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SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

AIR STATIONARY SOURCE COMPLIANCE AND ENFORCEMENT INFORMATION 

REPORTING (Renewal)

1. IDENTIFICATION OF THE INFORMATION COLLECTION

 1(a) TITLE OF THE INFORMATION COLLECTION

Air Stationary Source Compliance and Enforcement Information Reporting (Renewal), 

EPA ICR Number 0107.11, OMB Control Number 2060-0096, EPA-HQ-OECA-2014-0523

1(b) ABSTRACT:

Air Stationary Source Compliance and Enforcement Information Reporting is an activity

whereby State, Local, Tribal, Territorial and Commonwealth governments (hereafter referred to 

as "delegated agencies") report air stationary source compliance and enforcement information to 

the U.S. Environmental Protection Agency (the EPA or the Agency) on a regular basis. The

information is provided to the EPA via input to the Integrated Compliance Information System 

(ICIS). ICIS replaced the Air Facility System (AFS) as the database of record for this 

information. The modules within ICIS that are used to report Air related data are collectively 

referred to as ICIS-Air. ICIS contains compliance and enforcement information on thousands of 

facilities regulated under numerous federal statutes including the Clean Water Act – National 

Pollutant Discharge and Elimination System (NPDES) program. The majority of delegated 

agencies maintain their own data system and extract data from it and report it to ICIS either 

electronically or manually. A small number of delegated agencies use ICIS as their only data 

system. The information provided to the EPA includes source information, compliance

monitoring activities, violation determinations, and enforcement activities. The EPA uses this 

information to assess the health of the compliance and enforcement program established under 

the Clean Air Act (CAA). The EPA also uses ICIS to record comparable federal activities. 

(i) Terms of Clearance

The following Terms of Clearance were given by OMB in the prior ICR, 0107.10:

"In accordance with 5 CFR 1320, the collection is approved for 3 years. The agency has 

indicated it anticipates system modernization changes as described in the Supporting Statement 

to occur between 2013-2014 and that it will timely submit a request for revision with substantive 

changes upon completion of that modernization effort. Upon resubmission, it is further suggested 

that EPA pay close attention to burden estimates and reassess expected burden changes."

ICIS-Air Implementation:
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The EPA Office of Compliance replaced AFS with ICIS-Air, a modern, web-based data system, 

via a multi-year modernization project to improve the ability of EPA and delegated agencies to 

share and manage information regarding CAA compliance and enforcement programs. The 

Agency completed replacement of AFS with ICIS-Air in October 2014. There will be subsequent 

releases of ICIS-Air as new functionality is developed. Due to the enhanced functionality

provided by a web-based system and the superior electronic data transfer process ICIS-Air 

utilizes, the Agency expects the overall burden of data reporting to be less than what delegated 

agencies experienced using AFS. 

2. NEED FOR AND USE OF THE COLLECTION

2(a) NEED/AUTHORITY FOR THE COLLECTION

(i) Authority

The CAA calls for state, local, federal and tribal governments to implement the Act in 

partnership to reduce pollution. It is well understood that working closely with government 

partners leads to better programs that are more effective and efficient. For regulatory programs, 

EPA often has discussions early in the rulemaking process with government partners (federal, 

state, local and tribal) and with interested parties such as affected industries, environmental 

groups, and communities. After a rule is complete, EPA works with government partners and 

stakeholders to achieve effective implementation. This ICR supports the partnership established 

for CAA program implementation by facilitating regular information exchange. Section 

114(a)(1) of the CAA, 42 U.S.C. § 7414(a)(1), establishes that EPA may request information on 

a one-time, periodic or continuous basis for the purpose of carrying out any provision of the Act.

Individually, certain provisions of the Act and its implementing regulations include specific 

language for the collection of some of the information requested by this ICR. For example, 

110(p) of the CAA, 42 U.S.C § 7410(p), establishes that EPA may request information to assess 

the implementation of any state implementation plan. 40 CFR § 70.4(j)(1) (Title V) requires that 

any information obtained or used in the administration of a Title V permit program be available 

to EPA. This ICR encompasses this information in addition to information that assists with 

carrying out additional provisions of the Act. Related provisions include but are not limited to 

New Source Performance Standards (NSPS) in 40 CFR Part 60, National Emission Standards for 

Hazardous Air Pollutants (NESHAP) in 40 CFR Part 61 and Part 63, and New Source Review 

(NSR) permitting regulations in 40 CFR Part 51 and Part 52. The periodic reporting of regulated 

source information, compliance monitoring, violation determination, and enforcement 

information is the subject of this renewal ICR.

(ii) General Need for the Data

The national air stationary source compliance monitoring and enforcement program 

promotes effective, cooperative, and coordinated efforts among the EPA and the delegated 

agencies. The Agency recognizes the primary role of the delegated agencies in the prevention 

and control of air pollution. But, the CAA requires that EPA regularly monitor delegated 
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agencies to ensure adequate implementation and enforcement of delegated and authorized 

programs. To do this, the EPA has identified the minimum amount of data or the Minimum Data 

Requirements (MDRs) it believes is necessary to manage the national air stationary source 

compliance monitoring and enforcement program within this ICR. Reporting the MDRs, which 

are listed in Table 1 in Section 4(b), is critical in order to:

• Manage the national CAA compliance and enforcement program to ensure effectiveness 

and consistency; 

• Oversee state/local/tribal efforts and assess progress in achieving protection of the 

environment and public health; 

• Target compliance activities and enhance ability to use advanced monitoring tools; 

• Improve efforts to achieve health and environmental benefits envisioned by our 

regulations and permits;

• Increase transparency and meet public expectations for readily accessible and detailed 

information; and

• Provide complete and timely responses to inquiries (e.g., Congress, OMB, public).

In addition to the regulatory infrastructure the data supports, it also allows the Agency to 

effectively implement our compliance and enforcement guidance and policies. These are: 

- The Clean Air Act Stationary Source Compliance Monitoring Strategy, July 14, 2014

(CMS) – The CMS establishes a baseline compliance monitoring program with emphasis 

on CAA Title V major sources (as defined by CAA §501(2)) and a limited subset of synthetic 

minor sources, while providing delegated agencies with the flexibility to address local air 

pollution and compliance concerns. The CMS also establishes a framework of minimal 

data requirements for reporting to the EPA. Data included in this ICR is a critical 

component of the implementation of the CMS.

- The Clean Air Act National Stack Testing Guidance, April 27, 2009 – The EPA 

developed the stack testing guidance to improve uniformity in conducting stack tests and

promote coordination among the EPA and delegated agencies. ICIS-Air is the Agency’s 

repository for stack test data regarding compliance with CAA regulations. 

- The Guidance on Federally-Reportable Violation for Clean Air Act Stationary Sources, 

September 23, 2014 (FRV policy)– The EPA developed the 2014 FRV policy to balance 

a commitment to share information with the public about violations of CAA regulations 

that affect their communities with the need to prioritize the use of limited resources 

available to delegated agencies. The FRV policy supports the Agency in managing the 

national CAA compliance and enforcement program. ICIS-Air is the Agency’s repository

for data pertaining to federally-reportable violations, which are violations of federallyenforceable regulations. 

- The Enforcement Response Policy for High Priority Violations of the Clean Air Act, 

August 25, 2014 (HPV policy) – The EPA developed the 2014 HPV policy to help 
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Federal, state, local and tribal delegated agencies prioritize enforcement efforts with 

respect to sources of air pollution. The HPV policy addresses a subset of federallyreportable violations, called high priority violations (HPVs), that the Agency believes 

warrant additional oversight. The additional oversight serves to ensure that delegated 

agencies respond to such violations in a timely and appropriate manner and, if needed, 

have access to federal assistance. ICIS-Air fully supports reporting HPV activity: the 

discovery action, notice/advisement provided to the regulated entity, addressing the 

violation, and resolution of the violation and enforcement action.

Data concerning stationary source compliance monitoring and enforcement programs is 

critical to conducting oversight of delegated agency compliance and enforcement programs. The 

EPA Office of Enforcement and Compliance Assurance (OECA), the Environmental Council of 

States (ECOS), state media associations, and other delegated agency representatives developed a 

State Review Framework (SRF) for conducting consistent reviews of core monitoring and 

enforcement activities pursuant to the CAA, Clean Water Act (CWA), and the Resource 

Conservation and Recovery Act (RCRA) programs. These SRF reviews were initiated in 2004, 

and have occurred in 4-year cycles. The data reported to ICIS-Air is paramount for these 

reviews. Each review begins with an analysis of data metrics to identify any obvious trends or 

issues. The SRF reviews are a platform for collaborative problem solving regarding compliance 

monitoring, enforcement, and data management. 

Specific data from ICIS-Air will be provided to the EPA Web site, Enforcement and 

Compliance History Online (ECHO) (http://www.epa.gov/echo), which allows the public to 

access compliance and enforcement information for multiple statutory programs on 

approximately 800,000 regulated facilities nationwide. ECHO is updated via weekly data 

extracts from ICIS. ECHO allows the public to retrieve information about CAA regulated 

sources as well as EPA and delegated agency compliance evaluations, violation determinations, 

and enforcement actions. In addition to ECHO, data from ICIS is included in the EPA’s

ENVIROFACTS, a web tool developed and maintained by the EPA Office of Environmental 

Information (http://www.epa.gov/enviro/index.html) that allows the public to retrieve data from 

a multitude of EPA databases. ICIS-Air data also will be used as part of performance measures 

satisfying the Government Performance Results Act requirements. 

(iii) Reasons for New Data as Part of this Renewal ICR

This renewal introduces the following policy changes that affect the way that violations 

are to be reported. These changes will effectively reduce the reporting burden compared to the 

current ICR that was approved in January 2012: 

 Guidance on Federally-Reportable Violations for Clean Air Act Stationary Sources (FRV 

policy) and Data: In coordination with national and regional organizations representing 

air compliance and enforcement programs as well as with individual delegated agencies, 

on September 23, 2014, the EPA issued a revised FRV policy which superseded the 2010 

FRV clarification memo. The EPA developed the revised FRV Policy in response to 
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concerns raised by delegated agencies regarding resource constraints and reporting 

burden associated with the 2010 FRV Clarification Memo. 

FRV reporting is important, as it supports the Agency in managing the national CAA 

compliance and enforcement program. The collected data supports: policy analysis and 

evaluation; decision-making in determining the significance of violations and 

enforcement priorities; targeting efforts; and meeting public expectations for accessible, 

detailed information.

The revised policy reduces the overall reporting burden by changing the method for 

reporting violations and limiting the universe of sources whose violations of federally

enforceable requirements are reportable. In AFS, to report a violation, agencies changed 

the compliance status of a regulated pollutant to “in violation.” The delegated agency

then had to change the compliances status back to “in compliance” once the violation was 

resolved. This process was a multi-step process that required the same piece of data to be 

updated at least twice. It was referred to as tracking compliance status. The revised FRV 

policy replaced tracking compliance status with reporting a violation. Agencies now 

report the violation one time. Once the violation is reported by selecting a violation type, 

agencies do not have to touch that specific piece of data again. 

