6,
above,
Emergency
Reporting
Model)
°
The
Final
Rule
does
not
require
file
storage
or
audits.
°
Mailing
charges
have
been
increased
to
reflect
inflation.

(
1)
Copying:
Emergency
Report
300
pages/
report
x
5
copies
x
$
0.10/
page
=
$
150.00
A/
V
Information
50
pages/
package
x
5
copies
x
$
0.10/
page
=
25.00
(
2)
Mailing:
Emergency
Report
1
Emergency
Report
x
$
32/
report
=
32.00
A/
V
Information
1
A/
V
package
x
$
17/
package
=
17.00
O&
M
for
Emergency
Reporting
in
one
year
=
224.00
Averaged
annual
Emergency
Reporting
assuming
one
emergency
per
10
years
=
23.00
Exhibit
1D
incorporates
these
estimated
O&
M
costs
in
the
estimated
Emergency
Response
respondent
hours
and
costs
for
years
one
through
three.

6(
b)
ESTIMATED
ANNUAL
FEDERAL
GOVERNMENT
HOURS
AND
COST
Exhibits
2A,
2B
(
including
Table
2),
and
2C
present
the
estimated
Federal
government
hours
and
cost
for
processing
and
reviewing
the
three
possible
levels
of
environmental
documentation
(
e.
g.,
PERM,
IEE,
CEE)
and
associated
post­
expedition
assessment
and
verification
information.
Exhibit
2D
presents
the
estimated
Federal
government
hours
and
cost
for
activities
associated
with
reporting
for
cases
of
30There
is
no
respondent
burden
or
cost
associated
with
Section
8.12.

31See:
Exhibits
2A
through
E,
the
Federal
government
estimates
for
hours
and
cost.
For
example,
technical
activities
associated
with
Environmental
Documentation
include:
review
of
environmental
documents,
including
any
public
comments,
and
providing
comments
to
the
operator;
consultation
with
operators;
and
review
of
the
revised/
final
document
submissions
and
notification
of
the
operator,
if
necessary.
Other
activities
listed
under
Environmental
Documentation,
such
as
posting
document
receipt
on
the
WWW,
are
administrative.

32For
the
"
Technical
staff,"
the
model
uses
the
GS­
14
level
rates,
and
assumes
that
the
technical
staff
may
actually
be
composed
of
GS­
13
through
GS­
15
level
staff.
For
the
"
Attorney,"
the
model
uses
the
GS­
14
level
rates,
and
assumes
that
the
attorneys
may
actually
be
composed
of
GS­
14
and
GS­
15
level
staff.
The
EPA
estimated
rates
used
in
the
calculations
are
base
rates
on
the
GS
scale
for
the
Washington,
DC,
area
with
a
25%
increase
to
incorporate
overhead
and
fringe
benefits.

30
emergency,
and
Exhibit
2E
presents
the
estimated
Federal
government
hours
and
cost
for
coordinating
the
review
of
information
received
from
other
Parties.
30
The
Final
Rule
does
not
involve
or
otherwise
impact
governmental
jurisdictions
including
state,
local
or
tribal
governments.

Federal
government
burden
tables
were
prepared
for
each
type
of
environmental
documentation
since
the
effort
should
increase
as
an
increasing
level
of
environmental
documentation
is
required;
e.
g.,
from
PERM
to
IEE
to
CEE.
As
with
the
respondents,
the
model
used
for
the
Federal
government
estimates
is
a
nongovernmental,
U.
S.­
based
ship­
based
tour
operator,
and
the
estimated
hours
and
cost
for
the
Federal
government
is
based
on
the
assumption
that
most
environmental
documentation
submitted
by
operators
will
be
IEEs.

The
following
assumptions
were
factored
into
the
hourly
burden
and
cost
estimates
for
the
Federal
government:

1.
Number
of
Respondents:
The
Federal
government
estimates
are
consistent
with
the
respondent
(
i.
e.,
operators)
estimates
with
regard
to
the
number
of
respondents
and
the
projected
numbers
of
environmental
documents
that
may
be
submitted
(
see:
Section
6(
a)).

2.
Basis
for
Cost
Estimates:
The
cost
estimates
are
based
on
consideration
of
a
"
model"
government
employee
for
activities
associated
with
the
Final
Rule.
Two
Federal
employee
"
models"
were
developed:
(
1)
"
Federal
Model
1"
is
used
for
costing
activities
more
technical
in
nature,
and
(
2)
"
Federal
Model
2"
is
used
for
costing
activities
that
are
more
administrative.
31
"
Federal
Model
1"
­
Technical
Activities:
The
skill
mix
used
for
technical
activities
includes
Managers,
Technical
Staff
(
such
as
scientists,
environmental
protection
specialists,
and
other
such
technical
classifications),
Attorneys,
and
Clerical
Support.
Relative
hours
are
listed
in
whole
hour
increments.
The
development
of
the
cost
per
hour
for
"
Federal
Model
1"
is
as
follows:
32
FIGURE
3.
Federal
Model
1
31
Job
Estimate
of
Estimated
time
Pay
Rate
Classification
Relative
Hours
Per
Hour
(
Based
on
GS­
Level)
Cost/
Hour
Manager
2
0.16
$
76.33
for
GS
15
$
12.22
Technical
8
0.68
64.89
for
GS
14
44.13
Attorney
1
0.08
64.89
for
GS­
14
5.20
Clerical
1
0.08
39.04
for
GS­
07
3.13
_________
_________
__________
12
hours
1.00
hour
$
64.68/
hour
"
Federal
Model
2"
­
Administrative
Activities:
The
skill
mix
used
for
administrative
activities
includes
Managers,
Technical
Staff
(
such
as
scientists,
environmental
protection
specialists,
and
other
such
technical
classifications),
Attorneys,
and
Clerical
Support.
Relative
hours
are
listed
in
whole
hour
increments.
The
development
of
the
cost
per
hour
for
"
Federal
Model
2"
is
as
follows:

FIGURE
4.
Federal
Model
2
Job
Estimate
of
Estimated
Pay
Rate
Classification
Relative
Hours
Time
Per
Hour
(
Based
on
GS­
Level)
Cost/
Hour
Manager
1
0.20
$
76.33
for
GS
15
$
15.27
Technical
1
0.20
64.89
for
GS
14
12.98
Attorney
0
0.00
64.89
for
GS­
14
0.00
Clerical
3
0.60
39.04
for
GS­
07
23.43
__________
_________
__________
5
hours
1.00
hour
$
51.68/
hour
Based
on
EPA's
experience
for
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect,
EPA
estimates
that
the
administrative
costs
have
been
no
more
than
about
2%
of
the
total
estimated
costs
for
the
Federal
government.
Because
this
percentage
is
so
low,
the
Federal
government
costs
in
Exhibit
2A
through
2E
are
all
calculated
at
the
$
65/
hour
rate
for
technical
activities.
The
margin
of
difference
would
be
as
follows:

Amount
for
technical
activities
Amount
for
administrative
activities
For
$
1,000
$
980
$
20
For
$
5,000
$
4,900
$
100
For
$
10,000
$
9,800
$
200
3.
PERM
Model
for
Review
of
Submissions:
For
PERMs,
the
respondent
needs
to
comply
with
the
Final
Rule
at
Section
8.4,
preparation
of
environmental
documents,
generally,
and
Section
8.6,
preliminary
environmental
review.
The
hourly
burden
for
Federal
government
review
of
a
PERM
is
estimated
to
be
25%
of
the
respondent's
time
to
prepare
a
PERM,
or
10
hours,
plus
an
additional
2
hours
for
administrative
activities.
Assessment
and
verification
procedures
are
not
required
at
the
PERM
level
of
activity
and
documentation.
Although
one
33For
purposes
of
demonstrating
the
hourly
burden
for
an
operator
submitting
a
"
Multi­
Year"
IEE,
EPA
assumed
two
operators
would
submit
multi­
year
IEEs
during
the
time
covered
by
this
ICR
renewal.
It
is
possible
that
two
of
the
operators
listed
under
the
"
Revised"
IEE
model
may
submit
"
multi­
year"
rather
than
"
revised"
IEEs.
However,
since
the
intent
of
these
operators
is
unknown,
EPA
assumed
these
two
operators
would
submit
"
revised"
IEEs,
an
assumption
that
provides
the
maximum
hours
and
cost
estimates
for
the
three
year
period
of
this
ICR
renewal
since
the
hours
and
costs
per
operator
are
more
for
a
"
Revised"
IEE
than
for
a
"
Multi­
Year"
IEE.

32
respondent
per
year
is
estimated
for
purposes
of
the
cost
calculations
in
Exhibit
2A,
EPA
anticipates
that
the
actual
number
of
nongovernmental
expeditions
with
activities
that
will
likely
proceed
with
less
than
minor
or
transitory
impacts
may
well
be
reduced
to
less
than
one
respondent
per
year.
In
fact,
only
one
PERM
has
been
submitted
as
the
final
documentation
for
an
expedition
during
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect.

4.
IEE
Model
for
Review
of
Submissions:
For
IEEs,
the
respondent
needs
to
comply
with
the
Final
Rule
at
Section
8.4,
preparation
of
environmental
documents,
generally,
and
Section
8.7,
initial
environmental
evaluation.
Under
the
Final
Rule
(
see
Figure
1),
EPA
assumes
operators
would
submit
IEEs.
Operators
can
choose
to
submit
a
"
Core"
or
"
Revised"
or
a
"
Multi­
Year"
IEE
as
discussed
for
the
respondents
in
Section
6(
a).
Under
the
"
Multi­
Year"
IEE
model,
EPA
assumes
the
operators,
as
applicable,
would
submit
a
"
Revised"
IEE
in
the
initial
year
and,
for
purposes
of
maximum
burden
estimation,
supplemental
information
for
the
subsequent
four
years.
Eight
"
multi­
year"
have
previously
been
submitted
for
17
of
the
anticipated
22
operators.
During
the
following
three
austral
seasons
(
e.
g.,
the
three­
year
life
of
this
ICR
renewal),
these
eight
IEEs
will
be
in
the
"
subsequent"
years
of
their
documentation
requirements.
For
purposes
of
demonstrating
the
full
model
for
a
"
multi­
year"
IEE,
EPA
assumes
two
operators
may
submit
"
multi­
year"
IEEs.
33
EPA
has
developed
a
model
for
Federal
government
review
of
the
three
models
for
IEEs.
A
detailed
discussion
of
the
"
Model
for
Federal
Government
Review
of
IEEs"
is
presented
Section
6(
c).

5.
CEE
Model
for
Review
of
Submissions:
For
CEEs,
the
respondent
needs
to
comply
with
the
Final
Rule
at
Section
8.4,
preparation
of
environmental
documents,
generally,
and
Section
8.8,
comprehensive
environmental
evaluation.
The
hourly
burden
for
Federal
government
review
of
a
CEE
is
estimated
to
be
50%
of
the
respondent's
time
to
prepare
a
CEE,
or
120
hours,
plus
an
additional
15
hours
for
administrative
activities.
The
hourly
burden
for
review
of
assessment
and
verification
information
is
estimated
to
be
50%
of
the
respondent's
time
to
prepare
the
assessment
and
verification
information,
or
30
hours.
Although
one
respondent
per
year
is
estimated
for
purposes
of
the
cost
calculations
in
Exhibit
2C,
EPA
anticipates
that
the
actual
number
of
nongovernmental
expeditions
with
activities
that
will
likely
proceed
with
more
than
minor
or
transitory
impacts
may
well
be
reduced
to
less
than
one
respondent
per
year.
In
fact,
there
were
no
CEEs
submitted
during
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect.

6.
Reviewing
Emergency
Reports:
Reporting
for
Cases
of
Emergency
is
based
on
the
Final
Rule
at
Section
8.10,
Cases
of
Emergency,
which
would
require
operator
notice
and
reporting
for
activities
taken
in
cases
of
emergency
which
would
have
otherwise
required
the
34See
Final
Rule
at
Section
8.10.
Emergency
reporting
would
be
required
for
emergency
activities
which
would
have
otherwise
required
the
preparation
of
a
CEE.
The
estimate
is
based
on
reporting
requirements
only,
not
the
actual
cost
of
the
emergency
response
action.
The
hours
and
cost
estimate
assumes
one
such
emergency
per
10
years.
(
See:
Respondent
Assumption
6.)

35Three
years
are
used
in
these
calculations
because
that
is
the
period
of
time
the
ICR
is
in
effect
before
it
must
be
renewed.

33
preparation
of
a
CEE.
The
estimated
hourly
burden
for
Federal
government
review
of
an
Emergency
Report
is
estimated
to
be
50%
of
the
respondent's
time
to
prepare
a
CEE,
34
or
120
hours,
and
50%
of
the
respondent's
time
to
prepare
the
assessment
and
verification
information
for
an
emergency,
or
30
hours,
for
review
of
this
information.
An
additional
15
hours
are
assumed
for
notifying
the
Parties
and
for
administrative
activities.
As
with
the
respondents,
the
Federal
government
hours
and
cost
estimate
assumes
one
such
emergency
per
10
years.

7.
Capital/
Start
Up
Costs:
The
EPA
does
not
anticipate
any
capital
or
start
up
costs
on
the
part
of
the
Federal
government
to
comply
with
the
provisions
of
the
Final
Rule.

8.
O&
M
Costs:
The
EPA
estimates
the
following
operating
and
maintenance
(
O&
M)
costs
associated
with
the
paperwork
requirements
for
the
Federal
government
to
comply
with
the
provisions
of
the
Final
Rule.
Assumptions
and
calculations
used
in
EPA's
O&
M
estimate
for
the
three
levels
of
environmental
documentation
are
as
follows:

PERMs.
The
assumptions
used
for
the
O&
M
estimates
include:

°
PERMs
are
estimated
to
average
25
pages
including
any
supplemental
information.
°
One
PERM
submitted
per
year
by
one
operator.
In
fact,
during
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect,
only
one
PERM
has
been
submitted
as
the
final
environmental
documentation.
°
Six
copies
of
each
PERM
are
needed
for
Federal
government
reviewers.
°
PERMs
do
not
require
assessment/
verification
procedures.
°
File
storage
and
maintenance
is
estimated
at
$
10
per
PERM.

The
estimated
O&
M
costs
for
a
PERM
are
calculated
as
follows:

(
1)
Copying:
25
pages/
PERM
x
6
copies
x
$
0.10/
page
=
$
15.00
(
2)
File
Storage:
1
PERM
package
x
$
10/
package
=
10.00
Exhibit
2A
incorporates
these
estimated
O&
M
costs
in
the
estimated
Federal
government
hours
and
costs
for
PERMs
for
a
three
year
period.
35
The
O&
M
cost
for
copying
is
doubled
based
on
the
assumption,
for
purposes
of
maximum
cost
calculation,
that
the
initial
submission
will
be
revised
and
resubmitted
for
Federal
government
review.
36Three
years
are
used
in
these
calculations
because
that
is
the
period
of
time
the
ICR
is
in
effect
before
it
must
be
renewed.

34
IEEs.
The
assumptions
used
for
the
O&
M
estimates
include:

°
Figure
2
lists
the
potential
respondents.
°
The
maximum
length
for
an
IEE
is
200
pages
including
supplemental
information.
(
See:
Section
6(
a)).
°
Six
copies
of
each
IEE
are
needed
for
Federal
government
reviewers.
°
Assessment/
verification
(
A/
V)
information
packages,
are
estimated
as
25
pages
per
operator.
°
Six
copies
of
each
A/
V
information
package
is
needed
for
Federal
government
reviewers.
°
File
storage
and
maintenance
is
estimated
at
$
10
including
storage
for
an
IEE
package
and
the
associated
A/
V
information.

The
estimated
O&
M
cost
for
the
three
IEE
models
are
calculated
as
follows:

"
Core"
IEE:
(
1)
Copying:
200
pages/
Core
IEE
x
6
copies/
IEE
x
$
0.10/
page
=
$
120.00
10
pages
Supplemental
Info.
x
6
copies
x
$
0.10/
page
=
6.00
25
pages/
A/
V
information
x
6
copies
x
$
0.10/
page
=
15.00
(
2)
File
Storage:
1
IEE
package
x
$
10/
package
=
10.00
"
Revised"
IEE:
(
1)
Copying:
200
pages/
Revised
IEE
x
6
copies/
IEE
x
$
0.10/
page
=
$
120.00
10
pages
Supplemental
Info.
x
6
copies
x
$
0.10/
page
=
6.00
25
pages/
A/
V
information
x
6
copies
x
$
0.10/
page
=
15.00
(
2)
File
Storage:
1
IEE
package
x
$
10/
package
=
10.00
"
Subsequent
Year,
Multi­
Year"
IEE:
(
1)
10
pages
Supplemental
Info.
x
6
copies
x
$
0.10/
page
=
6.00
25
pages/
A/
V
information
x
6
copies
x
$
0.10/
page
=
15.00
(
2)
File
Storage:
1
IEE
package
x
$
10/
package
=
10.00
Exhibit
2B,
including
Table
2B,
incorporates
these
estimated
O&
M
costs
in
the
estimated
Federal
government
hours
and
costs
for
IEEs
per
year
for
a
following
three­
year
period
based
as
summarized
in
Table
4.36
The
O&
M
costs
for
copying
the
core
and
revised
IEE
submissions
are
doubled
based
on
the
assumption,
for
purposes
of
maximum
cost
calculation,
the
initial
submission
will
be
revised
and
resubmitted
for
Federal
government
review.

