	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

	Draft May 2010

Page

1.	Identification of the Information Collection . . . . . . . . . . . .
. . . . . . . . . .	   1

1(a)	Title of the Information Collection . . . . . . . . . . . . . . . .
. . . . . . .	   1

1(b)	Abstract . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . .	   1

 		Environmental Documentation . . . . . . . . . . . . . . . . . . . . .
. . . . .	   2

Coordination of Review of Information Received from 

Other Parties to the Treaty . . . . . . . . . . . . . . . . . . . . . .
. . . . . . .	   3

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

2(a)	Need/Authority for the Collection . . . . . . . . . . . . . . . . .
. . . . . . .	   4

2(b)	Practical Utility/Users of the Data . . . . . . . . . . . . . . . .
. . . . . . . .	   4

Role of the Information in Regulatory Decisions . . . . . . . . . . . .
.	   4

Users of the Information . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . .	   6

3.	Nonduplication, Consultations, and Other Collection Criteria . . . .
. . . . .	   6

3(a)	Nonduplication . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . .	   6

3(b)	Public Notice Required Prior to ICR Submission to OMB . . . . . .	 
 7

3(c)	Consultations . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . .	   7

3(d)	Effects of Less Frequent Collection . . . . . . . . . . . . . . . .
. . . . . . . .	   8

3(e)	General Guidelines . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . .	   8

3(f)	Confidentiality . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . 	   9

3(g)	Sensitive Questions . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . .	   9

4.	The Respondents and the Information Requested  . . . . . . . . . . .
. . . . . . . .	   9

4(a)	Respondents/SIC and NAICS Codes. . . . . . . . . . . . . . . . . .
. . . . . 	   9

4(b)	Information Requested . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . .	   9

Data items, including recordkeeping requirements . . . . . . . . . . . .
.	   9

Respondent Activities . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . .	  10

5.	The Information Collected--Agency Activities, Collection Methodology,

and Information Management . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . .	   15

5(a)	Agency Activities . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . .	   15

5(b)	Collection Methodology and Management . . . . . . . . . . . . . . .
. . .	   16

5(c)	Small Entity Flexibility . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . .	   17

5(d)	Collection Schedule . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . .	   19

6.	Estimating the Hours and Cost Burden of the Collection . . . . . . .
. . . . . . .	  21

6(a)	Estimated Annual Respondent Hours and Cost  . . . . . . . . . . . .
. 	  21

6(b)	Estimated Annual Federal Government Hours and Cost . . . . . . .	 
30

6(c)	Model for Federal Government Review of IEEs . . . . . . . . . . . .
. .	  37

6(d)	Estimated Annual Aggregate Hours and Cost . . . . . . . . . . . . .
. .	  42

6(e)	Reason for Change in Burden . . . . . . . . . . . . . . . . . . . .
. . . . . . . .	  44

6(f)	Burden Statement . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . .	  44

Exhibit 1A:  PERMs - Estimated Respondent Hours and Cost . . . . . . . .
. . . . . . 	  46

Exhibit 1B:  IEEs - Estimated Respondent Hours and Cost . . . . . . . .
. . . . . . . .	  47

Table 1.  IEEs - Total Estimated Hours and Cost for the Three IEE

   Models with 3.5% Escalation Rate  . . . . . . . . . . . . . . . . . .
. . . .	  49

Exhibit 1C:  CEEs - Estimated Respondent Hours and Cost . . . . . . . .
. . . . . . . .	  51

Exhibit 1D:  Reporting for Emergencies - Estimated Respondent Hours and
Cost	 

Exhibit 2A:  PERMs - Estimated Federal Government Hours and Cost . . . .
. . . .	  53

Exhibit 2B:  IEEs - Estimated Federal Government Hours and Cost . . . .
. . . . . . 	  55

Table 2.  IEEs - Total Estimated Hours and Cost for the Three IEE

   Models with 3.5% Escalation Rate . . . . . . .. . . . . . . . . . . .
. . . . 	  58

Exhibit 2C:  CEEs - Estimated Federal Government Hours and Cost . . . .
. . . . . 	  59

Exhibit 2D:  Reporting for Emergencies - Estimated Federal Government

Hours and Cost . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . .	  60

Exhibit 2E:  Coordinating Review of Information Received from Other
Parties -

Estimated Federal Government Hours and Cost . . . . . . . . . . . . . .	
 61

Exhibit 3:    Summary - Estimated Respondent/Federal Government

Hours and Cost . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . 	  62

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 . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . .	  62

