	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
	December 2013

                                                                  Page

1.	Identification of the Information Collection . . . . . . . . . . . . . . . . . . . . . .	   1
      1(a)	Title of the Information Collection . . . . . . . . . . . . . . . . . . . . . . .	   1
      1(b)	Short Characterization/Abstract . . . . . . . . . . . . . . . . . . . . . . . .            1
 		
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
      
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 . . . . . . . . . . . . . . . . . . . . . . . .	   7
      3(e)	General Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	   8
      3(f)	Confidentiality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 	   8
      3(g)	Sensitive Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	   8
      
4.	The Respondents and the Information Requested  . . . . . . . . . . . . . . . . . . .	   9
      4(a)	Respondents/SIC Codes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .          9
      4(b)	Information Requested . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	   9
      (i)  Data items, including recordkeeping requirements.  . . . . . . .	   9
            (ii) Respondent Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .         10
            
5.	The Information Collected--Agency Activities, Collection Methodology,
      and Information Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	   14
      5(a)	Agency Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	   14
      5(b)	Collection Methodology and Management . . . . . . . . . . . . . . . . . .	   16
      5(c)	Small Entity Flexibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	   16
      5(d)	Collection Schedule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	   19



6.	Estimating the Hours and Cost Burden of the Collection . . . . . . . . . . . . . .	  20
      6(a)	Estimating Respondent Burden   . . . . . . . . . . . . . . . . . . . . . . . . . . 	  20
      6(b)	Estimating Respondent Costs   . . . . . . . . . . . . . . . . . . . . . . . . . . . .	  25
      	(i)Estimating Labor Costs  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .        25
      	(ii)Estimating Capital and Operations and Maintenance Costs. . .       27
      	(iii) Annualizing Capital Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . .     31
      6(c)	Estimating Agency Burden and Costs. . . . . . . . . . . . . . . . . .	              31
	6(d)	Estimating the Respondent Universe and Total Burden and Costs      43
      6(e)     Bottom Line Burden Hours and Cost Tables. . . . . . . . . . . . . . . . .       46
		(i)Respondent Tally . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .        46
		(ii)The Agency Tally . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .      46
		(iii)Variations in the Annual Bottom Line . . . . . . . . . . . . . . . . . .       46
      6(f)      Reason for Change in Burden . . . . . . . . . . . . . . . . . . . . . . . . . . . .	  46
      6(g)     Burden Statement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	  46

Exhibit 1A:  PERMs - Estimated Respondent Hours and Cost . . . . . . . . . . . . . . 	  48
Exhibit 1B:  IEEs - Estimated Respondent Hours and Cost . . . . . . . . . . . . . . . .	  49
      Table 1.  IEEs - Total Estimated Hours and Cost for the Three IEE
               Models with 3.5% Escalation Rate  . . . . . . . . . . . . . . . . . . . . . .	  51
Exhibit 1C:  CEEs - Estimated Respondent Hours and Cost . . . . . . . . . . . . . . . .	  53
Exhibit 1D:  Reporting for Emergencies - Estimated Respondent Hours and Cost	  54

Exhibit 2A:  PERMs - Estimated Federal Government Hours and Cost . . . . . . . .	  55
Exhibit 2B:  IEEs - Estimated Federal Government Hours and Cost . . . . . . . . . . 	  57
      Table 2.  IEEs - Total Estimated Hours and Cost for the Three IEE
               Models with 3.5% Escalation Rate . . . . . . .. . . . . . . . . . . . . . . . 	  60
Exhibit 2C:  CEEs - Estimated Federal Government Hours and Cost . . . . . . . . . 	  61
Exhibit 2D:  Reporting for Emergencies - Estimated Federal Government
            Hours and Cost . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	  63
Exhibit 2E:  Coordinating Review of Information Received from Other Parties -
            Estimated Federal Government Hours and Cost . . . . . . . . . . . . . .	  64
Exhibit 3:    Summary - Estimated Respondent/Federal Government
            Hours and Cost . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 	  65
      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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	  65
      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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	  65
      Chart 3.  Estimated hours and costs for environmental documentation
               for 3-year period of this ICR renewal . . . . . . . . . . . . . . . . . . . . . 	  66
Exhibit 4:  Summary for Respondents and Federal Government - O&M Costs  . . 	  67

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 1808.07, OMB Control Number 2020-0007"

      1(b)	SHORT CHARACTERIZATION/ABSTRACT:  The Environmental Protection Agencys (EPAs) 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 governments 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 EPAs 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 governments 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-2007-0468.  Public comments were requested via the Federal Register (78 FR 57847) on September 20, 2013. The proposed information collection did not receive any comments. 
      