Table
4.
Summary
of
the
3­
Year
Average
O&
M
Costs
for
a
PERM,
the
Three
IEE
Models,
and
a
CEE
37Three
years
are
used
in
these
calculations
because
that
is
the
period
of
time
the
ICR
is
in
effect
before
it
must
be
renewed.

35
PERM
"
Core"
IEE
"
Revised"
IEE
"
Subsequent
Year,
Multi­
Year"
IEE
CEE
Copying:
$
30
File
Storage:
$
10
TOTAL
$
40
Copying:
$
261
File
Storage:
$
10
TOTAL
$
271
Copying:
$
261
File
Storage
:
$
10
TOTAL
$
271
Copying:
$
21
File
Storage:
$
10
TOTAL
$
31
Copying:
$
1740
File
Storage:
$
10
FedReg:
$
310
TOTAL
$
2060
CEEs.
The
assumptions
used
for
the
O&
M
estimates
include:

°
A
Federal
Register
Notice
of
Availability
must
be
published
for
receipt
of
each
draft
and
final
CEE;
publication
costs
are
estimated
at
$
155
per
column
and
two
columns
are
assumed
to
be
needed.
°
CEEs
are
estimated
to
average
300
pages
including
any
supplemental
information.
°
One
CEE
submitted
per
year
by
one
operator.
In
fact,
during
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect,
no
CEEs
were
submitted.
°
Six
copies
of
each
CEE
are
needed
for
Federal
government
reviewers.
°
Forty­
five
copies
of
each
CEE
are
needed
for
distribution
to
Parties
and
the
Committee
for
Environmental
Protection.
°
Assessment/
verification
(
A/
V)
information
is
estimated
as
50
pages
per
operator.
°
Six
copies
of
each
A/
V
information
package
is
needed
for
Federal
government
reviewers.
°
File
storage
and
maintenance
is
estimated
at
$
10
including
storage
for
a
CEE
package
and
associated
A/
V
information.
°
Federal
Register
publication
charges
have
been
increased
to
reflect
inflation.

The
estimated
O&
M
costs
for
a
CEE
are
calculated
as
follows:

(
1)
Copying:
300
pages/
CEE
x
6
copies
x
$
0.10/
page
=
$
180.00
300
pages/
CEE
x
45
copies
x
$
0.10/
page
=
1,350.00
50
pages/
A/
V
information
x
6
copies
x
$
0.10/
page
=
30.00
(
2)
FR
Publication:
1
CEE
x
$
145/
column
x
2
columns
=
310.00
(
3)
File
Storage:
1
CEE
package
x
$
10/
package
=
10.00
Exhibit
2C
incorporates
these
estimated
O&
M
costs
in
the
estimated
Federal
government
hours
and
costs
for
CEEs
for
a
three
year
period.
37
The
O&
M
cost
for
copying
is
doubled
based
on
the
assumption,
for
purposes
of
maximum
cost
calculation,
that
the
initial
submittal
will
be
revised
38Three
years
are
used
in
these
calculations
because
that
is
the
period
of
time
the
ICR
is
in
effect
before
it
must
be
renewed.

39Three
years
are
used
in
these
calculations
because
that
is
the
period
of
time
the
ICR
is
in
effect
before
it
must
be
renewed.

36
and
resubmitted
for
Federal
government
review
and
that
both
the
draft
and
final
CEEs
will
also
be
provided
to
the
Parties.

Reporting
for
Cases
of
Emergency.
The
assumptions
used
for
the
O&
M
estimates
include:

°
Emergency
Reports
are
estimated
to
average
300
pages
including
supplemental
information.
°
Six
copies
of
each
report
are
needed
for
Federal
government
reviewers.
°
Forty­
five
copies
of
each
report
are
needed
for
distribution
to
Parties
and
the
Committee
for
Environmental
Protection.
°
Assessment/
verification
(
A/
V)
information
is
estimated
as
50
pages
per
incident.
°
Six
copies
of
each
A/
V
information
package
needed
for
Federal
government
reviewers.
°
The
O&
M
costs
are
first
calculated
to
indicate
the
annual
cost
assuming
one
such
emergency
per
10
years.
°
File
storage
and
maintenance
is
estimated
at
$
10
including
storage
for
the
emergency
report
package
and
associated
A/
V
information.

(
1)
Copying:
300
pages/
report
x
6
copies
x
$
0.10/
page
=
$
180.00
300
pages/
report
x
45
copies
x
$
0.10/
page
=
1,350.00
50
pages/
A/
V
information
x
6
copies
x
$
0.10/
page
=
30.00
(
2)
Store
File:
1
report
package
x
$
10/
package
=
10.00
Exhibit
2D
incorporates
these
estimated
O&
M
costs
in
the
estimated
Federal
government
hours
and
costs
for
emergency
reports
for
a
three
year
period.
38
9.
Coordinating
Review
of
Other
Parties'
Documents:
In
accordance
with
the
Final
Rule
at
Section
8.12,
the
Department
of
State
would
be
responsible
for
the
coordination
of
the
review
of
documents
received
from
other
Parties.
There
is
no
respondent
burden
associated
with
Section
8.12.
Exhibit
2E
provides
the
Federal
government
hourly
burden
and
cost
estimate
based
on
Employee
Model
1
and
the
O&
M
assumptions
and
estimates
below.
It
is
not
possible
to
predict
what
may
be
received
from
another
Party
in
any
given
year,
and
since
there
is
no
respondent
burden
associated
with
Section
8.12,
hours
and
costs
for
a
three
year
period
are
not
provided
beyond
those
estimates
listed
in
Exhibit
2E.
39
The
assumptions
used
for
the
O&
M
estimates
include:
37
°
A
Federal
Register
Notice
of
Availability
must
be
published
for
receipt
of
each
draft
CEE;
publication
costs
are
estimated
at
$
155
per
column
and
two
columns
are
assumed
to
be
needed.
°
Draft
and
Final
CEEs
received
from
other
Parties
are
estimated
to
average
300
pages
including
supplemental
information.
°
Other
documents
(
e.
g.,
description
of
national
procedures,
significant
monitoring
information)
received
from
other
Parties
are
estimated
to
average
50
pages.
°
Annual
lists
of
IEEs
are
estimated
to
average
10
pages.
°
Six
copies
of
each
document
are
needed
for
Federal
government
reviewers
and
four
copies
for
the
public.
°
File
storage
and
maintenance
is
estimated
at
$
10
including
storage
for
the
sum
total
of
any
such
documents
received.

(
1)
Copying:
300
pages/
draft
CEE
x
10
copies
x
$
0.10/
page
=
$
300.00
300
pages/
final
CEE
x
10
copies
x
$
0.10/
page
=
300.00
50
pages/
other
x
10
copies
x
$
0.10/
page
=
50.00
10
pages/
IEE
list
x
10
copies
x
$
0.10/
page
=
10.00
(
2)
FR
Pub:
1
CEE
x
$
155/
column
x
2
columns
=
310.00
(
3)
Store
File:
1
set
of
reports
from
Parties
x
$
10/
set
=
10.00
6(
c)
MODEL
FOR
FEDERAL
GOVERNMENT
REVIEW
OF
IEEs
As
noted
in
the
assumptions
above
for
both
the
respondents
and
the
Federal
government,
EPA
assumes
that
most
environmental
documentation
submitted
under
the
Final
Rule
will
be
IEEs.
Based
on
experience
during
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect,
and
the
assumption
that
operators
will
continue
to
employ
the
paperwork
reduction
provisions
in
the
Final
Rule,
including
the
provision
for
multi­
year
documentation,
EPA
has
developed
a
model
for
Federal
government
review
of
IEEs
based
on
three
types
of
IEE
documentation:
(
1)
"
Core"
IEE,
(
2)
"
Revised"
IEE,
and
(
3)
"
Multi­
Year"
IEE.

The
hourly
estimates
for
activities
associated
with
Environmental
Documentation
in
Exhibit
2B
are
based
on
experience
during
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect
and
the
anticipated
degree
of
consultation
with
other
interested
Federal
agencies.
The
calculations
include
the
estimated
technical
review
time
for
the
three
IEE
models,
the
estimated
technical
hours
per
Federal
review,
and
the
Federal
agencies
participating
in
the
review
process
and
their
relative
level
of
participation.

1.
Estimated
Hours
for
Technical
Review
of
an
IEE:
This
estimate
includes
the
following
assumptions
consistent
with
those
in
the
respondents'
estimated
burden
(
Section
6(
a))
and
consideration
of
the
experience
under
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect:

°
Section
6(
a),
including
Figure
2,
lists
the
potential
respondents.
40For
an
IEE
that
covers
multiple
operators,
the
cost
per
review
per
operator
is
further
reduced;
specific
examples
are
listed
as
a
footnote
for
each
model
calculation.

38
°
The
maximum
length
for
an
IEE
is
about
200
pages
including
supplemental
information.
°
An
IEE
consists
of
"
core"
information
with
supplemental
expedition­
specific
(
e.
g.,
dates,
landing
sites,
number
of
tours,
etc.)
or
other
project­
specific
information
attached
or
referenced.
°
The
core
information
requires
a
"
Core
IEE"
review,
and
certain
of
the
supplemental
information
not
considered
to
be
part
of
the
"
core"
document
(
e.
g.,
supplemental
expedition­
specific
information
for
individual
tour
operators),
requires
a
"
Supplemental
Information"
review.
A
"
Core
IEE"
review
is
estimated
to
be
50%
of
the
respondent's
time
to
prepare
a
"
core"
IEE,
or
80
hours,
and
a
"
Supplemental
Information"
review
is
estimated
to
be
25%
of
the
respondent's
time
to
prepare
the
information,
or
about
1
hour
per
supplemental
package
of
information
not
considered
to
be
part
of
the
"
core"
document.
Review
time
for
supplemental
information
considered
to
be
part
of
the
"
Core
IEE"
and
included
by
reference
is
included
in
the
review
time
for
the
"
Core
IEE."
°
The
time
to
review
a
"
Revised
IEE"
is
estimated
to
be
25%
of
the
respondent's
time
to
prepare
a
"
core"
IEE,
or
40
hours,
and
a
"
Supplemental
Information"
review
to
take
1
hour
per
supplemental
package
of
information
not
considered
to
be
part
of
the
"
revised"
document.
°
Operators
may
employ
the
multi­
year
provision
whereby
multi­
year
IEE
documentation
will
be
submitted.
The
multi­
year
provision
also
allows
operators
to
update
basic
information
and
to
provide
information
on
additional
activities
to
supplement
the
multiyear
environmental
document
without
having
to
revise
and
re­
submit
the
entire
document.
Review
of
the
initial
multi­
year
document
is
assumed
to
be
the
same
as
review
of
a
"
Revised
IEE,"
e.
g.,
40
hours
for
the
"
Revised
IEE"
and,
for
purposes
of
maximum
burden
estimation,
1
hour
for
supplemental
information.
For
the
subsequent
four
years,
the
annual
advance
notice
and
confirmation
that
the
conditions
of
the
multi­
year
document
are
unchanged
is
estimated
to
take
10
hours
per
IEE.
°
The
IEE
level
of
documentation
requires
assessment
and
verification
(
A/
V)
procedures.
The
hourly
burden
for
review
of
A/
V
information
is
estimated
to
be
75%
of
the
respondent's
time
to
prepare
the
A/
V
information,
or
15
hours
per
information
package.
°
For
an
IEE
that
covers
multiple
operators,
the
hours
and
costs
per
operator
for
reviews
are
spread
among
the
total
number
of
operators;
e.
g.,
the
more
operators
under
one
document,
the
lower
the
hours
and
costs
for
each
review
on
a
per
operator
basis.
40
IEE
Model
1
­
"
Core"
IEE:
The
following
estimate
is
based
on
EPA's
experience
for
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect
and
considers
the
paperwork
reduction
options
utilized
by
the
operators.
EPA
anticipates
five
one­
time
"
core"
IEEs
will
be
prepared
for
the
three
austral
summer
seasons
this
ICR
renewal
will
be
in
effect.
The
Federal
government
hourly
burden
for
preparation
of
a
"
Core"
IEE
is
estimated
as
follows:

Review
"
core"
IEE
80
hrs/
IEE
x
5
IEEs
=
400
hours
41If,
for
example,
the
"
Core"
IEEs
cover
six
operators
(
e.
g.,
four
of
the
IEEs
cover
one
operator
each
and
one
of
the
IEEs
covers
2
operators),
the
cost
per
operator
is
reduced
from
96
hours
to
80
hours.

42If
a
new
IEE
is
submitted
by
another
U.
S.­
based
operator,
the
hourly
burden
estimate
for
this
IEE
is
the
same
as
for
an
initially
prepared
"
core"
IEE.

43If,
for
example,
the
"
Revised"
IEEs
cover
four
operators
(
e.
g.,
two
of
the
IEEs
cover
one
operator
each
and
one
of
the
IEEs
covers
2
operators),
the
cost
per
operator
is
reduced
from
56
hours
to
42
hours
per
review
per
operator.

39
Review
supplemental
information
1
hr/
review
x
5
operators
=
5
hours
Review
of
A/
V
information
15
hrs/
A/
V
pkg
x
5
operators
=
75
hours
TOTAL
HOURS
=
480
hours
TOTAL
HOURS
PER
IEE
(
5
IEEs)
=
96
hours
TOTAL
HOURS
PER
OPERATOR
(
5
operators)
=
96
hrs41
IEE
Model
2
­
"
Revised"
IEE:
For
purposes
of
maximum
burden
assessment,
EPA
assumes
that
three
present
ship­
based
tour
operators
will
remain
the
same,
and
that
these
operators
will
continue
to
submit
revised
IEEs
for
the
three
austral
summer
seasons
this
ICR
will
be
in
effect.
Updates
are
likely
to
include
such
items
as
dates
of
expeditions
and
changes
in
landing
locations.
Revisions
could
address
items
such
as
assessment
of
the
potential
impacts,
including
cumulative
impacts,
of
modifications
to
the
planned
activities
and
any
associated
mitigation
measures,
or
a
reassessment
of
overall
impacts
for
the
expedition.
Thus,
for
subsequent
seasons,
EPA
estimates
the
government
review
time
to
be
25%
of
the
respondent's
time
to
prepare
a
"
core"
IEE,
or
40
hours,
and
the
hours
for
review
of
supplemental
information
will
remain
the
same.
42
The
model
for
estimating
respondent
hourly
burden
for
a
"
Revised"
IEE
is
based
on
EPA's
experience
under
the
Rule
and
considers
the
paperwork
reduction
options
employed
by
the
operators.
The
operator
hourly
burden
for
preparation
of
a
"
Revised"
IEE
is
estimated
as
follows:

Review
"
revised"
IEE
40
hrs/
IEE
x
3
IEEs
=
120
hours
Review
supplemental
information
1
hr/
review
x
3
operators
=
3
hours
Review
of
A/
V
information
15
hrs/
A/
V
pkg
x
3
operators
=
45
hours
TOTAL
HOURS
=
168
hours
TOTAL
HOURS
PER
IEE
(
3
IEEs)
=
56
hours
TOTAL
HOURS
PER
OPERATOR
(
3
operators)
=
56
hrs43
Model
3
­
"
Multi­
Year"
IEE:
Under
the
Final
Rule,
operators
may
also
choose
to
submit
multi­
year
IEE
documentation.
Under
this
model,
EPA
assumes
the
operators
will
submit
a
"
Revised"
IEE
in
the
initial
year.
The
multi­
year
provision
then
allows
operators
to
supplement
the
multi­
year
environmental
document
without
having
to
revise
and
re­
submit
the
entire
document
in
order
to
update
basis
information
as
necessary,
and
to
provide
information
on
any
new
activities
or
revisions
to
the
documented
activities.
44For
purposes
of
demonstrating
the
hourly
burden
for
an
operator
submitting
a
"
Multi­
Year"
IEE,
EPA
assumed
two
operators
would
submit
multi­
year
IEEs
during
the
time
covered
by
this
ICR
renewal.
It
is
possible
that
the
two
operators
listed
under
the
"
Revised"
IEE
model
may
submit
"
multi­
year"
rather
than
"
revised"
IEEs.
However,
since
the
intent
of
these
operators
is
unknown,
EPA
assumed
these
two
operators
would
submit
"
revised"
IEEs,
an
assumption
that
provides
the
maximum
hours
and
cost
estimates
for
the
three
year
period
of
this
ICR
renewal
since
the
hours
and
costs
per
operator
are
more
for
a
"
Revised"
IEE
than
for
a
"
Multi­
Year"
IEE.

45If,
for
example,
the
two
"
Multi­
Year"
IEEs
cover
three
operators
(
e.
g.,
one
IEE
covers
one
operator
and
the
other
covers
two
operators),
the
hours
per
operator
is
reduced
from
24
hours
to
16
hours
(
e.
g.,
the
hours
for
review
of
the
annual
supplemental
information
and
A/
V
information)
as
the
initial
review
cost
of
the
"
Revised"
IEE
is
spread
among
the
operators.

46The
number
of
operators
covered
by
the
IAATO
Multi­
Year
IEE
varies
from
year
to
year;
for
purposes
of
this
ICR
renewal,
EPA
estimated
there
would
be
seven
IAATO
members
covered
under
the
IAATO
Multi­
Year
IEE.