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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . .	  62

Chart 3.  Estimated hours and costs for environmental documentation

   for 3-year period of this ICR renewal . . . . . . . . . . . . . . . .
. . . . . 	  63

Exhibit 4:  Summary for Respondents and Federal Government - O&M Costs 
. . 	  64

Part B:  Statistical Survey . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . .	 B-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

	___________________________________

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 1808.05, 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 (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  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 Rule apply to operators of nongovernmental
expeditions organized in or proceeding from the territory of the United
States to Antarctica and include commercial and non-commercial
expeditions.  Expeditions may include ship-based tours; yacht, skiing or
 mountaineering expeditions; privately funded research expeditions; and
other nongovernmental activities.  The 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 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 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 Rule must prepare
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.

The Protocol and the 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.  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 to be undertaken without
completion of the documentation procedures set out in the 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.

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
2009-2010 austral summer seasons during the time Rule has 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 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 Rule
does not impose paperwork requirements on any nongovernmental person
subject to U.S. regulation.

2.	NEED FOR AND USE OF THE COLLECTION

2(a)	NEED/AUTHORITY FOR THE COLLECTION:    The basis for the Rule is the
United States Code as amended:  16 U.S.C. 2401 et seq., as amended, 16
U.S.C. 2403a.

The 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 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 Rule
includes Federal agency requirements, but does not impose paperwork
requirements on any nongovernmental person subject to U.S. regulation.

The procedures in the 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 Rule are consistent with and implement
the environmental impact assessment provisions of Article 8 and Annex I
to the Protocol.  The provisions of the 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.

The Rule addresses measures to assess and verify environmental impacts
but does not set schedule requirements for submission of assessment and
verification reports.  Under the 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 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 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.

The purpose of the 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
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 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 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 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 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 Rule.  However, the
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 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.  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 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
HQ-OECA-OECA-2007-0468.  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.

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 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 agencies.



3(d)	Effects of Less Frequent Collection:  The 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 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 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 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 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 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 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 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
non-commercial expeditions.  Expeditions include ship-based tours;
yacht, skiing or mountaineering expeditions; flights; privately funded
research expeditions; and other nongovernmental or
nongovernment-sponsored activities.  The 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 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 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 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 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 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 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 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 Rule,
against an operator who violates any provision of the 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.  For purposes of renewing this ICR,
EPA estimated the hours and costs to respondents under the 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 Rule are for operators and activities
associated with ship-based tourism as summarized in Figure 1.



Figure 1.	Numbers of Operators Submitting Environmental Documentation
Under the Rule 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  	

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





2001-2002	

      12	

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 



2004-2005	

21	

16 total IEEs submitted including:

     ( 6 IEE submitted on behalf of 11 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

     ( 1 IEE submitted by one IAATO-member operator for its expeditions
to the Continental area

     ( 8 IEEs submitted by 8 non-IAATO operators 



2005-2006	

19	

13 total IEEs submitted including:

     ( 5 IEEs submitted on behalf of 11 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

     ( 1 IEE submitted by one IAATO-member operator for its expeditions
to the Continental area

     ( 6 IEEs submitted by 8 non-IAATO operators 



2006-2007	

21	

13 total IEEs submitted including:

     ( 5 IEEs submitted on behalf of 14 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

     ( 1 IEE submitted by one IAATO-member operator for its expeditions
to the Continental area

     ( 6 IEEs submitted by 6 non-IAATO operators 

2007-2008

14 total IEEs submitted including:

     ( 6 IEEs submitted on behalf of 14 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

     ( 1 IEE submitted by one IAATO-member operator for its expeditions
to the Continental area

     ( 6 IEEs submitted by 6 non-IAATO operators

2008-2009

12 total IEEs submitted including:

     ( 8 IEEs submitted on behalf of 13 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

     ( 1 IEE submitted by one IAATO-member operator for its expeditions
to the Continental area

     ( 2 IEEs submitted by 2 non-IAATO operators

2009-2010

11 total IEEs submitted including:

     ( 9 IEEs submitted on behalf of 14 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

     ( 1 IEE submitted by one IAATO-member operator for its expeditions
to the Continental area

     ( 0 IEEs submitted by non-IAATO operators



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
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:

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 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 agencies
for activities associated with the 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 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 Rule, Section 8.12, Coordination of reviews
from other Parties, and for circulating a CEE that is prepared in
accordance with the Rule at Section 8.8, along with any decisions by the
operator relating thereto, to all Parties.  Activities associated with
the 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 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 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.