      3(c)	CONSULTATIONS:

      The Office of Federal Activities attempted to contact four potential respondents.  The following is a list of potential respondents contacted:
      
      Ted Cheeseman                                     Ron Naveen
      Cheesemans' Ecology Safaris               Oceanites, Inc. /Antarctic Site Inventory
      408-741-5330                                        202-237-6262

      Bill Davis                                              Bob Simpson
      Quark Expeditions                                Abercrombie & Kent USA, LLC
      416-645-8253                                        630-725-3400 Ext 150
 
Only Ted Cheeseman of Cheesemans' Ecology Safaris and Ron Naveen of Oceanites, Inc. provided responses. OFA inquired whether or not the respondent burden in the Supporting Statement was an accurate portrayal. Ted Cheeseman believed that the majority of burden hours were accurate with the exception of the estimate for the  multi-year IEE documentation. He believes the "multi-year" IEE documentation estimate should be double of what has been anticipated.  Ron Naveen believed that his burden was half of what EPA estimates to be the burden.  


      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 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:


                       (i)  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 (PRA).
		
      
                  (ii) Respondent Activities:  The EPA considered the definition of "burden" developed for the PRA and the Office of Management and Budgets (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
24
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
17
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
16
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
2010-2011
18
16 total IEEs submitted including:
      12 IEEs submitted on behalf of 14 IAATO-member operators for expeditions to the Peninsula area
      0 IEE submitted by one IAATO-member operator for its expeditions to the Ross Sea area
      0 IEE submitted by one IAATO-member operator for its expeditions to the Continental area
      4 IEEs submitted by non-IAATO operators
2011-2012
15
14 total IEEs submitted including:
      9 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
      3 IEEs submitted by non-IAATO operators
2012-2013
16
1 PERM submitted for a one-time only flight
14 total IEEs submitted including:
      9 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
     3 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 rules 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 rules economic impact on small entities; explore regulatory options for reducing any significant economic impact on a substantial number of such entities; and explain the Agencys 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 rules burden on small entities.  It is EPAs policy to make an assessment of the rules 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 EPAs 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)	ESTIMATING RESPONDENT BURDEN: 

      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.	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.


      2.	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-yearIEE 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 three present ship based tour operators will remain the same, and that these operators will continue to submit revised IEEs for the three austral summer seasons this ICR will be in effect.  Updates are likely to include such items as dates of expeditions and changes in landing locations.  Revisions could address items such as assessment of the potential impacts, including cumulative impacts, of modifications to the planned activities and any associated mitigation measures, or a reassessment of overall impacts for the expedition.  Thus, for subsequent seasons, EPA assumes a reduced number of hours would be required for revision of the "core" IEE, and the hours for preparation of supplemental information will remain the same.  The model for estimating respondent hourly burden for a Revised IEE is based on EPA's experience for the 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			=  120hours
Prepare supplemental information:		    5 hrs/operator x 3 operators	=   15 hours
A/V procedures:				  20 hrs/operator x 3 operators	=   60 hours
TOTAL HOURS									= 195 hours
TOTAL HOURS PER IEE (3 IEEs)							=   65 hours
TOTAL HOURS PER OPERATOR (3operators)					=   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 nine multi-year IEEs will be submitted on behalf of 12 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 12 ops x 1 year	=   60 hours
      A/V procedures:    20 hrs/operator x 12 ops x 1 year	=   240hours
Four Subsequent Years for a Total of Five Consecutive Years:
      Prepare supplemental information: 5 hrs/operator x 12 ops x 4 years	=   240 hours
      A/V procedures:  20 hrs/operator x 12ops x 4 years	= 960 hours
TOTAL HOURS for 5-Year Period of Multi-Year IEE	= 1860 hours
TOTAL HOURS PER YEAR (5 Years) PER IEE (9 IEEs)	=   42 hours
TOTAL HOURS PER YEAR (5 Years) PER OPERATOR (12 operators)	=   31 hours
      
      3.	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.