40
For
purposes
of
demonstrating
the
full
model
for
a
"
multi­
year"
IEE,
EPA
assumes
two
operators
may
submit
"
multi­
year"
IEEs,
and
the
Federal
government
hourly
burden
for
review
of
the
"
Multi­
Year"
IEE
will
require
review
at
the
"
Revised
IEE"
level
of
review
(
e.
g.,
40
hours)
and
1
hour
for
supplemental
information.
Review
also
includes
15
hours
for
A/
V
information.
In
subsequent
years,
for
purposes
of
maximum
burden
estimation,
2
hours
per
IEE
is
estimated
for
review
of
supplemental
information
and
15
hours
for
A/
V
information.
The
Federal
government
hourly
burden
is
estimated
as
follows
for
review
of
"
Multi­
Year"
IEEs:
44
Initial
Year:
Review
"
Revised"
IEE:
40
hrs/
IEE
x
2
IEEs
x
1
yr
=
80
hours
Review
supplemental
information:
1
hr/
operator
x
2
ops
x
1
year
=
2
hours
Review
A/
V
information:
15
hrs/
operator
x
2
ops
x
1
year
=
30
hours
Four
Subsequent
Years
for
a
Total
of
Five
Consecutive
Years:
Review
supplemental
information:
1
hr/
operator
x
2
ops
x
4
years
=
8
hours
Review
A/
V
information:
15
hrs/
operator
x
2
ops
x
4
years
=
120
hours
TOTAL
HOURS
for
5­
Year
Period
of
"
Multi­
Year"
IEE
=
240
hours
TOTAL
HOURS
PER
YEAR
(
5
Years)
PER
IEE
(
2
IEEs)
=
24
hours
TOTAL
HOURS
PER
YEAR
(
5
Years)
PER
OPERATOR
(
2
operators)
=
24
hours45
Under
the
Final
Rule,
eight
"
multi­
year"
IEEs
have
been
submitted
for
an
estimated
14
of
the
anticipated
22
operators.
46
During
the
three
austral
seasons
covered
by
the
three­
year
life
of
this
ICR
renewal,
these
eight
IEEs
will
be
in
the
"
subsequent"
years
of
their
documentation
requirements.
The
Federal
government
hourly
burden
for
review
of
the
"
subsequent"
years
for
these
eight
"
Multi­
Year"
IEEs
is
estimated
as
follows:

Three
Subsequent
Years
(
life
of
ICR
renewal)
for
the
Current
"
Multi­
Year"
IEEs:
Review
supplemental
information:
1
hrs/
operator
x
14
ops
x
3
years
=
42
hours
Review
A/
V
information:
15
hrs/
operator
x
14
ops
x
3
years
=
630
hours
TOTAL
HOURS
for
3­
Year
Period
of
this
ICR
Renewal
for
"
Multi­
Year"
IEE
=
672
hours
41
TOTAL
HOURS
PER
YEAR
(
3
Years)
PER
IEE
(
8
IEEs)
=
28
hours
TOTAL
HOURS
PER
YEAR
(
3
Years)
PER
OPERATOR
(
14
operators)
=
16
hours
2.
Estimated
Technical
Hours
by
Federal
Agency
for
Review
of
an
IEE:
EPA
has
used
and
would
continue
to
use
a
"
Principal
Reviewer/
Associate
Reviewer"
process
to
review
environmental
documentation
submitted
by
operators.
OFA
would
serve
as
the
Principal
Reviewer.
Associate
Reviewers
may
include
representatives
from
program
offices
within
EPA
and
other
Federal
agencies
with
an
interest
in
Antarctica.
The
interested
Federal
agencies
are
listed
in
Section
5(
a).
Based
on
experience
during
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect
and
the
anticipated
consultation
needs
under
the
Final
Rule,
the
following
calculations
spread
amongst
the
Federal
agencies
the
96
total
hours
per
"
Core"
IEE
review,
the
56
total
hours
per
"
Revised"
IEE
review,
and
the
16
total
hours
per
"
Subsequent
Year,
Multi­
Year"
IEE.

"
Core"
IEEs
"
Revised"
IEEs
"
Subseq.
Yrs,
Multi­
Year"
IEEs
Federal
Agency
Relative
Time/
Hr
x
96
Hrs
Hrs
Relative
Time/
Hr
x
56
Hrs
Hrs
Relative
Time/
Hr
x
16
Hrs
Hrs
EPA
NSF
DOS
Others
0.49
0.35
0.15
0.01
x
96
x
96
x
96
x
96
47
34
14
1
0.50
0.35
0.15
0.00
x
56
x
56
x
56
x
56
28
20
8
0
0.50
0.40
0.10
0.00
x
16
x
16
x
16
x
16
8
6
2
0
Totals
1.00
96
1.00
56
1.00
16
"
Others"
may
include:
USCG,
NOAA,
MMC
and
DOJ
The
model
further
assumes
that
2/
3
of
the
time
for
review
of
each
document
applies
to
the
draft
IEE,
and
1/
3
of
the
time
to
the
final
IEE:

"
Core"
IEEs
"
Revised"
IEE
"
Subsequent
Years,
Multi­
Year"
IEE
Review
Hours
per
Draft
64
37
11
Review
Hours
per
Final
32
19
5
Total
Hours
96
56
16
The
hours
are
then
spread
amongst
the
Federal
agencies
as
follows:
47Exhibit
2E
summarizes
the
Federal
government
hours
and
cost
for
coordinating
review
of
information
received
from
other
Parties
and
is
not
further
summarized
since
it
is
not
possible
to
predict
what
may
be
received
from
another
Party
in
any
given
year,
and
there
is
no
associated
respondent
hours
or
costs.

48Three
years
are
used
in
these
calculations
because
that
is
the
period
of
time
the
ICR
is
in
effect
before
it
must
be
renewed.

42
"
Core"
IEE
"
Revised"
IEE
"
Subseq.
Yrs,
Multi­
Year"
IEE
Draft
Final
Draft
Final
Draft
Final
EPA
NSF
DOS
Others
.49
.35
.15
.01
31
22
10
1
16
11
5
0
.50
.35
.15
.00
18
13
6
0
10
7
2
0
.50
.35
.15
.00
6
4
1
0
3
2
0
0
Totals
64
32
37
19
11
5
In
Exhibits
2A
through
2E
for
the
"
Estimated
Federal
Government
Hours
and
Cost,"
the
total
hours
listed
for
the
Government
hours/
year
are
assumed
to
include
the
spread
of
hours
across
the
Federal
agencies
as
calculated
above.
The
costs
in
Exhibits
2A
through
2E
are
calculated
at
the
$
65/
hour
rate
for
technical
activities
as
discussed
in
Section
6(
b),
item
2.

6(
d)
ESTIMATED
ANNUAL
AGGREGATE
HOURS
AND
COST
Exhibit
3
is
the
summary
of
the
estimated
hours
and
costs
for
respondents
and
the
Federal
government.
This
summary
compiles
the
totals
for
the
respondents
(
Exhibits
1A,
1B
including
Table
1,
1C,
and
1D)
and
Federal
government
(
Exhibits
2A,
2B
including
Table
2,
2C,
and
2D)
for
each
level
of
environmental
documentation.
47
Chart
2
in
Exhibit
3
further
summarizes
for
respondents
and
the
Federal
government
the
hours
and
costs
for
the
most
likely
documentation
scenario
for
the
3­
year
life
of
this
ICR
renewal,
namely,
a
"
Multi­
Year"
IEE
which
includes
for
the
initial
year
a
"
Revised"
IEE
and
"
Subsequent
Year,
Multi
 
Year"
IEE
documentation
for
the
two
subsequent
years.
Exhibit
3
is
annualized
over
a
three
year
period
by
assuming
a
3.5%
escalation
rate
per
year,
the
assumed
Consumer
Price
Index
(
CPI)
escalation
rate.
48
Based
on
the
reporting
by
operators
for
the
seven
austral
summer
seasons
during
the
time
the
Rule
has
been
in
effect
under
an
OMB­
approved
ICR
and
EPA's
understanding
of
the
types
of
nongovernmental
activities
likely
to
continue
to
be
undertaken
by
U.
S.­
based
operators
in
Antarctica,
EPA
anticipates
that
the
most
likely
scenario
during
the
three­
year
renewal
period
this
information
collection
will
be
in
effect
consists
of
the
following:

°
Twenty­
two
operators
will
likely
plan
expeditions
to
Antarctica
and
will
submit
environmental
documentation
including
assessment
and
verification
information.
Seventeen
will
likely
be
repeat
operators
with
annual
expeditions,
and
five
operators
may
submit
new
documentation.
These
five
may
include
new
operators
planning
annual
expeditions
and
operators
of
one­
time
only
expeditions.
43
°
Three
of
the
17
repeat
operators
with
annual
expeditions
will
submit
revised
IEEs.
°
Repeat
operators
with
annual
expeditions
will
likely
submit
supplemental
information
for
multi­
year
IEEs.
However,
for
purposes
of
maximum
burden
estimates,
it
was
assumed
that
six
of
the
17
repeat
operators
would
submit
new
Multi­
Year
IEEs,
including
a
"
Revised"
IEE
in
the
initial
year
and
"
Subsequent
Year,
Multi­
Year"
IEE
documentation
for
the
two
subsequent
years.
The
burden
estimates
further
assume
that
eight
of
the
17
repeat
operators
will
submit
only
"
Subsequent
Year,
Multi­
Year"
IEE
documentation.
°
No
CEEs
have
been
submitted
as
the
final
documentation
during
the
past
seven
austral
seasons
and
only
one
PERM
has
been
submitted
during
this
time­
frame.
No
CEEs
or
PERMs
are
anticipated
during
the
effective
period
for
this
ICR
renewal.
°
There
were
no
emergencies
requiring
emergency
reporting
during
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect,
and
none
are
expected
to
occur
during
the
effective
period
for
this
ICR
renewal.
°
Other
than
receipt
of
the
annual
list
of
IEEs,
there
is
no
way
to
anticipate
receipt
of
environmental
documents
from
the
Parties
on
an
annual
basis
or
during
the
effective
period
for
this
ICR
renewal.
There
is
no
burden
to
the
respondents
associated
with
receipt
of
documents
from
the
Parties.
Therefore,
there
are
no
burden
estimates
associated
with
coordinating
review
of
information
received
from
other
Parties
included
in
the
burden
summary.
°
The
Consumer
Price
Index
(
CPI)
is
estimated
to
be
3.5%
for
the
subsequent
years
and
is
incorporated
into
the
cost
calculations
for
these
years.

Based
on
the
above
assumptions,
Chart
3
in
Exhibit
3
summarizes
the
estimated
hours
and
costs
for
the
respondents
and
the
Federal
government
for
the
3­
year
period
of
this
ICR
renewal.
This
summary
assumes
22
operators
per
year
with
5
new
operators
and
17
repeat
operators
each
year.
For
the
17
repeat
operators,
the
assumptions
are
that
three
will
prepare
"
Revised"
IEEs
and
14
will
prepare
"
Multi­
Year"
IEEs.
For
the
14
"
Multi­
Year"
IEEs,
the
assumptions
are
that
six
will
be
new
"
Multi­
Year"
IEEs
and
eight
operators
will
submit
"
Subsequent
Year,
Multi­
Year"
IEE
documentation.

As
summarized
in
Chart
3,
for
the
estimated
22
operators
submitting
environmental
documentation
under
the
Final
Rule
during
this
ICR
renewal
period,
the
annual
total
hours
for
the
22
operators
is
estimated
to
be
1,548
hours,
and
the
annual
total
hourly
burden
per
operator
is
estimated
to
be
70
hours.
These
annual
totals
reflect
submission
of
different
levels
of
documentation
by
the
22
operators.
The
estimated
annual
average
time
per
respondent
ranges
from
25
to
185
hours
depending
on
the
level
of
environmental
documentation
and
the
paperwork
reduction
provisions
employed
by
the
respondent.

As
summarized
in
Chart
3,
for
the
estimated
22
operators
submitting
environmental
documentation
under
the
Final
Rule
during
this
ICR
renewal
period,
the
annual
total
cost
for
the
22
operators
is
estimated
to
be
$
124,065,
and
the
annual
total
cost
burden
per
operator
is
estimated
to
be
$
5,639.
These
annual
totals
reflect
submission
of
different
levels
of
documentation
by
the
22
operators.
The
estimated
annual
average
per
respondent
ranges
from
44
$
1,990
to
$
14,678
depending
on
the
level
of
environmental
documentation
and
the
paperwork
reduction
provisions
employed
by
the
respondent.

As
summarized
in
Chart
3,
for
the
estimated
22
operators
submitting
environmental
documentation
under
the
Final
Rule
during
this
ICR
renewal
period,
the
annual
total
hours
and
cost
for
the
Federal
government
is
estimated
as
950
hours
and
$
92,230.
The
annual
total
hours
and
cost
per
operator
for
the
Federal
government
is
estimated
as
43
hours
and
$
4,192.
These
annual
totals
reflect
submission
of
different
levels
of
documentation
by
the
22
operators.
The
estimated
annual
average
hours
and
cost
per
respondent
ranges
from
16
hours
and
$
1,093
to
96
hours
and
$
6,757
depending
on
the
level
of
environmental
documentation
and
the
paperwork
reduction
provisions
employed
by
the
respondent.

6(
e)
REASONS
FOR
CHANGE
IN
BURDEN
The
current
inventory
approved
by
the
Office
of
Management
and
Budget
(
OMB)
for
the
annual
reporting
and
recordkeeping
hourly
burden
is
562
hours.
The
total
3­
year
estimated
hourly
burden
of
4,644
hours
for
the
anticipated
22
operators
represents
an
annual
reporting
and
recordkeeping
hourly
burden
of
1,548
hours,
or
70
hours
per
operator
for
this
3­
year
renewal
period.
This
increased
adjustment
to
the
annual
reporting
and
recordkeeping
hourly
burden
is
986
hours.
This
increased
adjustment
is
the
result
of
an
increase
in
the
number
of
respondents
anticipated
during
the
3­
year
renewal
period
and
the
level
of
environmental
documentation
EPA
anticipates
the
operators
will
submit.

The
current
inventory
approved
by
OMB
for
the
annual
reporting
and
recordkeeping
cost
burden
is
$
0.
Respondents
incur
O&
M
costs
for
copying
and
mailing
(
see
Section
6(
a));
there
are
no
capital/
startup
costs.
EPA
previously
included
the
O&
M
costs
in
the
total
respondent
cost
estimates.
For
this
ICR
renewal
period,
these
costs
are
summarized
Exhibit
4
and
EPA's
request
for
renewal
includes
a
request
for
an
increased
adjustment
to
reflect
the
anticipated
total
annual
O&
M
costs.
This
increased
adjustment
is
to
specifically
identify
the
O&
M
costs
and
is
based
on
the
increased
number
of
respondents
anticipated
during
the
3­
year
renewal
period
and
the
level
of
environmental
documentation
EPA
anticipates
the
operators
will
submit.

6(
f)
BURDEN
STATEMENT
Burden
Statement:
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
1,548
hours
annually,
or
70
hours
per
response.
This
hourly
burden
reflects
annual
submission
of
different
levels
of
environmental
documentation
by
an
anticipated
22
respondents
(
e.
g.,
U.
S.­
based
nongovernmental
operators).
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
45
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OECA­
2004­
0026,
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
Ave.,
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)
564­
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.
Once
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
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
OECA­
2004­
0026)
and
OMB
control
number
(
2020­
0007)
in
any
correspondence.
46
Exhibit
1A:
PERMs
­
ESTIMATED
RESPONDENT
HOURS
AND
COST
Respondent
Respondent
Rate
Range
Capitol/
O
&
M
No.
of
Totals
for
Respondent
Rate
Range
ICR
Activity:
PERMs
Hrs/
Yr
$
65/
hour
$
75/
hour
$
100/
hour
Startup
Cost
Cost
Respondents
$
65/
hour
$
75/
hour
$
100/
hour
Environmental
Documentation
1.
Study
the
regulations
2.
Search
reference
sources
for
existing
information
and
compile
information
from
company
records
3.
Prepare
PERM
and
submit
4.
Revise
PERM
in
response
to
EPA's
comments
and
submit
Post­
Expedition
Assessment
&

Verification
1.
Prepare
A/
V
information
and
submit
­
NOT
REQUIRED
FOR
PERMs
40
$
2,600
$
3,000
$
4,000
Env.
Doc.

None
Post­
Exp.
A/
V
None
Env.
Doc.

Copying
$
25
Mailing
54
_____________

$
79
Post­
Exp.
A/
V
Copying
$
0
Mailing
0
____________

$
0
$
79
1
$
2,679
$
3,079
$
4,079
Totals
for
Respondent
Rate
Range
Hours
$
65/
hour
$
75/
hour
$
100/
hour
YEAR
ONE
40
$
2,679
$
3,079
$
4,079
YEAR
TWO
(
3.5%
estimated
CPI
escalation
rate)
40
2,773
3,187
4,222
YEAR
THREE
(
3.5%
estimated
CPI
escalation
rate)
40
2,870
3,298
4,370
TOTAL
ESTIMATED
POTENTIAL
HOURS
and
COST:
120
$
8,322
$
9,564
$
12,671
AVERAGE
EST.
HOURS
and
COST
PER
YEAR
PER
OPERATOR:
40
$
2,774
$
3,188
$
4,224
Assumptions:

1.
Exhibit
1A
represents
the
estimated
hours
and
cost
for
PERMs.
In
fact,
during
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect,
only
one
PERM
was
submitted
as
the
final
documentation
for
an
expedition.

