**SUPPORTING STATEMENT**

**– INFORMATION COLLECTION REQUEST (ICR)**  **Federal Implementation Plans t o**  **Reduce Interstate Transport of**

**Fine Particulate Matter and Ozone (** **Renewal )**  **1. 0**  **I dentification**  **of the Information C**  **ollection 1.1**  **Title of the Information Collection** Federal Implementation Plans to Reduce Interstate Transport of Fine Particulate Matter and Ozone , EPA I CR Number 239 1.0 3 , OMB Control Number 2060
- 0667
. **1.2 Short Characterization/Abstract**  The United States Environmental Protection Agency (EPA) is renewing an information collection request for the Federal Implementation Plans to Reduce Interstate Transport of Fine Particulate Matter and Ozone (Transport Rule) to allow for future implementation of the rule
. The Transport Rule was published in the Federal Register on August 8, 2011 (76 FR 48208) 1 and compliance obligations were originally scheduled to commence on January 1, 2012. However, the U .S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) stayed the rule prior to implementation and subsequently issued an opinion vacating the rule. On April 29, 2014 , the U.S. Supreme Court reversed the D.C. Circuit opinion vacating the Transport Rule
. On June 26, 2014, the U.S. Department of Justice filed a motion on EPA’s behalf at the D.C. Circuit seeking to have the stay lifted and to allow compliance obligations under the rule to commence as of January 1, 2015. The D.C. Circuit ha s not yet ruled on that motion. Once implemented, the Transport Rule’s requirements would incorporate and supersede the existing requirements under the Clean Air Interstate Rule (CAIR). CAIR’s requirements, in turn, incorporated certain requirements under the NO X SIP Call. The Transport Rule includes new reporting requirements and , like CAIR and the NO X SIP Call , combines these requirements with existing requirements from the Acid Rain Program (ARP) under Title IV of the C lean A ir A ct (CAA) Amendment s of 1990. Each of these existing requirements has an approved ICR in place
. The current ICRs are : CAIR ( EPA ICR Number 2152.0 5 /OMB Control Number 2060
- 0570) , NO X SIP Call ( EPA I CR Number 1857. 06 /OMB Control Number 2060
- 0445) and ARP ( EPA I CR Number 1633. 16 /OMB Control Number 2060
- 0258)
. Thi s supporting statement and ICR are being submitted to account for the incremental burden associated with the Transport Rule (TR) , once it is implemented and supersedes CAIR
. As such, this supporting statement re ferences the burden anal ys is include d in EPA IC R Numbers 2152.0 4 , 1857.0 5 , and 1633.1 5 , and estimates the change in burden resulting from the TR beyond the scope of the existing IC R for the ARP. The burden included in this ICR includes (1) for units not subject to the ARP, start - up and capital costs , to the extent those costs were not already incurred under CAIR, and ongoing annualized capital costs originally incurred under CAIR , and (2) for all TR
- affected units , operating and maintenance costs incremental to any ARP
- related operation and maintenance costs , including any incremental operating and

1 A supplemental rule extending the Transport Rule’s ozone
- season NO X requirements to sources in five additional states wa s published in the Federal Register on December 27, 2011 (76 FR 80760).Transport Rule ICR July 2, 2014

2 maintenance costs previously incurred under CAIR
. Under the TR , the burden and costs accounted for under the CAIR ICR ( EPA ICR Number 2152.04 ) would no longer occur as part of CAIR implementation
. In stead, all such ongoing burdens and costs would be accounted for under this I CR as part of T R implementation. EPA has publish ed a Notice of Proposed Rulemaking in the Federal Re gister that detail s the additions and changes to reporting requirements associated with the TR
. Taken together, the existing emission reporting requirements under the ARP and CAIR cover many of the same sources and have similar or identical emission reporting requirements as the TR
. The incremental burden imposed by the TR in general is described below. First , sources located in Kansas, Minnesota, Nebraska, and Oklahoma , which were not affected under CAIR, will now be affected under the TR. Specificall y, sources in Kansas, Minnesota and Nebraska will be subject to TR NO X and SO 2 mass emissions annual reporting requirements , and sources in Oklahoma will be subject to TR NO X mass emissions ozone season reporting requirements. Non
- ARP sources in these states will need to install and operate CEMS (or an approved alternative) and meet 40 CFR part 75 requirements for NO X and /or SO 2, as applicable. ARP sources in these states will need to make a one
- time upgrade to their data handling and acquisition system (DAHS) software
. Second , sources located in Georgia and Texas will now be required to report NO X mass emissions during the five
- month ozone season, in addition to being required to report NOx and SO 2 mass emissions for the full year as currentl y required under CAIR
. This change will require some sources to modify their DAHS software. Third , sources located in Florida, Louisiana, and Mississippi, which under CAIR were required to report NO X and SO 2 mass emissions annually , will now onl y be required to report NO X mass emissions for the TR ozone season . (ARP
- affected sources in these states will still be required to report SO 2 mass emissions and NO X emission rate under that program.) This change is a reduction in reporting requirements, but sources may need to modify their DAHS software. Fourth, sources located in Connecticut, Delaware, Massachusetts, and the District of Columbia, which were affected under CAIR, are not affected under the TR. (ARP
- affected sources in these states will still be required to report SO 2 mass emissions and NO X emission rate under that program.) This change is a reduction in reporting requirements for these sources. Sources located in Alabama, Illinois, Indiana, Iowa, Kentucky, Maryland, Michigan, Missouri, New Jersey , New York, No rth Carolina, Ohio, Pennsylvania, South Carolina, Tennessee, Virginia, West Virginia, and Wisconsin will continue to monitor and report NO X and SO 2 mass emissions on a year- round b asis (as well as NO X mass emissions on an ozone
- season basis) under the TR as currentl y required under CAIR. Sources located in Arkansas will , under the TR, continue to report NO X mass emissions for the o zone season onl y as currentl y required under CAIR. To meet the TR emissions monitoring, recordkeeping and reporting requirements, affected units are required to: (1) submit a monitoring plan and certification reports for eachTransport Rule ICR July 2, 2014

3 monitoring system, (2) record hourl y emissions data, and (3) submit reports of their emissions and operating data to EPA. All sources affected by the TR will be required to monitor and report NO X and/or SO 2 emissions in accordance with 40 CFR part 75. Sources with monitors already certified under 40 CFR part 75 may be exempt from initial certification requirements. Like the ARP, the NO X SIP Call, and CAIR, the TR employs emission trading programs as a mechanism to reduce the overall costs of reducing emissions. In addition to the emission monitoring, recordkeeping, and reporting requirements just described, trading programs require other tasks that involve an information collection burden for sources, EPA, and permitting authorities . These tasks include: (1) transferring and tracking allowances; (2) permitting; and (3) determining annual ye ar end compliance. Emission allowance market p articipants using the CAMD Business System (CBS) to transfer allowances are required either to complete and submit an allowance transfer form for each allowance transfer or to perform the transfer on
- line. CBS users that are not covered sources, such as allowance brokers, fuel suppliers, and environmental groups, are also required to file a onetime account information application to establish accounts in CBS. The TR regulates sources directly through Federal Implementation Plans (FIPs) and does not impose any

reporting obligations on non
- industry entities. States have the option to replace the FIPs in whole or in part by submitting revisions to their State Implementation Plans (SIPs). **2. 0**  **N eed**  **for and U**  **se of**  **the C**  **ollection 2.1**  **Need/Authority for the Collection**  Emissions data are of vital importance to the EPA for fulfilling a host of monitoring, standard
- setting, rulemaking, reviewing, and reporting duties
. Section 110(a)(2)(D) of the CAA, often referred to as the “good neighbor” provision o f the Act, requires states to prohibit certain emissions because of their impact on air quality in downwind states. Specifically, it requires all states, within 3 years of promulgation of new or revised NAAQS, to submit state implementation plans ( SIPs ) that prohibit certain emissions of air pollutants because of the impact they would have on air quality

in other states. The Transport Rule addresses the requirement in section 110(a)(2)(D)(i)(I) regarding the prohibition of emissions within a state that wi ll significantl y contribute to nonattainment or interfere with maintenance of NAAQS in any other state. EPA issued two previous rules interpreting and clarifying the requirements of section 110(a)(2)(D)(i)(I). The NO X SIP Call, promulgated in 1998, was l argely upheld by

the U.S. Court of Appeals for the D.C. Circuit in Michigan v. EPA , 213 F.3d 663 (D.C. Cir. 2001 )
. CAIR, promulgated in 2005, was remanded by the D.C. Circuit in North Carolina v. EPA , 531 F.3d 896 (D.C. Cir. ) , modified on rehearing, 550 F.3d. 1176 (D.C. Cir. 2008 )
. Section 301(a)(1) of the CAA also gives the EPA Administrator general authority to prescribe such regulations as are necessary to carry out her functions under the Act , 42 U.S.C. § 7601(a)(1). Pursuant to this section, EPA has the authority to clarify the applicability

of CAA requirements. In this action, among other things, EPA is clarifying the applicability of section 110(a)(2)(D)(i)(I) b y identifying NO X and SO 2 emissions that must be prohibited with respect to the PM 2. 5 NAAQS promulgated in 1997 and 2006 and the 8
- hour ozone NAAQS promulgated inTransport Rule ICR July 2, 2014