      4.	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.
      
      6(b)       ESTIMATING RESPONDENT COSTS
 ESTIMATING LABOR COSTS

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

Figures 2, 3, 4, 5, and 6 present the estimated Respondent labor cost for drafting the three possible levels of environmental documentation (e.g., PERM, IEE, CEE) and associated post-expedition assessment and verification information.  



FIGURE 2.  Respondent Labor Costs for PERM Model

Industry 						
Representatives    Rate   	Hours	              Pay Rate/Hour	                    Total Cost

High       	                           40		       $100.00                            $4.000
Intermediate	                           40		           75.00                	          3,000
Low      	                           40		           65.00                	          2,600
            


FIGURE 3.  Respondent Labor Costs for IEE "Core" Model

Industry 						
Representatives   Rate   	             Hours	              Pay Rate/Hour	                    Total Cost

High       	                           185		       $100.00                 	        $18,500
Intermediate	                           185		           75.00                	          13,875
Low      	                           185		           65.00                	          12,025
            



FIGURE 4.  Respondent Labor Costs for "Revised" IEE Model

Industry 						
Representatives    Rate              Hours	              Pay Rate/Hour	                    Total Cost

High       	                             65		       $100.00                           $6,500
Intermediate	                             65		           75.00                	          4,875
Low      	                             65		           65.00                	          4,225
            


FIGURE 5.  Respondent Labor Costs for "Subsequent Years" IEE Model

Industry 						
Representatives    Rate                 Hours        Pay Rate/Hour	                    Total Cost

High       	                             30		       $100.00                 	        $3,000
Intermediate	                             30		           75.00                             2,250
Low      	                             30		           65.00                	          1,950
            					



FIGURE 6.  Respondent Labor Costs for CEE Model

Industry 						
Representatives    Rate   	Hours	              Pay Rate/Hour	                    Total Cost

High       	                           300		       $100.00                           $30,000
Intermediate	                           300	                        75.00                	          22,500
Low      	                           300	                        65.00                	          19,500
            




 ESTIMATING CAPITAL AND OPERATIONS AND MAINTENANCE COSTS
                  
      1.	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.

      2.	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:   1Revised 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.

 ANNUALIZING CAPITAL 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. Therefore, there is no need to annualize capital costs if there is not any capital or start up costs.

	
      6(c)	ESTIMATING AGENCY BURDEN 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 7.  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 8.  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 two PERMs has been submitted as the final documentation for expeditions during the thirteen 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 are 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

      

      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 thirteen 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 thirteen 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 thirteen austral summer seasons the Rule has been in effect and considers the paperwork reduction options utilized by the operators.  EPA anticipates three 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 3IEEs		=    240 hours
Review supplemental information  1 hr/review x 3 operators	=        3hours
Review of A/V information   15 hrs/A/V pkg x 3 operators 	=      45 hours
TOTAL HOURS	=    288 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 three present ship-based tour operators will remain the same, and that these operators will continue to submit revised IEEs for the three austral summer seasons this ICR will be in effect.  Updates are likely to include such items as dates of expeditions and changes in landing locations.  Revisions could address items such as assessment of the potential impacts, including cumulative impacts, of modifications to the planned activities and any associated mitigation measures, or a reassessment of overall impacts for the expedition.  Thus, for subsequent seasons, EPA estimates the government review time to be 25% of the respondent's time to prepare a "core" IEE, or 40 hours, and the hours for review of supplemental information will remain the same.  The model for estimating respondent hourly burden for a Revised IEE is based on EPAs 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 twelve 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 12 ops x 1 year	=     12 hours
      Review A/V information:   15 hrs/operator x 12 ops x 1 year	=   180 hours
Four Subsequent Years for a Total of Five Consecutive Years:
      Review supplemental information: 1 hr/operator x 12 ops x 4 years	=     48 hours
      Review A/V information:   15 hrs/operator x 12 ops x 4 years	=    720 hours
TOTAL HOURS for 5-Year Period of Multi-Year IEE	=   1320 hours
TOTAL HOURS PER YEAR (5 Years) PER IEE 9 IEEs)	=      29 hours
TOTAL HOURS PER YEAR (5 Years) PER OPERATOR (12 operators)	=   22 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



40
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)	ESTIMATING RESPONDENT UNIVERSE AND TOTAL BURDEN AND COSTS:
Number of Respondents:  Based on EPAs experience during the thirteen 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 eighteen as delineated in Figure 9.  This estimate includes 15 repeat operators who are expected to submit new or revised or multi-year IEE documentation, and three new operators who are expected to submit new IEEs.


