1813ss09

1United States Environmental Protection Agency

EPA

Office of Air and Radiation

Office of Air Quality Planning and Standards

Air Quality Policy Division

Geographic Strategies Group

August, 2003

INFORMATION COLLECTION REQUEST

SUPPORTING STATEMENT FOR

EPA ICR NUMBER 1813.09,

RENEWAL OF THE ICR FOR THE REGIONAL HAZE REGULATIONS

EPA # 1813.09

EPA # 1230.16

Executive Summary

Draft 05/01/06

This ICR, EPA Form 1813.09, is an update of the Office of Management and Budget (OMB) Control Number 2060-0421; EPA Form 1813.08 which expires on March 31, 2016. The current approved collection is for 53 respondents, 6,048 hours per year, and $293,631 per year. This renewal requests approval for 52 respondents (52 state agencies), 10,307 hours per year and $510,489 per year. Table E.1 summarizes the total annual respondent burden for this renewal. Tribes are not required to submit regional haze plans, so there are no burden estimates for Tribal governments.

The change in burden reflects changes in labor rates, changes in the activities conducted due to the normal progression of the program, and the fact that the states will be shifting their primary focus to development of interim progress reports required by the regional haze rule and to development of periodic comprehensive SIP revisions due in 2018 (and, for 2 states, development of initial SIPs).

Table E-1 Estimated State Respondent Burden to Implement Requirements

Task Element	States
	Average Annual Hours	Average Annual Cost ($)
Total Burden by Respondent	10,307	510,489

1.1 Title

EPA TRACKING NUMBER: 1813.09

E-TRACKING NUMBER:

OMB-2060-0421

1 Identification of the Information Collection

1.2 Description

This document fulfills the Agency's requirements under the Paperwork Reduction Act (PRA) with regards to determining the regulatory burden associated with the implementation of the regional haze program (40 CFR 51.308) and requirements related to the Grand Canyon Visibility Transport Commission (40 CFR 51.309). It has been assigned EPA tracking number 1813.09. The title of this Information Collection Request (ICR) is “Information Collection Request Supporting Statement for EPA ICR Number 1813.09, Renewal of The ICR for the Regional Haze Rule.”

Subpart P of 40 CFR 51, Protection of Visibility, also known as the regional haze rule, is the subject of this clearance request. In the next three years, activities conducted by the states, Federal Land Managers (FLMs), and the EPA will focus on submitting SIP revisions and progress reports for regional haze. 40 CFR 51.308 (f) requires states to develop regional haze implementation plan revisions evaluating and reassessing reasonable progress goals, calculations of baseline and natural visibility conditions, the long-term strategy, the monitoring strategy and other implementation plan requirements. There are similar reporting requirements under 40 CFR 51.309, a section of the regional haze rule in which three states (Utah, Wyoming, and New Mexico) elected to submit their SIPs. Under section 309, these states adopted regional haze strategies for the period from 2003 to 2018 for sulfur dioxide emissions. These strategies are based on recommendations from the Grand Canyon Visibility Transport Commission (GCVTC) for protecting the 16 Class I areas in the Colorado Plateau area. During the next three years, fourteen states will also be responsible for submitting progress reports. 40 CFR 51.308 (g) requires states to develop periodic reports evaluating progress towards the reasonable progress goals for improving visibility in Class I areas inside the state and in neighboring states, and 40 CFR 51.309(d)(10) requires similar actions on the part of the 3 states that submitted regional haze SIPs under 40 CFR 51.309.

Under the 1999 regional haze rule, states are required to set periodic goals for improving visibility in the 156 Mandatory Class I Federal Areas. As states work to reach these goals, they must develop regional haze implementation plans that contain enforceable measures and strategies for reducing visibility-impairing pollution. States were required to develop their initial implementation plans by December, 2007. Periodic comprehensive revisions to implementation plans are due July 31, 2018 and every 10 years thereafter.