In addition to the method of reporting a violation, the new applicable universe of 

violation sources is limited to: Title V Major Sources; SM-80 sources; sources included 

in a CMS plan; and any source at which a HPV has been identified. This source universe 

provides consistency between compliance monitoring policies and violation reporting for

the delegated agencies. The previous applicable universe included: all synthetic minor 

sources, minor sources subject to a Part 61 NESHAP regulation, and any source subject 

to a formal enforcement action. The narrowed universe of sources is anticipated to result 

in improved data completeness and accuracy. 

As stated in the revised policy, FRVs are violations of federally enforceable CAA 

requirements at a source within the applicable universe stated above. FRVs include 

violations of any emission limit, emission standard, or surrogate parameter. They also 

include procedural violations such as failure to maintain reports and underlying records 

as required by permit or regulation; failure to timely test or conduct valid monitoring as 

required by permit or regulation; failure to timely report; failure to construct, install, or 

operate facility/equipment in accordance with the permit or regulation; failure to obtain 

or maintain a permit; work practice violation; and violation of consent decree, court order 

or administrative order.

To report an FRV into ICIS-Air, a delegated agency creates a Case File. Once the Case 

File is created, the delegated agency is to report the violation type, the applicable federal 

air program or the state or local regulation, pollutant(s), where applicable, associated with 

the violation, and the date the FRV determination was made. If no date is reported, the 

date the FRV is reported in ICIS-Air will be set as a default date. FRVs are expected to 
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be reported within 60 days of when the determination is made that a violation occurred. 

The Case File in which the FRV was reported may be designated as “enforcement 

sensitive” in ICIS-Air, but once the source is notified of the violation(s) or a formal 

enforcement action is issued or entered by a court, the designation should be removed by

either linking an enforcement action record to the Case File or removing the enforcement 

sensitive flag from the Case File.

 The Enforcement Response Policy for High Priority Violations of the Clean Air Act (HPV 

policy): The most recent revision to the HPV policy was issued August 25, 2014,

superseding the 1998 version. The HPV policy addresses a subset of federallyenforceable CAA violations, called High Priority Violations (HPVs) that the EPA 

believes warrant additional oversight to ensure that delegated agencies respond to such 

violations in a timely and appropriate manner and, if needed, have access to federal 

assistance. The policy provides criteria used to identify an HPV.

The revised 2014 HPV policy reflects two substantial changes from the 1998 policy that 

will reduce the reporting burden of the delegated agencies. First, the EPA has focused the 

criteria of what constitutes an HPV on those violations that are most likely to be 

significant for human health and the environment or for maintenance of strong CAA 

programs. In doing so, the Agency has replaced the ten General Criteria and the Matrix 

Criteria with six Criteria. The EPA expects that fewer violations will be classified as an 

HPV, and, as such, there will be a significant reduction in reporting. 

Second, the EPA determined that even when a violation falls within a category of HPVs, 

not every such violation warrants additional tracking and attention at a national level. 

Although prompt identification and communication is a key element in resolving a 

violation, if it is later determined jointly by EPA and delegated air agencies that such 

violation does not warrant additional tracking, delegated agencies can reprioritize their 

efforts. The revised HPV policy provides explicit mechanisms implemented in ICIS-Air 

to remove the matter from HPV oversight. Because these decisions will be made jointly, 

explicitly, and earlier in the process, the EPA expects that delegated agencies will not 

need to continue to consult with the EPA and report on violations that no longer warrant 

the additional oversight. 

To report an HPV into ICIS-Air, a delegated agency creates a Case File. Once the Case 

File is created, the delegated agency reports an HPV by selecting a violation type

associated with an HPV, the applicable federal air program or the state or local 

regulation, pollutant(s), where applicable, and the date the violation was determined to be 

an HPV. This date is referred to as the Day Zero date. HPVs are expected to be reported 

within 60 days of when the determination is made. The Case File in which the HPV was 

reported may be designated as “enforcement sensitive” in ICIS-Air, but once a source is 

notified of the violation(s) or a formal enforcement action is issued or entered by a court, 

the designation should be removed by either linking an enforcement action record to the 

Case File or removing the enforcement sensitive flag from the Case File.
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(iv) Opportunities for New Data 

As agencies become familiar and comfortable with reporting to ICIS-Air, EPA believes 

opportunities for new data will be realized. Over the course of this ICR, EPA would like to 

evaluate the following data for possible inclusion in future ICRs: 

 Source Reported Compliance Status - The requirement to report a compliance status for 

each review of a Title V annual compliance certification was eliminated. In lieu of this, 

the Agency would like to explore reporting the compliance status reported by the source

on the annual certification. 

 Title V Compliance Certification Period Covered - Because some Title V permits require 

quarterly or semi-annual compliance certifications, it would be beneficial for the period 

covered by each certification to be reported in these cases. 

 Subparts for all sources with a Title V permit – If the subpart is included in a Title V

permit, it would be readily accessible and easily reported.

 Source Classification – A source level classification in lieu of a pollutant level 

classification. 

 Linking a Notification to a Case File – Currently, the discovery action, addressing action 

and resolving action are linked to a Case File that includes an HPV. Linking the 

notification would fill the gap in the pathway of activities pertaining to the Case File. 

 Violation Start and End Date – Where a start and end date can be determined, it would be 

beneficial to the public to report this information. The determination may be based on 

self-reported information (e.g., excess emissions reports, etc.) or determined through 

compliance evaluations.

(b) USE/USERS OF THE DATA

There are many ways in which the EPA, delegated agencies, and the public use the data 

included in this ICR. As stated previously, the MDRs represent the minimum amount of data the 

Agency believes necessary for effective management of the national air stationary source 

compliance monitoring and enforcement program. Some of the key uses of the data on a national 

basis are to:

 Provide an accurate and accessible inventory of sources subject to federally enforceable 

regulations;

 Support efficient and effective targeting and enhanced enforcement strategies;
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 Provide the public with transparent access to compliance monitoring and enforcement 

data, while providing facilities with an incentive to fix compliance problems;

 Support essential oversight activities;

 Assist in identifying national trends and issues related to the CAA;

 Develop measures of regulatory program success;

 Communicate performance and results on a national, regional, sector, or other level;

 Standardize delegated agency reporting to EPA;

 Assist regulatory analyses and design of new regulations;

 Support multimedia initiatives which integrate quarterly reports of air, water, and land 

compliance data;

 Provide timely and accurate response to information requests made by citizens, the 

regulated community, Congress and other information requesters; and

 Provide a forum and model of successful delegated agency compliance programs (that 

include Federal data reporting) which can be used by other agencies in the development 

or expansion of their existing programs.

(c) ABOUT ICIS

ICIS is a data system designed to track compliance and enforcement information. It is a

modern web-based system which provides easy access to historical and current records for the 

EPA, and state/local/tribal agency staff involved in compliance and enforcement activities.

Within ICIS, there are data modules specifically for reporting compliance and enforcement data 

pertaining to activities related to the CAA. These modules are collectively referred to as ICISAir. The following are important facets of ICIS:

 ICIS provides both electronic submission and Graphical User Interface (GUI) 

capabilities. 

 ICIS provides modern and streamlined methods for electronic transfer of data. 

 ICIS implements robust security features to ensure the integrity of the software and data, 

protect confidentiality of data, and maximize availability to users.

 ICIS follows the EPA standards for software and hardware development, including the 

use of the Central Data Exchange (CDX) and EPA/ECOS data standards.

 ICIS supports all baseline MDRs necessary to conduct the national air stationary source 

enforcement and compliance assurance program. 
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 ICIS contains a set of streamlined data entry screens with maximized system-generation 

of data based on user permissions and types of records being reported.

ICIS is designed to meet the currently approved MDRs. Hence, the type of information 

(e.g., basic facility information, CMS data, applicable air programs, regulated pollutants, actions, 

and violations) reported into the new system remains essentially the same as in the old system. 

However, due to the design of the new system, there are a few changes to how the MDRs are

reported. 

As an example, to navigate to the appropriate screen on which data is reported, ICIS-Air 

requires an initial indication of the type of activity to be reported (e.g., Inspection/Evaluation). 

In spite of these few additional steps for reporting, we anticipate significant efficiencies in 

reporting and an overall reduction in reporting burden for both direct users, as well as those 

using electronic data transfer (EDT) to report MDRs. System efficiencies will be realized in part 

because: 

(1) ICIS-Air auto-populates data fields to the greatest extent possible based on the record 

type being added or type of agency (e.g., state) associated with the user adding the 

record. 

(2) Drop-down menus of values and type-ahead functionality are provided wherever possible 

to facilitate entry of information, provide greater consistency in data entry, eliminate the 

need to refer to multiple lists of regional action types, and improve overall data quality. 

(3) The technology and capabilities of the new EDT process are a vast improvement over the 

current AFS direct batch process and the “Universal Interface.” 

 (d) PROGRAM CHANGES

There are a few changes in the MDRs. For example, the MDR for “Compliance Status” is 

being streamlined so that the compliance status of an air program pollutant will no longer be 

required, nor will it be required to subsequently change it back to reflect a return to compliance. 

Instead, only violations will be reported into the new system. This change is being made at the 

request of delegated agencies. Also, delegated agencies will no longer be required to report the 

MDR for “Attainment Status.” The new system will automatically obtain this information from 

the EPA Facility Registry System (FRS). In addition, as referenced above, the method for 

reporting MDRs has changed resulting in a few new elements of data necessary to report the 

MDRs. For example, delegated agencies will report whether their enforcement response is 

administrative or judicial, whereas in AFS, the type of enforcement was inherent in the action 

reported.

While EPA is not covered in this ICR, to ensure complete national tracking and 

transparency, there is an expectation that EPA will implement this ICR where appropriate. For 

example, EPA will report compliance monitoring activities for which they were the lead agency, 

and all enforcement actions issued or entered. 

 
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3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION

CRITERIA

(a) NON-DUPLICATION

The MDR elements outlined in Table 1 of Section 4(b) represent minimum data

requirements for effective implementation and management of a national compliance and 

enforcement program. For EPA and the public, the ICIS data will be the only national repository

of information on CAA stationary source compliance and enforcement activities. This ICR 

relates to information that delegated agencies generally collect as part of their customary

business practice to manage their compliance and enforcement programs. Some delegated 

agencies will use ICIS as their sole data system for managing the MDRs and other data elements, 

while others have their own data management systems and will be reporting information they

manage in their own system to ICIS-Air. Roughly one third of the reporting delegated agencies

will report data using electronic data transfer (EDT). 