4 1997. In addition, section 110(k)(1)(A) calls for the Administrator to establish criteria for determining whether SIP submissions are complete , 42 U.S.C. sec. 7410(k)(1)(A). Among other things, this action helps to clarify what SIP submissions must contain to address the requirements of section 110(a)(2)(D)(i). Section 110(c)(1) of the Act also requires EPA to act in certain circumstances where state SIP deficiencies exist
. S pecificall y, section 110(c)(1) requires the Administrator to promulgate a federal implementation plan (FIP ) at any time within two ye ars after the Administrator either (1) finds that a s tate has failed to make a required SIP submission ; (2) finds that a SIP submission is incomplete ; or (3) disapproves a SIP submission . The Administrator must promulgate a FIP in the above
- described scenarios unless the s tate corrects the deficiency and the Administrator approves the SIP revision before the Administrator promulgates the relevant FIP
. 42 U.S.C. sec. 7410(c)(1). **2 .2**  **Practical Utility/Users of the Data** Emission s data and related information on stationary point and nonpoint sources, as well as nonroad mobile and onroad mobile sources, are routinely used by OAP, OAQPS, and the EPA Regional Offices in carrying out a variety of activities
. These activities support regulatory functions as well as functions that are more programmatic in nature such as trend anal ys es . Such projects include:
● Evaluation of existing control strategies, such as the Transport Rule , for s tates and larger areas;
● Evaluation of proposed control strategies for s tates and larger areas, including applications of regional scale models;
● Development of national control strategies and preparation of Regulatory Impact Analyses (RIA s );
● Preparation and publication of national summaries of emissions , including trend anal ys es;
● Development and maintenance of a data base to a ssist in the identification of important source categories for future regulation; and
● Preparation of the stationary source portion of a report to Congress on SO 2 emissions
. This report is required b y Section 406 of the CAA and is due on a five
- year cyc le that began on January

1, 1995
. The report must contain an inventory of national annual SO 2 emissions from industrial sources (as defined in Title IV of the CAA). EPA ' s Office of Research and Development (ORD) uses emission source data in determining priorities for control technology research and as a key

data component in the application of regional scale models
. The EPA ' s Regional Offices use emission and other source parameters to support source inspections and in the anal ys es of the impact of new or modifiedTransport Rule ICR July 2, 2014

5 sources within an area
. EPA ' s Emission Factor and Inventory Group (EFIG) use s the data to assess and analyze trends in criteria pollutant emissions over time. In addition to supporting projects and initiatives internal to EPA, both the O ffice of A ir Quality P lanning and S tandards (OAQPS) and the Regional Offices respond to numerous requests for reports on emission s from sources . Most requests come from contractors and consultants involved in special studies; a smaller number come from the pre ss, universities , and others involved in research. The collection of emissions data specific to nonattainment areas for certain criteria air pollutants is necessary

to comply

with requirements specified in Title I of the CAA
. States with nonattainment areas rel y on current emissions informati on from point, nonpoint, and mobile sources to revise their SIPs and to plan for emission reductions mandated by the CAA
. In addition, a s tate - wide inventory compiled at least every three ye ars for all point, nonpoint, and mobile sources is considered to be a key tool to assist s tates in meeting CAA requirements that address emissions tracking, compliance issues, and mid
- course adjustments
. State
- wide emission inventories can be used b y s tates affected by pollution transport from upwind areas to develop more efficient control strategies to meet NAAQS
. State
- wide emission inventories that were developed b y EPA (the N ational Emissions Inventory , or NEI) are being used by the Regional Planning Organizations (RPOs ) as the starting point for the development of s tate - wide emission inventories used in the regional haze program to define control strategies. Accurate data from emissions monitoring under 40 CFR part 75 is indispensable to successful implementation of the trading programs for two reasons:
● Accurate emissions data is integral in EPA and state assessment of the impact of the trading programs in reducing NO X and SO 2 emissions, and therefore in assisting s tates in meeting the ozone and fine particulate matter NAAQS. By reducing levels of NO X and SO 2 emissions, the trading programs reduce the adverse effects of the transport of ozone, ozone precursors , and fine particles from upwind s tates . ● EPA enforce s the program (in part) by comparing emissions data measured, recorded, and reported under 40 CFR part 75 from affected sources with the number of allowances held in the respective compliance accounts of such affected sources
. In formation collected on allowance transfers in the CAMD Business S ys tem (CBS ) is used by EPA to track allowances for the purpose of determining compliance with the NO X and SO 2 trading p rograms . Information on allowance transfers is also used b y participants in the allowance market and the public to evaluate the activities of affe cted sources, and by EPA for program evaluation. Permit applications, including proposed compliance plans, are us ed b y s tates and EPA to issue operating permits. A permit application is legall y binding on the owners, operators, and designated representative of a source until the permit is issued. Affected sources rely on the permit for information regarding the applicable requirements with which they must compl y.Transport Rule ICR July 2, 2014

6 Because permit applications and permits are public documents, they may be used by

the public to examine activities undertaken b y affected sources. Together, the emissions data, CBS , and operating permits help to provide the accountability

to allow the NO X and SO 2 trading p rograms to function without more stringent command and control approaches. **3. 0**  **N onduplication**  **, C onsultations**  **, and Other**  **C ollection**  **C riteria**  **3 .1**  **Nonduplication** Reporting requirements for affected sources for the TR NO X and SO 2 trading p rograms are integrated with existing reporting formats under 40 CFR part 75
. The se reporting formats are currentl y used by ARP
- affected units under Title IV of the Act , as well as by CAIR
- affected units. Thus, for units subject to ARP or TR quarterly reporting requirements, or both, only one submission will need to be made on a quarterly basis
. ( CAIR trading program reporting will be superseded b y TR reporting.) Permitting requirements for TR
- affected sources are integrated with other source permitting requirements under Title V. **3.2 Public Notice**  EPA previously

provided public notice of the proposed I CR in the Federal Register on February 6, 2014 (79 FR 7179)
. EPA receive d no comments during the comment period announced in that notice. Docket ID No. EPA
- HQ
- OAR
- 2009
- 0491 is available for online viewing at www.regulations.gov or in
-person viewing at the Air and Radiation Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, D.C. **3 .3**  **Consultations** During the development of CAIR, discussions were held with the National Association of Clean Air Agencies (NACAA) to clarif y EPA ' s logic in developing the emissions reporting requirement s contained within the rule and to answer questions. Information ari sing from those discussions, as well as the decision handed down in the North Carolina v. EPA court case related to CAIR (531 F.3d at 908) , was taken into consideration when developing the TR emission reporting requirements
. The requirements for the TR have been developed using the methodology found in existing trading programs , consultations with interested parties , and reflections on the decision handed down in the North Caro lina court case (531 F.3d at 908)
. EPA modified the cap
- and
trade strategy previousl y used in the ARP , the Ozone Transport Commission ' s NO X Budget Program, the NO X SIP Call , and CAIR in order to address the D.C. Circuit’s concerns related to " emissions from sources that contribute significantly and interfere with maintenance " in another s tate . North Carolina (531 F.3d at 908). This resulted in the development of an unlimitedTransport Rule ICR July 2, 2014

7 intrastate and limited interstate trading program based on state
- specific budgets rather than regional caps. EPA held two workshops with s tate s that participated in the NO X SIP Call or OTC programs to dis cuss lessons learned in those programs when formulating the emissi on trading requirements of CAIR
. Additionally , EPA has had frequent interaction with affected sources and s tate s in the course of implementing the ARP , NO X SIP Call , and CAIR trading p rograms . In 2009, EPA held a series of conference calls and meetings with stakeholders to identify potential options for addressing the North Carolina v. EPA court decision
. EPA received comments following the workshops and through other interactions and considered and incorporated those comments into the TR and this IC R. Finally , as part of updating the ICR for the ARP monitoring requirements (40 CFR part 75) , EPA contacted various affected parties to gather information on CEM capital co sts, CEM operation and maintenance costs, fuel meter capital costs, and CEM/fuel meter testing costs
. That information has been used in this IC R , as appropriate. **3.4 Effects of Less Frequent Collection**  Submittal o f allowance trading and emissions information on an annual basis (and/or on an ozone - season basis, as applicable) provides the data necessary to determine whether state budgets have been exceede d
. If this information collection were not carried out annually for sources subject to the TR , EPA would not be able to verify that emission red

uctions necessary

to meet each s tate ' s NO X and SO 2 emission budgets were being achieved
. Because the NO X and SO 2 budgets prescribed have been deemed essential in order to aid downwind s tates in attaining th e NAAQS in a timely

manner, data collected less frequentl y would be of little or no use. Quarterl y collection of emissions data allows for frequent checking of data for errors and provide s rapid feedback to industry of needed adjustments to data collectio n systems, thereby promoting more accurate and reliable emissions data
. Also , existing federal and s tate emission monitoring programs often require quarterl y reporting, or in some cases, monthly
. Less frequent collection, such as semi
- annually or annuall y, would increase the amount of preparation and review time at the end of the reporting period both for regulated sources and for EPA , and would slow down the process of compliance determination
. **3 .5**  **General Guidelines** This ICR does not violate any of OMB ' s guidelines for information collections. **3 .6**  **Confidentiality** Any data that is submitted to EPA under this rule will be considered in the public domain and cannot be treated as confidential. As required b y Section 114 of the CAA , estimates or measurements of emissions must be treated as non
- confidential
. Under Agency procedures, data items relating to the computation ofTransport Rule ICR July 2, 2014