The primary focus for estimating burden for this 3 year renewal period (March 31, 2016 – March 31, 2019) will apply to the next program milestone which are the periodic comprehensive SIP revisions due in July 2018 (see 40 CFR 51.308(f)) for all states, including those covered under 40 CFR 51.309. In addition, 2 states have still yet to submit the first SIPs due December 17, 2007 (see 40 CFR 51.308(b)). In the 5-year progress report required by 11 states during this 3 year renewal period, those states are required to describe the status of the implementation of measures needed to achieve reasonable progress goals, report on the emissions reductions achieved, assess visibility changes, and evaluate whether the current implementation plan is sufficient to meet all established reasonable progress goals. Similar progress report requirements apply to the 3 states covered under 40 CFR 51.309.

2.1 Need / Authority for the Collection

2 Need and Use of the Collection

Section 169A of the Clean Air Act (CAA) sets forth a national goal for visibility. The goal is the “prevention of any future, and the remedying of any existing, impairment in visibility in mandatory Class I Federal areas which impairment results from man-made air pollution.” This section of the CAA also calls for EPA regulations to assure that states provide for reasonable progress toward meeting the national goal. The original regulations on protection of visibility in mandatory Class I Federal areas, developed in 1980, addressed visibility that is “reasonably attributable” to a single source or small group of sources. Actions under those regulations

are triggered by a FLM. The regional haze rule, promulgated in 1999, added new sections to the code of federal environmental regulations. These included sections 40 CFR 51.308 and 40 CFR 51.309. This ICR renewal request provides for continued implementation of the regional raze rule. During this clearance period, we anticipate that the reporting requirements under 40 CFR 51.308(f) and (g) will be the major program focus along with the similar reporting requirements (see 40 CFR 51.309(d)(10)) for the three states that submitted regional haze SIPs under 40 CFR 51.309 (and for 2 states, the reporting requirements for the first SIPs under 40 CFR 51.308(b)).

2.2 Practical Utility / Users of the Data

The data collected from respondents include revised state implementation plans and progress reports. These data confirm progress in assessing visibility impairment and source contribution, and provide the foundation for the establishment of the reasonable progress goals and control strategies.

2.3 Caveats and Considerations

The information in this ICR is based upon the best data available to the Agency at this time. However, incomplete data and sampling limitations imposed necessitated a certain amount of extrapolation and “best-guess” estimates. Consequently, the reader should not consider the conclusions to be an exact representation of the level of burden or cost that will occur. Instead, this ICR should be considered a directionally correct assessment of the impact the programmatic changes included in this rulemaking may have over the next 3 years.

Throughout this ICR, the reader will observe estimated values that show accuracy to the single hour or dollar. However, reporting values at the single unit level can be misleading. In most situations, the proper way to present estimated data would be to determine an appropriate level of precision and truncate values accordingly, usually in terms of thousands or millions of units. For instance, a spreadsheet generated estimation of $5,456,295 could be presented in the text as $5.5 (millions) or $5,456 (thousands). One problem with such an approach is the loss of data richness when the report contains a mixture of very large and very small numbers. Consequently, to avoid the loss of information through rounding, this ICR reports all values at the single unit level and reminds the reader that there is no implied precision inherent in this style of reporting.

3.1 Non-Duplication

This information collection renewal request is related to provisions in 40 CFR 51.308(b), (f) and (g) and 40 CFR 51.309(d)(10) which require initial SIPs, periodic comprehensive SIP revisions and periodic reports (in the form of implementation plan revisions) describing progress towards the reasonable progress goals. In addition to the periodic comprehensive SIP revisions due July 31, 2018 each state must submit a progress report evaluating whether improvement in visibility is made towards the reasonable progress goal for each mandatory Class 1 Federal area located within the state and in each mandatory Class 1 Federal area located outside the state which may be affected by emissions from within the state. For most states, these progress reports are due 5 years from the submittal of the initial regional haze plan. The initial SIPs, periodic comprehensive SIP revisions and progress reports required by the regional haze rule are unique and do not duplicate other implementation plan requirements.

3 Non-Duplication, Consultation, and Other Collection Criteria

3.2 Public Notice Requirements

The ICR for the regional haze rule was revised last in March 2013. We

solicited public comments on this ICR prior to submitting it to OMB. We

issued a Federal Register notice requesting comments on the ICR renewal

on September 29, 2015 (80 FR 58473) and provided a 60-day public notice and comment period. The EPA received no comments during the comment period.