For
purposes
of
estimating
the
potential
maximum
hours
and
cost
associated
with
PERMs
over
the
three­
year
life
of
the
ICR,
the
three­
year
projection
assumes
submission
of
one
PERM
per
year
for
each
of
the
next
three
years.
Although
one
respondent
per
year
is
estimated
for
purposes
of
the
burden
calculations,
EPA
anticipates
that
the
actual
number
of
nongovernmental
expeditions
with
activities
that
will
likely
proceed
with
less
than
minor
or
transitory
impacts
may
well
be
reduced
to
less
than
one
respondent
per
year.

2.
Estimates
for
preparation
of
a
PERM
are
based
on
estimated
time
that
would
be
needed
to
comply
with
the
Final
Rule
at
Section
8.4,
preparation
of
environmental
documents,
generally,
and
Section
8.6,
preliminary
environmental
review.

3.
The
cost
estimates
are
based
on
industry
labor
rates
obtained
during
informal
consultations
with
industry
representatives
and
include
overhead
and
fringe
benefits.
The
three
rates
used
in
the
calculations
represent
the
rates
provided
by
the
industry
representatives.
The
$
75/
hour
intermediate
rate
is
used
for
summary
purposes.
See
Part
D
for
additional
information
on
the
consultations
with
affected
respondents.

4.
Hours
and
cost
associated
with
preparation
of
higher
level
EIA
documentation,
if
necessary,
is
addressed
in
Exhibits
1B
(
IEEs)
and
1C
(
CEEs).
47
Exhibit
1B:
IEEs
­
ESTIMATED
RESPONDENT
HOURS
AND
COST
Respondent
Respondent
Rate
Range
Capitol/
O
&
M
No.
of
Totals
for
Respondent
Rate
Range
ICR
Activity:
IEEs
Hrs/
Yr
$
65/
hour
$
75/
hour
$
100/
hour
Startup
Cost
Cost
Respondents
$
65/
hour
$
75/
hour
$
100/
hour
MODEL
1:
"
Core"
IEE
Environmental
Documentation
1.
Study
the
regulations
2.
Search
reference
sources
for
existing
information
and
compile
information
from
company
records
3.
Prepare
Core
IEE
and
submit
4.
Revise
in
response
to
EPA's
comments
and
submit
Supplemental
Information
1.
Prepare
and
submit
supplemental
information
Post­
Expedition
Assessment
&

Verification
1.
Prepare
A/
V
information
and
submit
185
$
12,025
$
13,875
$
18,500
Env.
Doc.

None
Supp.
Info.

None
Post­
Exp.
A/
V
None
Env.
Doc.

Copying
$
200
Mailing
54
_____________

$
254
Supp.
Info.

Copying
$
5
Mailing
12
____________

$
17
Post­
Exp.
A/
V
Copying
$
13
Mailing
17
____________

$
30
$
301
See
Table
1
$
12,326
$
14,176
$
18,801
Assumptions
for
IEEs:

1.
IEEs
would
need
to
comply
with
the
Final
Rule
at
Section
8.4,
preparation
of
environmental
documents,
generally,
and
Section
8.7,
initial
environmental
evaluation.

2.
A
"
Core"
IEE
and
associated
supplemental
information
comprises
the
IEE
package
for
the
initial
preparation
of
an
IEE
by
an
operator.

3.
A
"
Revised"
IEE
and
associated
supplemental
information
comprises
the
IEE
package
for
a
current
year's
submission
developed
through
revision
of
a
previous
year's
submission.

4.
A
"
Multi­
Year"
IEE
consists
of
a
"
Revised"
IEE
and
the
associated
supplemental
information
in
the
initial
year
and,
for
each
of
the
subsequent
four
years,
an
annual
submission
of
the
advance
notice
and
confirmation
that
the
information
provided
in
the
Multi­
Year
IEE
is
unchanged.

5.
Supplemental
information
for
purposes
of
the
costs
estimated
in
Exhibit
1B
and
Table
1
refers
to
supplemental
information
submitted
regarding
the
specifics
of
the
tours/
expedition
(
e.
g.,
dates,
number
of
tours,
etc.)
rather
than
supplemental
information
of
a
more
technical
nature
that
is
incorporated
into
the
"
Core"
or
"
Revised"
IEE
by
reference.

6.
The
cost
estimates
are
based
on
industry
labor
rates
obtained
during
informal
consultations
with
industry
representatives
and
include
overhead
and
fringe
benefits.
The
three
rates
used
in
the
calculations
represent
the
rates
provided
by
the
industry
representatives.
The
$
75/
hour
intermediate
rate
is
used
for
summary
purposes.
See
Part
D
for
additional
information
on
the
consultations
with
affected
respondents.
48
Respondent
Respondent
Rate
Range
Capitol/
O
&
M
No.
of
Totals
for
Respondent
Rate
Range
ICR
Activity:
IEEs
Hrs/
Yr
$
65/
hour
$
75/
hour
$
100/
hour
Startup
Cost
Cost
Respondents
$
65/
hour
$
75/
hour
$
100/
hour
MODEL
2:
"
Revised"
IEE
Environmental
Documentation
1.
Study
the
regulations
2.
Search
reference
sources
for
existing
information
and
compile
information
from
company
records
3.
Prepare
Revised
IEE
and
submit
4.
Revise
in
response
to
EPA's
comments
and
submit
Supplemental
Information
1.
Prepare
and
submit
supplemental
information
Post­
Expedition
Assessment
&

Verification
1.
Prepare
A/
V
information
and
submit
65
$
4,225
$
4,875
$
6,500
Env.
Doc.

None
Supp.
Info.

None
Post­
Exp.
A/
V
None
Env.
Doc.

Copying
$
200
Mailing
54
_____________

$
254
Supp.
Info.

Copying
$
5
Mailing
12
____________

$
17
Post­
Exp.
A/
V
Copying
$
13
Mailing
17
____________

$
30
$
301
See
Table
1
$
4,526
$
5,176
$
6,801
Respondent
Respondent
Rate
Range
Capitol/
O
&
M
No.
of
Totals
for
Respondent
Rate
Range
ICR
Activity:
IEEs
Hrs/
Yr
$
65/
hour
$
75/
hour
$
100/
hour
Startup
Cost
Cost
Respondents
$
65/
hour
$
75/
hour
$
100/
hour
49
"
Subsequent
Years"
for
Multi­

Year
IEE
under
MODEL
3
Supplemental
Information
1.
Prepare
and
submit
supplemental
information
Post­
Expedition
Assessment
&

Verification
1.
Prepare
A/
V
information
and
submit
25
$
1,625
$
1,875
$
2,500
Supp.
Info.

None
Post­
Exp.
A/
V
None
Supp.
Info.

Copying
$
5
Mailing
12
____________

$
17
Post­
Exp.
A/
V
Copying
$
13
Mailing
17
____________

$
30
$
47
See
Table
1
$
1,672
$
1,922
$
2,547
TABLE
1.
IEEs
­
TOTAL
ESTIMATED
HOURS
AND
COST
FOR
THE
THREE
IEE
MODELS
WITH
3.5%
ESCALATION
RATE
"
Core"
IEE
for
One
Operator
and
One
IEE
Totals
for
Respondent
Rate
Range
Hours
$
65/
hour
$
75/
hour
$
100/
hour
YEAR
ONE
185
$
12,326
$
14,176
$
18,801
YEAR
TWO
(
3.5%
estimated
CPI
escalation
rate)
185
12,757
14,672
19,459
YEAR
THREE
(
3.5%
estimated
CPI
escalation
rate)
185
13,203
15,186
20,140
TOTAL
ESTIMATED
POTENTIAL
HOURS
and
COST:
555
$
38,286
$
44,034
$
58,400
AVERAGE
EST.
HOURS
and
COST
PER
YEAR
PER
OPERATOR:
185
$
12,762
$
14,678
$
19,467
"
Revised"
IEE
for
One
Operator
and
One
IEE
Totals
for
Respondent
Rate
Range
Hours
$
65/
hour
$
75/
hour
$
100/
hour
YEAR
ONE
65
$
4,526
$
5,176
$
6,801
YEAR
TWO
(
3.5%
estimated
CPI
escalation
rate)
65
4,684
5,357
7,039
YEAR
THREE
(
3.5%
estimated
CPI
escalation
rate)
65
4,848
5,544
7,285
TOTAL
ESTIMATED
POTENTIAL
HOURS
and
COST:
195
$
14,058
$
16,077
$
21,125
AVERAGE
EST.
HOURS
and
COST
PER
YEAR
PER
OPERATOR:
65
$
4,686
$
5,359
$
7,042
"
Multi­
Year"
IEE
for
One
Operator
and
One
IEE
­
A
"
Multi­
Year"
IEE
consists
of
a
"
Revised"
IEE
and,
for
each
of
the
subsequent
four
years,
an
annual
submission
of
the
advance
notice
and
confirmation
that
the
information
provided
in
the
Multi­
Year
IEE
is
unchanged.
See
above
for
the
hours
and
cost
per
operator
for
the
"
Revised"
IEE
for
the
initial
year.
The
hours
and
cost
per
operator
for
the
subsequent
years
follows
for
which
hours
and
cost
are
calculated
for
"
Subsequent
Year
Multi­
Year"
IEE
submissions.

"
Subsequent
Year
Multi­
Year"
IEE
for
One
Operator
Totals
for
Respondent
Rate
Range
50
Hours
$
65/
hour
$
75/
hour
$
100/
hour
YEAR
ONE
25
$
1,672
$
1,922
$
2,547
YEAR
TWO
(
3.5%
estimated
CPI
escalation
rate)
25
1,730
1,989
2,636
YEAR
THREE
(
3.5%
estimated
CPI
escalation
rate)
25
1,790
2,059
2,728
TOTAL
ESTIMATED
POTENTIAL
HOURS
and
COST:
75
$
5,192
$
5,970
$
7,911
AVERAGE
EST.
HOURS
and
COST
PER
YEAR
PER
OPERATOR:
25
$
1,731
$
1,990
$
2,637
Average
Estimated
Hours
and
Cost
for
One
Operator
Initiating
and
Continuing
with
a
Multi­
Year
IEE
During
This
ICR
Renewal
Period
"
Revised"
IEE
based
on
$
75/
hour
rate
and
average
cost
65
$
5,359
"
Subsequent
Year
Multi­
Year"
IEE
based
on
$
75/
hour
rate
and
average
cost
for
two
subsequent
years
25hrs
x
2
=
50
$
1,990
x
2
=
$
3,980
TOTAL
ESTIMATED
POTENTIAL
HOURS
and
COST:
115
$
9,339
(
over
3­
year
life
of
this
ICR
Renewal)

AVERAGE
EST.
HOURS
and
COST
PER
YEAR
PER
OPERATOR:
38
$
3,113
(
over
3­
year
life
of
this
ICR
Renewal)
51
Exhibit
1C:
CEEs
­
ESTIMATED
RESPONDENT
HOURS
AND
COST
Respondent
Respondent
Rate
Range
Capitol/
O
&
M
No.
of
Totals
for
Respondent
Rate
Range
ICR
Activity:
CEEs
Hrs/
Yr
$
65/
hour
$
75/
hour
$
100/
hour
Startup
Cost
Cost
Respondents
$
65/
hour
$
75/
hour
$
100/
hour
Environmental
Documentation
1.
Study
the
regulations
2.
Search
reference
sources
for
existing
information
and
compile
information
from
company
records
3.
Prepare
CEE
and
submit
4.
Revise
in
response
to
EPA's
comments
and
submit
Post­
Expedition
Assessment
&

Verification
1.
Prepare
A/
V
information
and
submit
300
$
19,500
$
22,500
$
30,000
Env.
Doc.

None
Post­
Exp.
A/
V
None
Env.
Doc.

Copying
$
300
Mailing
64
___________

$
364
Post­
Exp.
A/
V
Copying
$
25
Mailing
17
____________

$
42
$
406
1
$
19,906
$
22,906
$
30,406
Totals
for
Respondent
Rate
Range
Hours
$
65/
hour
$
75/
hour
$
100/
hour
YEAR
ONE
300
$
19,906
$
22,906
$
30,406
YEAR
TWO
(
3.5%
estimated
CPI
escalation
rate)
300
20,603
23,708
31,470
YEAR
THREE
(
3.5%
estimated
CPI
escalation
rate)
300
21,324
24,538
32,571
TOTAL
ESTIMATED
POTENTIAL
HOURS
and
COST:
900
$
61,833
71,152
94,447
AVERAGE
EST.
HOURS
and
COST
PER
YEAR
PER
OPERATOR:
300
$
20,611
23,717
31,482
Assumptions:

1.
Exhibit
1C
represents
the
estimated
hours
and
cost
for
CEEs.
In
fact,
no
CEEs
were
submitted
during
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect.
For
purposes
of
estimating
the
potential
maximum
hours
and
cost
associated
with
CEEs
over
the
three­
year
life
of
the
ICR,
the
three­
year
projection
assumes
submission
of
one
CEE
per
year
for
each
of
the
next
three
years.
Although
one
respondent
per
year
is
estimated
for
purposes
of
the
cost
calculations,
EPA
anticipates
that
the
actual
number
of
nongovernmental
expeditions
with
activities
that
will
likely
proceed
with
less
than
minor
or
transitory
impacts
may
well
be
reduced
to
less
than
one
respondent
per
year.

2.
Estimates
for
preparation
of
a
CEE
are
based
on
estimated
time
that
would
be
needed
to
comply
with
the
Final
Rule
at
Section
8.4,
preparation
of
environmental
documents,
generally,
and
Section
8.8,
comprehensive
environmental
evaluation.

3.
The
cost
estimates
are
based
on
industry
labor
rates
obtained
during
informal
consultations
with
industry
representatives
and
include
overhead
and
fringe
benefits.
The
three
rates
used
in
the
calculations
represent
the
rates
provided
by
the
industry
representatives.
The
$
75/
hour
intermediate
rate
is
used
for
summary
purposes.
See
Part
D
for
additional
information
on
the
consultations
with
affected
respondents.
52
1D.
REPORTING
FOR
EMERGENCIES
­
ESTIMATED
RESPONDENT
HOURS
AND
COST
Respondent
Respondent
Rate
Range
Capitol/
O
&
M
No.
of
Totals
for
Respondent
Rate
Range
ICR
Activity:
CEEs
Hrs/
Yr
$
65/
hour
$
75/
hour
$
100/
hour
Startup
Cost
Cost
Respondents
$
65/
hour
$
75/
hour
$
100/
hour
Reporting
for
Cases
of
Emergency
1.
Initial
Report
2.
Full
Report
Post­
Emergency
Assessment
&
Verification
1.
Prepare
A/
V
information
and
submit
300
$
19,500
$
22,500
$
30,000
Reporting
None
Post
A/
V
None
Reporting
Copying
$
150
Mailing
32
_____________

$
182
Post
A/
V
Copying
$
25
Mailing
17
_____________

$
42
$
224
1
$
19,724
$
22,724
$
30,224
There
were
no
emergencies
that
required
reporting
during
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect.
An
incident
requiring
emergency
reporting
could
occur
in
the
subsequent
years.
The
following
cost
estimates
are
not
additive,
however,
since
only
one
such
emergency
in
10
years
is
estimated.

Totals
for
Respondent
Rate
Range
Hours
$
65/
hour
$
75/
hour
$
100/
hour
YEAR
ONE
300
$
19,724
$
22,724
$
30,224
YEAR
TWO
(
3.5%
estimated
CPI
escalation
rate)
300
20,414
23,519
31,282
YEAR
THREE
(
3.5%
estimated
CPI
escalation
rate)
300
21,128
24,342
32,377
Assumptions:

1.
Reporting
for
Cases
of
Emergency
is
based
on
the
Final
Rule
at
Section
8.10,
Cases
of
emergency,
which
requires
notice
and
reporting
for
activities
taken
in
cases
of
emergency
which
would
have
otherwise
required
the
preparation
of
a
CEE.
The
estimate
is
based
on
reporting
requirements
only,
not
the
actual
cost
of
the
emergency
response
action.
The
hours
and
cost
estimate
assumes
one
such
emergency
per
10
years.

2.
Only
one
incident
requiring
emergency
reporting
is
estimated
to
occur
over
a
10­
year
period.
In
fact,
there
was
no
emergency
reporting
during
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect.