5(b)	COLLECTION METHODOLOGY AND MANAGEMENT:  The environmental
documentation that is required by the 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
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. 
EPA, in consultation with other interested Federal agencies, reviews the
environmental documentation relative to the general requirements (e.g.,
Rule, Section 8.4) and the specific requirements for each level of
documentation (e.g.,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.

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.

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 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 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 Rule,
Section V.D, Paperwork Reduction Act.  Further, EPA has included
provisions in the 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 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.

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 Rule at Section
8.5(b) provides that EPA may waive or modify the deadlines of the 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 Rule does not provide an exemption from coverage of the collection
of information, or any part thereof.  This is because the 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.

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 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 Rule.

Initial Environmental Evaluation (IEE):  In accordance with the 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.

(  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.

(  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 tour ship operator.  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 ten
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-three as delineated in Figure 2.  This estimate
includes 18 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				17 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			0 Peninsular 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.

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 ten
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.

(  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 information.

(  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.

(  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.

IEE Model 1 - (Core( IEE:  The following estimate is based on EPA(s
experience for the ten 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 hrs

IEE Model 2 - (Revised( IEE:  For purposes of maximum burden assessment,
EPA anticipates that two 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 ten 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 (2 IEEs)							=   65 hours

TOTAL HOURS PER OPERATOR (2 operators)					=   65 hours

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 eight (multi-year( IEEs will be submitted on behalf of 16
operators, and the operator hourly burden for preparation of a
(Multi-Year( IEE is estimated as follows:

Initial Year:

Prepare (Revised( IEE:		40 hrs/IEE x 9 IEEs			=   360 hours

Prepare supplemental information:	 5 hrs/operator x 14 ops x 1 year	= 
70 hours

A/V procedures:			20 hrs/operator x 14 ops x 1 year	=   280 hours

Four Subsequent Years for a Total of Five Consecutive Years:

Prepare supplemental information:	 5 hrs/operator x 14 ops x 4 years	=  
280 hours

A/V procedures:			20 hrs/operator x 14 ops x 4 years	= 1120 hours

TOTAL HOURS for 5-Year Period of (Multi-Year( IEE				= 2110 hours

TOTAL HOURS PER YEAR (5 Years) PER IEE (9 IEEs)				=   47 hours

TOTAL HOURS PER YEAR (5 Years) PER OPERATOR (14 operators)		=   30 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
ten austral summer seasons the Rule has been in effect.

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 ten 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.

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.  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
thirteen austral summer seasons the Rule has been in effect, only one
PERM has been submitted 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.

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

(1)  Copying:		25 pages/PERM  x  5 copies  x  $0.10/page			=  $12.50

(2)  Mailing:		1 PERM package  x  $27/package				=    27.00

Exhibit 1A incorporates double these estimated O&M costs in the
estimated respondent burden and costs for PERMs for a three year period
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.

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

  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.  Over the next three years, all Multi-Year
IEE submissions will follow the Multi-Year Model with a revised
submission one year and two subsequent years where only supplemental
information is filed.  To calculate the O&M costs over the three year
period for the Multi-Year IEEs, the costs of one Model Multi-Year and
two Subsequent Years Multi-Years are averaged.  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:   $ 85

Mailing:    $ 47

TOTAL    $ 132	

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 ten 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.

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.  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 emergency, and Exhibit
2E presents the estimated Federal government hours and cost for
coordinating the review of information received from other Parties.  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.