3.3 Consultations

Additionally, under 5 CFR 1320.8(d)(1), OMB requires agencies to consult with potential ICR respondents and data users about aspects of ICRs before submitting an ICR to OMB for review and approval. In accordance with this regulation, the EPA submitted questions to nine parties via e-mail. The individuals contacted were:

Albert Pearce

Georgia Department of Natural Resources

Albert.Pearce@dnr.ga.gov

Michael Kiss

Virginia Department of Environmental Quality

michael.kiss@deq.virginia.gov

David Healy

New Hampshire Department of Environmental Services

david.healy@des.nh.gov

Preston McLane

Florida Department of Environmental Protection

Preston.McLane@dep.state.fl.us

Jerry Beasley

Mississippi Department of Environmental Quality

Jerry_Beasley@deq.state.ms.us

Maeve Mason

South Carolina Department of Health and Environmental Control

masonmr@dhec.sc.gov

Sushma Masemore

North Carolina Department of Environmental Quality

sushma.masemore@ncdenr.gov

Jim Boylan

Georgia Department of Natural Resources

James.Boylan@dnr.ga.gov

Jimmy Johnston

Tennessee Department of Environment & Conservation

James.Johnston@tn.gov

Mr. David Healy of the New Hampshire Department of Environmental Services responded and agreed with the estimates of burden on potential respondents, with the caveat that it could take somewhat longer than 500 hours for a state to prepare periodic comprehensive SIP revisions in some circumstances, especially for a state that contains one or more Class I Federal areas. The EPA received no other responses to its solicitation for consultations.

3.4 Less Frequent

Collection

The information collection requested under this ICR is necessary to ensure implementation of the 40 CFR 51.308 and 40 CFR 51.309 requirements.

3.5 General

Guidelines

OMB's general guidelines for information collections must be adhered to by all federal agencies for approval of any rulemaking's collection methodology. In accordance with the requirements of 5 CFR 1320.5, the Agency believes:

1. The regional haze regulations do not require periodic reporting more frequently than every 5 years.

2. The regional haze regulations do not require respondents to participate in any statistical survey.

3. Written responses to Agency inquiries are not required to be submitted in less than 30 days.

4. Respondents do not receive remuneration for the preparation of reports required by the Act or part 51.

5. To the greatest extent possible, the Agency has taken advantage of automated methods of reporting.

The recordkeeping and reporting requirements contained in the current regional haze program and the changes proposed in this rulemaking do not exceed any of the Paperwork Reduction Act guidelines contained in 5 CFR 1320.5, except for the guideline which limits retention of records by respondents to 3 years. The Act requires both respondents and state or local agencies to retain records for a period of 5 years. The justification for this exception is found in 28 U.S.C. 2462, which specifies 5 years as the general statute of limitations for federal claims in response to violations by regulated entities. The decision in U.S. v. Conoco, Inc., No. 83-1916-E (W.D. Okla., January 23, 1984) found that the 5-year general statute of limitations applied to the CAA.

3.6 Confidentiality

Confidentiality is not an issue for this rulemaking. In accordance with the Clean Air Act Amendments of 1990, any monitoring information to be submitted by sources is a matter of public record. To the extent that the information required is proprietary, confidential, or of a nature that could impair the ability of the source to maintain its market position, that information is collected and handled subject to the requirements of §503(e) and §114(c) of the Act. Information received and identified by owners or operators as confidential business information (CBI) and approved as CBI by EPA, in accordance with Title 40, Chapter 1, Part 2, Subpart B, shall be maintained appropriately (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 39999, September 8, 1978; 43 FR 42251, September 28, 1978; 44 FR 17674, March 23, 1979).

3.7 Sensitive

Questions

The consideration of sensitive questions, (i.e., sexual, religious, personal or other private matters), is not applicable to this rulemaking. The information gathered to develop an implementation plan does not include personal data on any owner or operator.

3.8 Environmental Justice Considerations

Because the regional haze program operates nationwide and across numerous industry classifications, the Agency does not believe there are disproportionate environmental justice impacts in implementing in the regional haze program.