Agencies that report data to ICIS-Air via EDT submit their data in Extensible Markup 

Language (XML) format. To facilitate the submission of data, node plug-ins have been 

developed for agencies to extract the data requested by this ICR and convert it into XML

submission files that are submitted to ICIS via the EPA’s Central Data Exchange (CDX). To 

support state agencies with creating their own customized code for extracting, formatting, and 

submitting their data to ICIS or with using a plug-in for their EDT process, $3,055,606 was 

awarded in Exchange Network grants in FFY 13 and 14. Some of the grants awarded included

other goals not directly related to ICIS-Air (e.g., support the Air Quality System). 

(b) PUBLIC NOTICE REQUIRED PRIOR TO SUBMISSION TO OMB

EPA published a Federal Register notice on August 21, 2014 soliciting public comments 

for 60 days. EPA received ten comments (see section below for a full discussion of these 

comments). EPA will publish a second Federal Register notice soliciting comments for 30 days 

concurrently with the submission of this ICR to OMB. 

(c) CONSULTATIONS

The requirements for ICIS-Air were developed by a committee that included state and 

local agencies, EPA regional staff and organizations, like the National Association of Clean Air 

Agencies, representing multiple delegated agencies. In addition, the design phase of ICIS-Air 

included two similarly comprised workgroups that focused on migration of data from AFS to 

ICIS-Air and the design of the web Graphic User Interface (GUI); and an Integrated Project 

Team that focused on the EDT process. These groups met between July 2013 and October 2014. 

This collaborative design and development process was initiated to ensure clear communication 

of Agency plans; hear, understand and consider delegated agency perspectives; encourage 

delegated agencies to participate as partners in ICIS-Air development tasks; and help the EPA 

understand the barriers that delegated agencies face in achieving a major information system 
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transition. 

EPA initiated additional consultations with air agencies in order to collect estimates of 

one-time burden associated with transitioning air compliance and enforcement reporting from 

AFS to ICIS-Air, and separately to collect annual estimates of the relative time to report to ICISAir via EDT versus reporting to AFS via batch processes. The feedback EPA received is 

summarized in Section 6(a) Estimating Respondent Burden. 

The first FR notice for this ICR was published August 21, 2014. Comments were 

received from six delegated agencies, one association, and three anonymously. Where 

appropriate these comments were addressed by this ICR. Some of the comments received were

not directly related to this ICR. 

Comments and Agency Responses:

In response to the first FR Notice (79 FR 49511), we received comments from 10 entities.

Comments generally focused on two areas: clarification of the federally-reportable universe, and

our method for estimating the burden associated with reporting to ICIS-Air. At this time, EPA is 

not changing the list of sources that comprise the federally-reportable universe. To clarify the 

federally-reportable universe and its relationship to the CMS, FRV and HPV policies, we offer 

the following:

 The federally-reportable universe is broader than the universe of sources included in the 

CMS, FRV and HPV policies. It is EPA’s expectation that all minimum reportable activities 

(identified in Table 1 of this ICR), which includes informal and formal enforcement actions,

would be reported against the federally-reportable universe. The FRV and HPV policies 

reduce the burden of reporting violation determinations only. For sources that are only 

reportable because they were subject to a formal enforcement action, any minimum 

reportable activity that occurs after the formal enforcement action was issued or entered 

should be reported. 

 Because a source is part of the federally-reportable universe does not mean that a FCE must 

be completed at the source. The EPA Stationary Source CMS policy, which establishes 

EPA’s recommendations for completing FCEs, focuses on Title V majors and 80% synthetic 

minor sources. These facilities are a subset of the federally-reportable universe. But, if an 

FCE is completed at a federally-reportable source, it is EPA’s expectation that the FCE 

would be reported.

In response to the comments regarding our claim that ICIS-Air will result in an overall 

burden reduction, see Section 6 of this ICR for the methodology and results of a limited burden 

assessment. This limited assessment does include a one-time estimate of the resources required 

to participate in the design and development of ICIS-Air. Some agencies opined that previous 

assessments significantly underestimated the actual burden of reporting to AFS. 
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In light of further experience in using ICIS-Air, EPA may decide to renew this ICR in less 

than three years. 

(d) EFFECTS OF LESS FREQUENT COLLECTION

During this ICR renewal process, the EPA is not requesting any changes to the reporting 

timeframes. The 2012 ICR renewal included a change from quarterly reporting to within 60 days 

of the day of the event. This request was made to ensure that the data used by the Agency was 

accurate and as timely as possible, and provided the public with current information. Data 

received quarterly did not provide capability for meaningful reviews at mid-year and end of year. 

Concessions were made in the last ICR for the timeliness of reporting the results of stack tests or 

performance tests. These activities are to be reported within 120 days of the conclusion of the 

test. This concession addressed regulatory allowances where the source is provided 60 days from 

the conclusion of the test to submit the results to the delegated agency. Agencies are then given 

another 60 days to review the test results to determine if a performance test passed or failed. 

If the EPA received data less frequently (e.g., quarterly), there would be an adverse 

impact on the collaborative process for conducting compliance monitoring evaluations and 

ensuring violations discovered are addressed and resolved timely. In addition, the timeliness of 

making this information available to the public would suffer. The lack of timeliness would add to 

data quality concerns.

(e) GENERAL GUIDELINES

This information collection contains no special circumstances that would conflict with 

the general guidelines in 5 CFR § 1320.5.

 (f) CONFIDENTIALITY 

Any information submitted to the Agency for which a claim of confidentiality is made 

will be safeguarded according to Agency policies set forth in Title 40, Chapter 1, Part 2, Subpart 

B - Confidentiality of Business Information (see also 40 CFR 2; 41 FR 36902, September 1, 

1976; amended by 43 FR 42251, September 20, 1978; and 44 FR 17674, March 23, 1979). 

(g) SENSITIVE QUESTIONS

This section is not applicable.

4. THE RESPONDENTS AND THE INFORMATION COLLECTED

(a) RESPONDENTS/NAICS CODES

The respondents for the information collection activity are state, local, territorial, and

tribal delegated agencies. These agencies are classified in NAICS 924110. Source compliance 
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data assembled by delegated agencies covers numerous NAICS categories. Most contacts are 

identified on the EPA Web site (see Contacts List at 

http://www.epa.gov/compliance/contact/data-afscontacts.html ). The total number of respondents 

is 99 (50 states, the District of Columbia, Puerto Rico, the Virgin Islands, Guam, American 

Samoa, the Mariana Protectorate and 43 local air pollution control agencies). The classification 

of small, medium, and large agencies is made based upon the number of major sources included 

in their federally-reportable universe: > 59 major sources is defined as a small agency, 60 - 349 

is defined as a medium agency, and 350 or more major sources is defined as a large agency. But, 

in addition to major sources of which there are 13,742 active as of the drafting of this ICR, these 

delegated agencies track a significant number of non-major sources that are federally reportable 

(25,466 synthetic minors and 3,176 minors). 

The list of agencies by category can be found in Appendix 1, Delegated Agency

Classification by Size. 

(b) INFORMATION REQUESTED

(i) Specific Data Reporting and Record keeping Items

Reporting: To manage the national air stationary source compliance monitoring and 

enforcement program, the EPA provides a set of MDRs that identify the specific data elements to 

be reported and tracked in ICIS-Air. The list of MDRs as reported to ICIS is found in Table 1, 

MDRs for Renewal. Because of the recent transition, Table 2 provides, for reference, the MDRs 

as reported to AFS. The data elements include source information, compliance monitoring 

activities, violation determinations and enforcement actions. Activities can be reported as either 

planned or completed. In general, the completed or concluded date is the relevant date for this 

ICR. Minimum reportable activities include compliance evaluations, investigations, performance 

tests and results, informal enforcement actions, and formal enforcement actions. The following 

section describes each of these data elements. 

A facility1is a stationary source, containing one or more pollutant-emitting units. It

includes portable sources, which are stationary sources that can be moved from one physical 

location to another, such as an asphalt processing plant. Each facility is associated with one 

delegated agency. The delegated agency is identified by a unique combination of characters 

embedded in a facility’s Programmatic Identifier. In ICIS-Air a facility record must exist before 

users can enter data for activities associated with that facility such as compliance evaluations and 

enforcement actions. Activities are to be reported when they occur at a facility that is part of the 

federally-reportable universe, which is comprised of all: 

 Title V major sources, 

 Synthetic minor sources, 

 Sources subject to a Part 61 NESHAP regulation, 

 

1 The terms facility and source are used interchangeably throughout this ICR.
14

 Facilities included in a CMS plan,

 Facilities subject to a formal enforcement action, and 

 Facilities with an HPV. 

The Agency is aware that the federally-reportable universe included in this ICR differs 

from the universe of sources generally covered by the CMS, FRV and/or HPV policies. The 

CMS policy focuses on Title V majors and 80% synthetic minor sources, the FRV policy sets the 

universe of sources at which FRVs are to be reported to Title V majors, 80% synthetic minors, 

sources on a CMS plan, and any source with an HPV; and the HPV policy generally applies to 

Title V majors. This difference will result in compliance monitoring activities and enforcement 

actions being reported for some sources not covered by these policies. 

Compliance monitoring activities are evaluations of the compliance status of the facility. 

These activities include compliance evaluations (both partial and full), investigations, 

performance tests, and receipt and review of Title V annual compliance certifications.

A compliance evaluation generally includes:

 A review of all required reports and the underlying records;

 An assessment of air pollution control devices and operating conditions;

 Observing visible emissions; 

 A review of facility records and operating logs; or

 An assessment of process parameters, such as feed rates, raw material 

compositions, and process rates.

After a compliance monitoring activity is completed a review of all acquired materials 

against the regulatory framework and/or permit is conducted to determine if any violations 

occurred. Some agencies are authorized to make a violation determination during the compliance 

monitoring activity, while others are not. The 2014 FRV and HPV policies discuss when a 

violation is to be reported to ICIS-Air. To report a violation, delegated agencies must first create 

a Case File activity. Within the Case File, violations are reported by selecting a violation type

and air program violated (e.g., New Source Performance Standards). Some violation types also 

require a pollutant (e.g., Violation of an Emission Limit). FRVs include violations of federallyenforceable rules and regulations, which include all limitations and conditions that are 

enforceable by the Administrator and citizens under the CAA or that are enforceable under other 

statutes administered by the Administrator.

If a FRV determination is made, then typically a source is notified of such findings via an 

informal enforcement action. An informal enforcement action notifies or advises the recipient of 

apparent deficiencies, findings concerning noncompliance, or that the issuing agency believes 

one or more violations occurred at the referenced source and provides instructions for coming 

into compliance. An informal enforcement action offers an opportunity for the recipient to 

discuss with the issuing agency actions they have taken to correct the violations identified or 

provide reasons they believe the violations did not occur. An informal enforcement action may
15

include reference to an issuing agencys’ authority to elevate the matter, and/or liability of the 

recipient to pay a penalty. This data is intended to ensure that the delegated agency informs the 

source as soon as possible of the agency’s findings so that the source is on notice of the need to 

promptly correct conditions giving rise to the violation(s) or potential violation(s). 