3.
The
cost
estimates
are
based
on
industry
labor
rates
obtained
during
informal
consultations
with
industry
representatives
and
include
overhead
and
fringe
benefits.
The
three
rates
used
in
the
calculations
represent
the
rates
provided
by
the
industry
representatives.
The
$
75/
hour
intermediate
rate
is
used
for
summary
purposes.
See
Part
D
for
additional
information
on
the
consultations
with
affected
respondents.
53
Exhibit
2A:
PERMs
­
ESTIMATED
FEDERAL
GOVERNMENT
HOURS
AND
COST
Federal
Gov't.
Federal
Gov't.
Capitol/
O
&
M
No.
of
Total
ICR
Activity:
PERM
hours/
year
$
65/
hour
Startup
Cost
Cost
Respondents
Cost/
Year
PERMs
from
U.
S.­
Based
Operators:

1.
Post
PERM
receipt
on
WWW,
provide
copies
to
interested
Federal
agencies
and
public,
if
requested
2.
Review
PERM
and
any
public
comments,
provide
comments
to
and
consult
with
operator
3.
Provide
copies
of
revised/
final
PERM
to
interested
Federal
agencies,

review,
and
notify
operator,
if
necessary
4.
Maintain
file
Post­
Expedition
Assessment
&

Verification
1.
Review
A/
V
information
­

NOT
REQUIRED
FOR
PERMs
12
$
780
PERM
None
Post­
Exp
A/
V
None
PERM
Copying
$
30
FR
Pub.
0
Store
Files
10
_____________

$
40
Post­
Exp
A/
V
None
$
40
1
$
820
Hours
Cost
YEAR
ONE
12
$
820
YEAR
TWO
(
3.5%
estimated
CPI
escalation
rate
on
$
794)
12
849
YEAR
THREE
(
3.5%
estimated
CPI
escalation
rate
on
$
822)
12
879
TOTAL
ESTIMATED
POTENTIAL
BURDEN
and
COST:
36
$
2,548
AVERAGE
EST.
BURDEN
and
COST
PER
YEAR
PER
OPERATOR:
12
$
849
Assumptions:

1.
Exhibit
2A
represents
the
estimated
hours
and
cost
for
PERMs.
In
fact,
during
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect,
only
one
PERM
was
submitted
as
the
final
documentation
for
an
expedition.

For
purposes
of
estimating
the
potential
maximum
hours
and
cost
associated
with
PERMs
over
the
three­
year
life
of
the
ICR,
the
three­
year
projection
assumes
submission
of
one
PERM
per
year
for
each
of
the
next
three
years.
Although
one
respondent
per
year
is
estimated
for
purposes
of
the
cost
calculations,
EPA
anticipates
that
the
actual
number
of
nongovernmental
expeditions
with
activities
that
will
likely
proceed
with
less
than
minor
or
transitory
impacts
may
well
be
reduced
to
less
than
one
respondent
per
year.

2.
Estimates
for
review
of
a
PERM
is
estimated
as
25%
of
the
respondent's
time,
or
10
hours,
to
prepare
a
PERM
that
would
be
in
compliance
with
the
Final
Rule
at
Section
8.4,
preparation
of
environmental
documents,

generally,
and
Section
8.6,
preliminary
environmental
review,
and
two
hours
for
administrative
activities.

3.
Hours
and
cost
associated
with
preparation
of
higher
level
EIA
documentation,
if
necessary,
is
addressed
in
Exhibits
2B
(
IEEs)
and
2C
(
CEEs).
54
4.
Based
on
EPA's
experience
for
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect,
EPA
estimates
that
the
administrative
costs
have
been
no
more
than
about
2%
of
the
total
estimated
costs
for
the
Federal
government.
Because
this
percentage
is
so
low,
the
Federal
government
costs
in
Exhibit
2A
through
2E
are
all
calculated
at
the
$
65/
hour
rate
for
technical
activities.
55
Exhibit
2B:
IEEs
­
ESTIMATED
FEDERAL
GOVERNMENT
HOURS
AND
COST
Federal
Gov't.
Federal
Gov't.
Capitol/
O
&
M
No.
of
Total
ICR
Activity:
IEEs
hours/
year
$
65/
hour
Startup
Cost
Cost
Respondents
Cost/
Year
Environmental
Documentation
MODEL
1:
"
Core"
IEE
1.
Post
IEE
receipt
on
WWW,
provide
copies
to
interested
Federal
agencies
and
public,
if
requested
2.
Review
IEE
and
any
public
comments,
provide
comments
to
and
consult
with
operator
3.
Provide
copies
of
revised/
final
IEE
to
interested
Federal
agencies,
review
,
and
notify
operator,
if
necessary
4.
Maintain
file
Supplemental
Information
1.
Review
supplemental
information
Post­
Expedition
Assessment
&
Verification
1.
Review
A/
V
information
­
Core
IEE
80
1
15
96
$
5,200
$
65
$
975
$
6,240
Core
IEE
None
Supp.
Info.

None
Post­
Exp
A/
V
None
Core
IEE
Copying
$
261
Store
Files
10*

___________

$
271
*
File
storage
includes
Supp.

and
A/
V
Information
Supp.
Info.

Included
above
Post­
Exp
A/
V
Copying
$
15
File
Storage
*
____________

$
15
*
Included
above
$
286
See
Table
2
$
6,526
56
Federal
Gov't.
Federal
Gov't.
Capitol/
O
&
M
No.
of
Total
ICR
Activity:
IEEs
hours/
year
$
65/
hour
Startup
Cost
Cost
Respondents
Cost/
Year
Environmental
Documentation
MODEL
2:
"
Revised"
IEE
1.
Post
IEE
receipt
on
WWW,
provide
copies
to
interested
Federal
agencies
and
public,
if
requested
2.
Review
IEE
and
any
public
comments,
provide
comments
to
and
consult
with
operator
3.
Provide
copies
of
revised/
final
IEE
to
interested
Federal
agencies,
review,
and
notify
operator,
if
necessary
4.
Maintain
file
Supplemental
Information
1.
Review
supplemental
information
Post­
Expedition
Assessment
&
Verification
1.
Review
A/
V
information
­
Revised
IEE
40
1
15
56
$
2,600
$
65
$
975
$
3,640
Revised
IEE
None
Supp.
Info.

None
Post­
Exp
A/
V
None
Revised
IEE
Copying
$
261
Store
Files
10*

___________

$
271
*
File
storage
includes
Supp.

and
A/
V
Information
Supp.
Info.

Included
above
Post­
Exp
A/
V
Copying
$
15
File
Storage
*
____________

$
15
*
Included
above
$
286
See
Table
2
$
3,926
57
Federal
Gov't.
Federal
Gov't.
Capitol/
O
&
M
No.
of
Total
ICR
Activity:
IEEs
hours/
year
$
65/
hour
Startup
Cost
Cost
Respondents
Cost/
Year
Environmental
Documentation
MODEL
3:
"
Multi­
Year"
IEE
Year
1:
"
Revised"
IEE
Years
2
and
3:
"
Subsequent
Years
Multi­
Year"
IEE
1.
Review
supplemental
information
2.
Review
A/
V
information
­
40
1
15
$
3,926
Years
2
and
3
$
65
$
975
________

$
1,040
None
None
Year
1
Copying
$
261
Store
Files
10*

___________

$
271
*
File
storage
includes
Supp.

and
A/
V
Information
Years
2
and
3
Copying
$
15
File
Storage
*
____________

$
15
See
Table
2
See
Table
2
Assumptions:

1.
IEEs
would
need
to
comply
with
the
Final
Rule
at
Section
8.4,
preparation
of
environmental
documents,
generally,
and
Section
8.7,
initial
environmental
evaluation.

2.
A
"
Core"
IEE
and
associated
supplemental
information
comprises
the
IEE
package
for
the
initial
submittal
of
an
IEE
by
an
operator.

3.
A
"
Revised"
IEE
and
associated
supplemental
information
comprises
the
IEE
package
for
a
current
year's
submittal
developed
through
revision
of
a
previous
year's
submittal.

4.
A
"
Multi­
Year"
IEE
consists
of
a
"
Revised"
IEE
and
the
associated
supplemental
information
in
the
initial
year
and,
for
each
of
the
subsequent
four
years,
an
annual
submission
of
the
advance
notice
and
confirmation
that
the
information
provided
in
the
Multi­
Year
IEE
is
unchanged.

5.
Supplemental
information
for
purposes
of
the
costs
estimated
in
Exhibit
2B
and
Table
2
refers
to
supplemental
information
submitted
regarding
the
specifics
of
the
tours/
expedition
(
e.
g.,
dates,
number
of
tours,
etc.)
rather
than
supplemental
information
of
a
more
technical
nature
that
is
incorporated
into
the
"
Core"
or
"
Revised"
IEE
by
reference.
The
one
hour
for
review
of
the
supplemental
information
is
assigned
to
EPA
to
simplify
the
model
and
calculations.
58
______________________________________________________________________________________________________

TABLE
2.
IEEs
­
TOTAL
ESTIMATED
HOURS
AND
COST
FOR
THE
THREE
IEE
MODELS,
3.5%
ESCALATION
RATE
"
Core"
IEE
for
One
Operator
and
One
IEE
­
(
Core
IEE
+
Supplemental
Information
+
A/
V
Information)

HOURS
COST
YEAR
ONE
96
$
6,526
YEAR
TWO
(
3.5%
estimated
CPI
escalation
rate)
96
6,754
YEAR
THREE
(
3.5%
estimated
CPA
escalation
rate)
96
6,990
TOTAL
ESTIMATED
POTENTIAL
HOURS
and
COST:
288
$
20,270
AVERAGE
EST.
HOURS
and
COST
PER
YEAR
PER
OPERATOR
96
$
6,757
"
Revised"
IEE
for
One
Operator
and
One
IEE
­
(
Revised
IEE
+
Supplemental
Information
+
A/
V
Information)

HOURS
COST
YEAR
ONE
56
$
3,926
YEAR
TWO
(
3.5%
estimated
CPI
escalation
rate)
56
4,063
YEAR
THREE
(
3.5%
estimated
CPA
escalation
rate)
56
4,205
TOTAL
ESTIMATED
POTENTIAL
HOURS
and
COST:
168
$
12,194
AVERAGE
EST.
HOURS
and
COST
PER
YEAR
PER
OPERATOR
56
$
4,065
"
Multi­
Year"
IEE
for
One
Operator
and
One
IEE
­
A
"
Multi­
Year"
IEE
consists
of
a
"
Revised"
IEE
and,
for
each
of
the
subsequent
four
years,
an
annual
submission
of
the
advance
notice
and
confirmation
that
the
information
provided
in
the
Multi­
Year
IEE
is
unchanged.
See
above
for
the
hours
and
cost
per
operator
for
the
"
Revised"
IEE
for
the
initial
year.
The
hours
and
cost
per
operator
for
the
subsequent
years
follows
for
which
hours
and
cost
are
calculated
for
"
Subsequent
Year
Multi­
Year"
IEE
submissions.

"
Subsequent
Year
Multi­
Year"
IEE
for
One
Operator
­
(
Supplemental
Information
+
A/
V
Information)

HOURS
COST
YEAR
ONE
16
$
1,055
YEAR
TWO
(
3.5%
estimated
CPI
escalation
rate)
16
1,092
YEAR
THREE
(
3.5%
estimated
CPA
escalation
rate)
16
1,131
TOTAL
ESTIMATED
POTENTIAL
HOURS
and
COST:
48
$
3,278
AVERAGE
EST.
HOURS
and
COST
PER
YEAR
PER
OPERATOR
16
$
1,093
Average
Estimated
Hours
and
Cost
for
One
Operator
Initiating
and
Continuing
with
a
Multi­
Year
IEE
During
This
ICR
Renewal
Period
"
Revised"
IEE
for
One
Operator
and
One
IEE
HOURS
COST
"
Revised"
IEE
56
$
4,065
"
Subsequent
Year
Multi­
Year"
IEE
­
cost
for
2
years
16
hrs
x
2
=
32
$
1,093
x
2
=
2,186
TOTAL
ESTIMATED
POTENTIAL
HOURS
AND
COST:
88
$
6,251
(
over
3­
year
life
of
this
ICR
Renewal)

AVERAGE
EST.
HOURS
and
COST
PER
YEAR
PER
OPERATOR:
29
$
2,084
59
(
over
3­
year
life
of
this
ICR
Renewal)
_________________________________________________________________________________________
60
Exhibit
2C:
CEEs
­
ESTIMATED
FEDERAL
GOVERNMENT
HOURS
AND
COST
Federal
Gov't.
Federal
Gov't.
Capitol/
O
&
M
No.
of
Total
ICR
Activity:
CEE
hours/
year
$
65/
hour
Startup
Cost
Cost
Respondents
Cost/
Year
CEEs
from
U.
S.­
Based
Operators:

1.
Post
CEE
receipt
on
WWW,
provide
copies
to
interested
Federal
agencies
and
public,
if
requested
2.
Prepare/
publish
FR
notices
for
receipt
of
draft
CEE
and
NOA
for
final
CEE;
copy
and
transmit
final
CEE
to
Parties
3.
Review
draft
CEE
and
any
public
comments,

provide
comments
to
and
consult
with
operator
4.
Provide
copies
of
revised/
final
CEE
to
interested
Federal
agencies
and
public,
if
requested,
and
to
Parties,
review,
and
notify
operator,
if
necessary
5.
Maintain
file
Post­
Expedition
Assessment
&
Verification
1.
Review
A/
V
information
­
CEE
135
Post­
Exp
A/
V
30
165
CEE
$
8,775
Post­
Exp
A/
V
$
1,950
$
10,725
CEE
None
Post­
Exp
A/
V
None
CEE
Copying
$
1710
FR
Pub.
310
Store
Files
10*

_____________

$
2030*

*
Includes
CEE
and
A/
V
Information
Post­
Exp
A/
V
Copying
$
30
FR
Pub.
0
Store
Files
*
_____________

$
30
*
Included
above
$
2,060
1
$
12,785
YEAR
ONE
165
$
12,785
YEAR
TWO
(
3.5%
estimated
CPI
escalation
rate
on
$
12,590)
165
$
13,232
YEAR
THREE
(
35%
estimated
CPI
escalation
rate
on
$
13,031)
165
$
13,695
TOTAL
ESTIMATED
POTENTIAL
BURDEN
and
COST:
495
$
39,712
AVERAGE
EST.
BURDEN
and
COST
PER
YEAR
PER
OPERATOR:
165
$
13,237
Assumptions:

1.
Exhibit
2C
represents
the
estimated
hours
and
cost
for
CEEs.
In
fact,
no
CEEs
were
submitted
during
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect.
For
purposes
of
estimating
the
potential
maximum
hours
and
cost
associated
with
CEEs
over
the
three­
year
life
of
the
ICR,
the
three­
year
projection
assumes
submittal
of
one
CEE
per
year
for
each
of
the
next
three
years.
Although
one
respondent
per
year
is
estimated
for
purposes
of
the
cost
calculations,
EPA
anticipates
that
the
actual
number
of
nongovernmental
expeditions
with
activities
that
will
likely
proceed
with
less
than
minor
or
transitory
impacts
may
well
be
reduced
to
less
than
one
respondent
per
year.

2.
Estimates
for
review
of
a
CEE
is
estimated
as
50%
of
the
respondent's
time,
or
120
hours,
to
prepare
a
CEE
that
would
be
in
compliance
with
the
Final
Rule
at
Section
8.4,
preparation
of
environmental
documents,

generally,
and
Section
8.8,
comprehensive
environmental
evaluation,
with
an
additional
15
hours
for
administrative
activities,
and
50%
of
respondent's
time
for
assessment
and
verification
procedures
for
review
of
the
information.

3.
EPA
would
publish
Federal
Register
notices
for
domestic
CEEs,
and
the
Department
of
State
would
publish
the
Federal
Register
notice
and
circulate
copies
of
CEEs
to
all
Parties
and
others
that
may
request
copies.
61
Exhibit
2D:
Reporting
for
Emergencies
­
Estimated
Federal
Government
Hours
and
Cost
Federal
Gov't.
Federal
Gov't.
Capitol/
O
&
M
No.
of
Total
ICR
Activity:
CEE
hours/
year
$
65/
hour
Startup
Cost
Cost
Respondents
Cost/
Year
Reporting
for
Cases
of
Emergency
1.
Notify
Parties
2.
Provide
initial
and
full
report
to
interested
Federal
agencies
and
review
3.
Provide
full
report
to
Parties
4.
Review
A/
V
information
5.
Maintain
files
165
$
10,725
None
Copying
$
1740
FR
Pub.
0
Store
Files
10
_____________

$
1750
1
$
10,660
1,750
________

$
12,475
TOTAL
165
$
12,410
YEAR
ONE
165
$
12,475
YEAR
TWO
(
3.5%
estimated
CPI
escalation
rate
of
$
12,410)
165
12,912
YEAR
THREE
(
3.5%
estimated
CPI
escalation
rate
for
$
12,845)
165
13,364
Assumptions:

1.
Reporting
for
Cases
of
Emergency
is
based
on
the
Final
Rule
at
Section
8.10,
Cases
of
emergency,
which
would
require
notice
and
reporting
for
activities
taken
in
cases
of
emergency
which
would
have
otherwise
required
the
preparation
of
a
CEE.
The
estimate
is
based
on
reporting
requirements
only,
not
the
actual
cost
of
the
emergency
response
action.
The
hours
and
cost
estimate
assumes
one
such
emergency
per
10
years.

2.
Only
one
incident
requiring
emergency
reporting
is
estimated
to
occur
over
a
10­
year
period.
In
fact,
there
was
no
emergency
reporting
during
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect.
An
incident
requiring
emergency
reporting
could
occur
in
the
subsequent
years.
The
cost
estimates
for
reporting
for
cases
of
emergency
are
not
additive
because
only
one
such
emergency
in
10
years
is
estimated.

3.
Estimates
for
review
of
an
Emergency
Report
is
estimated
as
50%
of
the
respondent's
time
to
prepare
the
Emergency
Report
that
would
be
in
compliance
with
the
Final
Rule
at
Section
8.10,
or
120
hours,
and
50%
of
respondent's
time
for
assessment
and
verification
procedures
for
review
of
the
information,
or
30
hours,
with
an
additional
15
hours
for
administrative
activities.