"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:

FIGURE 3.  Federal Model 1



Job 		Estimate of		Estimated time		Pay Rate

Classification	Relative Hours		Per Hour        		(Based on GS-Level)
Cost/Hour

Manager	      2 			       0.16		$84.02 for GS 15	 $13.44

Technical	      8			       0.68		  71.41 for GS 14	   48.56

Attorney	      1			       0.08		  71.41 for GS-14	     5.71

Clerical	                   1			       0.08		  28.65 for GS-07	     2.29

_________		_________ 					__________

12 hours		1.00 hour					$70.00/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	           $84.02 for GS 15		  $16.81

Technical	      1			       0.20	             71.41 for GS 14		    14.28

Attorney	      0			       0.00	             71.41 for GS-14		      0.00

Clerical	                   3			       0.60	             28.65 for GS-07
	    17.19

__________		_________					__________

   5 hours		1.00 hour					$48.28/hour



Based on EPA(s experience for the thirteen 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
$70/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 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 ten 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 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.  Over the next three years, all Multi-Year IEE
submissions will follow the Multi-Year Model with a revised submission
one year and two subsequent years where only supplemental information is
filed.  EPA assumes sixteen operators will submit eight (multi-year(
IEEs.  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 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 ten 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 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, 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 ten
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. 
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.

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.  Over
the next three years, all Multi-Year IEE submissions will require a
revised submission one year and two subsequent years where only
supplemental information is filed.  To calculate the O&M costs over the
three year period for the Multi-Year IEEs, the costs of one Model
Multi-Year and two Subsequent Years Multi-Years are averaged.  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



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:   $ 101

File

Storage:    $   10

TOTAL    $   111	

Copying:   $1740

File

Storage:    $  10

FedReg:    $  326

TOTAL     $2076



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
$163 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 ten
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  $163/column  x  2 columns			=      
326.00

(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. 
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 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.

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.

The assumptions used for the O&M estimates include:

(  A Federal Register Notice of Availability must be published for
receipt of each draft CEE; publication costs are estimated at $163 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 $163/column x 2 columns				=    326.00

(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 ten 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 ten
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 ten austral summer seasons the Rule has been in
effect:

(  Section 6(a), including Figure 2, lists the potential respondents.

(  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 multi-year 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.

IEE Model 1 - (Core( IEE:   The following estimate is based on EPA(s
experience for the ten 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

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 hrs

IEE Model 2 - (Revised( IEE:  For purposes of maximum burden assessment,
EPA assumes that two 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.  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 hrs

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.

EPA assumes eight 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:

Initial Year:

Review (Revised( IEE:		40 hrs/IEE x 9 IEEs x 1 yr		=   360 hours

Review supplemental information:	 1 hr/operator x 14 ops x 1 year	=    
14 hours

Review A/V information:		15 hrs/operator x 14 ops x 1 year	=   210 hours

Four Subsequent Years for a Total of Five Consecutive Years:

Review supplemental information:	  1 hr/operator x 14 ops x 4 years	=   
 56 hours

Review A/V information:		15 hrs/operator x 14 ops x 4 years	=    840
hours

TOTAL HOURS for 5-Year Period of (Multi-Year( IEE				=   1480 hours

TOTAL HOURS PER YEAR (5 Years) PER IEE 98 IEEs)				=      33 hours

TOTAL HOURS PER YEAR (5 Years) PER OPERATOR (14 operators)		=   21 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 ten 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 40

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 40

x 40

x 40

x 40	

 20

 16

 4

 0



Totals	

	

1.00	

	

 96	

	

1.00	

	

56	

	

  1.00	

	

30

(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	

27



Review Hours per Final	

32	

19	

  13



Total Hours	

96	

56	

40



The hours are then spread amongst the Federal agencies as follows:

               (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	

 13

 11

 3

 0	

 6

 6

 1

 0



Totals	

	

64	

 32	

	

	

37	

 19	

	

	

27	

 13



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.  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.

Based on the reporting by operators for the thirteen 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.

( Three of the 18 repeat operators with annual expeditions will submit
revised IEEs.

( It was assumed that 9 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.

(  No CEEs have been submitted as the final documentation during the
past thirteen 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
ten 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.

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
1,708 hours, and the annual total hourly burden per operator is
estimated to be 78 hours.  These annual totals reflect submission of
different levels of documentation by the 23 operators.  The estimated
annual average time per respondent ranges from 42 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
$136,675, and the annual total cost burden per operator is estimated to
be $6,213.  These annual totals reflect submission of different levels
of documentation by the 22 operators.  The estimated annual average per
respondent ranges from $3,372 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 1054 hours and $80,471.  The annual total hours and cost
per operator for the Federal government is estimated as 48 hours and
$3,658.  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 29 hours and $2,224 to 96 hours and
$7,254 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 1,663
hours.  The total 3-year estimated hourly burden of 5,124 hours for the
anticipated 22 operators represents an annual reporting and
recordkeeping hourly burden of 1,708 hours, or 78 hours per operator for
this 3-year renewal period.  This increased adjustment to the annual
reporting and recordkeeping hourly burden is 45 hours.  This increased
adjustment is the result of a change to 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 1,708 hours
annually, or 78 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 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
[EPA-HQ-OECA-2007-0468], which is available for online viewing at
www.regulations.gov, or in person viewing at the Enforcement and
Compliance Docket and Information Center  in the EPA Docket Center
(EPA/DC), EPA West, Room 3334, 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 at www.regulations.gov.  This site can be
used to submit or view public comments, access the index listing of the
contents of the public docket, and to access those documents in the
public docket that are available electronically.  When in the system,
select (search,( then key in the docket ID number identified above.

