Supplemental Burden Tables

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Overview

Tables
Wage_rate

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Sheet 1: Tables

EPA/Delegated Tribes FTE				Small Entity Estimates
FTE					Orig FARR	Estimated # of	Estimated # of
Estimate	Tasks	Explanation of changes		Rule #		Respondents	Small Entities	Comments	Explanation of changes
0.45	Registration, including online registration system	Burden will be slightly higher the first year but overall the burden will decrease in subsequent years. No change made.		49.122	Orig FARR	1	1	Assumed all Tribal governments were small entities.	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.
0.70	Misc approvals & oversight related to reporting & recordkeeping	Increase in FTEs expected to be within rounding error. No change made.
0.50	Non-Title V operating permits	Increase in FTEs expected to be within rounding error. No change made.		49.126	Orig FARR	100	86	Assumed all the simple sources and construction sources were small entities.	Used the same proportion of sources (simple, moderately complex) from the previous ICR, and applied to the revised total of 100 sources.
2.75	Nez Perce Burn Permit Program
1.00	Umatilla Burn Permit Program			49.130	Orig FARR	117	108	Assumed all but T5 sources were small entities.
0.20	Database Development			49.131	Orig FARR	3	3	Assumed all were small entities.	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.
0.10	Delegations
5.70	TOTAL			49.132	Orig FARR	1040	1014	For large open burns (farms and businesses), assumed 85%* were small entities. For small open burns (individuals), assumed all were small entities.
EPA Average Annual Burden and Costs
				49.133	Orig FARR	200	170	Assumed 85%* of farms were small entities.
Total Hours	$/Hour	Annual EPA Cost
Original FARR				49.134	Orig FARR	15	8	For Governmental entities, assumed 50% were federal (large) and 50% were tribal (small).
11,856	$62.31	$738,747			Orig FARR	10	8	For logging industry businesses, assumed 75% were small entities.
0		$0		49.138	Orig FARR	156	145	Assumed all but T5 sources were small entities.	Used the same proportion of sources (simple, moderately complex, etc.) from the previous ICR, and applied to the revised total of 156 sources.
TOTAL
11,856		738,747		49.139	Orig FARR	16	3	These sources are generally large enough to be major sources, therefore we assumed only 20% were small entities.	Revised number of respondents based on information in latest list of registered sources.
See Wage_rate tab for basis of composite hourly wage rate
				* For farms, we used the 2002 Census of Agriculture data for Idaho and Oregon to estimate
				the number of farms that are considered small entities (less than $750,000 average annual receipts).
				We calculated approx. 89% of farms are small entities for Oregon and 81% for Idaho, so we used an
				average of 85% overall for our estimates.

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Sheet 2: Wage_rate

Determination of 2017 Federal Salary Rates 1
and Total Hourly Cost									Annual salary	Hours	Hourly rate
Wage rate of Permit Staff, GS 11 Step 5 2							$35.42		$73,681	2,080	$35.42
Wage rate of Supervisory Staff, GS 13 Step 5 2					$50.49		+		$105,018	2,080	$50.49
	Factor: 0.091 3			x	0.091
							$4.59
Wage rate of Support Staff, GS 6 Step 5 2					$21.54		+		$44,805	2,080	$21.54
	Factor: 0.091 4			x	0.091
							$1.96
Annual Applicable Salary of Permit,
Supervisor and Support Staff							$41.97
							+
Benefits (36.45 percent of salary) 5							$15.30
							+
General Overhead (12 percent of salary) 5							$5.04
Total Hourly Cost							$62.31
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1 The salary levels shown for the positions indicated are assumed to represent the average of the combined salaries
for EPA, Tribal and SEE program staff allocated to the respective position classification.
2 U.S. Office of Personnel Management. “Salary Table 2017-SEA”, General Schedule incorporating locality pay.
https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2017/SEA.pdf
3 Based on an administrator managing a staff of 10 technicians and one support staff person, i.e., a 1/11 ratio,
where: 1/11 = 0.091
4 Based on one support staff person assisting 10 technicians and one manager, i.e., a 1/11 ratio = 0.091
5 OMB Circular A-76. “Figure C1 - Table of Standard A-76 Costing Factors”; and OMB Circular
No. A-76 Revised, May 29, 2003, reflecting OMB Memorandum M-07-02. Applicable to FY 07.
http://www.whitehouse.gov/omb/circulars/index.html
In OMB Circular A-76, Figure C1:
- The term Benefits is identified as “Civilian Position Full Fringe Benefit Cost Factor”; and
- The term General Overhead is identified as “Overhead Factor.”