8 emissions may

be identified as sensitive by a s tate and are then treated as " s tate - sensitive " by EPA
. The potentially

s tate - sensitive items include the following: Process rate, boiler design capacity , emission estimation codes, percent space heat, operating rate, and maximum operation rate/hour
. Where f

ederal and s tate requirements are inconsistent, the appropriate EPA Re gional Office should be consulted. **3 .7**  **Sensitive Questions** This information collection does not ask any questions concerning sexual behavior or attitudes, religious beliefs, or other matters usually considered private. **4. 0**  **T he**  **R espon**  **d e**  **n ts**  **and the**  **I nformation**  **R equested**  **4.1 Respondents/Standard Industrial Classification (SIC) Codes**  This ICR estimates a burden for affected industry sources to monitor NO X and SO 2 mass emissions and demonstrate compliance with NO X and SO 2 control measures
. Sources report data directly to EPA as required to meet the monito ring and reporting requirements of 40 CFR p art 75
. This rule affects large el ectric utility sources which are generall y classified as either SIC 4911
- Electric Services, or 4931
- Electric and Other Services Combined [NAI CS 221112 Electric Power Distribution]. As noted above, the TR regulates sources directl y through FIPs and does not impose any reporting obligations on non
- industry entities. However, states have the option to replace the FIPs in wh ole or in part by submitting revisions to their SIPs , including limited SIP revisions that would change onl y how TR emission allowances are allocated among the state’s affected sources . This ICR estimates a burden for each of the 28 states with TR
- affecte d sources to submit SIP revisions for th at purpose. **4.2 Information Requested**  The ARP and NO X SIP Call established the basic emission reporting requirements under 40 CFR part 75
. CAIR modified these requirements and the TR would continue to implement the changes included in the CAIR requirements
. Only the incremental changes to the ARP and NO X SIP Call reporting requirements that would change reporting burden are discussed here. This section describes the data items requested from affected sources for the collections described in this I CR
. This section also defines the activities in which respondents must engage to assemble, submit, or store these data items. (i) Data Items, Including Recordkeeping Requirements (a) Allowance Tracking There are several data items required for allowance tracking activities
. For each affected source , the designated representative must submit a certificate of representation
. Under 40 CFR §§ 97.41 6 , 97 .51 6 , 97. 61 6 , and 97.716 , a complete certificate of representation include s :Transport Rule ICR July 2, 2014

9 ● Id enti fication of the source and unit;
● Dates on which the unit commenced commercial operation;
● Name and contact information for the TR designat ed representative and alternate (if applicable) ;
● A list of the owners and op erators of each unit; and
● A certification statement and signature of the TR designated representative and alternate (if applicable)
. Certification applications are to be kept for a period of five ye ars pursuant to the general requirements imposed for Title V permitted facilities. Sources and other trading program participants must also submit allowance transfer, allowance deduction, and compliance assurance information, as necessary.

(b) Permitting The basic requirement for permitting is an application for a permit revision to a source ' s operating permit issued under Title V of the Act
. Although there is some possibility that a non
Title V source could be affected under the TR , all TR
- affected sources are assumed to be Title V sources for purposes of this I CR
. It is assumed the permit revision application and all other monitoring, reporting , or recordkeeping requirements associated with Title V permitting are part of the baseline Title V requirements
. Title V permit applications must be kept for five ye ars pursuant to Title V recordkeeping requirements
.

(c) Monitoring and Reporting TR
- affected sources are required to monitor NO X and /or SO 2 mass emissions and record and report emissions data using the requirements of 40 CFR p art 75
. The emissions monitoring requirements specify

that affected sources must (1) submit a monitoring plan for each affected unit at a source, (2) submit data for cer tification of each monitor, (3) record hourly operational, pollutant monitor, and flow monitor data for each affected unit , and (4) submit quarterly reports of their emissions data to EPA. Respondents are required under 40 CFR 75.64 to submit the quarterl y NO X and SO 2 mass emissions data via direct electronic submission to EPA . S uch data must include a certification statement by

the designated representative of th e facility attesting to the accuracy , truthfulness, and completeness of the submission
. Generally, all monitoring records are required to be kept for three ye ars.Transport Rule ICR July 2, 2014

10 (ii) Respondent Activitie s The primary

tasks that will be performed b y respondents to meet the emissions monitoring requirements are : (1) completing and su bmitting appropriate monitoring plan forms for each affected source and each affected unit at a source; (2) conducting tests to certify monitors and submitting test results to EPA; (3) recording hourl y emissions data (this activity is generall y performed ele ctronically); (4) performing operation and maintenance activities associated with monitoring, including quality assurance activities; (5) assuring data quality , preparing quarterl y reports of emissions data , and submitting these reports to EPA; and (6) responding to error messages generated b y such submissions
. Inaddition, respondents will have to purchase the necessary monitoring hardware and electronic data reporting software (or software upgrades). For respondents that are also subject to the ARP, most of the burden associated with these activities is included in the ARP ICR. **5. 0**  **T he**  **I nformation**  **C ollected** 

**– A**  **gency A**  **ctiv ities**  **, C ollection Methods**  **, and**  **I nformation Management**  **5.1 Agency Activities**  The EPA activities associated with the TR include:
● Receiving, reviewing, and storing emission inventory data submitted by

each source ;
● Processing and updating data submitted by sources , including performing quality assurance of data, and coordination of efforts to resolve errors and anomalies; and
● Fulfilling information requests. Other EPA activities related to the TR include (1) allocation of allowances to affected units, (2) maintenance and administration of the NO X allowances , ( 3 ) reviewing and processing certificates of representation, (4) reviewing permit applications, (4 ) reviewing monitoring plans and certification applications, ( 5 ) proce ssing, reviewing , and evaluating reports of quarterl y emission s data from affected units, ( 6 ) calculating/reviewing annual emissions from affected sources , and aggregating such annual emissions for compliance assurance purposes , and ( 7 ) reviewing total annual emissions data submitted to track each s tate ' s progress toward meeting its budgets and creating a summary report of emissions. EPA use s a computer system to track and maintain monitoring and emissions information , and will also answer respondent qu estions and conduct audits of data submissions.Transport Rule ICR July 2, 2014

11 **5 .2**  **Collection Methodology and Management** To ensure consistency

region wide and to expedite data entry , EPA requires that standard formats used for reporting under 40 CFR part 75 be used to submit the info rmation collected for the TR
. Several computer systems and associated databases have been developed to (1) track allowance activity , (2) record quarterl y emissions monitoring data, and (3) calculate the number of allowances to be deducted each ye ar . The se sy stems and database s are designed to provide eas y access to information for use b y the Agency, s tate s, regulated community , and general public. The EPA has also established a Clean Air Markets website , which includes detailed information collected from emissions reports
. Those without access to the internet may use the Clean Air Markets Hotline to request information, including summary reports . The Agency

will rely on these electronic means to disseminate information about the TR as the program is implemented. **5 .3**  **Small Entity Flexibility** The TR applies to fossil fuel
- fired units (stationary boilers and combustion turbines) that serve an electrical generator with nameplate capacity greater than 25 MWe
. Some cogeneration units and solid waste incinerators are exempt from the TR if they me et certain criteria. The low mass emissions provisions under 40 CFR 75.19 provide for optional reduced monitoring, quality

assurance, and reporting requirements for certain units that combust natural gas and/or fuel oil . Such units must emit no more than 100 tons of NO X annually , 50 tons of NO X during the ozone season (May 1

– September 30) , and 25 tons of SO 2 annually , and calculate no more than the se same amount s based on specified proc edures for calculating and reporting emissions
. Units that qualify are exempted from certain requirements to install and operate monitoring equipment, conduct fuel sampl ing, and perform quality assurance or quality control tests
. Moreover, emissions reporting requirements are significantl y simplified for these units. G as - or oil
- fired unit s that do not qualify for the low mass emissions unit p rovisions under 40 CFR part 75 may still meet criteria that allows for the use of alternative methods to measure emissions
. As discussed in the Regulatory Impact Anal ys is of the final ARP regulations (October 19, 1992), smaller utilities are more like ly to be dependent on these oil
- and gas
- fired units, especially

very small utilities
. **5 .4**  **Collection Schedule** Collection frequency

under the TR is on a quarterly basis. All affected industry sources will use the Emission C ollection and M onitoring Plan S ys tem (ECMPS) to submit monitoring plan, quality

assurance, certification test, and emissions data to EPA quarterly . In addition, theTransport Rule ICR July 2, 2014