	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 thirteen 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 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).

	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 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.



  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



"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 	

  30	

$   1,950	

$   2,250	

$   3,000	

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	

$   1,987	

$   2,297	

$   3,047



	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.

  SEQ CHAPTER \h \r 1 “Subsequent Year Multi-Year” IEE for One
Operator

													     Totals for Respondent Rate Range

										Hours			$65/hour	$75/hour	$100/hour

YEAR ONE									   30			$   1,987	              $ 2,297		$   3,047

YEAR TWO (3.5% estimated CPI escalation rate)					   30	   		     2,057	
                2,377		     3,154

YEAR THREE (3.5% estimated CPI escalation rate)					   30			     2,129	 
               2,460		     3,264

TOTAL ESTIMATED POTENTIAL HOURS and COST:				   90			$  5,192		$ 7,134	
$  9,465

AVERAGE EST. HOURS and COST PER YEAR PER OPERATOR:			   30			$  1,731		$
2,378		$  3,155

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				   30hrs x 2 =	   60	$2,378
x 2 =	$   4,756

TOTAL ESTIMATED POTENTIAL HOURS and COST:				 125			$  10,115

(over 3-year life of this ICR Renewal)

AVERAGE EST. HOURS and COST PER YEAR PER OPERATOR:	 		  42			$   3,372

(over 3-year life of this ICR Renewal)

	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 ten 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.

	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 ten 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.

	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       	$70/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	

 $   840	

PERM  

      None

Post-Exp A/V

       None	

PERM

Copying   $   30

FR Pub.          0

Store Files     10

_____________

                 $  40

Post-Exp A/V

None

$    40	

       1	

$    880



Hours	Cost

YEAR ONE				 				12	$    880

YEAR TWO (3.5% estimated CPI escalation rate on $794)			12	      911

YEAR THREE (3.5% estimated CPI escalation rate on $822)			12	      943

TOTAL ESTIMATED POTENTIAL BURDEN and COST:			36	$ 2,734

AVERAGE EST. BURDEN and COST PER YEAR PER OPERATOR:	12	$    911

Assumptions:

1.  Exhibit 2A represents the estimated hours and cost for PERMs.  In
fact, during the thirteen 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).

4.  Based on EPA(s experience for the thirteen 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
$70/hour rate for technical activities. 

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       	$70/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	

$   5,600

$        70

$      1050

 $   6,720	

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	

$   7,006





    Federal Gov't.	Federal Gov't.	Capitol/	       O & M    	    No. of	 
          Total

ICR Activity: IEEs	 			   hours/year       	$70/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	

$   2,800

$        70

$      1050

 $   3,920	

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	

$   4,206





    Federal Gov't.	Federal Gov't.	Capitol/	        O & M    	    No. of	
           Total

ICR Activity: IEEs	 	   hours/year       	$70/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

	

$   2,800

Years 2 and 3

$        70

$      1050

________

 $   1,120	

      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 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.

_______________________________________________________________________
_______________________________

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			$   7,006

YEAR TWO (3.5% estimated CPI escalation rate)			     96			     7,251

YEAR THREE (3.5% estimated CPA escalation rate)			     96			     7,504

TOTAL ESTIMATED POTENTIAL HOURS and COST:			   288			$ 21,761

AVERAGE EST. HOURS and COST PER YEAR PER OPERATOR	     96			$   7,254

(Revised( IEE for One Operator and One IEE - (Revised IEE + Supplemental
Information + A/V Information)

HOURS		COST

YEAR ONE								     56			$   4,206

YEAR TWO (3.5% estimated CPI escalation rate)			     56			     4,353

YEAR THREE (3.5% estimated CPA escalation rate)			     56			     4,505

TOTAL ESTIMATED POTENTIAL HOURS and COST:			   168			$ 13,064

AVERAGE EST. HOURS and COST PER YEAR PER OPERATOR	     56			$   4,355

"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.