3.
The
Department
of
State
is
responsible
for
notification
of
Parties
and
follow­
up
coordination
with
the
Parties;
hours
have
been
allocated
to
the
DOS
accordingly.
62
Exhibit
2E:
Coordinating
Review
of
Information
Received
from
Other
Parties
­
Estimated
Federal
Government
Hours
and
Cost
Federal
Gov't.
Federal
Gov't.
Capitol/
O
&
M
No.
of
Total
ICR
Activity:
Other
Party
Docs.
hours/
year
$
65/
hour
Startup
Cost
Cost
Respondents
Cost/
Year
Coordinate
Review
of
Information
Received
from
Other
Parties
1.
Prepare
and
publish
FR
notice
of
receipt
of
draft
CEE,
provide
copies
to
interested
Federal
agencies
and
public,
if
requested
2.
Review
draft
CEE
and
provide
inter­
agency
response
to
Party
3.
Provide
copies
of
other
documents
(
including
final
CEEs,
annual
list
of
IEEs,
national
procedures,

significant
monitoring
information)
to
interested
Federal
agencies
and
public,
if
requested
4.
Post
receipt
of
significant
monitoring
information
on
WWW
and
provide
copies
to
interested
Federal
agencies
and
public,
if
requested
5.
Maintain
files
110
$
7,150
None
Copying
$
*

FR
Pub
310
Store
Files
10
____________

$
320
*
Copying
per
document:

Draft
CEE
$
360
Final
CEE
180
Other
doc.
50
IEE
list
10
See:
Assum.
2,

below
See:
Assum.
2,

below
Assumptions:

1.
The
Department
of
State
would
be
responsible
for
compliance
with
the
Final
Rule
at
Section
8.12,
Coordination
of
reviews
from
other
Parties.

2.
The
calculations
in
Exhibit
2E
are
based
on
receipt
of
a
CEE
from
another
Party.
One
Draft
CEE
was
received
from
other
Parties
during
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect
other
than
the
annual
list
of
IEEs.
There
is
no
way
to
anticipate
receipt
of
environmental
documents
from
the
Parties,
other
than
the
annual
list
of
IEEs,
on
an
annual
basis.
There
is
no
burden
or
cost
to
the
respondents
associated
with
receipt
of
documents
from
the
Parties,
therefore,
the
costs
are
not
further
defined.
63
Exhibit
3:
SUMMARY
­
ESTIMATED
RESPONDENT/
FEDERAL
GOVERNMENT
HOURS
AND
COST
CHART
1:
Summary
for
Respondents
and
Federal
Government
­
Estimated
Total
and
Annual
Average
hours
and
cost
for
each
type
of
environmental
document
that
is
submitted
by
a
Respondent
under
the
Final
Rule
PERM
Core
IEE
Revised
IEE
Subsequent
Year
Multi­
Year
IEE
CEE
Emergency
Reporting
Respondent
Year
1
Year
2
Year
3
TOTAL
Annual
Average
40
$
3,079
40
$
3,187
40
$
3,298
120
$
9,564
40
$
3,188
185
$
14,176
185
$
14,672
185
$
15,186
555
$
44,034
185
$
14,678
65
$
5,176
65
$
5,357
65
$
5,544
195
$
16,077
65
$
5,359
25
$
1,922
25
1,989
25
2,059
75
$
5,970
25
$
1,990
300
$
22,906
300
$
23,708
300
$
24,538
900
$
71,152
300
$
23,717
300
$
22,724
300
$
23,519
300
$
24,342
Federal
Government
Year
1
Year
2
Year
3
TOTAL
Annual
Average
12
$
820
12
$
849
12
$
879
36
$
2,548
12
$
849
96
$
6,526
96
$
6,754
96
$
6,990
288
$
20,270
96
$
6,757
56
$
3,926
56
$
4,063
56
$
4,205
168
$
12,194
56
$
4,065
16
$
1,055
16
$
1,092
16
$
1,131
48
$
3,278
16
$
1,093
165
$
12,785
165
$
13,232
165
$
13,695
495
$
39,712
165
$
13,237
165
$
12,475
165
$
12,912
165
$
13,364
TOTAL
Annual
Average
156
$
12,112
52
$
4,037
843
$
64,304
281
$
21,435
363
$
28,271
121
$
9,424
123
$
9,248
41
$
3,083
1395
$
110,864
465
$
36,954
CHART
2:
Summary
for
Respondents
and
Federal
Government
­
Estimated
total
hours
and
costs
for
Multi­
Year
IEE
as
the
anticipated
level
and
type
of
environmental
document
most
respondents
submit
under
the
Final
Rule
for
the
3­
year
ICR
renewal
(
Year
1
=
"
Revised"
IEE,
Years
2
and
3
=
"
Subsequent
Year
Multi­
Year"
IEE)

Multi­
Year
IEE
Total
Hours
3­
Year
Total
Annual
3­
Yr
Average
Total
Cost
3­
Year
Total
Annual
3­
Yr
Average
Respondent
(
for
one
operator)
115
hours
38
hrs
per
op
per
yr
$
9,339
$
3,113
per
operator
per
year
Federal
Government
(
for
one
op.)
88
hours
29
hrs
per
op
per
year
$
6,251
$
2,084
per
op
per
year
TOTALS
­
For
one
operator
203
hours
67
hrs
per
op
per
yr
$
15,590
$
5,197
per
op
per
year
NOTES:
Annual
Average
is
the
average
per
respondent
per
year.
Chart
1
presents
the
maximum
hours
and
cost
for
a
respondent.
Chart
2
presents
the
maximum
hours
and
cost
based
on
the
anticipated
level
and
type
of
environmental
document
a
respondent
would
likely
submit
under
the
Final
Rule.
The
$
75/
hour
intermediate
rate
is
used
for
summary
purposes.
The
hours
and
cost
estimates
for
Emergency
Reporting
assume
one
such
emergency
per
10
years.
64
CHART
3:
Summary
for
Respondents
and
Federal
Government
­
Estimated
hours
and
costs
for
environmental
documentation
for
3­
year
period
of
this
ICR
renewal.

Summary
assumes
22
operators
per
year
with
5
new
operators
and
17
repeat
operators
each
year.
For
the
17
repeat
operators,
the
assumptions
are
that
3
will
prepare
"
Revised"

IEEs
and
14
will
prepare
"
Multi­
Year"
IEEs.
For
the
14
"
Multi­
Year"
IEEs,
the
assumptions
are
that
6
will
be
new
"
Multi­
Year"
IEEs
and
8
operators
will
submit
"
Subsequent
Year,
Multi­
Year"
IEE
documentation.
For
Chart
3,
the
calculations
use
the
"
Annual
Average"
from
Chart
1for
"
Core,"
"
Revised,"
and
"
Subsequent
Year,
Multi­
Year"
IEEs
and
the
hours
and
cost
in
Chart
2
for
the
"
Multi­
Year"
IEE.

Operators:
22
operators
each
year
for
the
3­
year
ICR
renewal
period
Respondent
Burden
Hours
Cost
Federal
Government
Burden
Hours
Cost
5
new
operators
submit
"
Core"
IEEs
each
year
Burden
per
year
Total
3­
year
burden
185
x
5
=
925
$
14,678
x
5
=
$
73,390
925
x
3
=
2,775
$
73,390
x
3
=
$
220,170
96
x
5
=
480
$
6,757
x
5
=
$
33,785
480
x
3
=
1,440
$
33,785
x
3
=
$
101,355
3
of
17
repeat
operators
submit
"
Revised"
IEEs
each
year
Burden
per
year
Total
3­
year
burden
65
x
3
=
195
$
5,359
x
3
=
$
16,077
195
x
3
=
585
$
16,077
x
3
=
$
48,231
56
x
3
=
168
$
4,065
x
3
=
$
12,195
168
x
3
=
504
$
12,195
x
3
=
$
36,585
6
of
17
repeat
operators
submit
new
"
Multi­
Year"
IEEs
Burden
per
year
Total
3­
year
burden
38
x
6
=
228
$
3,113
x
6
=
$
18,678
228
x
3
=
684
$
18,678
x
3
=
$
56,034
29
x
6
=
174
$
6,251
x
6
=
$
37,506
174
x
3
=
522
$
37,506
x
3
=
$
112,518
8
of
17
repeat
operators
submit
"
Subseq.
Yr.,
MY"
IEEs
Burden
per
year
Total
3­
year
burden
25
x
8
=
200
$
1,990
x
8
=
$
15,920
200
x
3
=
600
$
15,920
x
3
=
$
47,760
16
x
8
=
128
$
1,093
x
8
=
$
8,744
128
x
3
=
384
$
8,744
x
3
=
$
26,232
ANNUAL
TOTAL
BURDEN
for
22
operators
ANNUAL
TOTAL
BURDEN
per
operator
TOTAL
3­
YEAR
BURDEN
for
22
operators
TOTAL
3­
YEAR
BURDEN
per
operator
1,548
$
124,065
70
$
5,639
4,644
$
372,195
211
$
16,918
950
$
92,230
43
$
4,192
2,850
$
276,690
130
$
12,577
49New
"
Multi­
Year"
IEE
includes
"
Revised"
IEE
in
the
first
year
and
"
Subsequent
Year,
Multi­
Year"
IEE
in
years
2
and
3.
The
average
cost
for
the
three
year
period
of
the
ICR
renewal
is
used
in
the
calculations
in
Exhibit
4.

For
the
total
three
years:
Respondent
$
301
+
(
2
x
$
47)
=
$
395
Federal
Government
$
271
+
(
2
x
$
31)
=
$
333
Average
for
the
three
years:
Respondent
$
395
÷
3
years
=
$
132/
year
Federal
Government
$
333
÷
3
years
=
$
111/
year
65
EXHIBIT
4:
SUMMARY
FOR
RESPONDENTS
AND
FEDERAL
GOVERNMENT
­
O&
M
COSTS
Estimated
O&
M
costs
for
Respondents
and
the
Federal
Government
and
O&
M
breakout
within
the
total
cost
burden.

Operators:
22
operators
each
year
for
the
3­
year
ICR
renewal
period
Respondent
Burden
O&
M
Cost
O&
M
+
Labor
=
Total
Cost
Federal
Government
Burden
O&
M
Cost
O&
M
+
Labor
=
Total
Cost
5
new
operators
submit
"
Core"
IEEs
each
year
Burden
per
year
Total
3­
year
burden
$
301
x
5
=
$
1,505
$
1,505
+
71,885
=
$
73,390
$
1,505
x
3
=
$
4,515
$
4,515
+
215,655
=
$
220,170
$
271
x
5
=
$
1,355
$
1,355
+
32,430
=
$

33,785
$
1,355
x
3
=
$
4,065
$
4,065
+
97,290
=
$
101,355
3
of
17
repeat
operators
submit
"
Revised"
IEEs
each
year
Burden
per
year
Total
3­
year
burden
$
301
x
3
=
$
903
$
903
+
15,174
=
$

16,077
$
903
x
3
=
$
2,709
$
2,709
+
45,522
=
$
48,231
$
271
x
3
=
$
813
$
813
+
11,382
=
$

12,195
$
813
x
3
=
$
2,439
$
2,439
+
34,146
=
$

36,585
6
of
17
repeat
operators
submit
new
"
Multi­
Year"

IEEs49
Burden
per
year
Total
3­
year
burden
$
132
x
6
=
$
792
$
792
+
17,886
=
$

18,678
$
792
x
3
=
$
2,376
$
2,376
+
53,658
=
$
56,034
$
111
x
6
=
$
666
$
666
+
36,840
=
$

37,506
$
666
x
3
=
$
1,998
$
1,998
+
110,520
=

$
112,518
8
of
17
repeat
operators
submit
"
Subseq.
Yr.,
MY"
IEEs
Burden
per
year
Total
3­
year
burden
$
47
x
8
=
$
376
$
376
+
15,544
=
$

15,920
$
376
x
3
=
$
1,128
$
1,128
+
46,632
=
$
47,760
$
31
x
8
=
$
248
$
248
+
8,496
=
$

8,744
$
248
x
3
=
$
744
$
744
+
25,488
=
$

26,232
66
ANNUAL
TOTAL
BURDEN
for
22
operators
ANNUAL
TOTAL
BURDEN
per
operator
TOTAL
3­
YEAR
BURDEN
for
22
operators
TOTAL
3­
YEAR
BURDEN
per
operator
O&
M
Labor
Total
Cost
$
3,576
+
120,489
=
$
1
2
4
,
0
6
5
$
162
+
5,477
=
$
5,639
$
10,728
+
361,467
=
$
372,195
$
488
+
16,430
=
$
16,918
O&
M
Labor
Total
Cst
$
3,082
+
89,148
=
$

92,230
$
140
+
4,052
=
$

4,192
$
9,246
+
267,444
=
$
276,690
$
420
+
12,157
=
$

12,577
B­
1
PART
B
OF
THE
SUPPORTING
STATEMENT
STATISTICAL
SURVEY
This
collection
of
information
does
not
use
or
is
otherwise
based
on
a
statistical
survey.
50Federal
Register/
Vol.
69,
No.
94/
Friday,
May
14,
2004/
Notices.

Part
C­
1
PART
C
OF
THE
SUPPORTING
STATEMENT
RESPONSE
TO
PUBLIC
COMMENTS
ON
THE
ICR
RENEWAL
The
Office
of
Federal
Activities
(
OFA)
published
a
Federal
Register
Notice
seeking
public
comments
on
the
ICR
renewal
for
the
Agency's
Final
Rule
at
40
CFR
Part
8,
Environmental
Impact
Assessment
of
Nongovernmental
Activities
in
Antarctica
(
40
CFR
Part
8).
50
OFA
received
two
comments
online
through
the
EPA
Docket
ID
number
OECA­
2004­
0026.
No
comments
were
received
by
mail
or
telephone.
The
two
online
comments
(
Document
ID
OECA­
2004­
0026­
0005
and
Document
ID
OECA­
2004­
0026­
0006),
submitted
on
July
2,
2004,
were
submitted
by
Barbara
Sachau
and
are
duplicates
in
content.
Copies
from
the
EPA
Docket
of
these
online
comments
are
attached
at
the
end
of
Part
C.
OFA
offers
the
following
response
to
the
commentor.

Comment
Title:
"
No
More
Human
Impact
On
Antarctica":
The
commentor
believes
"...
it
is
time
to
get
some
strict
regulations
on
human
activity
..."
and
that
"...
the
people
presently
regulating
there
now
are
not
doing
an
adequate
job
of
protecting
this
environment
and
its
birds
and
wildlife."
The
commentor
also
protests
"...
the
flights
that
are
being
forced
to
go
into
this
land
...",
that
"[
i]
t
is
time
to
make
sure
we
only
have
healthy
people
there
so
that
these
dangerous
trips
stop
...",
and
that
"...
stunt
people
who
want
to
go
to
Antarctica
to
do
their
stunts
should
be
turned
away."

Response
to
Comment:
The
Environmental
Protection
Agency
(
EPA)
solicited
comments
on
the
proposed
continuation
of
the
Information
Collection
Request
(
ICR)
for
its
regulations
at
40
CFR
Part
8
in
compliance
with
the
Paperwork
Reduction
Act
(
44
U.
S.
C.
3501
et
seq.).
The
EPA
solicited
comments
to:
(
i)
Evaluate
whether
the
proposed
collection
of
information
is
necessary
for
the
proper
performance
of
the
functions
of
the
Agency,
including
whether
the
information
will
have
practical
utility;
(
ii)
Evaluate
the
accuracy
of
the
Agency's
estimate
of
the
burden
of
the
proposed
collection
of
information,
including
the
validity
of
the
methodology
and
assumptions
used;
(
iii)
Enhance
the
quality,
utility,
and
clarity
of
the
information
collected;
and
(
iv)
Minimize
the
burden
of
the
collection
of
information
on
those
who
are
to
respond,
including
through
the
use
of
appropriate
automated
electronic,
mechanical,
or
other
technological
collection
techniques
or
other
forms
of
information
technology,
e.
g.,
permitting
electronic
submission
of
responses.

The
commentor
did
not
comment
on
any
of
these
four
items.