4.1 Respondents

4 The Respondents and the Information Requested

The major categories of respondents directly affected during this ICR period of March 31, 2016 through March 31, 2019 include the states. The states are developing periodic comprehensive SIP revisions and progress reports under 40 CFR 51.308(f) and (g) and 40 CFR 51.309(d)(10) which require periodic comprehensive SIP revisions and periodic reports (in the form of implementation plan revisions) evaluating progress towards the reasonable progress goal for each mandatory Class I Federal area located within the state and in each mandatory Class I Federal area located outside the state which may be affected by emissions from within the state. In addition, 2 states are developing initial SIPs under 40 CFR 51.308(b).

4.2 Information

Requested

The information required under this ICR renewal provides for a continuation of the process initiated with previous ICRs for the regional haze rule. In this stage of the process, the states are mainly focusing on revising their SIPs and submitting periodic comprehensive SIP revisions by July 31, 2018, which falls within this ICR period. In addition, 2 states are focusing on submitting initial SIPs, the requirements for which are substantially similar to the requirements for the periodic comprehensive SIP revisions. Certain states are also working on progress reports to report on progress made towards reaching their long term visibility goals. For 14 states, the progress reports will be due during the March 31, 2016 to March 31, 2019 ICR period.

The information that is requested under this renewal period under the regional haze rule requirements includes:

Requirements for Periodic Reports Describing Progress towards the Reasonable Progress Goals

• Description of status of control measures

• Summary of emission reductions

• Calculation of visibility conditions and changes

• Calculation of 5 year progress

• Assessment of contributing emissions

• Assessment of reasonable progress goals

• Review monitoring strategy and note changes

• Submit 5 year progress report

• Determine degree of visibility improvement

• Consult with FLMs

• Interstate consultation with states

The progress report must be in the form of an implementation plan revision that complies with procedural requirements of 40 CFR 51.102 and 40 CFR 51.103. For most states, the report is due five years after the initial regional haze plan submission.

Requirements for Regional Haze Periodic Comprehensive SIP Revision

• Affirmation of, and revision to, reasonable progress goals, including determination of reasonableness of any additional measures that could be adopted to achieve the degree of visibility improvement projected by the analysis in the original SIP

• Calculate baseline and natural visibility conditions

• Address current visibility conditions and actual progress made toward natural conditions

• Conduct 2028 modeling

• Evaluate effectiveness of, and re-develop, long term strategies

• Submit monitoring strategy

The States are working to prepare and submit periodic comprehensive SIP revisions by the July 2018 deadline.

5 The Information Collected - Agency Activities, Collection Methodologies, and Information Management

5.1 Agency Activities

EPA. Each EPA regional office is responsible for reviewing and approving the periodic comprehensive SIP revisions and progress reports. For this ICR renewal period, the EPA will primarily be reviewing the SIP revisions and progress reports required under CFR 51.308(f) and (g) and 51.309(d)(10). The ten EPA regional offices and the EPA headquarters offices will provide direction and facilitate resolution of major issues, and deliver data, tools, and training to the states as needed. Each regional office must address public comments before approving the SIP revisions.

FLMs. The FLMs will be reviewing the progress reports, the periodic comprehensive regional haze SIP revisions, and offering comments to the states in fulfillment of the requirement under 40 CFR 51.308(i)(4) for the states to coordinate their regional haze efforts with the FLMs.

5.2 Collection

Methodology

and

Management

This section discusses the development of burden estimates and their conversion into costs, which are separated into burden costs and capital and O&M costs. Capital and O&M costs display the cost of any new capital equipment the respondent may have to purchase solely for information collection, assimilation, and storage purposes. For example, if a source had to purchase a new mini-computer to store and manipulate data, that computer would be a cost of administration subject to reporting in the ICR. In addition, the latest guidance instructs the Agency to differentiate the burden associated with a source’s labor and that which it hires through outside contractors. To the extent a source contracts out for administrative purposes (e.g., employing consultants to perform visibility modeling), the burden associated with those contracted tasks are not a burden to the source - but they still remain a cost. The reader should read this section with the following considerations in mind:

• The Agency believes the time necessary to perform a task is independent of the origins of its labor. For example, if a source would employ 20 hours of burden to fully perform a function, then a contractor hired by the source would also take 20 hours to perform that same task. Furthermore, the Agency assumes no economies or diseconomies of scale. The linear combination of any amount of contractor and source effort will also sum to 20 hours. Therefore, the burden estimates in this ICR act as an accurate assessment of the total burden to respondents.