A formal enforcement action either requires that a person comply with regulations, 

requirements, or prohibitions established under the CAA; sets compliance schedule with 

milestones, requires payment of a penalty or establishes an agreement to pay a penalty; initiates 

an administrative procedure (e.g., file a complaint) or civil action (e.g., referral); or constitutes a 

civil action. Generally these actions are referred to as complaints, settlement agreements, 

compliance or penalty orders, referrals, consent agreements, or consent decrees. In other words, 

formal enforcement actions have legal consequences if the source does not comply. All facilities 

subject to formal enforcement are to be tracked in ICIS until the resolution of the enforcement 

action, regardless of classification. 

In addition to the current MDRs, EPA will be soliciting feedback during the period 

covered by this ICR on existing and new data requirements. We are not requesting that 

comments be submitted on these elements in response to this ICR. The data elements for which 

feedback will be solicited, include, but are not limited to the data identified at 2(a)(iv) of this 

ICR. If warranted, the EPA may renew this ICR in less than three years.

Record keeping: Data provided to the EPA by delegated agencies will be maintained by

the EPA in ICIS-Air and, when appropriate, transferred to the National Archives and Records

Administration. Delegated agencies are not required to report these data elsewhere in other 

federal EPA systems. 

 

(ii) Respondent Activities

The respondent (i.e., delegated agency) activities associated with reporting of compliance 

and enforcement actions include:

1. Process, compile, and review information for accuracy and appropriateness; 

2. Transmit information for entry into ICIS-Air, including any necessary changes to 

delegated agency data systems to facilitate the transfer of MDRs; and

3. Affirm that the data has been transmitted accurately

These tasks generally are to be performed on a 60-day basis. Most of the burdens under 

Activity 1 are designated as Customary Business Practice, because the delegated agencies collect 

the majority of information required by the EPA for their own program management purposes.

Record Retention: Delegated agencies should maintain MDR data in ICIS for at least five 

(5) years with the exception of data pertaining to HPVs. Sources with HPVs are to be kept in 

ICIS-Air indefinitely regardless of operating status. In addition, ICIS-Air users may delete data 

from the system that is no longer valid or that pertains to sources that are no longer federally-
16

reportable or are permanently closed. 
17

TABLE 1

ICIS-AIR: REPORTING MINIMUM DATA REQUIREMENTS – DELEGATED AGENCIES

This table shows provides the CAA stationary source compliance and enforcement minimum data requirements (MDRs) and where they are reported in 

ICIS-Air. 

In some instances there is a difference between reporting requirements for web entry and electronic data transfer (EDT) in ICIS-Air. An example is an 

activity identifier. In ICIS-Air, agencies that will report using EDT will provide an activity identifier for each activity reported, agencies that will report via the 

web will have an activity identifier generated for them. This difference exists to allow EDT agencies to report an identifier generated by their state or local 

agency system. In this table, agencies that will report via the web are referred to as “web agencies,” and agencies that will report using EDT are “EDT agencies.”

Area MDR ICIS-Air Data Field Further explanation of specific data fields.

Source Information

Source/Facility 

Record

Facilities Required Data Fields A facility is a stationary source of pollutants including portable stationary 

sources. All sources included in the federally-reportable universe are to be 

reported. 

Facility ID Programmatic ID The Program ID is 18 alphanumeric characters comprised of the State or 

Tribe, LCON (where applicable), and 13 characters unique within the 

reporting agency. A facility is uniquely defined by its Programmatic ID. The 

Programmatic ID is provided by the delegated agency.

Facility Name Facility Site Name The Facility Name would indicate the environmental relevance of the facility 

or reference the regulated activities (e.g., Joe’s Widget Manufacturing 

Facility). Name changes should be reported as soon as they are known. 

Street Address The address reported is the physical address of a facility. This is the address 

of the location where the emissions occur; not, for example, the corporate 

headquarters. If no physical address exists, delegated agencies may report a 

PO Box along with a latitude and longitude for the physical location of the 

facility.

City City (GNIS City Code or 

City Name) 

The city can be reported in the City free text field or in the City Name 

(GNIS) field using the GNIS Feature ID. If no city is available, a 

corresponding value indicating such should be provided in the City text field 

(e.g., No City) with an accurate latitude and longitude reported. 

State State The postal state code that corresponds to the state in which the facility is 

physically located. 

County County Name (GNIS) A county is required if the City text field is used to report the City. If the City 

Name (GNIS) is used to report the City, the county will be set based on the 
18

Area MDR ICIS-Air Data Field Further explanation of specific data fields.

City Name (GNIS) reported. 

Zip Code Zip Code The zip code that corresponds to the physical location of the facility. 

NAICS Code Primary NAICS Code The North American Industry Classification System (NAICS) is the standard 

used by Federal statistical agencies in classifying business establishments.

NAICS are assigned based on a facility’s primary business activity. A 

complete and valid NAICS code contains six digits.

Government Ownership Facility Type of Ownership Facility Type of Ownership reflects whether the facility is privately owned or

owned by different levels of government. Although identification of the 

owner/operator can be defined down to the municipal level, at a minimum 

any federally owned/operated facility should be identified. 

Air Programs All Applicable 

Federally-Enforceable 

Air Program(s)

Required Data Fields Air programs are CAA regulatory programs (e.g., Title V permits). All 

applicable air program codes are to be reported, but a plant should have at 

least one air program. Programs that are not delegated or enforced by a state 

or local agency are not required to be reported by delegated agencies (e.g., 

Mandatory GHG Reporting Rule, CFC Tracking (CAA Title VI)). EPA 

should report these air programs, where applicable. 

Air Program Air Program An Air Program code represents a CAA regulatory program applicable to a 

facility. In cases where state or local regulations are stricter than federal 

regulations, reporting of the federal air program is sufficient. Another option 

available to delegated agencies is to report a general “Federally-Enforceable 

Requirement” and provide a state or local regulatory citation in a free text 

field. Typically state and local permits identify the permit conditions that are 

federally-enforceable. So, this information is readily available. 

Air Program Operating 

Status

Air Program Operating 

Status

An operating status must be reported for each air program. The Operating 

Status represents the operational condition of the unit(s) or processes to 

which the air program applies or the operational condition of the facility. 

Subparts for NSPS, 

NESHAP, MACT

Subparts A subpart is associated with an air program. A subpart is required for 

NESHAP Part 61 regardless of facility classification. A subpart is required 

for NESHAP Part 63 and NSPS if the facility is a Title V major. Part 63 and 

NSPS subparts are optional but encouraged for any non-major facility. Where 

Subpart A – General Provisions are incorporated into a source specific 

subpart wholly or by reference, delegated agencies do not also have to report 

Subpart A as an applicable Subpart. 

Pollutants Regulated Pollutant(s) 

by Air Program

Required Data Fields All pollutants for which a source is regulated should be reported, but at a 

minimum each facility should have at least one pollutant. 

Pollutant Code or CASN Pollutant Name or CASN Pollutants reported include those for which a source is regulated. 
19

Area MDR ICIS-Air Data Field Further explanation of specific data fields.

Pollutant Classification Delegated Agency 

Pollutant Classification 

Pollutant classification indicates the rate at which a facility can potentially 

emit a pollutant. A pollutant classification is required for each pollutant. If a 

classification is not applicable, agencies may report “Not Applicable” as the 

classification. 

CMS Record CMS Required Data Fields The CMS Record identifies sources that are included on a CMS plan. This 

data is only reported for sources that are included on a CMS plan. 

CMS Source Category CMS Source Category The Source Category corresponds to the category defined by the CMS policy

in which a facility is assigned based on its potential to emit (PTE). For the 

purposes of the CMS policy, PTE is the maximum capacity of a stationary 

source to emit a pollutant under its physical and operational design. 

CMS Minimum 

Frequency Indicator

CMS Minimum Frequency The Minimum Frequency is the minimum number of federal fiscal years 

recommended between full compliance evaluations at a source covered by 

the CMS policy. If the CMS policy includes a recommended minimum 

frequency for the CMS Source Category applied to the facility, the CMS 

Minimum Frequency will default to the policy recommended minimum 

frequency on the web. Delegated agencies may overwrite the Minimum 

Frequency. EDT agencies must submit the Minimum Frequency, it will not 

default. 

Minimum Reportable Activities

FCE Record FCEs Required Data Fields A Full Compliance Evaluation (FCE) is a comprehensive evaluation of a 

facility. All FCEs should be reported. 

Facility ID Programmatic ID Delegated agencies must associate the FCE to one facility. The Programmatic 

ID is the unique identifier for the facility. 

Action Type (Lead 

Agency/On or Off Site)

Compliance Monitoring 

Activity Type

As a result of the structure of ICIS, delegated agencies must first identify the 

type of activity they wish to report (e.g., Inspection/Evaluation). Web 

agencies do this via the Add link. EDT agencies must include this in their 

submission. 

Compliance Monitoring 

Type 

The compliance monitoring type indicates the specific type of compliance 

evaluation performed. If any component of the evaluation was performed onsite, the FCE should be reported as on-site. 

Lead Agency The Lead Agency indicates the agency that primarily performed the activity 

reported. If the reporting agency was not the lead agency for the activity, they 

must select the Lead Agency. Otherwise, the field will default based on the 

record type being added (i.e., state, local, etc.). 

Date Achieved Actual End Date The actual end date is the date the reported activity occurred. 

Air Program(s) Air Programs The air program is the applicable regulation. All air programs for an activity 
20

Area MDR ICIS-Air Data Field Further explanation of specific data fields.

should be reported on the action record.

Activity Identifier Compliance Monitoring 

Identifier 

The identifier is unique for every record in ICIS. It allows agencies to easily 

and accurately identify their records for updating or editing purposes. ICISAir will generate the activity identifier automatically when the record is 

created directly on the web. EDT users must provide the identifier. This was 

established so that an identifier generated by or recognized by their state or 

local system could also be used for tracking in ICIS-Air. 

PCE Record PCEs Required Data Fields A Partial Compliance Evaluation (PCE) is a documented compliance 

assessment focusing on a subset of regulated pollutants, regulatory 

requirements, or emission units at a given facility. PCEs are only required 

when they are a discovery action for an HPV or are included in a CMS 

alternative plan.

Facility ID Programmatic ID Delegated agencies must associate the PCE to one facility. The Programmatic 

ID is the unique identifier for the facility.

Action Type (Lead 

Agency/On or Off Site)

Compliance Monitoring 

Activity Type

As a result of the structure of ICIS, delegated agencies must first identify the 

type of activity they wish to report (e.g., Inspection/Evaluation,). Web 

agencies do this via the Add link. EDT agencies must include this in their 

submission. 

Compliance Monitoring 

Type 

The compliance monitoring type indicates the specific activity performed. If 

the PCE was conducted on-site, a delegated agency can report the specific 

evaluation activity conducted (e.g., PCE On-site Interview). 