12 TR requires the collection of allowance trading information as transfers are submitted , as well as information regarding other " event " submissions made on a one - time or annual basis
. **6. 0**  **E stimatin**  **g the**  **B urden**  **and C**  **ost of the**  **C ollection**  **6.1 Estimating Respondent Burden**  This section estimates the paperwork burden and cost of submitting permit applications, certificates of representation, and allowance tracking and transfer materials ; ye ar- end compliance activities , submittal of monitoring plans, obtaining certification of each monitoring s ys tem, conducting monitor quality assurance activities, and recording and reporting data from CEM systems (or approved alternatives). To estimate the burden and/or cost of each requirement, EPA utilized prior estimates of the costs of activities, estimates provided by affec ted utilities in comments to the Agency , and /or estimates base d on the Agency' s experience in implementing existing trading programs. The TR generally requires all affected sources to monitor their NO X emission rate, SO 2 emission rate , and heat input in order to determine NO X mass emissions and SO 2 mass emissions ( except that the TR does not require SO 2 monitoring for sources subject to only the TR NO X ozone program)
. Coal
- fired units use NO X , SO 2 , and flow CEMS to meet those requirement s. Oil and gas units have alternatives. For SO 2 , these units can use fuel sampling and anal ys is (or an SO 2 default f

actor for pipeline natural gas) combined with a fuel flow meter. In addition, peaking units that burn natural gas and/or fuel oil may use an alternative method for calculating NO X emission rates
. EPA will also allow certain low mass emissions units to us e assumed emissions factors together with operational data to calculate emissions. For purposes of thi s I CR, burdens and costs are calculated only in terms of incremental impacts for units subject to the ARP
. Units sub ject to the ARP already have much of the monitoring and reporting capability required under the TR , and th e associated burdens and costs are entirel y or largely accounted for under the ARP I CR
. Non
- ARP units subject to CAIR similarly already have all or much of the monitoring and reporting capability required under the TR, but their burden and costs have been accounted for under the CAIR ICR and the ongoing burden, including annualized capital costs originally incurred under CAIR, will be accounted for under this I CR once the TR supersedes CAIR. Thus, it should be noted that the labor hour s and cost estimates per unit identified in this document represent the weighted average burden and cost for all units and do not represent the actual burden and cost fo r a particular unit
. See the following table for a grap hical reference of s tate reporting classifications related to CAIR, the NO X SIP Call, and the TR
.Transport Rule ICR July 2, 2014

13 **Table 6 -**  **1 :**  **State Reporting Classifications for the CAIR and**  **the TR**

**State CAIR** 

**Ozone CAIR** 

**Annual (NO**  **X & SO**  **2 )**  **TR Ozone**  **TR Annual**  **(NO X**  **& SO 2** **) States with**  **No Change in Classification from** **CAIR to TR** Alabama X X X X Arkansas X X Illinois X X X X Indiana X X X X Iowa X X X X Kentucky X X X X Maryland X X X X Michigan X X X X Missouri X X X X New Jersey X X X X New York X X X X North Carolina X X X X Ohio X X X X Pennsylvania X X X X South Carolina X X X X Tennessee X X X X Virginia X X X X West Virginia X X X X Wisconsin X X X X

**CAIR Annual -**  **Only States Becom ing TR Annual/Ozone States**  Georgia X X X Texas X X XTransport Rule ICR July 2, 2014

14 **Table 6 -**  **1 :**  **State Reporting Classifications for the CAIR and the TR**  **(cont.)**

**State CAIR** 

**Ozone CAIR** 

**Annual (NO**  **X & SO**  **2 )**  **TR Ozone**  **TR Annual**  **(NO X**  **& SO 2** **) CAIR Annual/Ozone States Becom** **ing TR Ozone -**  **Only States** Florida X X X Louisiana X X X Mississippi X X X

**CAIR Non -**  **Covered States Becom ing TR Covered States**  Kansas 1 X Minnesota X Nebraska X Oklahoma X

**CAIR Covered States Becoming TR Non -**  **Covered States** Connecticut X Delaware X X District of Columbia X X Massachusetts X 1 Kansas is subject to the TR annual programs only. However, in 2011 EPA proposed a SIP call for Kansas to address transport obligations under the 1997 ozone NAAQS. 76 FR 763 (Jan. 6, 2011). If that SIP call were finalized as proposed, it is possible that Kansas ’s obligations could be met by including Kansas sources in the TR ozone
- season program. To avoid the need for an ICR revision in that event, this ICR encompasses the small incremental burden that would arise under that contingency. The following discuss ion highlights some of the basic differences for the categories of units
. In cluded in this discussion is the consideration of monitoring and reporting that is done by many of th ese sources under the ARP and CAIR Program s . Existing units in states whose T R program coverage is the same as their CAIR program coverage
– i.e., the 18 states subject to both the annual and ozone
- season programs under both CAIR and the TR , and Arkansas, which is subject to only the ozone
- season program under both rules

– will hav e no incremental burden with regard to monitoring and reporting
. These units are already monitoring and reporting both NO X and SO 2 mass emissions on a year- round basis (except for Arkansas units, which under both CAIR and the TR are onl y required to report NO X mass emissions for the ozone season) and will not incur additional burdens (or capital , operating , and maintenance costs) as a result of the TR since they have already installed and are operating CEMS (or approved alternative s ) and meet 40 CFR p art 75 requirements for NO X and /or SO 2 , as appropriate. For ARP
- affected units in these states, the burden and costs associated with the required ongoing monitoring are accounted for in the ARP ICR. This IC R incorporates theTransport Rule ICR July 2, 2014

15 burden and costs associated with ongoing monitoring at non - ARP units in these states , including annualized capital costs incurred under CAIR that would continue to be born e under the TR
. Existing units in states covered b y CAIR but whose TR program coverage differs from their CAIR program coverage

– i.e., Georgia and Texas, which are covered by onl y the CAIR annual program s but are covered b y both the TR annual and ozone
- season programs , and Florida, Louisiana, and Mississippi, which are covered b y both the CAIR annual an d ozone
- season programs but are covered by onl y the TR ozone
- season program
– will also have a very small incremental burden with regard to monitoring and reporting. These units are already monitoring and reporting both NO X and SO 2 mass emissions on a year - round basis and have already installed and are operating CEMS (or an approved alternative) and meet 40 CFR part 75 requirements for both NO X and SO 2 . Their only additional burden resulting from the TR will consist of minor one - time DAHS software upgrades to change what information that is already being monitored and recorded will be reported to EPA. For ARP
- affected units in these states, the burden and costs associated with the required ongoing monitoring are accounted for in the ARP I CR. This IC R incorporates the burden and costs associated with ongoing monitoring at non - ARP units in these states, including annualized capital costs incurred under CAIR that would continue to be born e under the TR. In states covered b y the TR but not covered b y C AIR

– i.e., Kansas, Minnesota, and Nebraska, which are covered b y the TR annual programs, and Oklahoma, which is covered b y the TR ozone
- season program
– the TR will result in very minor incremental burdens for ARP
affected units, but more substantial burdens for non - ARP units. ARP
- affected units in these states are already monitoring and reporting SO 2 mass emissions and NO X emission rates on a ye ar round basis and in accordance with 40 CFR part 75
. Monitoring of SO 2 mass emissions requires heat input measurement that can be used with the NO X emission rate information to calculate NO X mass emissions
. Therefore, these sources would need to make minor one - time DAHS software upgrades in order to compute and report NO X mass emissions under the TR , either o n an annual or ozone
- season basis as appropriate, but would not likely need to purchase additional monitoring equipment
. The burden and costs associated with the required ongoing monitoring for these ARP
- affected units are accounted for in the ARP I CR. The non
- ARP
- affected existing units in states covered b y the TR but not covered b y CAIR were not previously required to monitor under 40 CFR part 75 under either the ARP or CAIR ( or the NO X SIP Call), although some units may have had similar monitoring re quirements under other regulatory

programs. Under the TR, these units will be required to monitor and report both NO X and SO 2 mass emissions on a year- round basis , in the case of Kansas, Minnesota, and Nebraska, or to monitor and report NO X mass emissions on an ozone - season basis, in the case of Oklahoma. The units will have to install and operat e CEMS (or an approved alternative) and meet 40 CFR part 75 requirements for NO X and/or SO 2 , as appropriate. The monitoring burden depend s in part on the ty pe of fuel combusted and the amount of time the unit is operated
. Therefore, the costs will vary depending on what monitoring alternative is appropriate for the unit and what monitoring requirements appl y to the unit under other regulatory

programs . This ICR includes estimated burden and costs for these newl y a ffected non - ARP sources in TR states .Transport Rule ICR July 2, 2014