• For some burden categories, the Agency believes the hours assigned to them will be divided between the source and outside contractors. For these categories, the Agency established a composite cost per hour by developing a weighted average of the source and contractor wages, with the weight defined by the percentage of total effort each burden source applied. Consequently, the cost developed in this ICR should be interpreted as an upper bound on the actual cost of administration by the source. The methodology for determining cost per hour can be found in greater detail in section 6.2, below.

• While this ICR renewal estimates burden to federal and state agencies, it does not include costs estimates to the industrial sources. This is because the effort for this ICR renewal period, March 31, 2016 through March 31, 2019 mainly involves preparation and review of the periodic comprehensive SIP revisions and progress reports required under CFR 51.308(f) and (g) and 51.309(d)(10) of the regional haze rule. Sources, for the most part, will not be involved in preparation of these reports.

The periodic comprehensive SIP revisions prepared by the states are due by July 31, 2018. The periodic comprehensive SIP revisions must at a minimum include the following elements (similar elements are required for the initial SIPs):

• A summary of affirmation of, and revision to, reasonable progress goals, including determination of reasonableness of any additional measures that could be adopted to achieve the degree of visibility improvement projected by the analysis in the original SIP

• A description of baseline and natural visibility conditions

• An assessment of current visibility conditions and actual progress made toward natural conditions

• Details on modeling conducted for the 2028 milestone

• A summary of the effectiveness of, and re-development of, long term strategies

• A description of the monitoring strategy

The progress reports prepared by the states are, in most cases, due five years after the state submits its comprehensive regional haze SIP. The progress reports must at a minimum include the following elements:

• A description of the status of all measures included in the regional haze implementation plan for achieving reasonable progress.

• A summary of the emissions reductions achieved throughout the state through implementation of the measures.

• An assessment of the following visibility conditions and changes for each mandatory Class 1 Federal area within the state with values for most impaired and least impaired days expressed in terms of 5-year averages of the annual values: current visibility conditions for the most impaired and least impaired days; the difference between current visibility conditions for the most impaired and least impaired days and baseline visibility conditions; and the change in visibility impairment for the most impaired and least impaired days over the past 5 years.

• An analysis tracking the change over the past 5 years in emissions of pollutants contributing to visibility impairment from all sources and activities within the state.

• An assessment of any significant changes in anthropogenic emissions within or outside the state that have occurred over the past 5 years that have limited or impeded progress in reducing pollutant emissions and improving visibility.

• An assessment of whether the current regional haze implementation plan elements and strategies are sufficient to enable the state, or other states with mandatory Class I Federal areas affected by emissions from the state, to meet all established reasonable progress goals.

• A review of the state’s visibility monitoring strategy and any modifications to the strategy as necessary.

• Other elements, including reporting, record keeping, and other measures, necessary to assess and report on visibility.

5.3 Small Entity

Flexibility

The Regulatory Flexibility Act (RFA) requires regulatory agencies, upon regulatory action, to assess that action’s potential impact on small entities (businesses, governments, and small non-governmental organizations) and report the results of the assessments in (1) an Initial Regulatory Flexibility Analysis (IRFA), (2) a Final Regulatory Flexibility Analysis (FRFA), and (3) a Certification. For ICR approval, the Agency must demonstrate that it "has taken all practicable steps to develop separate and simplified requirements for small businesses and other small entities" (5 CFR 1320.6(h)). In addition, the agencies must assure through various mechanisms that small entities are given an opportunity to participate in the rulemaking process.

The EPA determined that it was not necessary to prepare a regulatory flexibility analysis in connection with the regional haze rule (July 6, 2005, 70 FR 39104) because the rule did not have a significant economic impact on a substantial number of small entities. Similarly, this ICR renewal will not impose any direct requirements on small entities and will apply primarily to states which are developing the SIP revisions.