Lead Agency The Lead Agency indicates the agency that primarily performed the activity 

reported. If the reporting agency was not the lead agency for the activity, they 

must select the Lead Agency. Otherwise, the field will default based on the 

record type being added (i.e., state, local, etc.).

Date Achieved Actual End Date The actual end date is the date the reported activity occurred. 

Air Program(s) Air Programs The air program is the applicable regulation. All air programs for an activity 

should be reported on the action record.

Activity Identifier Compliance Monitoring 

Identifier 

The identifier is unique for every record in ICIS. It allows agencies to easily 

and accurately identify their records for updating or editing purposes. ICISAir will generate the activity identifier automatically when the record is 

created directly on the web. EDT users must provide the identifier. This was 

established so that an identifier generated by or recognized by their state or 

local system could also be used for tracking in ICIS-Air. 
21

Area MDR ICIS-Air Data Field Further explanation of specific data fields.

Investigations Investigation

Conducted

Required Data Fields An investigation is limited to a portion of a facility, is more resource 

intensive, and involves a more in-depth assessment of a particular issue. All 

investigations conducted should be reported. 

Facility ID Programmatic ID Delegated agencies must associate the investigation to at least one facility. 

The Programmatic ID is the unique identifier for the facility.

Action Type (Lead 

Agency)

Compliance Monitoring 

Activity Type

As a result of the structure of ICIS, delegated agencies must first identify the 

type of activity they wish to report (e.g., Inspection/Evaluation). Web 

agencies do this via the Add link. EDT agencies must include this in their 

submission. 

Compliance Monitoring 

Type 

The compliance monitoring type indicates the specific activity performed. 

Lead Agency The Lead Agency indicates the agency that primarily performed the activity 

reported. If the reporting agency was not the lead agency for the activity, they 

must select the Lead Agency. Otherwise, the field will default based on the 

record type being added (i.e., state, local, etc.).

Date Achieved Actual End Date (for 

Investigation Conducted)

For an investigation, the Actual End Date corresponds to the date the 

investigation concluded.

Actual Start Date (for 

Investigation Initiated)

Delegated agencies can optionally report the Actual Start Date to identify 

when the Investigation was initiated (this is required for EPA). If the only the 

Actual Start Date is reported, the record will be enforcement sensitive. 

Air Program(s) Air Programs The air program is the applicable regulation. All air programs for an activity 

should be reported on the action record. 

Activity Identifier Compliance Monitoring 

Identifier 

The identifier is unique for every record in ICIS. It allows agencies to easily 

and accurately identify their records for updating or editing purposes. ICISAir will generate the activity identifier automatically when the record is 

created directly on the web. EDT users must provide the identifier. This was 

established so that an identifier generated by or recognized by their state or 

local system could also be used for tracking in ICIS-Air. 
22

Area MDR ICIS-Air Data Field Further explanation of specific data fields.

Stack Tests Stack Tests Conducted Required Data Fields A stack test, also referred to as a performance or source test, measures the 

amount of a specific regulated pollutant, pollutants, or surrogates being 

emitted; demonstrates the capture efficiency of a capture system; or 

determines the destruction or removal efficiency of a control device used to 

reduce emissions at facilities subject to CAA requirements. All stack tests 

conducted for demonstrating or determining compliance with federallyenforceable requirements should be reported. 

Facility ID Programmatic ID Delegated agencies must associate the stack test to one facility. The 

Programmatic ID is the unique identifier for the facility.

Action Type (Who 

Conducted/Who 

Observed, Lead Agency)

Compliance Monitoring

Activity Type

As a result of the structure of ICIS, delegated agencies must first identify the 

type of activity they wish to report (e.g., Inspection/Evaluation). Web 

agencies do this via the Add link. EDT agencies must include this in their 

submission. 

Compliance Monitoring 

Type

The compliance monitoring type indicates the specific activity performed. 

Conducted By Conducted By indicates who performed the test or contracted with a third 

party to perform the test. Since the majority of stack tests reported for 

compliance purposes are conducted by the owner/operator, the value defaults

to owner/operator on the web. Delegated agencies may overwrite this value. 

EDT agencies must include this in their submission, it will not default. 

Observed By Observed By indicates whether the delegated agency or EPA was on-site 

during the test to observe its performance. If an agency was present during 

the test, delegated agencies should select the agency. 

Lead Agency The Lead Agency indicates the agency that primarily performed the activity 

reported. If the reporting agency was not the lead agency for the activity, they 

must select the Lead Agency. Otherwise, the field will default based on the 

record type being added (i.e., state, local, etc.).

Date Achieved Actual End Date The actual end date is the date the stack test was completed. 

Test Results (Pass, Fail, 

Pending)

Stack Test Status The status corresponds to whether the measured results indicate the unit was 

able to meet the emission, parameter or surrogate limit measured; or capture, 

destruction or removal efficiency required. 

Air Program(s) Air Programs The air program is the applicable regulation. All air programs for an activity 

should be reported on the action record. 

Activity Identifier Compliance Monitoring 

Identifier 

The identifier is unique for every record in ICIS. It allows agencies to easily 

and accurately identify their records for updating or editing purposes. ICISAir will generate the activity identifier automatically when the record is 
23

Area MDR ICIS-Air Data Field Further explanation of specific data fields.

created directly on the web. EDT users must provide the identifier. This was 

established so that an identifier generated by or recognized by their state or 

local system could also be used for tracking in ICIS-Air. 

TV ACC 

Due/Received

All TV ACCs Required Data Fields The Title V permitting program (Part 70) requires that a compliance 

certification be submitted not less than annually. All compliance 

certifications should be reported. 

Facility ID Programmatic ID Delegated agencies must associate the TV ACC to one facility. The 

Programmatic ID is the unique identifier for the facility.

Action Type – TV ACC 

Due/Received (Lead 

Agency)

Compliance Monitoring 

Activity Type

As a result of the structure of ICIS, delegated agencies must first identify the 

type of activity they wish to report (e.g., Inspection/Evaluation); for EDT the 

Compliance Monitoring Activity Type for TV ACC records will be generated 

based on the XML submission type.

Compliance Monitoring 

Type

The compliance monitoring type indicates the specific activity performed. 

The TV ACC Due/Received indicates the date the compliance certification is 

due and the date it is received. There are instances where a source is required 

to submit quarterly or semi-annual certifications. In these instances, all 

compliance certifications received are to be reported. When multiple 

compliance certifications are submitted, it is recommended but not required 

that the delegated agency report the Certification Period in order to show that 

the full year was covered by the certifications. 

Lead Agency The Lead Agency indicates the agency that primarily performed the activity 

reported. If the reporting agency was not the lead agency for the activity, they 

must select the Lead Agency. Otherwise, the field will default based on the 

record type being added (i.e., state, local, etc.).

Due/Received Date Planned End Date The Planned End Date reflects the date the Title V Annual Compliance 

Certification is due to the permitting authority and/or EPA. Where Title V

sources submit semi-annual certifications this date should reflect the date 

each semi-annual certification is due to the permitting authority and/or EPA. 

Actual End Date The Actual End Date reflects the date the Title V Annual Compliance 

Certification was received by the permitting authority and/or EPA. Where 

Title V sources submit semi-annual certifications this date should reflect the 

date each semi-annual certification was received by the permitting authority 

and/or EPA.

Air Program(s) Air Programs The air program is the applicable regulation. All air programs for an activity 

should be reported on the action record. 

Activity Identifier Compliance Monitoring The identifier is unique for every record in ICIS. It allows agencies to easily 
24

Area MDR ICIS-Air Data Field Further explanation of specific data fields.

Identifier and accurately identify their records for updating or editing purposes. ICISAir will generate the activity identifier automatically when the record is 

created directly on the web. EDT users must provide the identifier. This was 

established so that an identifier generated by or recognized by their state or 

local system could also be used for tracking in ICIS-Air. 

TV ACC 

Review

All TV ACCs Required Data Fields All compliance certifications received should be reviewed, and the review 

should be reported. 

Action Type – TV ACC 

Review (Lead Agency)

Reviewer Agency Part 70 requires that a source submit their compliance certification to both the 

permitting authority and EPA. Both agencies can report the date and results 

of a review of a compliance certification on the same Due/Received activity 

record. Therefore, each agency must identify themselves in order to 

distinguish between multiple reviews. 

Date Achieved (Review 

action, Lead Agency)

Reviewed on [Date] The Reviewed on date corresponds to the date the agency completed their 

review of the compliance certification. 

Deviations? Did Facility Report 

Deviations?

Part 70 requires that a compliance certification identify each deviation. The 

reviewer agency reports Yes or No to identify whether or not the source 

reported that deviations occurred during the certification period. 

Informal 

Enforcement 

Actions

Notification of a 

Violation

Required Data Fields An informal enforcement action notifies or advises the recipient of apparent 

deficiencies, findings concerning noncompliance, or that the issuing agency 

believes one or more violations occurred at the referenced source and 

provides instructions for coming into compliance. All informal enforcement 

actions should be reported. 

Facility ID ICIS-Air Programmatic ID Delegated agencies must associate the informal enforcement action to at least 

one facility. The Programmatic ID is the unique identifier for the facility.

Action Type (Lead 

Agency)

Enforcement Action Forum As a result of the structure of ICIS, delegated agencies must first identify the 

type of activity they wish to report (e.g., Judicial Enforcement). Web 

agencies do this via the Add link. For EDT, the forum for Informal 

Enforcement Actions will be generated based on the XML submission type. 

Enforcement Action Type The type of informal enforcement action refers to the method or the vehicle 

used for notifying a source of a violation. Notification includes any notice of 

violation required by Section 113 of the CAA or corresponding state, local, 

or tribal implementation plan as well as other written notices, meetings, 

teleconferences and electronic correspondence. For HPVs only, the other 

forms of notice (e.g., teleconference) are to be reported on a Case File, 

Violation Details as the Method of Advisement and are further referenced 

below. 
25

Area MDR ICIS-Air Data Field Further explanation of specific data fields.

Lead Agency The Lead Agency indicates the agency that primarily performed the activity 

reported. If the reporting agency was not the lead agency for the activity, they 

must select the Lead Agency. Otherwise, the field will default based on the 

record type being added (i.e., state, local, etc.).

Date Achieved Achieved Date The Achieved Date reflects the date the notice is issued or provided to the 

source.

Air Program Code(s) Programs Violated The programs violated are the applicable regulations which a facility was 

determined to have violated. All air programs violated should be reported on 

the action record. 

Activity Identifier Enforcement Action 

Identifier 

The identifier is unique for every record in ICIS. It allows agencies to easily 

and accurately identify their records for updating or editing purposes. ICISAir will generate the activity identifier automatically when the record is 

created directly on the web. EDT users must provide the identifier. This was 

established so that an identifier generated by or recognized by their state or 

local system could also be used for tracking in ICIS-Air. 