16 New units covered b y the TR will in most cases also be covered b y the ARP. The TR creates no material incremental burden or costs for these units, and their burden and costs (both capital/startup and ongoing) are accounted for in the ARP ICR. This I CR includes monitoring and reporting burden and costs for an estimated number of new TR units not covered b y the ARP. Sources will be subject to TR NO X and SO 2 monitoring and reporting requirements starting once the TR supersedes CAIR
. Table 6
- 5 shows the burden associated with monitoring NO X and SO 2 under the TR at various ty pes of sources. The primary

tasks under the TR with information collection
- related burden and costs are (1) permitting, (2) monitoring, recording, and reporting emissions data, and (3) allowance trading activities. (i) Respondent Permitting Activities Under the TR, the designated representative for e ach affected source must submit a certificate of representation to EPA. Since most existing TR
- affected sources are already subject to the ARP and/or CAIR, the Agency believes that the DRs for most TR
- affected sources will only need to revise their certificates of representation, and that such revision s are routine
. The Agency therefore estimates that, on a per unit basis, about one half hour of managerial time and one half hour of technical time will be required to revise the certificate of representation
. Some sources will also be required to construct additional facilities, and therefore will need to complete a permit to construct application . Based on the existing CAIR ICR, the Agency estimates that this task will take 20 hours of managerial and 20 hours of technician time , per permit
. (ii ) Agency Permitting Activities Agency permitting activities (including activities of permitting authorities) include receiving and processing certificates of represent ation , permit applications, and retired unit exemptions. The Agency estimates that these activities will require 2,9 26 hours per ye ar (see Table 6
- 6 )
. The ICR also includes a one
- time allocation of burden for staff at permitting authorities to read the requirements of the TR. (ii i ) Respondent Monitoring Activities For monitoring, the burdens differ greatl y based on the amount and type of monitoring the unit is already subject to and the particular subtask of monitoring being conducted
. The specific elements of this burden are described below. Start

- up ActivitiesTransport Rule ICR July 2, 2014

17 A large part of start
- up activities , involving both capital expenditures and labor costs , concerns the acquisition, installation, and testing of monitoring equipment, as foll o ws : 1) For all units in states whose TR program coverage is the same as their CAIR program coverage , the TR imposes no start
- up burdens beyond existing programs. 2) For all units in states covered by both the TR and CAIR, but with a change in program coverage ( Florida, Georgia, Louisiana, Mississippi, and Texas) , and for ARP
- affected units in states covered b y the TR but not by CAIR (Kansas, Minnesota, Nebraska, and Oklahoma) , the owner or operator will incur some small amount of burden and costs associated with DAHS upgrades for changing what information that is alre ady monitored and recorded is reported to EPA. 3) For non - ARP units in states covered by the TR annual programs and not b y CAIR (Kansas, Minnesota, and Nebraska) , the burdens and costs reflect purchase and certification of NO X and SO 2 monitoring systems. 4) For non - ARP units in states covered by the TR ozone
- season program and not by CAIR (Oklahoma), the burdens and costs reflect purchase and certification of NO X monitoring systems. Note that where the start
- up burdens were already incurred as a result of CAIR, this ICR reflects minimal burden hours or non
- capital costs, but continues to account for annualized capital costs incremental to burdens accounted for in the ARP ICR
. Regulatory Review The ICR includes an allocation of time for the managerial and technical staff to review the TR regulatory

requirements as well as the XML formats and instructions associated with electronic emissions data submissions
. The units not in the ARP or CAIR programs will have a burden similar to that estimated for ARP units in the ARP IC R
-- 16 hours of managerial time and 16 hours of technician time in year one of the program and four hours each for managerial and technician time, per year, after year one . The burden estimates for all units previously included in the ARP or CAIR is reduced because of the similar requirements involved in these trading programs
. The estimates for these units are ten hours of managerial time and ten hours of technician time in year one and one hour each per year after ye ar one. Response to Error Messages The Agency

provides feedback for errors that are found in monitoring plans or other reports . The Agency

estimates that for each unit not previously included in the ARP , an owner or operator will spend approximately four hours o f managerial time and eight hours of technician time responding to these error messages each ye ar . (The time for the other sources is accounted for in other ICRs.)Transport Rule ICR July 2, 2014

18 DAHS Debugging Based on experience with the ARP and CAIR Program s , some effort will be involved to fix problems with the DAHS software used to report in the 40 CFR part 75 formats
. This burden is assumed to fall primarily on units that have not previously been affected under the ARP or CAIR
. Consistent with the existing ARP I CR , the Agency estimates that about 14 managerial and 80 technician hours will be spent on this task in the first year of implementation, and then one managerial and four technician hours will be required in the second and subsequent years of implementation
. Units that are subject to the ARP, and/or were previousl y s ubject to CAIR , are expected to incur the " subsequent years " burden. Monitoring Plans The regulations require submittal of monitoring plans
. Because most of the monitoring plan elements are now part of the reporting format, the effort involved in developing and maintaining the plans are incorporated into the overall reporting burden estimate. Monitor Certification/Recertification Initial certification burdens and costs for new monitoring equipment are addressed above under start
- up activities since these costs are often part of the overall purchase expense for the equipment
. For some non
- ARP
- affected units, however, there will be burdens associated with certifying existing monito rs used under other programs , as well as burdens for recertification to the extent a change in a monitoring system requires recertification
. Based on the current CAIR ICR, EPA estimates that approximately ten percent of all units will have to recertify each ye ar following the ye ar in which the initial certification occurs . The ICR incorporates a labor burden estimate generally

consistent with existing Agency models for the labor burdens associated with certification
. However, note that the I CR reduces the labor hours for this activity to avoid double counting hours that are already accounted for in the quality assurance activity

area (see the following subsection)
. The double counting would occur because a portion of the labor incurred for the certification or recertification event replaces the labor burden that is generall y allocated to the annual relative accuracy test audit (RATA) in the year in which the certification event occurs. Quality Assurance Quality assurance (QA ) activities and other routine maintenance for monitoring s ys tems is the largest burden item under the TR
. These requirements generally include daily , quarterly , and annual QA requirements, depending on the monitoring approach being used
. For reporting units that use a CEMS, the Agency has assumed a per unit labor burden based on a variety of sources, including the existing ARP IC R, information provided by ARP and CAIR sources, a CEM cost model developed by EPA, and comments submitted in response to the s ection 110 SIP Call for ozone transport
. For units that rel y on alternative methodologies, reduced labor burden estimates apply

because the quality

assurance activities for the excepted methods are less than for a CEMS
. Consistent with the existing ARP and CAIR ICR s , the labor burden is expected to be almost entirel y technician labor.Transport Rule ICR July 2, 2014

19 Quarterly Reports Tasks performed b y utilities in preparing quarterl y reports include: (1) assuring the quality of the data, (2) preparing the quarterl y report, (3) revising the monitoring plan, if necessary , (4) preparation of hard cop y documentation accompanying the quarterl y report s, and (5) managerial review
. The existing Acid Rain ICR was used as the basis for these estimates. Fuel Sampling To calculate heat input where the source is using the fuel flow meter option for an oil or gas - fired unit, the source must obtain gross calorific value data from sampling in accordance with Appendix D of 40 CFR part 75
. For purposes of this I CR, it is assumed that the GCV data would be collected as part of standard business operating procedures to assure compliance with contractual specifications
. Thus no additional fuel sampling burdens or costs should be incurred. (iv) Agency

Monitoring Activities Agency activities related to the monitoring and reporting of emissions data include processing, reviewing , and evaluating reports of quarterl y emissions data from affected units. The Agency

estimates that these activities will require 4,500 hours per ye ar (see Table 6
- 10)
. (v) Respondent Allowance Transaction A ctivities The Agency

anticipates the average number of additional allowance transactions will be approximately 7,500 per year beginning in sometime after 2014
. This estimate is based on transaction data associated with the current CAIR trading programs. A portion of all sources will likely conduct transactions in each ye ar solel y as a result of this program. The Agency believes that each transaction will involve about one hour each of managerial and technician time. (v i ) Agency

Allowance Transaction A ctivities Agency activities related to allowance transactions include allocating allowances to existing and new units, reviewing allowance transfer information, recording transfers , notifying transfer participants, entering deduction data and deducting allowances , and ensuring compliance assurance provisions are met. In the event that compliance assurance provisions are not met it is estimated that the burden for each s tate exceeding compliance assurance levels would be 160 hours, however the agency assumes that zero s tate s would exceed the limit during the 2014 and beyond time period. The Agency estimates that these activities will require 290 hours per ye ar (see Tables 6
- 8 and 6
- 9 )
. (vii) State SIP Allowance Allocation Activities The FIPs promulgated b y EPA specify default allocations of TR emission allowances for each TR trading program among each state’s affected sources. States that wish to revise these default allocations may

d o so by submitting limited SIP revisions for that purpose . The Agency has conservatively

assumed that all states with TR
- affected sources will choose to submit suchTransport Rule ICR July 2, 2014