5.4 Collection

Schedule

States are required to submit their periodic progress reports, in the form of a SIP revision, five years after the initial regional haze plan submission (or in the case of 51.309 states, in 2018). Table 5.1 shows when these reports are due for each of the states. Note that some states have reports which are due outside of this renewal period, before March 31, 2016 or beyond March 31, 2019. Accordingly, we have estimated burden only for the 14 states with due dates that fall within this renewal period.

Table 5.1 Due Dates for the 5 Year Progress Reports¹

State	Progress Report Due Date
Alaska	4/4/2016
Colorado	6/11/2016
Illinois	6/24/2016
Nebraska	6/30/2016
Wisconsin	7/1/2016
District of Columbia	10/27/2016
Massachusetts	12/30/2016
Maryland	2/13/2017
Montana	9/18/2017
Hawaii	10/9/2017
Virgin Islands	10/22/2017
Utah	12/31/2018
Wyoming	12/31/2018
New Mexico	12/31/2018

All states (including those subject to a FIP) are required to develop and submit periodic comprehensive SIP revisions by July 31, 2018.

Two states are required to submit initial SIPs originally due December 17, 2007.

For the purposes of this ICR, we assume that each of these states will in fact submit progress reports and/or periodic comprehensive SIP revisions on the due dates indicated above, and the two states that still need to submit initial SIPs will do so before July 31, 2018.

6 Estimating the Burden and Cost of the Collection

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 ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; and transmit or otherwise disclose the information. The burden estimate should be composed of (1) the total capital and start-up cost component annualized over its useful life; (2) the total operation, maintenance and purchases of services component. Each component should be divided into burden borne directly by the respondent and any services that are contracted out.

6.1 Estimating Respondent Burden

This ICR renewal will apply to 50 states the District of Columbia and the U.S. Virgin Islands which are working on submitting periodic comprehensive SIP revisions (and for 2 of these, initial SIPs), and 11 of which are developing 5-year progress reports in the form of SIP revisions to satisfy the requirements of section 308(g). All periodic comprehensive SIP revisions are due by July 31, 2018. Table 5.1 above shows when progress reports are due for each of the 11 states. For this renewal period, the burden for industrial sources will be negligible as plans and reports are required from the states.

For three states (Utah, Wyoming, and New Mexico) which submitted their regional haze SIPs under section 309 of the regional haze rule, there are also 5-year periodic reporting requirements that are essentially the same as the requirements under section 308(g); the next due date for progress reports for these states is December 31, 2018. Table 6.1 summarizes the results for each of the major categories of respondents with details discussed in the narrative below.

Develop and Submit Progress Reports as required under the Regional Haze Rule. Based on the elements that are required for the report, which are described in section 5.2 above, we believe that an estimate of 280 hours per state to complete the 5-year progress report is reasonable. Much of the analysis for the report will entail the states assessing changes in their emission inventories for the reporting period and reporting on changes in visibility based on available monitoring data. This burden estimate does not include any hours for preparation and finalization of the emission inventories because it is assumed that the EPA will provide an approved inventory, with appropriate forward projections of future visibility conditions, which the states may use for their analyses. For each individual state, we believe that approximately 160 hours on average is needed to analyze, evaluate, and summarize changes in the inventory and monitoring data over the reporting period, and another 80 hours is sufficient to prepare the report in the form of a SIP revision. These estimates are based on informal conversations with state and the EPA’s technical staff. Finally, we assumed that states would need approximately 40 additional hours to address and respond to any public comments received on its SIP revision.

Develop and Submit Periodic Comprehensive SIP Revisions (or Initial SIPs) as required under the Regional Haze Rule. Based on the elements that are required for the periodic comprehensive SIP revisions (or initial SIPs), which are described in section 5.2 above, and a review of previous ICRs, we believe that an estimate of 500 hours per state to complete the periodic comprehensive SIP revision (or initial SIP) is reasonable.