Formal 

Enforcement 

Actions

Formal Enforcement 

Actions

Required Data Fields A formal enforcement action addresses or resolves a violation. Generally 

these actions are referred to as complaints, settlement agreements, 

compliance or penalty orders, referrals, consent agreements, or consent 

decrees. Formal enforcement actions have legal consequences if the source 

does not comply. All formal enforcement actions should be reported. 

Facility ID Programmatic ID Delegated agencies must associate the formal enforcement action to at least 

one facility. The Programmatic ID is the unique identifier for the facility.

Action Type (Lead 

Agency)

Enforcement Action Forum As a result of the structure of ICIS, delegated agencies must first identify the 

type of activity they wish to report (e.g., Judicial Enforcement). Web 

agencies will do this via the Add link. For EDT, they must include this in 

their submission. 

Enforcement Action Type In order to report a Final Order (e.g., Administrative Compliance Order) 

users must first create the Enforcement Action Type (e.g., Administrative 

Order). 

Lead Agency The Lead Agency indicates the agency that primarily performed the activity 

reported. If the reporting agency was not the lead agency for the activity, they 

must select the Lead Agency. Otherwise, the field will default based on the 

record type being added (i.e., state, local, etc.).

Milestones: Actual Date Milestones reference steps in the enforcement response. The milestones vary 

depending on the type of enforcement (administrative or judicial). When a 

complaint is filed it is reported as a milestone on an enforcement action. A 
26

Area MDR ICIS-Air Data Field Further explanation of specific data fields.

referral to the State Attorney General or its equivalent is reported as a 

milestone on a judicial enforcement action. The date that the milestone 

occurred must be reported. 

Air Program(s) Programs Violated The air program is the applicable regulation. All air programs for an activity 

should be reported on the action record. 

Activity Identifier Enforcement Action 

Identifier 

The identifier is unique for every record in ICIS. It allows agencies to easily 

and accurately identify their records for updating or editing purposes. ICISAir will generate the activity identifier automatically when the record is 

created directly on the web. EDT users must provide the identifier. This was 

established so that an identifier generated by or recognized by their state or 

local system could also be used for tracking in ICIS-Air. 

Final Order Formal Enforcement 

Actions

Required Data Fields The final order is the vehicle which captures a settlement agreement, 

compliance schedule, penalty assessment, or conditions to return to 

compliance. 

Activity Identifier Final Order ID Because multiple Final Orders can be reported on the same enforcement 

action type, a Final Order ID is needed to make the record unique. For web 

agencies, the Final Order ID will be generated when the record is saved. EDT 

users must provide the identifier. This was established so that an identifier 

generated by or recognized by their state or local system could also be used 

for tracking in ICIS-Air.

Facility ID ICIS-Air Programmatic ID Delegated agencies must associate the Final Order to at least one facility. The 

Programmatic ID is the unique identifier for the facility.

Action Type (Lead 

Agency)

Final Order Type The final order is the vehicle which captures a settlement agreement, 

compliance schedule, penalty assessment, or conditions to return to 

compliance, which may include injunctive relief. 

Date Achieved Final Order Issued Date 

(Admin) 

Final Order Entered Date 

(Judicial) 

The Final Order Issued Date is the date the final administrative order (e.g., 

administrative compliance order, administrative penalty order, or consent 

agreement) was signed by a delegated authority and/or the recipient source. 

The Final Order Entered Date is the date the final order is entered by a court. 

Resolving Action Air Resolved Date For violations addressed administratively or through any non-judicial 

process, resolved means all penalties have been collected, SEPs completed, 

and the source is confirmed to be in compliance with respect to violations 

included in the final order. For violations addressed judicially, resolved 

means a court of competent jurisdiction has entered an order adjudicating the 

case and the order is final.
27

Area MDR ICIS-Air Data Field Further explanation of specific data fields.

Cash Assessed Penalty Penalty Assessed to be Paid 

To:

The Cash Assessed Penalty value is the monetary penalty assessed in the 

penalty action or settlement offer. A penalty will be required for some 

enforcement action types, but not all. 

Case File Violation Tracking Required Data Fields A Case File must be added for a delegated agency to report a known or 

suspected violation. A Case File can contain information about more than one 

violation at a source. Violations should be reported in accordance with the 

2014 FRV and 2014 HPV policies. Each of these policies focuses on a subset 

of federally-enforceable violations.

Facility ID Programmatic ID Delegated agencies must associate the Case File to one facility. The 

Programmatic ID is the unique identifier for the facility.

Air Program Programs The air program is the applicable regulation that the facility was determined 

to have violated. 

Pollutant Pollutants The pollutant reported is the pollutant that is the basis for the regulation or 

permit condition that was violated. Multiple pollutants can be reported on a 

Case File.

Lead Agency Lead Agency The Lead Agency indicates the agency that primarily performed the activity 

reported. If the reporting agency was not the lead agency for the activity, they 

must select the Lead Agency. Otherwise, the field will default based on the 

record type being added (i.e., state, local, etc.).

Activity Identifier Case File Identifier The identifier is unique for every record in ICIS. It allows agencies to easily 

and accurately identify their records for updating or editing purposes. ICISAir will generate the activity identifier automatically when the record is 

created directly on the web. EDT users must provide the identifier. This was 

established so that an identifier generated by or recognized by their state or 

local system could also be used for tracking in ICIS-Air. 

Violation 

Details

Violation Tracking Required Data Fields This data is designated as enforcement sensitive.

Violation Violation Type All federally-reportable violations should be reported. The violation type 

indicates whether the violation is an FRV or HPV.

Air Program The air program is the applicable regulation or program that the facility was 

determined to have violated. Only one air program can be reported per 

violation type. 

Pollutant The pollutant reported is the pollutant that is the basis for the regulation or 

permit condition that was violated. Only one pollutant can be reported per 

violation type. 

Date Achieved HPV Day Zero Date The Day Zero Date is the earliest date that the delegated agency makes the 
28

Area MDR ICIS-Air Data Field Further explanation of specific data fields.

initial identification of a violation as an HPV. It is the date used to evaluate 

timeliness of actions in accordance with the HPV policy. 

Informal Enforcement Method of Advisement The delegated agency should record on the Violation Details that it advised a 

source of the violation by entering the method of advisement, which includes: 

any written notices, meetings, teleconferences, and electronic 

correspondence. If the initial notice is a Notice of Violation or Warning 

Letter issued pursuant to CAA § 113(a) or a State or Tribal implementation 

plan, the notice is to be reported using the Enforcement Action module. 

Date Achieved Date of Advisement This corresponds to the date when the facility was initially advised of any 

violation. 

HPV HPV Pathway Required Data Fields These actions are either linked to a Case File or reported on the Case File. 

When a compliance monitoring activity is linked to or reported on a Case 

File, it is the discovery action. When a formal enforcement action is linked to 

a Case File it is the addressing and resolving action. 

Discovery Action Discovery Action/Date The activity that led to the discovery of a violation. The Discovery Action 

can either be a compliance monitoring activity reported to ICIS as such and 

linked to a Case File, or other options for discovery action can be reported 

(e.g., self-disclosed). The other options are reported on a Case File. 

Addressing Action Addressing Action/Date The delegated agency can address a violation using one of the following 

legally-enforceable actions: (1) issuing a legally enforceable order, (2) 

issuing a legally enforceable order that imposes penalties, (3) issuing a 

legally enforceable order that imposes a schedule on the source to comply 

with the requirement(s) violated and penalties, or (4) transferring the matter 

to an organization with authority to initiate a civil or criminal judicial action. 

The addressing action can either be an enforcement action reported to ICIS as 

such and linked to a Case File, or there are non-enforcement options reported 

on the Case File as an addressing action (e.g., No Further Action, Lead 

Change). 

Resolving Action Resolving Action/Date Resolved means that: (a) in a filed judicial action (state, local or federal), a 

court of competent jurisdiction has entered an order adjudicating the case; (b) 

for violations addressed administratively or through any non-judicial means, 

all penalties have been collected, all SEPs completed, and the source is 

confirmed to be in compliance with respect to all HPVs included in the 

administrative order or non-judicial agreement; or (c) an enforcement agency 

has proposed revisions to its implementation plan regarding the violation. If 

the resolution was achieved via enforcement, then the date the violation was 
29

Area MDR ICIS-Air Data Field Further explanation of specific data fields.

resolved is reported on the enforcement action. If resolution was achieved 

through non-enforcement means, the resolving action is reported on the Case 

File (e.g., Proposed SIP Revision).
30

TABLE 2

SUMMARY OF NATIONAL MINIMUM DATA REQUIREMENTS (MDRs)

FOR CLEAN AIR ACT STATIONARY SOURCE COMPLIANCE-2012 ICR

Note: Unless otherwise noted, both the EPA Regions and delegated agencies report their own 

data. The universe of facilities for ICIS-Air includes: Major, Synthetic Minor and Part 61 

NESHAP Minor facilities, other facilities identified within the CMS Evaluation Plan, any facility

with a formal enforcement action, and any facility with an active HPV. Facilities with formal 

enforcement actions (i.e., administrative orders, consent decrees, civil or criminal referrals and 

actions) should be tracked until the resolution of the violation, regardless of classification. If a 

minor source is included in the CMS universe, has a current enforcement action of three (3)

years old, or is listed as a discretionary HPV, it is considered reportable. Individual regional/state 

agreements are not superseded by this listing. 

Identification AFS Acronym

1. Facility Name PNME

2. State STAB/STTE

3. County CNTY

4. Facility Number PCDS

5. Street STRS

6. City CYNM

7. Zip Code ZIPC

8. NAICS Code NIC1

[Note: While SIC Codes can be reported to AFS, reporting of the NAICS code is required.]

9. Government Ownership GOVT

10. HPV Linkage and Key Action (Day Zero) Linked from Action Data

Compliance Monitoring Strategy (CMS)

11. CMS Source Category CMSC

12. CMS Minimum Frequency Indicator CMSI

Note: Generally EPA enters these fields into AFS; delegated agencies provide this information 

per agreement with the EPA Region. An EPA Region may delegate data entry rights to a 

delegated agency. 

All Regulated Air Program(s) [Note: All applicable air programs should be reflected at the 

plant level of AFS.]

13. Air Program APC1

14. Operating Status AST1

15. Subparts for NSPS, NESHAP and MACT SPT1

Note: Any applicable subpart for the NSPS, NESHAP or MACT air program at major and 

synthetic minor sources, minor source NESHAP and all other facilities reported as MDR. 

Reporting of minor source NSPS and MACT subparts are optional, but recommended. 