  SEQ CHAPTER \h \r 1 “Subsequent Year Multi-Year” IEE for One
Operator - (Supplemental Information + A/V Information)

									HOURS		COST

YEAR ONE								     16			$   1,120

YEAR TWO (3.5% estimated CPI escalation rate)				     16			     1,159

YEAR THREE (3.5% estimated CPA escalation rate)			                   16	
	     1,200

TOTAL ESTIMATED POTENTIAL HOURS and COST:			     48			$   3,479

AVERAGE EST. HOURS and COST PER YEAR PER OPERATOR		     16			$   1,159

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			$   4,355

"Subsequent Year Multi-Year" IEE - cost for 2 years	       16 hrs x 2 =	
   32	$1,159 x 2 = 	     2,318

TOTAL ESTIMATED POTENTIAL HOURS AND COST:			    88			$   6,673

(over 3-year life of this ICR Renewal)

AVERAGE EST. HOURS and COST PER YEAR PER OPERATOR:	    29			$   2,224

(over 3-year life of this ICR Renewal)

________________________________________________________________________
_________________

	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       	$70/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

$   9,450

Post-Exp A/V

$    2,100

 $ 11,550	

CEE

  None

Post-Exp A/V

  None

	

CEE

Copying  $1710 FR Pub.       326

Store Files    10*

_____________

               $2046*

*Includes CEE and A/V Information

Post-Exp A/V

Copying  $  30

FR Pub.        0

Store Files    *

_____________

                $  30

* Included above

               $2,076	

      1	

$ 13,626



YEAR ONE						165	$13,626

YEAR TWO (3.5% estimated CPI escalation rate on $12,590)		165	$14,103

YEAR THREE (35% estimated CPI escalation rate on $13,031)		165	$14,597

TOTAL ESTIMATED POTENTIAL BURDEN and COST:		495	$42,326

AVERAGE EST. BURDEN and COST PER YEAR PER OPERATOR:	165	$14,109

Assumptions:

1.  Exhibit 2C represents the estimated hours and cost for CEEs.  In
fact, no CEEs were submitted during the ten 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.

	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       	$70/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	

  $ 11,550	

None	

Copying   $1740

FR Pub.            0

Store Files      10

_____________

                $1750 	

       1	

$ 10,660

    1,750

________

$13,300



YEAR ONE							165	$13,300

YEAR TWO (3.5% estimated CPI escalation rate of $12,410) 	             
165	  13,766

YEAR THREE (3.5% estimated CPI escalation rate for $12,845)	165	  14,248

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.

	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       	$70/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	

$7,700	

None	

Copying  $   *

FR Pub     326

Store Files  10

____________

              $ 336

* 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
ten 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.

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	

  30    $ 2,297

  30       2,377

  30       2,460

  

  90    $ 7,134

  30    $ 2,378	

  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    $    880

  12    $    911

  12    $    943

  36    $ 2,734

  12    $    911	

   96   $ 7,006

   96   $ 7,251

   96   $ 7,504

 288   $21,761

   96   $  7,254	

   56   $ 4,206

   56   $ 4,353

   56   $ 4,505

 168   $13,064

   56   $  4,355	

  16     $ 1,120

  16     $ 1,159

  16     $ 1,200

  48     $ 3,479

  16     $ 1,159	

  165   $ 13,626

  165   $ 14,103

  165   $ 14,597

  495   $ 42,326

  165   $ 14,109	

 165     $13,300

 165     $13,766

 165     $14,248



TOTAL

Annual Average	

156    $12,298

  52    $  4,099	

 843   $65,795

 281   $21,931	

 363    $29,141

 121    $  9,714	

138     $ 10,613

  46     $ 3,538	

1395 $113, 478

  465  $ 37,826	





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)	

   125 hours	 42 hrs per op per yr	

$    10,115		$  3,372 per operator per year



Federal Government (for one op.)	

      88 hours	 29 hrs per op per year	

$    6,673		$  2,224 per op per year



TOTALS - For one operator	

    213 hours	 71 hrs per op per yr	

$  16,366		$  5,456 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.