The
comments
offered
focus
on
the
need
for
stricter
regulations
including
not
allowing
certain
types
of
activities
to
be
undertaken
in
Antarctica.
Although
beyond
the
scope
of
this
solicitation
of
comments
and
requirement
to
respond,
OFA
responds
that
EPA's
regulations
were
promulgated
pursuant
to
the
Antarctic
Science,
Tourism,
and
Conservation
Act
of
1996
(
Act),
16
U.
S.
C.
2401
et
seq.,
as
amended,
16
U.
S.
C.
2403a,
which
implements
the
Protocol
on
Environmental
Protection
(
Protocol)
to
the
Antarctic
Treaty
of
1959
(
Treaty).
In
accordance
with
the
requirements
of
the
Protocol,
the
regulations
provide
for
assessment
of
the
environmental
impacts
of
nongovernmental
activities
in
Antarctica,
including
tourism,
for
which
the
United
States
is
required
to
give
advance
notice
under
Paragraph
5
of
Article
VII
of
the
Treaty.
Neither
Article
8
and
Annex
I
of
the
Protocol
nor
EPA's
regulations
prohibit
any
specific
activities
(
nor
does
EPA
force
any
flights
to
go
to
Antarctica).
The
regulations
do
provide
nongovernmental
operators
with
the
specific
requirements
they
need
to
meet
in
order
to
comply
with
the
requirements
of
Article
8
and
Annex
I
to
the
Protocol
and
are
intended
to
ensure
that
potential
environmental
effects
of
nongovernmental
activities
undertaken
in
Antarctica
are
appropriately
identified
and
considered
by
the
operator
during
the
planning
process
and
that
to
the
extent
Part
C­
2
practicable,
appropriate
environmental
safeguards
which
would
mitigate
or
prevent
adverse
impacts
on
the
Antarctic
environment
are
identified
by
the
operator.
EPA
then
assumes
the
operator
will
undertake
these
mitigation
measures.
Otherwise,
the
documentation
may
not
have
met
the
requirements
of
Article
8
and
Annex
I
of
the
Protocol
and
the
provisions
of
EPA's
regulations.
EPA's
regulations
state
that
it
is
unlawful
for
any
operator
to
violate
the
regulations.
An
operator
who
violates
any
of
the
regulations
will
be
subject
to
enforcement
proceedings,
which
may
include
civil
and
criminal
enforcement
proceedings,
and
penalties
pursuant
to
the
Antarctic
Conservation
Act.
Part
C­
3
Reproduced
from
EPA
Docket
ID
Number:
OECA­
2004­
0026
Document
ID:
OECA­
2004­
0026­
0005
Title:
Comment
entitled
"
No
More
Human
Impact
on
Antarctica"
submitted
by
Barbara
Sachau
Description:
Type:
Public
Comment
Phase:
Notice
Company/
Group/
Association
Name:
Author
Date:
07­
02­
2004
Effective
Date:
Comment:

IT
IS
DISGUSTING
THE
HUMAN
SLOBS
THAT
SEEM
TO
BE
GOING
TO
ANTARCTICAWITH
THEIR
HUMAN
GARBAGE
AND
POLLUTION.
IT
IS
TIME
TO
GET
SOME
STRICT
REGULATIONS
ON
HUMAN
ACTIVITY,
WHICH
THREATENS
TO
OVERWHELM
THIS
DELICATE
LAND,
WHICH
SHOULD
BE
SAVED
FOR
OUR
CHILDREN
AND
GRANDCHILDREN.
IT
IS
CLEAR
THAT
THE
PEOPLE
PRESENTLY
REGULATING
THERE
NOW
ARE
NOT
DOING
AN
ADEQUATE
JOB
OF
PROTECTING
THIS
ENVIRONMENT
AND
ITS
BIRDS
AND
WILDLIFE.
GET
THE
HUMAN
SLOBS/
PREDATORS
OUT
OF
THIS
LAND.
IT
IS
A
TRESURE
WHICH
DESERVES
PROTECTION.
I
ALSO
VERY
MUCH
PROTEST
THE
FLIGHTS
THAT
ARE
BEING
FORCED
TO
GO
INTO
THIS
LAND
AT
TIMES
WHEN
WE
KNOW
THEY
SHOULD
not
BE
FLYING
THERE.
IT
IS
TIME
TO
MAKE
SURE
WE
ONLYHAVE
HEALTHY
PEOPLE
THERE
SO
THAT
THESE
DANGEROUS
TRIPS
STOP.
I
ALSO
THINK
THE
STUNT
PEOPLE
WHO
WANT
TO
GO
TO
ANTARCTICA
TO
DO
THEIR
STUNTS
SHOULD
BE
TURNED
AWAY.
ANTARCTICA
DOES
NOT
NEED
ANYMORE
STUNTS.
THE
FIRST
KITE
FLYER
TO
GO
ACROSS
ANTARCITCA
­
THAT
KIND
OF
THING
SHOULD
BE
STOPPED.

Media:
ELECTRONIC
FILE
Page
Count:
1
Part
C­
4
Reproduced
from
EPA
Docket
ID
Number:
OECA­
2004­
0026
Document
ID:
OECA­
2004­
0026­
0006
Title:
Comment
entitled
"
No
More
Human
Impact
on
Antarctica"
submitted
by
Barbara
Sachau
Description:
Duplicate
Comment
see
­
OECA­
2004­
0026­
0005
Type:
Public
Comment
Phase:
Notice
Company/
Group/
Association
Name:
Author
Date:
07­
02­
2004
Effective
Date:
Comment:

IT
IS
DISGUSTING
THE
HUMAN
SLOBS
THAT
SEEM
TO
BE
GOING
TO
ANTARCTICAWITH
THEIR
HUMAN
GARBAGE
AND
POLLUTION.
IT
IS
TIME
TO
GET
SOME
STRICT
REGULATIONS
ON
HUMAN
ACTIVITY,
WHICH
THREATENS
TO
OVERWHELM
THIS
DELICATE
LAND,
WHICH
SHOULD
BE
SAVED
FOR
OUR
CHILDREN
AND
GRANDCHILDREN.
IT
IS
CLEAR
THAT
THE
PEOPLE
PRESENTLY
REGULATING
THERE
NOW
ARE
NOT
DOING
AN
ADEQUATE
JOB
OF
PROTECTING
THIS
ENVIRONMENT
AND
ITS
BIRDS
AND
WILDLIFE.
GET
THE
HUMAN
SLOBS/
PREDATORS
OUT
OF
THIS
LAND.
IT
IS
A
TRESURE
WHICH
DESERVES
PROTECTION.
I
ALSO
VERY
MUCH
PROTEST
THE
FLIGHTS
THAT
ARE
BEING
FORCED
TO
GO
INTO
THIS
LAND
AT
TIMES
WHEN
WE
KNOW
THEY
SHOULD
not
BE
FLYING
THERE.
IT
IS
TIME
TO
MAKE
SURE
WE
ONLYHAVE
HEALTHY
PEOPLE
THERE
SO
THAT
THESE
DANGEROUS
TRIPS
STOP.
I
ALSO
THINK
THE
STUNT
PEOPLE
WHO
WANT
TO
GO
TO
ANTARCTICA
TO
DO
THEIR
STUNTS
SHOULD
BE
TURNED
AWAY.
ANTARCTICA
DOES
NOT
NEED
ANYMORE
STUNTS.
THE
FIRST
KITE
FLYER
TO
GO
ACROSS
ANTARCITCA
­
THAT
KIND
OF
THING
SHOULD
BE
STOPPED.

Media:
ELECTRONIC
FILE
Page
Count:
1
51EPA
routinely
consults
with
the
Department
of
State
(
DOS)
and
the
National
Science
Foundation
(
NSF).
EPA
may
consult
with
other
agencies
when
appropriate
for
specific
activities.
These
may
include:
U.
S.
Coast
Guard
(
USCG),
Marine
Mammal
Commission
(
MMC),
National
Oceanic
and
Atmospheric
Administration
(
NOAA,
including
National
Marine
Fisheries
Service),
and
the
Department
of
Justice
(
DOJ).

Part
D­
1
PART
D
OF
THE
SUPPORTING
STATEMENT
SUMMARY
OF
CONSULTATIONS
WITH
INTERESTED
AGENCIES
AND
AFFECTED
RESPONDENTS
Summary
of
Consultations
with
Interested
Agencies
As
stated
in
Section
5(
a)
of
the
Supporting
Statement,
EPA
consults
with
the
Department
of
State,
the
National
Science
Foundation,
and
other
interested
Federal
agencies51
for
activities
associated
with
the
Final
Rule.
This
enables
appropriate
government
agencies
with
specific
Antarctic
interests
and
expertise
to
be
involved
with
the
review
of
the
environmental
documentation
for
proposed
nongovernmental
expeditions
including
coordination
of
appropriate
information
relative
to
the
U.
S.
Antarctic
Program.
Further,
violation
of
the
provisions
of
the
Final
Rule
could
result
in
enforcement
and
penalties
pursuant
to
the
Antarctic
Conservation
Act,
as
amended,
as
undertaken
by
the
National
Science
Foundation
and/
or
the
Department
of
Justice.
Finally,
the
Department
of
State
has
specific
responsibilities
under
the
Final
Rule,
Section
8.12,
Coordination
of
reviews
from
other
Parties,
and
for
circulating
a
CEE
that
is
prepared
in
accordance
with
the
Final
Rule
at
Section
8.8,
along
with
any
decisions
by
the
operator
relating
thereto,
to
all
Parties.

U.
S.
Department
of
State:

EPA's
regulations
at
40
CFR
Part
8,
state
that
EPA,
in
consultation
with
other
interested
Federal
agencies,
will
carry
out
a
review
of
the
environmental
documentation
submitted
by
an
operator
(
e.
g.,
respondent)
to
determine
if
the
submitted
document
meets
the
requirements
of
Article
8
and
Annex
I
of
the
Protocol
and
the
provisions
of
the
Final
Rule.
(
Also
see:
Section
1(
b)
of
the
Supporting
Statement.)
As
stated
in
Section
3(
a)
of
the
Supporting
Statement,
the
information
that
is
requested
from
respondents
under
this
ICR
is
required
by
statute
and
is
not
available
from
other
sources.
Operators
provide
an
advance
notice
to
the
U.
S.
Department
of
State.
This
information
is
similar
to
the
basic
information
requirements
for
preparation
of
environmental
documentation
under
the
Final
Rule.
Operators
can
include
a
copy
of
the
advance
notice
as
part
of
their
environmental
document.
Alternately,
under
the
paperwork
reduction
provisions
of
the
Final
Rule,
operators
could
choose
to
incorporate
the
advance
notice
by
referring
to
it
since
it
is
reasonably
available
to
EPA.
Practice
has
been
that
the
operators
have
included
a
copy
in
their
environmental
assessment
documentation.
If
submitted
by
the
operator
or
provided
by
the
Department
of
State,
EPA
reviews
the
advance
notification
in
coordination
with
the
State
Department
and
other
interested
Federal
agencies
as
part
of
its
review
of
the
operator's
environmental
document.

As
stated
in
Section
1(
b)
of
the
Supporting
Statement,
in
cases
of
emergency
relating
to
the
safety
of
human
life
or
of
ships,
aircraft,
equipment
and
facilities
of
high
value,
or
the
protection
of
the
environment
which
would
require
an
activity
to
be
undertaken
without
completion
of
the
documentation
procedures
set
out
in
the
Final
Rule,
the
operator
would
need
to
notify
the
Department
of
State
within
15
days
of
any
activities
which
would
have
otherwise
required
preparation
of
a
CEE,
and
provide
a
full
explanation
of
the
activities
carried
out
within
45
days
of
those
activities.
(
See:
40
CFR
8.10,
Cases
of
emergency.)

As
stated
in
Section
1(
b)
of
the
Supporting
Statement,
the
Final
Rule
also
provides
for
the
coordination
of
review
of
information
received
from
other
Parties
and
the
public
availability
of
that
information
including:
(
1)
Part
D­
2
a
description
of
national
procedures
for
considering
the
environmental
impacts
of
proposed
activities;
(
2)
an
annual
list
of
any
IEEs
and
any
decisions
taken
in
consequence
thereof;
(
3)
significant
information
obtained
and
any
action
taken
in
consequence
thereof
with
regard
to
monitoring
from
IEEs
and
CEEs;
and
(
4)
information
in
a
final
CEE.
This
provision
fulfills
the
United
States'
obligation
to
meet
the
requirements
of
Article
6
of
Annex
I
to
the
Protocol.
The
Department
of
State
is
responsible
for
coordination
of
these
reviews
of
drafts
with
interested
Federal
agencies,
and
for
public
availability
of
documents
and
information.
This
portion
of
the
Final
Rule
does
not
impose
paperwork
requirements
on
any
nongovernmental
person
subject
to
U.
S.
regulation.
(
See:
40
CFR
8.12,
Coordination
of
reviews
from
other
Parties.)
The
Department
of
State
is
also
responsible
for
circulating
a
CEE
that
is
prepared
by
a
U.
S.
operator
in
accordance
with
40
CFR
8.8,
along
with
any
decisions
by
the
operator,
to
all
Parties.

The
Department
of
State
was
a
member
of
EPA's
Regulation
Development
Workgroups
for
both
the
Interim
Final
and
Final
Rules
and
agreed
to
the
requirements
stated
in
40
CFR
8.8,
40
CFR
8.10
and
40
CFR
8.12.
The
Department
of
State
continues
to
fulfill
these
responsibilities.
EPA
also
continues
to
consult
with
the
Department
of
State
in
carrying
out
reviews
of
operators'
environmental
document
submissions.
As
part
of
the
ICR
renewal
process,
OFA
informally
consulted
with
Mr.
Fabio
Saturni,
Department
of
State,
and
reconfirmed
these
responsibilities
and
consultation
interests,
and
the
model
used
for
determining
the
Federal
Government's
hour
and
cost
burdens.

Contact:
Mr.
Fabio
Saturni
U.
S.
Department
of
State
Office
of
Oceans
Affairs,
Room
5805
HST
2201
C
Street,
NW
Washington,
DC
20520
Telephone:
202/
647­
0237
National
Science
Foundation:

EPA's
regulations
at
40
CFR
Part
8,
state
that
EPA,
in
consultation
with
other
interested
Federal
agencies,
will
carry
out
a
review
of
the
environmental
documentation
submitted
by
an
operator
(
e.
g.,
respondent)
to
determine
if
the
submitted
document
meets
the
requirements
of
Article
8
and
Annex
I
of
the
Protocol
and
the
provisions
of
the
Final
Rule.
(
Also
see:
Section
1(
b)
of
the
Supporting
Statement.)
The
National
Science
Foundation
(
NSF)
manages
the
U.
S.
Government's
Antarctic
Program.
EPA's
consultations
with
NSF
include
issues
of
technical
expertise
and
assurance
that
similar
procedures
are
being
used
for
assessing
both
governmental
and
nongovernmental
activities
in
Antarctica.
Consistent
with
this
approach,
EPA's
regulations
generally
establish
procedures
for
assessing
the
impacts
of
nongovernmental
activities
in
Antarctica
similar
to
those
used
for
governmental
activities
under
the
National
Science
Foundation
regulations.
(
See:
Preamble
to
EPA's
Final
Rule,
III.
D.
2.)

Operators
may
be
required
to
have
a
permit
for
management
of
certain
materials
and/
or
for
certain
activities
undertaken
in
Antarctica.
These
permits
are
issued
by
the
National
Science
Foundation
independent
of
EPA's
regulations.
When
a
permit
is
required,
the
operator
usually
states
in
the
environmental
document
for
the
expedition
that
a
permit
has
been
applied
for
or
received.
Receipt
of
the
permit
is
considered
by
EPA
to
provide
for
the
mitigation
measures
for
the
activities
described
in
the
operator's
environmental
document
that
are
subject
to
the
permit.
EPA
reviews
permit
applications
in
coordination
with
the
National
Science
Foundation
and
other
interested
Federal
agencies
as
part
of
its
review
of
an
operator's
environmental
document.
Independent
of
the
environmental
document,
EPA
may
also
submit
comments
to
NSF
on
the
permit
application.
Part
D­
3
As
stated
in
Sections
1(
b)
and
4(
b)
of
the
Supporting
Statement,
the
Protocol
and
the
Final
Rule
require
an
operator
to
employ
procedures
to
assess
and
provide
a
regular
and
verifiable
record
of
the
actual
impacts
of
an
activity
which
proceeds
on
the
basis
of
an
IEE
or
CEE.
Should
an
activity
require
a
CEE,
the
operator
should
consult
with
EPA
to:
(
a)
identify
the
monitoring
regime
appropriate
to
that
activity,
and
(
b)
determine
whether
and
how
the
operator
might
utilize
relevant
monitoring
data
collected
by
the
U.
S.
Antarctic
Program.
For
activities
that
require
a
CEE,
OFA
would
consult
with
the
National
Science
Foundation
and
other
interested
Federal
agencies
regarding
the
monitoring
regime
that
would
be
appropriate
to
the
activity
proposed,
and
with
regard
to
possible
utilization
of
relevant
monitoring
data
collected
by
the
U.
S.
Antarctic
Program.

As
stated
in
Section
2(
b)
of
the
Supporting
Statement,
40
CFR
8.9(
b)
requires
that
operators
have
"
procedures
designed
to
provide
a
regular
and
verifiable
record
of
the
impacts
of
these
activities."
For
activities
requiring
an
IEE,
an
operator
should
be
able
to
use
procedures
that
are
voluntarily
utilized
by
operators
to
provide
the
required
information.
The
operators
currently
provide
post­
visit
reports
to
Antarctic
Treaty
Parties.
Currently,
the
National
Science
Foundation
receives
the
information
voluntarily
submitted
by
the
tour
operators
and,
in
cooperation
with
the
International
Association
of
Antarctica
Tour
Operators
(
IAATO),
uses
the
information
to
prepare
annual
summary
reports.
EPA
assumes
this
voluntary
process
of
post­
visit
reporting
will
continue.

As
stated
in
Section
3(
a)
of
the
Supporting
Statement,
most
Antarctica
tour
operators
currently
provide,
on
an
informal
basis,
information
to
the
National
Science
Foundation.
Prior
to
each
Antarctic
season,
such
information
may
include
ship
schedules
and
contact
information,
and
following
the
season,
the
post­
trip
reports
noted
above.

