Burden Tables

2020t07Calculations.xlsx

Federal Implementation Plans under the Clean Air Act for Indian Reservations in Idaho, Oregon, and Washington (40 CFR Part 49, Subpart M) (Renewal)

Burden Tables

OMB: 2060-0558

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Overview

Tables
Wage_rate


Sheet 1: Tables

74.33 Note: "Original FARR" numbers reflect current ICR; hidden lines contain future proposed FARR revisions, not applicable to current ICR.







See Wage_rate tab for basis of composite hourly wage rate




Table 1a. Labor Costs per Respondent for the Rule for Partial Delegation of Administrative Authority to a Tribe - Original FARR (49.122) (2017$)





















New









Current Recurring Labor Recurring Number of New Labor Cost Total








Number of Hours per Year Labor Cost New Respondents Labor Hours Per Year Labor Cost








Respondents
Per Source Per Year Per Year Per Source Per Year






Apply for Delegation
0 0 $0 1 180 $13,379 $13,379
Five tribes have already received delegation under 49.122 and few additional tribes are expected to request delegation. For purposes of this ICR, it is assumed that one additional tribe will request delegation in the next 3 years.




Total All Respondents
0 0 $0 1 180 $13,379 $13,379






































Table 2a. Labor Costs per Respondent for the Fugitive Particulate Matter Rule - Original FARR (49.126) (2017$)





















New Source









Current Recurring Labor Recurring Number of New Source Labor Cost Total








Number of Hours per Year Labor Cost New Sources Labor Hours Per Year Labor Cost








Respondents
Per Source Per Year Per Year Per Source Per Year






Simple
46 2 $149 1 6 $446 $595
Used the same proportion of sources (simple, moderately complex) from the previous ICR, and applied to the revised total of 60 sources.




Moderately Complex
14 10 $743
20 $1,487 $2,230






Construction/Demolition


$0 39 6 $446 $446






Total All Respondents
60 232 $17,245 40 240 $17,839 $35,084






































Table 3a. Labor Costs per Facility for the Sulfur in Fuels Rule - Original FARR (49.130) (2017$)





New Source









Current
Recurring Number of New Source Labor Cost Total








Number of Recurring Labor Labor Cost New Sources Labor Hours Per Year Labor Cost








Respondents Hours per Year Per Source Per Year Per Year Per Source Per Year






















All Affected Facilities
115 10 $743 2 10 $743 $1,487






Total All Respondents
115 1150 $85,480 2 20 $1,487 $86,966






































Table 4a. Labor Costs per Respondent for the Open Burning Rule - Original FARR (49.131) (2017$)
















Current














Number of Recurring Labor Recurring












Respondents Hours per Year Labor Cost


























Fire Protection Services
3 3 $223




Although no sources are currently listed under section 49.131, we conservatively assume the number of requests for permission to perform open burning for firefighting training to be 3 per year under the original FARR




Total All Respondents
3 9 $669










































Table 5a. Labor Costs per Facility and Total Costs for the General Open Burning Permits Rule - Original FARR (49.132) (2017$)
































Number of Recurring Labor Recurring












Respondents Hours per Year Labor Cost


























Apply for Large Permit
177 0.5 $37










Total All Respondents
177 89 $6,578












































































Number of Recurring Labor Recurring












Respondents Hours per Year Labor Cost


























Apply for Small Permit
863 0.5 $37










Total All Respondents
863 432 $32,073


























































Table 6a. Labor Costs per Facility and Total Costs for the Agricultural Burning Permits Rule - Original FARR (49.133) (2017$)
































Number of Recurring Labor Recurring












Respondents Hours per Year Labor Cost


























Apply for Permit
200 0.45 $33










Total All Respondents
200 90 $6,690










































Table 7a. Labor Costs per Facility and Total Costs for the Forestry and Silvicultural Burning Permits Rule - Original FARR (49.134) (2017$)
































Number of Recurring Labor Recurring












Respondents Hours per Year Labor Cost


























Apply for Permit
25 0.6 $45










Total All Respondents
25 15 $1,115










































Table 8a. Labor Costs per Facility for the Registration Rule - Original FARR (49.138) (2017$)
















Current

Number of New Source New Source Total








Number of Recurring Labor Recurring New Sources Labor Hours Labor Cost Labor Cost








Respondents Hours per Year Labor Cost Per Year Per Year Per Year Per Year






















Simple



3 10 $743 $743






No Modifications
115 4 $297




Used the same proportion of sources (simple, moderately complex, etc.) from the previous ICR, and applied to the revised total of 152 sources.