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 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: 22operators 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		$  7,254 x 5 = $  36,270

480 x 3 = 1,440		$36,270 x 3 = $108,810



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		$  4,355 x 3 = $ 13,065

168 x 3 =    504		$13,065 x 3 = $ 39,195



14 of 17 repeat operators submit new "Multi-Year" IEEs

Burden per year

Total 3-year burden	

  42 x 14 =  588		$  3,372 x 14 = $   47,208

588 x 3 =    1764		$47,208 x 3 = $ 141,624	

  29 x 14 =  406		$ 2,224 x 14 = $31,136

406 x 3 =   1218		$31,136 x 3 = $93,408



ANNUAL TOTAL BURDEN for 22 operators

ANNUAL TOTAL BURDEN per operator

TOTAL 3-YEAR BURDEN for 22 operators

TOTAL 3-YEAR BURDEN per operator	

  1,708			         $136,675

       78			         $    6,213

  5,124			         $409,975

     233			         $ 18,635	

    1054			         $ 80,471

       48			         $   3,658

  3,162			         $ 241,413

     144			         $   10,973



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: 23 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 +   34,915 = $  36,270

$1,355 x 3 = $4,065     $ 4,065 +  104,745 = $108,810



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 +  12,252 = $ 13,065

$   813 x 3 = $2,439     $ 2,439 +   36,756 = $ 39,195



14 of 17 repeat operators submit new "Multi-Year" IEEs

Burden per year

Total 3-year burden	

$  132 x 14 = $ 1,848     $ 1,848 +   45,360 = $ 47,208

$ 1,848 x 3 = $ 5,544     $5,544 + 136,080 = $ 141,624	

$   111 x 14 = $ 1554     $ 1554 +  31,568 = $  31,136

$ 1554 x 3 = $4,662     $ 4,662 +   94,704 = $93,408



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

       $ 4,256 + 132,419 = 		$136,675

       $     193 +     6,019=		$    6,212

       $12,768 + 397,257 =		$401,025

       $     580 +   18,057 =		$  18,637	

       O&M        Labor	             Total Cst

       $3,722 +   78,735 =	              $ 82,457

       $   169 +     3,579 =	              $    3,748

       $11,166 + 236,205 =	              $247,371

       $   508 +   10,737 =	              $ 11,245

	PART B OF THE SUPPORTING STATEMENT

	STATISTICAL SURVEY

This collection of information does not use or is otherwise based on a
statistical survey.

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.

For 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.

During 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-
2010 which includes the 1997-1998 through 2009-2010 austral summer
seasons).

The 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. ...(

Alternately, under the paperwork reduction provisions of the 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.

For the 1997-1998 through 2009-2010 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.,
land-based; 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.

The 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 1997-2007 which includes the 1997-1998
through 2006-2007 austral summer seasons).

Nine 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.

Seven 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.

EPA 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).

For 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 U.S.C. 2401 et seq., as amended, 16 U.S.C. 2403a.

For the austral seasons the Rule has been in effect, operators have used
all of the available paperwork provisions available under the Rule.

See: 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.

For the ten 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.

For 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.

The 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).

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

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

If, 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.

If, 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.

For purposes of demonstrating the hourly burden for an operator
submitting a (Multi-Year( IEE, EPA assumed eight 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.

 Because the eight (Multi-Year( IEEs cover sixteen operators (e.g., one
IEE covers nine operators and the other seven cover one operators), the
burden per operator is reduced from 58 hours to 29 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.

One-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.

O&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.

For 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.

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

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

There is no respondent burden or cost associated with Section 8.12.

See: 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.

For 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.

For purposes of demonstrating the hourly burden for an operator
submitting a (Multi-Year( IEE, EPA assumed forteen operators will submit
nine multi-year IEEs during the time covered by this ICR renewal.  It is
possible that three 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.

See 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.)

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

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

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

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

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

For 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.

If, 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.

If 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.

If, 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.

For purposes of demonstrating the hourly burden for an operator
submitting a (Multi-Year( IEE, EPA assumed forteen operators would
submit nine multi-year IEEs during the time covered by this ICR renewal.
 It is possible that the three 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 three
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.

Because the eight (Multi-Year( IEEs cover forteen operators (e.g., one
IEE covers one operator and the other covers two operators), the hours
per operator is reduced from 24 hours to 20 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.

Exhibit 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.

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

New "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

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