Table 6.1. Estimated Respondent Burden to Implement Requirements

Task Element	Hours/State	Hours/Source	Year Incurred
Develop and submit §308(g) or 309(d)(10) Implementation Plan – 5-year periodic reports	280	0	2016 - 2019
Develop and submit periodic comprehensive SIP revisions (or initial SIP)	500	0	2016 - 2018

6.2 Estimating Respondent Costs

This ICR uses the most recently available wage values with the wage rate methods established in the New Source Review (NSR) ICRs². For this renewal period, the burden for industrial sources will be negligible as the reports are required from the states with review being done by the EPA and the FLMs.

Consistent with methodologies for previous NSR ICRs, the labor rate used to calculate federal, state, and local respondents’ labor costs is approximated from the 2015 federal government pay schedule. Managerial rates are accounted for by multiplying the hourly rate by 9%; the clerical support rates are multiplied by 13%.³ The hourly rate is $49.53, and the calculation is shown in Table 6.3

Table 6.3 Determination of Federal, State, and Local Wage Rates

Annual Salary of Technical Staff, GS 11 Step 3 (FY 15 Schedule)*		$54,718.00
Annual Cost of Supervisory Staff, GS 13 Step 3 (FY 15 Schedule)*	$77,989.00
Factor (1/11)	0.09
		$7,019.01
Annual Cost of Support Staff, GS 6 Step 6 (FY 15 Schedule)* Factor (1/8)	$36,392.00
	0.13
		$4,730.96
Annual Applicable Salary of Technical Staff		$66,467.97
Benefits (at 16%)		$10,634.88
Sick Leave / Vacation (at 10%)		$6,646.80
General Overhead (at 29%)		$19,275.71
Total Cost Per FTE		$103,025.36
Total Hourly Cost (Total Per FTE divided by 2,080 hours per year)		$49.53

* https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2015/GS.pdf January 2015

Since the purchase of capital equipment is believed to be an insignificant factor in meeting the requirements associated with this ICR renewal, the EPA assumes the operation, maintenance, or services are also negligible. Most of the data and other guidance for estimating emissions and visibility impacts are available in electronic form and any equipment needed to respond to requests will be part of the respondent’s operating inventory.

6.2.3 Annualized Capital Costs

Typically, annualized capital cost would be derived from a discounted net present value of the stream of costs that would occur over the life of the activity, or the ICR, whichever is shorter. However we do not anticipate these types of expenses will be incurred during this clearance period.

6.3 Estimating Agency Burden and Cost

For this ICR, we have assumed the following number of offices will be involved in implementing the Regional Haze requirements.

EPA Regional Offices. We assume that all 10 EPA Regional Offices will be responsible for reviewing progress reports and SIPs from the states in their jurisdiction, responding to public comments, and preparing federal register notices in taking final action on the SIPs.

EPA Headquarters. The EPA Headquarters staff will provide oversight and review of the submittals.

FLMs. The FLMs will review and comment on the submittals.

Table 6.4 presents our estimate of the Agency burden in the ICR clearance period which is the average to review one state plan. In developing these estimates, we considered previous estimates for similar activities, particularly related to the time necessary to review progress reports and SIPs and prepare federal register notices and respond to public comments.

For the progress reports, summing the total hours from Table 6.4 (360 hours) and multiplying by 14 total progress reports yields a total estimate of 5,040 hours. Using the calculated labor rate of $49.53/hr. from Table 6.3, multiplied by the 5,040 hours gives an estimated cost of $249,631, which when averaged over the 3 year collection period is about $83,210 per year as the Agency’s burden estimate for the progress reports.

For the periodic comprehensive SIP revisions, summing the total hours from Table 6.4 (400 hours) and multiplying by 54 total periodic comprehensive SIP revisions (or initial SIPs) yields a total estimate of 21,600 hours. Using the calculated labor rate of $49.53/hr, from Table 6.3, multiplied by the 21,600 hours gives an estimated cost of $1,069,848, which when averaged over the 3 year collection period is about $356,616 per year as the Agency’s burden estimate for the periodic comprehensive SIP revisions or initial SIPs.