Regulated Pollutant(s) within Air Programs(s)
31

16. Pollutant(s) by Code or Chemical 

Abstract Service Number

PLAP/CAPP

17. Classification(s): EPA/ST ECLP/SCLP

18. Attainment Status: EPA/ST EATN/SATN

[Note: The 2011 ICR restricts the values necessary for the Attainment Status to N = 

Nonattainment, A = Attainment, and U = Unknown]

19. Compliance Status: EPA/ST ECAP/SCAP

Actions Within Air Programs (includes Action Number, Type, Date Achieved)

20. Minimum Reportable Actions:

 Informal Enforcement Action: Notice of Violation(s)

 Formal Enforcement Actions: Administrative Order(s) and Assessed Penalties, Consent 

Decrees and Agreements, Civil and Criminal Referrals, Civil and Criminal Actions

 HPV Violation Discovered: Linked actions are FCEs, PCEs, Stack Tests (Observed or 

Reviewed), Title V Annual Compliance Certifications, Stack Test Notification Receipt

 HPV Addressing Actions: Linked actions include but are not limited to State/EPA Civil or

Criminal Referrals, State/EPA Civil or Criminal Actions, Administrative Orders, Consent 

Decrees, Source Returned to Compliance by State/EPA with no Further Action Required. 

 HPV Resolving Actions: Linked actions include but are not limited to Violation Resolved, 

Closeout Memo Issued, Source Returned to Compliance by State/EPA with no Further 

Action Required. 

 Full Compliance Evaluations (On or Off Site)

 Stack Tests: Date of the test is reported in the Date Achieved field, Pass/Fail/Pending 

codes (PP/FF/99) are reported in the results code field, must be reported to AFS within 120 

days.

 Title V Annual Compliance Certification Due/Received: Reported by EPA unless 

otherwise negotiated. The Due Date of a Title V Annual Compliance Certification will be 

reported as Date Scheduled on the “Title V Annual Compliance Certification 

Due/Received by EPA” action, and is not enforcement sensitive. 

 Title V Annual Compliance Certification Reviewed: Includes Results Codes for Annual 

Compliance Certification reviews: in compliance (MC), in violation (MV), and unknown 

(MU). Annual Compliance Certification deviation(s) will be indicated in RD08 for EPA 

reviews (and state reviews as negotiated). 

 Investigations: EPA Investigation Initiated (started) and State/EPA Investigation 

Conducted (finished). State Investigation Initiated is added for optional use. EPA and State 

Investigation Initiated (started) action types are enforcement sensitive. 

Additional Action Information:

21. Results Code RSC1

Note: Pass/Fail/Pending (PP/FF/99) codes are reported for Stack Test actions. Compliance 

Results Codes of “In Compliance (MC), In Violation (MV), or Unknown (MU)” are entered 

for Title V Annual Compliance Certification reviews. 

22. RD08 (Certification Deviations) RD81
32

Note: EPA reports into AFS unless otherwise negotiated. Compliance Codes of “In 

Compliance (MC), In Violation (MV), or Unknown (MU)” are entered for Title V Annual 

Compliance Certification reviews. 

23. Date Scheduled DTS1

Note: The Due Date of a Title V Annual Compliance Certification will be reported as Date 

Scheduled on the “Title V Annual Compliance Certification Due/Received by EPA” action, 

and is not enforcement sensitive. 

24. HPV Violation Type Code(s) VTP1

Note: To be identified when the Day Zero action is established

25. HPV Violating Pollutant(s)

Note: To be identified when the Day Zero action is established.

Timeliness Standard

26. Action Reported within 60 Days of Event reported in the Date Achieved (DTA1) field of 

the action record for delegated agencies, with a minimum upload of six (6) times per year. 

Monthly updating is encouraged. Federal Data is to be reported on a monthly basis. 

OPTIONAL/DISCRETIONARY DATA REPORTING: NON-MDR DATA

The following items cover data that are not considered MDRs, but as useful and helpful for 

program implementation, evaluation, and oversight. Delegated agencies are encouraged to 

report the following items whenever practicable. 

 Minor Facility information: For minor sources that are not MDR (MDR for minor facilities 

is defined as: Minor NESHAP, a minor facility identified within the CMS plan for 

evaluation, minor facilities with an enforcement action less than three (3) years old, or any 

HPV case regardless of class) reporting is optional but encouraged. Minor source 

information would include NSPS and MACT subpart applicability.

 Stack Test Pollutant (PLC1)

 Partial Compliance Evaluations (PCEs) and specific reporting of On-Site PCE activity

defined as: Complaint Partial Compliance Evaluation, Permit Partial Compliance 

Evaluation, Process Partial Compliance Evaluation, and Partial Compliance Evaluation 

On-Site Observation. (Note: All PCEs are required to be reported by EPA Regional 

offices. Also, any negotiated PCEs that are part of an alternative frequency which is part 

of an agency’s CMS plan are required to be reported.)

 Reporting more frequently than every 60 days. 

 State Investigations initiated (Enforcement Sensitive).

 Title V Permit Program Data Elements (PPDEs): Required for reporting to AFS by the 
33

Office of Air Quality Planning and Standards (OAQPS), used by the Office of 

Enforcement and Compliance Assurance (OECA) for major source universe population. 

To be established when the Title V permit is issued. AFS will require the establishment of 

an AFS ID, the individual permit number, category, and event type for permit issued plus 

the date achieved. Permit Program Data Elements (PPDEs) include the Permit Number 

(ASPN), Permit Category (PMTC), and Permit Issuance Event Types (IF – Permit Issued 

and IR – Permit Renewal) and the date (PATY/PDEA). 

 Automatic Generation of the Compliance Status for High Priority Violator (HPV) 

Pathways: Agencies have the option of using AFS software to generate the compliance 

status for sources with HPV pathways. 

5. AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION 

MANAGEMENT

(a) AGENCY ACTIVITIES

Activities performed by EPA personnel involve both EPA regional and headquarters 

staff. The regional offices generally serve as the primary liaison with respondents, and, if 

applicable, assume the primary role of any EPA reporting of data. Headquarters staff focus 

primarily on data system issues, data management practices, and other national program 

management activities. The EPA activities include2:

 Interaction with delegated agencies (e.g., answer respondent questions, train respondents 

on the use of the system, liaison with delegated agencies, participate in national data 

management discussions)

 Facilitate access to the database

 Audit and review of data submissions

 Data entry and verification

 Report preparation

 Program review (including review of user needs and suggestions of software revisions, or 

identification for delegated agencies of best/efficient data management and quality

assurance practices)

 Data interpretation and analysis (including targeting activities)

 Quality assurance guidance

(b) COLLECTION METHODOLOGY AND MANAGEMENT

(i) Overview

 

2 For purposes of estimating burdens, the first five items are considered the primary Regional Office 

activities and the last three items are considered the primary Headquarters activities.
34

Management of the compliance and enforcement information collected from delegated

agency respondents for entry into a national data system is a well-established process. Reporting

source information, violation determinations, and compliance and enforcement activity data to 

ICIS-Air and its predecessors, AFS and the Compliance Data System (CDS), has existed for the 

past 33 years. The MDRs have been developed as essential components of a compliance and 

enforcement tracking program and have been adopted into delegated agency data systems. Many

delegated agencies will electronically update ICIS-Air from their database, while the remaining 

agencies will enter data into ICIS-Air directly. In some instances, EPA Regional Offices will 

enter compliance and enforcement data. 

The EPA data collection guidance and technical support for respondents focuses on 

supporting agencies in their collection methodology to minimize the total burden associated with 

meeting their reporting requirements. The Agency also has developed documents and 

memoranda to explain the collection and reporting of MDRs, such as user manuals and a 

business rule compendium. New reporting, training, and user guidance documents have been 

developed for ICIS-Air. In addition to continuing to improve these documents, EPA will 

continue to provide services in support of optimizing the collection and reporting of MDRs,

including the following:

 An ICIS-Air telephone help line providing users with data collection transmittal and 

quality assurance.

 User training, both to ensure a smooth transition to ICIS-Air and to support the training 

of future ICIS-Air users on an ongoing basis.

 Support for development and use of plug-in technologies that greatly simplify the 

electronic transfer of data from delegated agency databases to ICIS-Air. 

 Periodic webinars to disseminate news and information to all registered users.

The EPA presents these tools in plain English to provide novice and experienced 

personnel with suggestions as to how their reporting burden can be minimized. More specific 

guidance is provided as each EPA Regional Office enters into specific agreements with 

delegated agencies on CAA stationary source compliance and enforcement information

reporting.

(ii) Data Quality Checking Procedures

ICIS-Air data that are directly entered via the web interface are edited and validated by 

the system upon submission for range, context, and appropriate database record identification 

and cross referencing. Analogous data quality checks are made within the EPA Central Data 

Exchange (CDX) when delegated agencies transfer data electronically to ICIS-Air. On a weekly

basis, the EPA downloads data from ICIS-Air and loads it into multiple applications providing 

data to the public: the ECHO system and ENVIROFACTS. These systems maintain procedures 
35

for error resolution and correction; thereby, improving the quality of data in ICIS-Air. 

Many delegated agencies have written Standard Operating Procedures or have expanded 

Quality Assurance Project Plans that define their reporting process. These procedures contain a 

data correction mechanism, define data ownership, and outline each step taken to report timely, 

accurate, and useable data to the EPA. Additionally, the OECA Office of Compliance has a 

Quality Management Plan requiring that data quality requirements be built into each information 

system managed by the Office. 

The EPA reviews a comprehensive set of data retrievals on a cyclic basis to review 

delegated agency progress within the CMS, review implementation of CAA FRV and HPV 

policies, examine milestone completion with HPV pathways, and enable overall review of data 

elements for accuracy.

The OECA State Review Framework (SRF) utilizes MDR data to document activity for 

air compliance and enforcement oversight on a periodic basis. Delegated agencies have an 

opportunity during an annual data verification process to validate the data, make corrections as 

appropriate, or develop processes to address identified program concerns. 

(iii) Machine and Processing Technology

ICIS-Air resides on EPA’s Enterprise Servers at the National Computer Center (NCC) in 

North Carolina and is accessible to all delegated agency users via the internet. 

(iv) Data Entry and Storage

Once compliance data are submitted to EPA, either directly online or via an electronic 

data transfer process by delegated agency data stewards, the data are managed and maintained by 

EPA. If either EPA staff or a delegated agency data steward identifies any concerns with the data 

or the system, EPA staff and the data steward discuss and resolve the concern. EPA policy

specifies the security and retention requirements for its databases, in addition to the specific 

program requirements and archiving protocols associated with each compliance data collection 

program. Users of ICIS-Air should maintain reportable MDR data in the system for at least five 

(5) years with the exception of data pertaining to HPVs. Sources with HPVs are to be kept in 

ICIS-Air regardless of operating status. 

(v) Public Access

The public may access CAA stationary source compliance and enforcement information

through:

 Review of ICIS-Air data available through EPA-supported Web sites such as 

ECHO (echo.epa.gov) and ENVIROFACTS (http://www.epa.gov/enviro/)

 Freedom of Information Act requests made to EPA
36

(c) SMALL ENTITY FLEXIBILITY

The respondents for this information collection activity are state, local, tribal, and

territorial delegated agencies. The Regulatory Flexibility Act (RFA), incorporated in the 1995 

Paperwork Reduction Act, defines a “small governmental jurisdiction as governments of cities, 

counties, towns, townships, villages, school districts, or special districts with a population of less 

than 50,000.” The delegated agencies covered by this renewal ICR are above that threshold, and 

therefore no small entities will be affected by this information collection. The respondents 

defined as local agencies are recipients of Clean Air Act Section 105 grants, or have assumed 

reporting responsibility from their respective state agency.