FIGURE 9.	Estimated Respondents and Anticipated Level of EIA Documentation Considering EPAs Experience Under the Rule

Operators		 Number of Operators
U.S.-based IAATO-member tour operators	11 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		2
U.S.-based possible new respondents			                          3
TOTAL ESTIMATED		18
      
      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:

       Eighteen operators will likely plan expeditions to Antarctica and will submit environmental documentation including assessment and verification information.  Thirteen will likely be repeat operators with annual expeditions, and five operators may submit new documentation.  These three may include new operators planning annual expeditions and operators of one-time only expeditions.
       Three of the 15 repeat operators with annual expeditions will submit revised IEEs.
       It was assumed that 12 of the 15 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 two PERMs 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 18 operators per year with 3 new operators and 15 repeat operators each year.  For the 15 repeat operators, the assumptions are that three will prepare "Revised" IEEs and 12 will prepare "Multi-Year" IEEs.

      As summarized in Chart 3, for the estimated 18 operators submitting environmental documentation under the Final Rule during this ICR renewal period, the annual total hours for the 18 operators is estimated to be 1,254 hours, and the annual total hourly burden per operator is estimated to be 70 hours.  These annual totals reflect submission of different levels of documentation by the 18 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 18 operators submitting environmental documentation under the Final Rule during this ICR renewal period, the annual total cost for the 18 operators is estimated to be $100,575, and the annual total cost burden per operator is estimated to be $5,588.  These annual totals reflect submission of different levels of documentation by the 18 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 18 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 804 hours and $61,515.  The annual total hours and cost per operator for the Federal government is estimated as 45 hours and $3,418.  These annual totals reflect submission of different levels of documentation by the 18 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.
      
      Exhibit 4 summarizes the Respondent and Agency estimated O&M costs as well as an O&M breakout within the total cost burden.  
      
      
      6(e)	BOTTOM LINE BURDEN HOURS AND COST TABLES: 
      
 RESPONDENT TALLY
      
                      TOTAL ESTIMATED RESPONDENT BURDEN AND COST SUMMARY

                                       
                             Number of Respondents
                             Total Hours Per Year
                           Total Labor Cost Per Year
                          Total Annual O&M Costs
                                  "Core"
                                       3
                                      555
                                    $43,131
                                     $903
                                 "Revised"
                                       3
                                      195
                                    $15,174
                                     $903
                               "Multi-Year"
                                      12
                                      504
                                    $38,880
                                    $1,584
                                     Total
                                      18
                                     1,254
                                    $97,185
                                    $3,390
      
 THE AGENCY TALLY
                 
                TOTAL ESTIMATED AGENCY BURDEN AND COST SUMMARY

                                       
                             Number of Respondents
                             Total Hours Per Year
                           Total Labor Cost Per Year
                          Total Annual O&M Costs
                                  "Core"
                                       3
                                      288
                                    $20,949
                                     $813
                                 "Revised"
                                       3
                                      168
                                    $12,252
                                     $813
                               "Multi-Year"
                                      12
                                      348
                                    $25,356
                                    $1,332
                                     Total
                                      18
                                      804
                                    $58,557
                                    $2,958
                 
 VARIATIONS IN THE BOTTOM LINE
      There is no anticipation of significant variation (>25%) in the annual respondent reporting/recordkeeping burden or cost over the course of the clearance period request. 
           

      6(f)	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 1,708 hours.  The total 3-year estimated hourly burden of 3,762 hours for the anticipated 18 operators represents an annual reporting and recordkeeping hourly burden of 1,254 hours, or 70 hours per operator for this 3-year renewal period.  This decreased adjustment to the annual reporting and recordkeeping hourly burden is 454 hours.  This decreased adjustment is the result of a change to the level of environmental documentation EPA anticipates the operators will submit.