Table 6.4. Estimated Agency Burden to Implement Requirements

Task Element	Hours/EPA Regional Office	Hours/EPA Headquarters	Hours/FLM	Year Incurred
Review §308(g) or 309(d)(10) Implementation Plan – 5-year progress reports	160	20	40	2016 - 2019
Respond to Public Comments and Prepare Federal Register Notices	120	20	0	2016 – 2019
Review periodic comprehensive SIP revisions or initial SIPs	200	20	40	2016 - 2019
TOTAL (progress report)	280	40	40	2016 - 2019
TOTAL (periodic comprehensive SIP revision)	320	40	40	2016 - 2019

6.4 Estimating the Respondent Universe

For the purpose of estimating burden in this ICR, the respondent universe is determined as follows.

States. We assume that 50 states, the District of Columbia, and the U.S. Virgin Islands will develop and submit the periodic comprehensive regional haze SIP revision required in 2018. We assume that 14 states will be affected by the regional haze rule 5-year progress reporting requirements.

Tribes. No tribes have elected to develop and implement the regional haze plan.

Industry. The sole regional haze requirements for this reporting period are for the states to submit periodic progress reports and periodic comprehensive SIP revisions, and thus there is no anticipated burden for industrial sources.

6.5 Bottom Line Burden and Cost

Tables 6.5 summarizes the total annual respondent burden to prepare and submit the 5-year progress reports and the periodic comprehensive revisions to state SIPs (or initial SIPs). The total respondent burden is estimated to be 10,307 hours per year and $510,489 per year. As described in section 6.2.2 and 6.2.3, there are no operation and maintenance costs or capital costs associated with activities to be conducted during this 3-year clearance period. The total number of respondents is 52 (52 state agencies.)

Table 6.5 Estimated Annual Respondent Burden to Implement Requirements

Task Element	States
	Average Annual Hours	Average Annual Cost ($)
Develop and submit §308(g) or 309(d)(10) Implementation Plan – 5-year periodic reports	1,307 Calculation: (280 hours per plan x 14 plans)/3 years= 1,307 hr/yr	64,719 Calculation: (1,307 hrs per yr x labor rate of $49.53)
Develop and submit periodic comprehensive SIP revisions	9,000 Calculation: (500 hours per plan x 54 plans)/3 years= 9,000 hr/yr	445,770 (9,000 hrs per yr x labor rate of $49.53)
Total Burden for Respondent	10,307	510,489

6.6 Reasons for Change in Burden

The burden estimates for this ICR renewal period cover different task elements than those for the previous renewal (1813.08). These differences reflect the requirements of the final regional haze rule with respect to the scheduled events and activities in the implementation process. The last collection request anticipated the program consisting mainly of submission and review of 5-year progress reports. The change in burden reflects changes in labor rates, changes in the activities conducted due to the normal progression of the program, and the fact that the periodic comprehensive regional haze SIP revisions will need to be acted on by the EPA beginning in 2018 and the states will be working on and submitting those periodic comprehensive SIP revisions.

6.7 Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 198 hours per respondent. 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; adjusting the existing ways to comply with any previously applicable instructions and requirements; training personnel to be able to respond to a collection of information; searching data sources; completing and reviewing the collection of information; and transmitting or otherwise disclosing the information. The 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 the 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 through the use of automated collection techniques, the EPA has established a public docket for this ICR under Docket ID No. EPA-HQ-OAR-2003-0162, that is available for public viewing at the Air and Radiation Docket and Information Center, in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the Air Docket is (202) 566-1742. An electronic version of the public docket is available at www.regulations.gov. This site can be used to submit or view public comments, 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, N.W., Washington D.C. 20503, Attention: Desk Officer for EPA. Please include EPA Docket ID No. EPA-HQ-OAR-2003-0162 and OMB Control Number 2060-0421 in any correspondence.

1 The EPA developed FIPs for Hawaii, Montana, and the Virgin Islands and due dates for the progress reports are based on the dates of the FIP promulgation.

2 U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, INFORMATION COLLECTION REQUEST FOR CHANGES TO PREVENTION OF SIGNIFICANT DETERIORATION AND NONATTAINMENT NEW SOURCE REVIEW: EMISSIONS TEST FOR ELECTRIC GENERATING UNITS, August 2006, p. 20

3 Ibid.

INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR EPA ICR NUMBER 1813.09, RENEWAL OF THE ICR FOR THE REGIONAL HAZE REGULATIONS

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