20 revisions, and that the activities to prepare the submissions will require 100 hours per year (see Table 6
- 4). **6 .2**  **Estimating Respondent Costs** Table 6
- 4 presents s tate and local respondent annualized hours and costs for each information collection activity
. To estimate annualized hours and costs for one
- time activities, the burden estimate is divided by three to estimate the burden over a three
- ye ar period
. Table 6
- 5 summarizes the annual industry respondent costs
. The following discussion describes how the costs were derived. (i) Estimating Labor Costs For this IC R, the labor rate used for technical staff at s tate agencies is $ 42.95 per hour , and the labor rate for managerial employees at s tate agencies is $ 52.01
. These labor rates include benefits and overhead , and are derived from data shown on the Bureau of Labor Statistics web site at http://stats.bls.gov/news.release/ecec.toc.htm
. Wage and salary rates are shown at the link “Table 3: State and local government, by major occupation and industry group (December 2013 ). " The wage and salary rates from this table account for benefits provided to workers
. When considering both technical and man agerial hours, labor costs for s tate and t erritorial agencies are estimated to be $5 4,000 per year per resp ondent, and labor costs for local agencies are estimated to be $3 5 ,000 per ye ar per respondent for the emissions reporting requirements
. In estimating labor costs for industry , EPA used the following amounts: $ 95.10 per hour for managers and $ 67.38 per hour for technicians
. These rates were used in the existing ARP ICR ( EPA ICR Number 1633. 16 ) and are the consistent with the Current Employ ment Cost Index year 20 1 4
. Federal Agency

labor rates were assumed to be $ 77.27 per hour
. This labor rate was derived from the federal government ' s 2014 U.S. Office of Personnel Management General Schedule " Salary

Table 20 1 4
- GS "(http:/www.opm.gov/pol icy
- data
- oversight/pay
- leave/salaries
wages/salary
- tables/pdf/2014/GS.pdf ) u sing the factors in Table 6
- 2 below
.Transport Rule ICR July 2, 2014

21 **Table 6 -**  **2: Determination of Federal Wage Rates**  **Labor Category Factors**  **Total** Annual Salary of Technical Staff, GS 1 3 Step 8 $ 89,282 Annual Cos t of Supervisory Staff, GS 1 5 , S tep 8 $ 124,102 Factor (1/11) 0.09 $ 11,169 Benefits 1.6 Total Cost per FTE $ 160,722 Total Hourly Cost (total per FTE dividend divided by 2,080 hours per year) $ 77.27 ( ii) Estimating Capital and Operations and Maintenance Costs Capital/start
- up costs include the cost of installing required CEMS or alternatives
. Operation and maintenance costs (exclusive of labor costs) reflect ongoing costs to a unit and include both contractor costs for the required recertification, diagnostic, and quality assurance (QA) testing, and other direct maintenance
- related expenses (e.g., spare parts and calibration gases)
. These cost estimates have been derived from EPA CEM cost models, existing ICRs, Agency staff experience under the ARP , CAIR, and NO X SIP Call programs, and supplemental estimates provided by

affected utilities and others related to the various cost items. All units in states covered by both the TR and CAIR to the same extent are not expected to incur any non - labor costs associated with this program . All units in states covered b y both the TR and CAIR , but to different extents, and ARP
- affected units in states covered b y the TR but not by CAIR, are expected to incur a $4,000 non
- labor startup cos t for a DAHS upgrade. This cost estimate is based on the existing CAIR ICR
. Non
- ARP units in states covered b y the TR but not by CAIR are expected require some combination of NO X diluent, SO 2 , and/or flow CEMS
. The estimated costs for these units range from $15,000 to $192,000
. Cost variance is due to the monitoring methodology

used and what monitoring equipment may already be in place at the unit. Note that testing contractor costs for certification, recertification and annual relative accuracy test a

udits (RATAs) are presented as other direct costs and are not converted to equivalent source labor hours
. This approach is consistent with the common business practice of obtaining outside contractors to conduct certification/recertification tests and annual RATAs
. For initial certification, the certification test costs are commonl y bundled with equipment purchase contracts, according to information provided by a range of CEMS equipment vendors
. For RATAs that are conducted either as part of the annual q uality assurance requirements or as part of recertification, industry contacts have indicated that RATA tes ting is usually performed under a fixed price contract basis, except for travel costs that may be billed on an hourl y basis beyond the basic contract cost.Transport Rule ICR July 2, 2014

22 The Agency

also notes that this I CR does not include a cost for the purchase of monitoring equipment for all affected units
. Many sources covered by

the TR are already required to have CEMS under other regulatory programs . Therefore, to the extent that no new equipment is needed b y these sources, capital costs are not included because those costs were included in the ICRs of those other programs
. Thus, the capital and other costs included in Table 6
- 5 represent weighted average costs for each respondent, not the total individual cost for any particular respondent. EPA has concluded that the Capital and Operations and Maintenance Costs estimated for the Agency under the ARP I CR are sufficient to accommodate the modest changes in reporting burden for the TR . Therefore, no further estimate of Capital and Operations and Maintenance Costs for the Agency were made for this ICR. ( iii) Capital/Start
- up vs. Operating and Maintenance (O & M) Costs Capital costs for emissions trading reflect one
- time costs for purchase of equipment which will be used over a period of ye ars . Conversely , operating and maintenance costs are those costs which are incurred on an annual or other scheduled basis
. For instance, costs associated with quality assurance activities, such as spare parts or contractor costs for work, will be incurred on an annual basis. (iv) Annualizing Capital Costs The relevant capital costs for this I CR were annualized at a rate of seven percent , ( i.e., the annualized capital cost was calculated assuming money to purchase the capital equipment was borrowed at a seven percent annual interest rate )
. The cost of the loan was amortized over the life of the loan to repay the borrowed amount plus interest
. The result is the annualized capital cost reported. ) The annualized cost of the necessary capital purchases varies from $ 600 to $ 29,572 per ye ar per unit, depending on the type of monitoring methodology
. Table 6
- 5 contains a breakdown of annual costs by monitoring methodology
. **6.3 Estimating the Respondent Universe and Total Burden and Costs** 

S tate and local permitting authorities will incur a burden associated with review of TR
- related permit submissions , which is included in Table 6
- 6
. The total number of permitting authorities (including authorities for areas not covered b y the TR) is estimated to be 5 0 s tates and the District of Columbia , four t erritories and 49 local agencies, totaling 104 authorities
. Table 6
- 4 details state, territory , and local agency one - time burdens associated with reading the rule upon publication. Additionally this I CR contains burdens to allow for State s to allocate allowances as part of the SIP process. While state allocation of allowances is optional under the TR, for conservative estimation pur poses this I CR estimates that all 28 states with sources covered b y the TR will incur an annual burden of 100 hours to allocate allowances at the state level. This burden is also included in Table 6
- 4.Transport Rule ICR July 2, 2014

23 The number of industry

respondents varies depending on the activity in question
. Activities such as T itle V permit application submission or allowance transfers can involve nearl y two thousand sources
. The number of units which will be required to install a particular ty pe of monitoring equipment is fewer since many already have the necessary monitoring equipment , especiall y if they are ARP units or are in CAIR s tate s . Table 6
- 5 gives estimates of annual industry

burden s beginning in once compliance obligations under the TR commence
. These burden s include monitoring, reporting , and other activities involved in participating in an emissions trading program
. The total number of respondents is estimated to be 1,2 0 1 facilities. Table s 6
- 6 through 6
- 10 give estimates of Agency and permitting authority burden s associated with permitting and managing the emissions trading programs. **6.4 Bottom Line Burden Hours and Cost Table**  Table 6
- 3 summarizes the bottom line burden and costs for state, industry , and Agency respondents. **Tab le 6**  **- 3**  **: Total Estimated Burden and Cost Summary**  **Number of Respondents**  **Total Hours Per Year**

**(All Respondents) Total Costs Per Year**  **(All Respondents)** State and Local 104 2,869 $ 129,826 Industry Respondents 1,201 185,132 $26, 589,016 Agency 1 7,716 $ 596,215
**6.5 Reasons for Change in Burden**  The large st burden associated with this rule is the cost of monitoring, certifying , quality assuring , and reporting emissions data from the large electric generating units regulated under the TR
. This burden is tempered , however , by the integration of these monitoring and reporting requirements with those already required under the ARP and (prior to TR implementation) under CAIR
. Otherwise, the burden and costs reported under this ICR would be significantl y higher and the number of sources reported under this I CR would be greater. Differences between this renewal and the previous I CR are due to revised current year labor costs, and the inclusion of 100 hours annuall y per state (28 states) to allocate allowanc es as part of the SIP process, which was inadvertently

omitted from the original rule ICR Supporting Statement. **6.6 Burden Statement**  The annual public reporting and recordkeeping burden for this collection of information is estimated to average 11 hours per response. Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, disclose or provide information to , or for , a f ederal agency
. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, andTransport Rule ICR July 2, 2014

24 verifying information ; processing , maintaining, 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 disclos ing 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 currentl y 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 facilitate 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 No. EPA
- HQ
- OAR
- 2009
- 0491 , which 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 and Radiation Docket and Informa tion Center 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, to 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, DC 20503, Attention: Desk Officer for EPA. Please include EPA Docket ID No. EPA
- HQ
- OAR
- 2009
- 0491 and OMB Control Number 2060
- 0667 in any correspondence.