        6(g)	BURDEN STATEMENT


Burden Statement:  The annual public reporting and recordkeeping burden for this collection of information is estimated to average 1,254 hours annually, or 70 hours per response.  This hourly burden reflects annual submission of different levels of environmental documentation by an anticipated 18 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 Docket ID Number 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 Avenue, NW, Washington, D.C.  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.  Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA.  Please include the EPA Docket ID Number EPA-HQ-OECA-2007-0468 and OMB Control Number 2020-0007 in any correspondence.

	Exhibit 1A:  PERMs - ESTIMATED RESPONDENT HOURS AND COST

  Respondent      	       Respondent Rate Range		         Capital/	      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 two PERMs were 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.

"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 thirteen 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 EPAs 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.   "Core" IEE and associated supplemental information comprises the IEE package for the initial submittal of an IEE by an operator.
3.   "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.

"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

Hours  Cost
Hours    Cost
Hours    Cost
Hours    Cost
Hours    Cost
Hours    Cost

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 18 operators per year with 3 new operators and 15 repeat operators each year.  For the 15 repeat operators, the assumptions are that 3 will prepare "Revised" IEEs and 12 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: 18 operators each year for the 3-year ICR renewal period

      Respondent Burden 
Hours		Cost

      Federal Government Burden
Hours			Cost

3 new operators submit "Core" IEEs each year
      Burden per year
      Total 3-year burden


185 x 3 =    555    	$14,678 x 3 = $ 44,034  
555 x 3 = 1,665	$44,034 x 3 = $132,102


  96 x 3 =    288	  $7,254 x 3 = $  21,762
288 x 3 = 864	  $21,762 x 3 = $65,286

3 of 15 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

12 of 15 repeat operators submit new "Multi-Year" IEEs
      Burden per year
      Total 3-year burden


  42 x 12 =  504    	$  3,372 x 12 = $   40,464
504 x 3 =    1,512  	$40,464 x 3 = $ 121,392


  29 x 12 =  348	$ 2,224 x 12 = $26,688
348 x 3 =   1044   	$26,688 x 3 = $80,064

ANNUAL TOTAL BURDEN for 18 operators
ANNUAL TOTAL BURDEN per operator
TOTAL 3-YEAR BURDEN for 18 operators
TOTAL 3-YEAR BURDEN per operator

        1,254	   $100,575
             70	   $ 5,588
        3,762	   $301,725
           209                                   $ 16,763

            804	   $ 61,515
             45	   $   3,418
        2,412	$ 184,545
           134	 $   10,253



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: 18 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

3 new operators submit "Core" IEEs each year
      Burden per year
      Total 3-year burden


$   301 x 3 = $  903       $903  +   43,131 = $  44,034   $903 x 3 = $  2,709     $2,709   + 129,393 = $132,102


$   271 x 3 = $813     $ 813  +   20,949 = $  21,762
$813 x 3 = $2,439     $ 2,439  +  62,847 = $65,286

3 of 15 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

12 of 15 repeat operators submit new "Multi-Year" IEEs
      Burden per year
      Total 3-year burden



$  132 x 12 = $ 1,584     $ 1,584 +   38,880 = $ 40,464
$ 1,584 x 3 = $ 4,752     $4,752 + 116,640 = $ 121,392



$   111 x 12 = $ 1,332     $ 1,332  +  25,356 = $26,688
$ 1,332    x 3 = $3,996    $ 3,996 +   76,068 = $80,064


ANNUAL TOTAL BURDEN for 18 operators
ANNUAL TOTAL BURDEN per operator
TOTAL 3-YEAR BURDEN for 18 operators
TOTAL 3-YEAR BURDEN per operator

             O&M        Labor	Total Cost
             $ 3,390 +   97,185   = 	$100,575
             $     188 +     5,399 =	$    5,587
             $10,170 + 291,555 =	$301,725
             $     565 +   16,198 =	$  16,763

             O&M        Labor	             Total Cost
             $2,958 +   58,557 =	              $ 61,515
             $   164 +     3,253 =	              $    3,417
             $8,874 + 175,671 =	              $184,545
             $   493 +   9,759 =	              $ 10,253











	PART B OF THE SUPPORTING STATEMENT
	STATISTICAL SURVEY


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