As
stated
in
Section
5(
a)
of
the
Supporting
Statement,
violation
of
the
provisions
of
40
CFR
Part
8
could
result
in
enforcement
and
penalties
pursuant
to
the
Antarctic
Conservation
Act,
as
amended,
as
undertaken
by
the
National
Science
Foundation
and/
or
the
Department
of
Justice.
EPA
would
consult
with,
and
may
make
a
referral
to,
NSF
if
an
alleged
violation
of
the
regulations
occurred.

The
National
Science
Foundation
was
a
member
of
EPA's
Regulation
Development
Workgroups
for
both
the
Interim
Final
and
Final
Rules
and
agreed
to
the
consultation
and
enforcement
requirements
stated
in
the
regulations.
The
National
Science
Foundation
continues
to
fulfill
these
responsibilities
including
consultation
during
reviews
of
operators'
environmental
documents.
As
part
of
the
ICR
renewal
process,
OFA
informally
consulted
with
Dr.
Polly
Penhale,
National
Science
Foundation,
and
reconfirmed
these
responsibilities
and
consultation
interests,
and
the
model
used
for
determining
the
Federal
Government's
hour
and
cost
burdens.

Contact:
Dr.
Polly
Penhale
National
Science
Foundation
Office
of
Polar
Programs
4201
Wilson
Boulevard
Arlington,
VA
22230
Telephone:
703/
292­
7420
Summary
of
Consultations
with
Affected
Respondents
As
part
of
the
ICR
renewal
process,
OFA
informally
consulted
seven
of
the
operators
(
e.
g.,
respondents)
that
operate
annually
in
Antarctica
in
order
to
gather
feedback
on
the
models
used
in
the
Supporting
Statement
and
the
hour
and
cost
burden
estimates.
Based
on
EPA's
experience
during
the
seven
austral
summer
seasons
the
Rule
has
been
in
effect,
respondents
operating
annually
have
included
one
privately
funded
researcher,
two
land­
52To
date,
only
one
one­
time
only
operator
submitted
a
PERM
and
no
CEEs
have
been
submitted.
Most
operators
with
annual
expeditions
have
submitted,
or
are
in
the
process
of
submitting,
a
multi­
year
IEE.

Part
D­
4
based
(
e.
g.,
continental)
operators,
and
the
remainder
have
been
ship­
based
tour
operators
with
expeditions
in
the
Ross
Sea
and/
or
the
Peninsula
Area.
Feedback
was
sought
from
a
cross­
section
of
these
respondents.

OFA
explained
to
each
operator
that
the
purpose
of
the
informal
consultation
was
to
seek
operator
input
regarding
the
document
models
in
the
ICR
Supporting
Statement
and
the
hour
and
cost
burden
estimates.
In
all
cases,
it
was
explained
that
the
Supporting
Statement
addresses
all
three
levels
of
environmental
documentation
(
e.
g.,
PERM,
IEE
and
CEE).
All
agreed
that
the
IEE
should
be
the
focus
of
the
discussion
since
this
is
the
level
of
documentation
operators
usually
submit.
52
OFA
explained
the
three
IEE
models
developed
for
the
burden
estimates:
(
1)
a
"
core
IEE"
which
is
the
initial
IEE
submission;
(
2)
a
"
revised
IEE"
which
is
a
revision
of
the
"
core
IEE"
to
address
items
such
as
assessment
of
new
or
modifications
of
planned
activities;
and
(
3)
a
"
Multi­
Year
IEE"
which
may
be
submitted
for
a
period
of
up
to
five
consecutive
austral
summer
seasons
and
consists
of
a
"
core
IEE,"
or
usually
a
"
revised
IEE,"
submitted
in
the
first
year
with
supplemental
information
submitted
in
the
subsequent
four
years.
The
supplemental
information
may
include
annual
update
of
the
basic
information
and
also
identification
and
assessment
of
an
additional
activity
or
activities.
(
For
multi­
year
environmental
documentation,
see:
40
CFR
8.4(
e)).
The
hour
and
cost
burden
estimates
used
in
the
informal
consultations
were
taken
from
Exhibit
3
of
the
Supporting
Statement,
"
Estimated
Respondent/
Federal
Government
Burden
and
Cost,"
in
the
draft
ICR
Supporting
Statement
that
is
available
in
EPA's
Docket,
ID
number
OECA­
2004­
0026
(
see:
Section
3(
b)
of
the
Supporting
Statement).
The
IEE
models
and
the
burden
estimates
used
in
the
discussions
were
as
follows:

IEE
Model
Hours
On
average
cost
Estimated
hourly
rate
Core
IEE
185
$
14,000
$
76
Revised
IEE
65
$
5,000
$
77
Subsequent
Multi­
Year
IEE
25
$
2,000
$
80
(
E.
g.,
$
75­
80/
hour)

In
summary,
all
operators
agreed
with
the
following:

°
The
environmental
documentation
process
includes
preparation
of
a
PERM,
IEE
or
CEE.
°
An
IEE
is
the
level
of
environmental
documentation
operators
usually
submit.
°
The
three
IEE
models
developed
are
appropriate
for
the
burden
estimates.
°
The
hours
estimated
for
the
three
IEE
models
are
generally
correct.
More
hours
may
be
needed
for
an
operator
with
less
experience
with
the
regulatory
and
other
pertinent
requirements,
and
less
hours
would
likely
be
needed
for
an
experienced
operator.
Also,
the
more
an
operator
can
incorporate
by
reference,
the
less
time
it
takes
to
prepare
the
documentation,
and
the
more
operators
included
within
one
document,
the
less
time
it
takes
the
operators
individually
to
prepare
the
documentation.
°
The
hourly
rate
used
in
the
cost
estimates
for
the
three
IEE
models
are
generally
correct.
Three
of
the
respondents
contacted
said
that
documents
were
prepared
in­
house
and
that
they
do
not
track
specific
costs
for
this
work
but
thought
the
estimates
reasonable.
One
less
experienced
operator
suggested
the
rate
should
be
about
$
100/
hour;
two
highly
experienced
operators
provided
hourly
rates
of
about
$
65
and
$
75/
hour
with
one
reporting
that
the
going
contractor
rate
in
the
business
is
$
50­
75/
hour.

Based
on
these
consultations
and
the
lack
of
any
pertinent
comment
during
the
public
comment
period
on
the
ICR,
OFA
revised
Exhibits
1A
through
D
in
the
Supporting
Statement
to
lump
the
hours
for
the
various
activities
for
each
document
type
(
e.
g.,
PERM,
three
IEE
models,
CEE)
and
calculated
the
estimated
costs
per
Part
D­
5
hour
over
a
range
including
$
65
as
a
low,
$
75
as
an
intermediate,
and
$
100
as
a
high.
The
$
75/
hour
intermediate
rate
is
used
in
Exhibit
1D
for
summary
purposes.

The
seven
respondents
contacted
by
OFA
during
the
informal
consultation
process
included
one
privately
funded
researcher,
one
land­
based
(
e.
g.,
continental)
operator,
and
the
remainder
were
ship­
based
tour
operators
with
expeditions
in
the
Ross
Sea
and/
or
the
Peninsula
Area.
Of
the
five
ship­
based
operators,
three
carry
and
land
less
than
200
passengers
per
voyage
(
which
represents
the
majority
of
the
ship­
based
operators),
one
carries
and
lands
about
525
passengers
per
voyage,
and
one
carries
about
1,000
passengers
on
cruise­
only,
no
landing
voyages.
Of
these
seven
respondents,
six
are
tour
operators,
and
five
of
these
six
are
members
of
the
International
Association
of
Antarctica
Tour
Operators
(
IAATO),
which
represents
the
majority
of
all
Antarctic
tour
operators.
The
following
identifies
the
operators
contacted
and
summarizes
the
consultation
discussion
with
each.

Privately
funded
researcher
Ron
Naveen
Oceanites,
Inc.
P.
O.
Box
15259
Chevy
Chase,
MD
20825
Telephone:
202/
237­
6262
Oceanites
has
a
Multi­
Year
IEE
which
includes
a
"
revised
IEE"
and
submission
of
supplemental
information
for
the
annual
updates.
Mr.
Naveen
agreed
with
the
models,
including
the
three
IEE
models,
and
generally
agreed
with
the
burden
estimates.
Mr.
Naveen
said
the
environmental
documents
are
prepared
in­
house
and
that
he
does
not
track
specific
costs
for
this
work.
He
though
the
estimates
seemed
reasonable
for
a
typical
ship­
based
tour
operator,
though
noted
that
for
him
the
burden
estimates
were
probably
high
because:
(
1)
he
incorporates
a
great
deal
of
information
by
reference
(
see:
40
CFR
8.4(
d)(
1)),
and
(
2)
he
knows
EPA's
regulations
and
the
pertinent
Antarctic
references
and
information
needed
in
the
IEE
so
that
it
has
been
relatively
easy
for
him
to
prepare
the
necessary
IEE
documentation
for
his
expeditions.

Land­
based
operator
David
Rootes
Antarctic
Logistics
&
Explorations
(
ALE)
4376
S.
700
East,
Suite
226
Salt
Lake
City,
UT
84107­
3006
Telephone:
801/
266­
4876
Alternate
Telephone
for
Mr.
Rootes
in
U.
K.:
9­
011­
44­
1954­
718044
ALE
is
an
IAATO
member
offering
land­
based
expeditions
in
continental
areas
of
Antarctica.
ALE
has
a
Multi­
Year
IEE
which
includes
a
"
core
IEE"
and
submission
of
supplemental
information
for
the
annual
updates
and
new
activities.
Mr.
Rootes
is
highly
experienced
with
land­
based
and
tour
ship
operations
in
Antarctica.
Mr.
Rootes
agreed
with
the
models,
including
the
three
IEE
models,
and
generally
agreed
with
the
burden
estimates.
He
reported
that
ALE
does
contract
work
at
a
rate
of
$
500/
day
for
an
8­
hour
day
(
which
calculates
to
$
62.50/
hour
and
is
listed
in
the
summary
bullets
as
about
$
65/
hour).
ALE
may
also
be
a
subcontractor
under
another
contractor
that
may
then
charge
$
600­
700/
day
for
an
8­
hour
day
(
which
calculates
to
$
75
to
$
87.50
per
hour).
Part
D­
6
Ship­
based
operators
Denise
Landau
IAATO
P.
O.
Box
2178
Basalt,
CO
81621
Telephone:
970/
704­
1047
IAATO­
member
operators
with
expeditions
on
ships
that
carry
and
land
less
than
200
passengers
per
voyage
in
the
Peninsula
Area
have
a
Multi­
Year
IEE
(
see:
40
CFR
8.4(
d)(
2)).
The
"
revised
IEE"
was
prepared
by
Ms.
Landau
on
behalf
of
these
IAATO­
member
operators,
and
she
also
prepares
certain
of
the
supplemental
information
for
the
annual
updates.
The
members
operating
under
this
IEE
in
a
given
year
also
submit
expedition­
specific
supplemental
information
for
the
annual
updates.
Ms.
Landau
provides
technical
assistance
to
the
member
operators
regarding
their
annual
submissions.
Ms.
Landau
agreed
with
the
models,
including
the
three
IEE
models,
and
generally
agreed
with
the
burden
estimates.
She
said
that
more
hours
may
be
needed
for
an
operator
with
less
experience
with
the
regulatory
and
other
pertinent
requirements,
and
less
hours
would
likely
be
needed
for
an
experienced
operator.
Also,
the
more
an
operator
can
incorporate
by
reference,
the
less
time
it
takes
to
prepare
the
documentation,
and
the
more
operators
included
within
one
document,
the
less
time
it
takes
on
a
per
operator
basis
for
the
individual
operators
to
prepare
the
documentation.
(
See:
40
CFR
8.4(
d)
and
8.4(
e).)

Victoria
Underwood­
Wheatley
Abercrombie
&
Kent/
Atholl
Shipping
Corporation
(
A&
K/
ASC)
1520
Kensington
Road
Oak
Brook,
IL
60523
Telephone:
858/
279­
0689
A&
K/
ASC
is
an
IAATO
member
that
is
included
annually
in
the
IAATO­
member
Multi­
Year
IEE
as
an
operator
with
expeditions
in
the
Peninsula
Area.
The
"
revised
IEE"
was
prepared
by
Ms.
Landau
on
behalf
of
these
IAATO­
member
operators,
and
she
also
prepares
certain
of
the
supplemental
information
for
the
annual
updates.
As
a
member
operating
annually
under
this
IEE,
A&
K/
ASC
also
submits
expedition­
specific
supplemental
information
for
the
annual
updates.
Ms.
Underwood­
Wheatley
is
highly
experienced
in
Antarctic
tour
ship
operations.
As
such,
she
has
previously
prepared
"
core
IEEs."
She
also
provides
consulting
services
to
other
Antarctic
tour
operators.
Ms.
Underwood­
Wheatley
agreed
with
the
models,
including
the
three
IEE
models,
and
generally
agreed
with
the
burden
estimates.
She
said
that
the
time
needed
to
prepare
the
document
is
tied
to
how
the
ship
will
be
used
(
e.
g.,
the
number
and
types
of
activities
involved
with
the
expedition).
She
also
said
that
less
hours
would
likely
be
needed
for
an
experienced
operator,
and
more
hours
may
be
needed
for
an
operator
with
less
experience
as
they
would
likely
need
more
time
to
review
the
regulations
and
any
other
pertinent
requirements,
and
then
compile
the
materials
and
information
needed
in
order
to
prepare
the
IEE.
She
said
that
the
contractor
rate
for
the
business
is
in
the
range
of
$
50
to
$
75/
hour
with
highly
experienced
contractors
receiving
$
75/
hour.

Susan
Adie
Quark
Expeditions
43
Willow
Ave.
Middletown,
RI
02842
Telephone:
401/
847­
1857
Quark
is
an
IAATO
member
with
ship­
based
expeditions
that
carry
and
land
less
than
200
passengers
per
Part
D­
7
voyage.
Quark
has
two
Multi­
Year
IEEs,
one
for
its
expeditions
in
the
Ross
Sea
Area
and
the
other
for
its
multiple
ship
operations
in
the
Peninsula
Area.
Both
Multi­
Year
IEEs
include
a
"
revised
IEE"
and
submission
of
supplemental
information
for
the
annual
updates
and
new
activities.
Ms.
Adie
agreed
with
the
models,
including
the
three
IEE
models,
but
thought
that
for
her
the
burden
estimates
were
probably
low.
She
was
recently
made
responsible
for
various
environmental­
related
matters
which,
for
her,
includes
items
such
as:
submitting
the
Advance
Notification,
IEE
documentation,
and
permit
updates
and
renewals;
consulting
with
IAATO
regarding
member
requirements,
operational
procedures,
and
any
new
regulatory
requirements;
and
time
with
customers
on
environmental­
related
issues.
She
did
not
attempt
to
break
out
the
time
specifically
necessary
for
the
IEE
documentation
process,
but
said
that
she
thought
the
costs
would
likely
be
1/
4
to
1/
3
more
for
her
because
she
has
less
experience
with
the
regulatory
and
other
pertinent
requirements.
She
said
that
for
her,
$
100/
hour
would
be
a
more
reasonable
rate
estimate.

Mr.
Erland
A.
K.
Fogelberg
Discovery
World
Cruises
(
DWC)
1800
SE
10th
Avenue,
Suite
205
Ft.
Lauderdale,
FL
33316
Telephone:
954/
683­
8905
Discovery
World
Cruises
offers
ship­
based
expeditions
in
the
Peninsula
Area
that
carry
and
land
about
525
passengers
per
voyage.
When
DWC
initially
started
offering
Antarctic
tours,
the
company
submitted
a
"
core
IEE"
and
is
now
in
the
process
of
submitting
a
Multi­
Year
IEE
that
includes
a
"
revised
IEE"
and
will
be
followed
by
submission
of
supplemental
information
for
the
annual
updates
in
subsequent
years.
Mr.
Fogelberg
was
previously
with
Orient
Lines
and
submitted
the
company's
Multi­
Year
IEE
and
supplemental
information
for
the
annual
updates.
Orient
Lines'
vessel
and
operations
are
similar
to
DWC.
Mr.
Fogelberg
agreed
with
the
models,
including
the
three
IEE
models,
and
generally
agreed
with
the
burden
estimates.
He
reported
that
DWC
prepares
the
environmental
documents
in­
house
and
that
the
company
does
not
track
specific
costs
for
this
work
but
thought
the
estimates
reasonable.
He
indicated
the
same
was
the
case
when
he
was
with
Orient
Lines.

Ms.
Kelly
Clark
Holland
America
Line,
Inc.
(
HAL)
300
Elliott
Avenue
West
Seattle,
WA
98119
Telephone:
206/
286­
3238
Holland
America
Line
offers
ship­
based
expeditions
in
the
Peninsula
Area
on
a
vessel
that
carries
about
1,000
passengers
on
cruise­
only,
no
landing
voyages.
HAL
has
a
Multi­
Year
IEE
which
includes
a
"
revised
IEE"
and
submission
of
supplemental
information
for
the
annual
updates.
Ms.
Clark
agreed
with
the
models,
including
the
three
IEE
models,
and
generally
agreed
with
the
burden
estimates.
She
reported
that
HAL
prepares
the
environmental
documents
in­
house
and
that
the
company
does
not
track
specific
costs
for
this
work.
She
thought
that
if
this
work
were
contracted
out,
the
cost
would
likely
be
$
75
to
$
100/
hour
though
she
had
not
checked
this
within
the
market.