**T able 6**  **- 4**  **: Annua**  **l State and Local**  **Burden and Cost by Activity**

**Hours and Costs Total Hours and Costs**  **Activity Mgr.** 

**$ 52.01**  **/Hr 1**  **Tech.**

**$ 42.95**  **/Hr 1**  **Respondent**

**Hours/Yr Labor** 

**Cost/Yr Number of** 

**Respondents Total** 

**Hours/Yr 2**  **Total**

**Cost/Yr 3**  **One -**  **tim e (Annualized)**  Read the reporting requirements of the rule 0.33 0.33 0.66 $ 31 10 4 69 $3, 224 **Annual** State SIP allowance allocation 25 75 100 $4,522 28 2,800 $126,602 **Total** 10 4 2,869 $ 129,826Transport Rule ICR July 2, 2014

25 1 See Section 6 .2 (i) for labor and overhead rates. 2 Hours per year are rounded to the nearest hour. 3 Costs per year are rounded to the nearest dollar.Transport Rule ICR July 2, 2014

26 **Table 6 -**  **5 :**  **Annual Industry Respondent Burden and Cost by Activity**
**Respondent Labor**  **Cost/Year Annual Capital**  **Manager $**  **95.10 Per Hour**  **( 20**  **1 3**  **) Technical** 

**$ 67.38**  **Per Hour (**  **20 1**  **3 )**  **Respondent**

**Hours/Year Startup**  **Costs O&M** 

**Cost Number of**  **Respondents Total** 

**Hours/Year Total** 

**Cost/Year** Permit to Construct (units) 20 20 40 $3, 250 8 320 $2 6 , 000 Certificate of Representation 0.50 0.50 1 $ 8 1 1201 1,201 $9 7 , 281 **Startup/ Capital Items**  **Kansas, Minnesota, Nebraska, Oklahom a**  **(Previously Not Affected)** a. DAHS modification (facilities) 2 4 6 $ 460 $1,333 35 210 $62, 745 b. Solid Fuel: SO 2 , NO X , and Flow CEMS (units) 34 2 3 57 $4, 783 $29,752 7 399 $241, 746 c . Gas
- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 64 10 74 $6, 760 $19,200 17 1,258 $4 41,323 d . Gas
- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 20 10 3 0 $2, 5 76 $2,304 29 870 $14 1 , 514 (cont.)Transport Rule ICR July 2, 2014

27 **Table 6**  **- 5**  **: Annual Industry Respondent Burden and Cost by Activity**  **(cont.)**
**Respondent Labor**  **Cost/Year Annual Capital**  **Manager $**  **95.10 Per Hour**  **(20 1**  **3 )**  **Technical**

**$ 67.38**  **Per Hour (20**  **1 3**  **) Respondent** 

**Hours/Year Startup**  **Costs O&M** 

**Cost Number of**  **Respondents Total** 

**Hours/Year Total** 

**Cost/Year Startup/** **Capital Items (cont.)**  **Georgia and Texas**  **(Ozone Status Changes, Annual Status R em**  **ains)** a. DAHS modification (facilities) 2 4 6 $ 460 $600 161 966 $ 170 , 615 b . Solid Fuel: SO 2 , NO X , and Flow CEMS (units) 0 0 0 $0 $29,752 1 0 $29,752 c . Gas
- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 0 0 0 $0 $19,200 38 0 $729,600 d . Gas
- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 0 0 0 $0 $2,304 39 0 $89,856 (cont.)Transport Rule ICR July 2, 2014

28 **Table 6**  **- 5**  **: Annual Industry Respondent Burden and Cost by Activity**  **(cont.)**
**Respondent Labor**  **Cost/Year Annual Capital**  **Manager $**  **95.10 Per Hour**  **(20 1**  **3 )**  **Technical**

**$ 67.38**  **Per Hour (20**  **1 3**  **) Respondent** 

**Hours/Year Startup**  **Costs O&M** 

**Cost Number of**  **Respondents Total** 

**Hours/Year Total** 

**Cost/Year Startup/** **Capital Items (cont.)**  **Mississippi ,**  **Florida ,**  **and Louisiana**  **(Now Ozone Season Only)** a. DAHS modification (facilities) 2 4 6 $ 4 60 $600 27 162 $28, 612 b . Solid Fuel: NO X and Flow CEMS (units) 0 0 0 $0 $22,500 6 0 $135,000 c . Gas
- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 0 0 0 $0 $19,200 6 0 $115,200 d . Gas
- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 0 0 0 $0 $2,304 62 0 $142,848 **States with No Change in Classification** a . Solid Fuel: SO 2 , NO X , and Flow CEMS (units) 0 0 0 $0 $29,752 64 0 $1,904,128 b . Gas
- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 0 0 0 $0 $19,200 67 0 $1,286,400 c . Gas
- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 0 0 0 $0 $2,304 533 0 $1,228,032 (cont.)Transport Rule ICR July 2, 2014

29 **Table 6**  **- 5**  **: Annual Industry Respondent Burden and Cost by Activity**  **(cont.)**
**Respondent Labor**  **Cost/Year Annual Capital**  **Manager $**  **95.10 Per Hour**  **(20 1**  **3 )**  **Technical**

**$ 67.38**  **Per Hour (20**  **1 3**  **) Respondent** 

**Hours/Year Startup**  **Costs O&M** 

**Cost Number of**  **Respondents Total** 

**Hours/Year Total** 

**Cost/Year Review Instructions and Requirements**  States with No Change in Classification 4 4 8 $ 6 50 26 1 2,088 $ 169,629 States in which Ozone Season Status Changes, Annual Status Remains

– Georgia, Texas 4 4 8 $ 6 50 161 1,288 $10 4,637 States now

Ozone Season Only
- Mississippi, Florida, Louisiana 4 4 8 $ 6 50 27 216 $17, 548 States Not Previously Covered
- Kansas, Minnesota, Nebraska, Oklahoma 8 8 16 $1, 300 35 560 $ 45,494 (cont.)Transport Rule ICR July 2, 2014

30 **Table 6**  **- 5**  **: Annual Industry Respondent Burden and Cost by Activity**  **(cont.)**
**Respondent Labor**  **Cost/Year Annual Capital**  **Manager $**  **95.10 Per Hour**  **(20 1**  **3 )**  **Technical**

**$ 67.38**  **Per Hour (20**  **1 3**  **) Respondent** 

**Hours/Year Startup**  **Costs O&M** 

**Cost Number of**  **Respondents Total** 

**Hours/Year Total** 

**Cost/Year Respond to EPA Generated Error Messages**  States with No Change in Classification 6 18 24 $1, 7 83 261 6,264 $4 65,478 States in which Ozone Season Status Changes, Annual Status Remains

– Georgia, Texas 6 18 24 $1, 7 83 161 3,864 $2 87,134 States now

Ozone Season Only

– Mississippi, Florida, Louisiana 6 18 24 $1, 7 83 27 648 $4 8,153 States Not Previously Covered
- Kansas, Minnesota, Nebraska, Oklahoma 6 18 24 $1, 7 83 35 840 $6 2,420 **Debug Computer Software** States with No Change in Classification 1 4 5 $ 3 65 261 1,305 $9 5,166 States in which Ozone Season Status Changes, Annual Status Remains

– Georgia, Texas 6 18 24 $1, 7 83 161 3,864 $2 87,134 (cont.)Transport Rule ICR July 2, 2014

31 **Table 6**  **- 5**  **: Annual Industry Respondent Burden and Cost by Activity**  **(cont.)**
**Respondent Labor**  **Cost/Year Annual Capital**  **Manager $**  **95.10 Per Hour**  **(20 1**  **3 )**  **Technical**

**$ 67.38**  **Per Hour (20**  **1 3**  **) Respondent** 

**Hours/Year Startup**  **Costs O&M** 

**Cost Number of**  **Respondents Total** 

**Hours/Year Total** 

**Cost/Year Debug Computer Software (cont.)**  States now

Ozone Season Only
- Mississippi, Florida, Louisiana 1 4 5 $ 3 65 27 135 $9, 845 States Not Previously Covered
- Kansas, Minnesota, Nebraska, Oklahoma 16 88 104 $7, 451 35 3,640 $2 60,786 **Certify Monitors Kansas, Minnesota, Nebraska, Oklahom**  **a (Previously Not Affected)**  a. Solid Fuel: SO 2 , NO X , and Flow CEMS (units) 15 48 63 $4, 661 $2,800 1 63 $7, 461 b. Gas
- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 10 32 42 $3, 107 $2,800 1 42 $5, 907 c. Gas
- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 8 24 32 $2, 3 78 $10,000 5 160 $61, 890 (cont.)Transport Rule ICR July 2, 2014

32 **Table 6**  **- 5**  **: Annual Industry Respondent Burden and Cost by Activity**  **(cont.)**
**Respondent Labor**  **Cost/Year Annual Capital**  **Manager $**  **95.10 Per Hour**  **(20 1**  **3 )**  **Technical**

**$ 67.38**  **Per Hour (20**  **1 3**  **) Respondent** 

**Hours/Year Startup**  **Costs O&M** 

**Cost Number of**  **Respondents Total** 

**Hours/Year Total** 

**Cost/Year Certify Monitors**  **(cont.) Georgia**  **and Texas (Ozone Status Changes, Annual Status R** **em ains)**  a. Solid Fuel: SO 2 , NO X , and Flow CEMS (units) 15 48 63 $4, 661 $2,800 1 63 $7, 461 b. Gas
- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 10 32 42 $3, 107 $2,800 4 168 $23, 629 c. Gas
- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 8 24 32 $2, 3 78 $10,000 4 128 $49, 512 **Mi ssissippi**  **, Florida ,**  **and Louisiana (Now Ozone Season O**  **nly)** a. Solid Fuel: NO X and Flow CEMS (units) 15 48 63 $4, 661 $2,800 1 63 $7, 461 a. Gas
- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 10 32 42 $3, 107 $2,800 1 42 $5, 907 b. Gas
- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 8 24 32 $2, 3 78 $10,000 6 192 $7 4,268 (cont.)Transport Rule ICR July 2, 2014