Modifications
5 8 $595










Moderately Complex & Title V



1 41 $3,048 $3,048






No Modifications
24 14 $1,041










Modifications
2 20 $1,487










Administrative Modificationsb
6 2 $149










Total All Respondents
152 888 $66,005 4 71 $5,277 $71,282






















b Administrative modifications could be made by simple facilities, moderately complex facilities, or Title V facilities, but there is no obvious way to assign














these costs to particular categories. These costs could be incurred by any facility in addition to the costs specific to the category they are in. The














administrative mods do not get counted in the total all respondents since they are already counted elsewhere.














































Table 9a. Labor Costs per Facility for the Operating Permits Rule - Original FARR (49.139) (2017$)
















# of Respond.
Average Number of New Source New Source Total








by end of ICR Recurring Labor Recurring New Sources Labor Hours Labor Cost Labor Cost








timeframe Hours per Year Labor Cost Per Year Per Year Per Year Per Year






















Apply for Permit
16 50 $3,717 0 250 $18,583 $22,299
Revised number of respondents based on information in latest list of registered sources




Total All Respondents
16 800 $59,464 0 0 $0 $59,464






































Table 10a. Total Cost of the Federal Air Rules for Reservations - Original FARR (2017$)

















New Source Total
New Source Total Total Number


Total


Rule Title Recurring Labor Cost Labor Cost Recurring Labor Hours Labor Hours of


Labor Hours




Labor Costs Per Year Per Year Labor Hours Per Year Per Year Respondants No. responses Hrs/response $/response Reporting Recordkeeping

Section 49.122 Partial Delegation of Administrative Authority to a Tribe $0 $13,379 $13,379 0 180 180 1 1 180 $13,379



Section 49.126 Fugitive Particulate Matter $17,245 $17,839 $35,084 232 240 472 100 100 4.7 $351



Section 49.130 Sulfur Content of Fuels $85,480 $1,487 $86,966 1150 20 1170 117 468 2.5 $186



Section 49.131 Open Burning $669 $0 $669 9 0 9 3 3 3 $223



Section 49.132A Large Open Burning Permits $6,578 $0 $6,578 89 0 89 177 177 0.5 $37



Section 49.132B Small Open Burning Permits $32,073 $0 $32,073 432 0 432 863 863 0.5 $37



Section 49.133 Agricultural Burning Permits $6,690 $0 $6,690 90 0 90 200 200 0.45 $33



Section 49.134 Forestry Burning Permits $1,115 $0 $1,115 15 0 15 25 25 0.6 $45



Section 49.138 Registration of Air Pollution Sources and the Reporting of Emissions $66,005 $5,277 $71,282 888 71 959 156 156 6.1 $457



Section 49.139 Operating Permits for Non-Title V Sources $59,464 $0 $59,464 800 0 800 16 16 50 $3,717



TOTAL
$275,318 $37,983 $313,301 3,704 511 4,215 1,658 2,009 2.10 $156 2,093 2,122
Total labor hours include 320 hours for non-title V reporting and 480 hours for non-title V recordkeeping



















Cost/response $156
Hours/response 2.10










Cost/respondent $189
Hours/respondent 2.54
























Basic Rules $228,862 $37,983 $266,845 3079 511 3590 393







Additional Rules $46,456 $0 $46,456 625 0 625 1265

























respondent+EPA $1,052,048













respondent+EPA 16,071



























Sheet 2: Wage_rate

Determination of 2017 Industry Wage Rates 1














Professional staff @ $53.80/hr 1





$53.80








Management support @ $71.12/hr 1



$71.12
+
Allocation Factor: 0.091 2


x 0.091

$6.21





$6.47








Office / administrative support @ $26.10/hr 1



$26.10
+
Allocation factor: 0.125 3


x 0.125








$3.26








Composite Wage Rate of Staff






associated Management / Clerical support





$63.53







+
General Overhead @ 17% of wage rate





$10.80








Total Composite Hourly Wage Rate $71.46





$74.33








1 Wage Rates (including benefits) by Employment Cost Trends, June 2017. Available at http://stats.bls.gov/news.release/ecec.t02.htm.






2 Represents a manager overseeing a staff of 10 technicians and one support person, e.g., a manager to staff ratio of 1:11, or 1/11 or 0.091 .






3 Represents one administrative support person assisting 7 professional staff and a manager, e.g., a support person to professional staff and manager ratio of 1:8, or 1/8 or 0.125.






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