33 **Table 6**  **- 5**  **: Annual Industry Respondent Burden and Cost by Activity**  **(cont.)**
**Respondent Labor**  **Cost/Year Annual Capital**  **Manager $**  **95.10 Per Hour**  **(20 1**  **3 )**  **Technical**

**$ 67.38**  **Per Hour (20**  **1 3**  **) Respondent** 

**Hours/Year Startup**  **Costs O&M** 

**Cost Number of**  **Respondents Total** 

**Hours/Year Total** 

**Cost/Year Certify Monitors**  **(cont.) States With No Change in Classification**  a. Solid Fuel: SO 2 , NO X , and Flow CEMS (units) 15 48 63 $4, 661 $2,800 6 378 $44, 764 b. Gas
- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 10 32 42 $3, 107 $2,800 7 294 $4 1,350 c. Gas
- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 8 24 32 $2, 3 78 $10,000 50 1,600 $61 8,896 **Perform QA Testing and Maintenance**  **Kansas, Minnesota, Nebraska, Oklahom a**  **(Previously Not Affected)** a. Solid Fuel: SO 2 , NO X , and Flow CEMS (units) 50 600 650 $4 5,183 $31,949 7 4,550 $53 9,924 b. Gas
- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 20 375 395 $2 7,170 $17,818 17 6,715 $7 64,788 c. Gas
- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 5 30 35 $2, 4 97 $1,843 29 1,015 $12 5,857 (cont.)Transport Rule ICR July 2, 2014

34 **Table 6**  **- 5**  **: Annual**  **Industry Respondent Burden and Cost by Activity (cont.)** 
**Respondent Labor**  **Cost/Year Annual Capital**  **Manager $**  **95.10 Per Hour**  **(20 1**  **3 )**  **Technical**

**$ 67.38**  **Per Hour (20**  **1 3**  **) Respondent** 

**Hours/Year Startup**  **Costs O&M** 

**Cost Number of**  **Respondents Total** 

**Hours/Year Total** 

**Cost/Year Perform** **QA Testing and Maintenance (cont.)**  **Georgia and Texas**  **(Ozone Season**  **Status Changes, Annual Status R em**  **ains)** a. Solid Fuel: SO 2 , NO X , and Flow CEMS (units) 40 400 440 $ 30,756 $31,949 1 440 $6 2,705 b. Gas
- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 20 375 395 $ 27,170 $17,818 38 15,010 $1, 709,525 c. Gas
- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 5 30 35 $2, 4 97 $1,843 39 1,365 $16 9,256 **Mi ssissippi**  **, Florida and Louisiana**  **(Now Ozone Season O nly)**  a. Solid Fuel: NO X and Flow CEMS (units) 40 400 440 $ 30,756 $31,949 6 2,640 $37 6,230 b. Gas
- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 20 375 395 $ 27,170 $17,818 6 2,370 $26 9,925 c. Gas
- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 5 30 35 $2, 4 97 $2,209 62 2,170 $2 91,766 (cont.)Transport Rule ICR July 2, 2014

35 **Table 6**  **- 5**  **: Annual Industry Respondent Burden and Cost by Activity**  **(cont.)**
**Respondent Labor**  **Cost/Year Annual**  **Capital Manager**  **$ 95.10**  **Per Hour (20**  **1 3**  **) Technical** 

**$ 67.38**  **Per Hour (20**  **1 3**  **) Respondent** 

**Hours/Year Startup**  **Costs O&M** 

**Cost Number of**  **Respondents Total** 

**Hours/Year Total** 

**Cost/Year Perform** **QA Testing and Maintenance (cont.)**  **States With No Change in Classification** a. Solid Fuel: SO 2 , NO X , and Flow CEMS (units) 40 400 440 $ 30,756 $31,949 64 28,160 $ 4,013,120 b. Gas
- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 20 375 395 $ 27,170 $17,818 67 26,465 $ 3,014,463 c. Gas
- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 5 30 35 $2, 4 97 $1,843 533 18,655 $2, 313,167 **Assure Data Quality, Prepare Reports, Submit Reports** States with No Change in Classification 16 42 58 $4, 352 261 15,138 $1, 135,757 States in which Ozone Season Status Changes, Annual Status Remains

– Georgia, Texas 16 42 58 $4, 352 161 9,338 $ 700,601 (cont.)Transport Rule ICR July 2, 2014

36 **Table 6**  **- 5**  **: Annual Industry Respondent Burden and Cost by Activity**  **(cont.)**
**Respondent Labor**  **Cost/Year Annual Capital**  **Manager $**  **95.10 Per Hour**  **(20 1**  **3 )**  **Technical**

**$ 6**  **7.38 Per Hour**  **(20 1**  **3 )**  **Respondent**

**Hours/Year Startup**  **Costs O&M** 

**Cost Number of**  **Respondents Total** 

**Hours/Year Total** 

**Cost/Year Perform** **QA Testing and Maintenance (cont.)**  States now

Ozone Season Only
- Mississippi , Florida, Louisiana 8 21 29 $2, 1 76 27 783 $5 8,746 States Not Previously Covered
- Kansas, Minnesota, Nebraska, Oklahoma 16 42 58 $4, 352 35 2,030 $ 152,305 **Other Trading Program Activities**  Allowance Transfers 1 1 2 $ 1 62 7500 15,000 $1, 218,600 Com pl iance Assurance Activites 1. .5 1 1.5 $112 0 0 0 **TOTAL** 185,1 32 $26, 589,016 1. Assumes that no State s will exceed their limits for the years covered by this ICR so, overall there would be zero burden for these provisions to industry.Transport Rule ICR July 2, 2014

37 **Table 6**  **- 6**  **: Agency Burden** 

**– Permitting**  **Information Collection**  **Activity Burden Hours per**  **Occurrence Cost per** 

**Source 1**  **Total Burden**

**(H ours)**  **Total Cost** EPA reviews certificates of representation and records information. 2 0.5 $ 38.64 600 $ 46,632 Revie w permit application, and issue draft, proposed, and final permit. 3 Permitting Authority action
. 8 $ 618.16 2,000 $ 154,540 EPA review
. 1 $ 77.27 240 $ 18,545 Receive and process retired unit exemptions
. 4 Permitting Authority action
. 2 $ 154.54 66 $ 5,100 EPA review
. 0.3 $ 23.18 20 $ 1,545 **TOTAL 2,926**  **$ 226,092**  1. 20 14 dollars
. 2
. Assumes 12 0 1 sources submit a certificate of representation. 3. Assumes 2 4 0 sources (approximately 20% of all affected sources) will submit a permit application each year. 4. Assumes 33 retired unit exemptions are submitted each year. **Table 6**  **- 7**  **: Agency Burden** 

**– Emissions Reporting** 
**Information Collection Activity**  **Quarterly**

**Burden Hours per Report**  **Quarterly Cost**

**per Report 1**  **Number**

**of Reports**  **2 Total Burden** 

**per Year (H**  **ours) Total** 

**Cost** Process, review , and evaluate quarterly report and issue feedback letter. 1 $ 77.27 4,500 4,500 $ 347,715 1
. Based on an average total compensation rate of $ 77.27 per hour. 2
. Assumes 1125 TR only emissions data reports are submitted each quarter.Transport Rule ICR July 2, 2014

38 **Table 6**  **- 8**  **: Agency Burden**  **- Allowance Allocations**  **Information Collection Activity Total Burden**  **(H ours)**  **Total Cost** Initial and annual allocation of allowances to existing and new units. 200 $ 15,454
**Table 6**  **- 9**  **: Agency Burden** 

**– Allowance Transfer & Deduction Burden**  **Information Collection**  **Activity Burden Hours** 

**per Occurrence Cost per** 

**Occurrence 1**  **Total Burden 2** 

**(H ours)**  **Total Cost** Revie w allowance transfer information, record transfer, and notify transfer participants. 1 $ 77.27 40 $ 3,091 Enter deduction data and deduct allowances. 0.5 $ 38.64 50 $ 3,864 Com pliance Assurance Provisions 3 1 $ 77.27 40 $ 3,091 **TOTAL 90**  **$ 6,954**  1. 201 4 dollars. 2. Assumes 20 transfers and 100 optional deduction forms are submitted annually. 3. Assumes zero s tate s would exceed the limit during the ICR time frame. **Table 6**  **- 10**  **: Agency Burden** 

**– Aggregate**  **Information Collection Activity Total Burden (H**  **ours) Total Cost**  **1** Annual allocation of allowances to existing and ne w units. 200 $ 15,454 Allowance transfers and deductions. 90 $ 6,954 Permits. Permitting Authority
. 2,066 $ 159,640 EPA
. 860 $ 66,452 Emissions reporting. 4,500 $ 347,715 **TOTAL 7,716**  **$ 596,215**  1. 201 4 dollars.