(d) COLLECTION SCHEDULE

Since the 2012 ICR, data from delegated agencies is collected on a 60-day schedule

(except for stack test dates and results), associated with the Federal fiscal calendar. EPA 

Regional and HQ data is to be reported to ICIS-Air on a monthly basis. Data is extracted weekly

and provided to EPA systems for use in analysis and to provide data to the public. On a routine 

basis Regional and Headquarters EPA program staff develop trend and status reports utilizing 

ICIS-Air data and assess the completeness of the data submitted. 

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

Please note that the EPA is providing a limited burden assessment in this ICR renewal. 

The EPA will develop a more robust burden assessment for the next ICR renewal. The 

assessment in this ICR is limited because delegated agencies have just begun using ICIS-Air and, 

at the time of this ICR renewal, not all agencies that will be reporting electronically are currently

doing so. In addition, the EPA completed key revisions to the HPV and FRV policies that EPA 

expects will result in burden reductions. 

For this ICR renewal, the burden estimate is based on the expected relative change in 

burden associated with reporting to ICIS-Air versus to AFS. EPA completed a time study to 

compare the amount of time required to enter data into AFS and ICIS-Air. EPA also interviewed 

agencies that have submitted data electronically to ICIS to compare the batch upload process 

they used for AFS to the EDT process they use for ICIS-Air. EPA interviewed agencies to 

measure the one-time burden imposed by the transition from AFS to ICIS-Air. 

(a) ESTIMATING RESPONDENT BURDEN

Comparing AFS and ICIS-Air Direct Data Entry Burden

To estimate the relative change in burden associated with directly entering required data 

to ICIS-Air versus to AFS, EPA conducted a time study comparing 47 different AFS direct data 

entry scenarios to the equivalent ICIS-Air direct entry scenarios (Appendix 2). The study, 
37

conducted in October 2014, included 28 different business processes within the databases. 

The time study was conducted by a contractor who has supported AFS for several 

decades and therefore knows the most efficient means to enter data into AFS. The contractor 

staff gained familiarity with ICIS-Air as they were involved in the ICIS-Air development effort 

as a sub-contractor and participated in training on ICIS-Air. Overall, given their deep AFS 

expertise and their modest degree of expertise in using ICIS-Air, the study likely has a bias 

toward underestimating the relative burden experienced by AFS users. 

The results provide a strong indication that ICIS-Air direct entry users will experience a 

discernable reduction in overall burden. In summary, the study found that:

 12 of the 47 AFS direct data entry scenarios (including establishing connectivity through 

Host on Demand, changing compliance status, archiving/de-archiving facilities, looking 

up table values, updating plant ids) no longer needed to be performed at all within ICISAir. 

 22 ICIS-Air direct data entry scenarios took less time than the equivalent AFS process.

 6 direct data entry processes took the same amount of time in AFS and ICIS-Air.

 7 AFS direct data entry scenarios took less time than the equivalent process in ICIS-Air. 

 

EPA is currently preparing several enhancements to ICIS-Air application software that 

will improve the efficiency of Case File/HPV data entry. These enhancements to ICIS-Air will 

address several of the 7 direct data entry processes in which AFS entry was more efficient during 

the time study. The time study demonstrates that replacing AFS with ICIS-Air will result in 

reduced burden to delegated agencies entering data directly to ICIS-Air. Therefore, we expect 

the actual burden estimate for ICIS-Air to be less than previous burden estimates calculated for 

AFS. 

Comparing AFS and ICIS-Air Electronic Data Transfer (EDT) Burden

Calculating burden associated with ICIS-Air electronic data transfer is very difficult at 

this time, since less than ten agencies have successfully transferred data to ICIS-Air since it was 

put into production on October 27, 2014. EPA recognizes that a comprehensive assessment of 

EDT burden cannot be performed at this time, as over thirty agencies have not yet successfully 

transferred data. EPA expects that approximately forty agencies will be able to successfully 

transfer to ICIS-Air by mid-2015. 

EPA requested initial feedback from the small number of agencies that have successfully

transferred data to ICIS-Air via EDT. These agencies were asked to estimate their burden for 

transferring data to ICIS-Air, given their initial experiences doing so, and compare it with their 

estimated previous year burden for submitting required data to AFS. EPA received responses 
38

from six agencies. The results, as referenced below, were inconclusive:

 One agency stated that they believed the burden would be about the same annually. 

(Approximately 312 hours per year)

 Two agencies both estimated that reporting to ICIS-Air would take twice as long as 

reporting to AFS (50 hours/year for ICIS-Air to 25 for AFS; and, 48 ICIS-Air to 24 

AFS)

 Two agencies estimated that their reporting burden would drop by up to 2/3 (30-36 

hours for AFS to 10-15 hours for ICIS-Air) and precipitously to near zero (12-36 hours 

for AFS to minutes for ICIS-Air) since the process was fully automated from that 

agency system to ICIS-Air.

 And, one agency estimated that their reporting burden will go up (from 48 hours to AFS 

to 60 hours for ICIS-Air)

EPA recognizes the importance of limiting reporting burden for delegated agencies. ICISAir was designed with that goal in mind. Our experience with the CWA/NPDES program, which 

made a similar transition from an aging mainframe database to ICIS-NPDES several years ago, 

indicates that the burden associated with reporting via EDT was reduced dramatically for many 

state agencies. EPA will continue to work with delegated agencies that will report to ICIS-Air 

via EDT to help them streamline and automate their reporting processes and achieve the dramatic 

reductions in burden experienced by two of the aforementioned agencies. 

Estimating One Time Burden Associate with the Transition from AFS and ICIS-Air

EPA is appreciative of the sustained and extensive time commitments made by delegated

agencies to transition from AFS to ICIS-Air. To understand the extent of the one-time transition 

burden associated with this system modernization effort, EPA solicited and received responses 

from eight delegated agencies regarding their estimated burden to participate in ICIS-Air 

workgroup activities, perform ICIS-Air testing, prepare their AFS data to successfully migrate to 

ICIS-Air, and prepare to flow data from their data base to ICIS-Air (if applicable). 

Based upon the estimates EPA received from the eight state/local agencies, the average 

one-time burden for transition from AFS to ICIS-Air was 124 hours for direct entry agencies 

(based on 3 responses) and 1103 hours for agencies reporting to ICIS-Air via EDT (based on 5 

responses). There are approximately 64 agencies that report to ICIS-Air directly and 35 agencies 

that plan to report via EDT. Using those figures as multipliers, EPA estimates that approximately

46,500 hours of one-time burden was experienced by employees of the 99 agencies that 

transitioned their reporting of CAA stationary source compliance and enforcement data from 

AFS to ICIS-Air. 

 The basis of the reportable universe is 13,742 major sources, 25,466 synthetic minor sources 

(sources with the potential to emit at the major threshold, but emit under this threshold due to 

process or operating restrictions), and 3,176 minor or other sources.
39

 The average respondent hours for reporting activities will depend on the number of sources 

for which a delegated agency must collect and report source information, and compliance and 

enforcement data. 

(b) ESTIMATING RESPONDENT COSTS

Because this burden estimate is limited in that it reflects very little user experience with 

the production ICIS-Air system, the EPA is providing the quantified estimates used for previous 

ICR renewals. The Agency did adjust the hours spent based on the redistribution of the size of 

agencies. 

(i) Estimating Labor Costs

The last column in Worksheet 1 reports the total costs of respondent burden 

activities. The costs reflect the use of appropriately skilled labor at $47.89 per hour. 

This hourly rate is in 2010 dollars reflecting average delegated agency government wages 

and salaries taken from the Bureau of Labor Statistics, US Department of Labor web site 

at http://stats.bls.gov/NEWS.RELEASE/ECEC.T04.HTM. This average wage 

incorporates 95% of Management, Professional, and Related rates and 5% Office and 

Administrative Support rates from the Occupational Group of Delegated agency

Government Employer costs per hour, to reflect the mix of skills required for data 

oversight. The 2008 ICR used a rate of $45.90 per hour. The burden cost by activity is 

computed as the product of burden hours and cost per hour. Added to cost are appropriate 

travel costs to meetings and workshops. The total annual burden cost for delegated 

agencies is estimated to be approximately $2.8 million. The burden per response is 

approximately 92 hours. 

(ii) Estimating Capital and Operations and Maintenance Costs

There are no capital and maintenance costs associated with this reporting activity. 

Delegated agencies maintain computers for their own tracking needs and this reporting 

activity only involves reformatting and transmission of that data.

(c) ESTIMATING AGENCY BURDEN AND COST

Section 5(a) identifies several Agency activities for this information collection. 

Worksheet 2 presents the Federal EPA burden and cost estimates for each of these activity

categories. Hours are allocated for data base management on the basis of 1.5 full-time equivalent 

positions dedicated to ICIS-Air activities in each Regional Office and 2 full time equivalents at 

the Headquarters level. The estimates are based on information from Regional Offices and on 

prior experience with the program. Estimates are formulated on a monthly basis versus bimonthly basis (every 60 days) required of delegated agencies. Cost estimates for Regional 

activities are based on the salary of a GS-12 (step 5) staffer in 2010. An overhead factor of 1.6 is 

applied, and an average locality adjustment pay is available via the Salary Table on the Office of 
40

Personnel Management’s web site to determine a full loaded hour rate for Regional activities or 

$2,036,369 annually across the nation (http://www.opm.gov/oca/10tables/indexGS.asp). The cost

also includes travel expenses for Regional employees to attend data meetings and workshops. 

The bottom half of Worksheet 2 shows the burden and costs for EPA Headquarters staff. 

Direct labor costs are based on a GS-14 (Step 5) System Administrator, and a GS-13 (Step 5) 

Security Manager. The fully loaded staffing cost, with Washington DC locality pay, using the 1.6 

benefit factor, is $355,037. The cost also includes travel expenses for Regional employees to 

attend data meetings and workshops. 
41

WORKSHEET 1

ANNUAL DELEGATED AGENCY RESPONDENT BURDEN 

ESTIMATES (2010; EPA-HQ-OECA-2010-0777; EPA ICR No. 0107.10, OMB 

Control No. 2096-0096.) Updated in 2014 to reflect a slight shift from the previous 

ICR in the distribution of agencies based on size.

Respondent Activities: Process, compile and review Number of Annual 

Annual 

Hours per Total Total

information; transmit information to AFS. Maintain Enforcement Responses Respondent Hours Cost

records for AFS reporting compatibility. Agencies

(6x per 

year)

Small Delegated agencies 54 324 1,685.00 10,110.00 $527,339.55

(less than or equal to 59 major sources)

Medium Delegated agencies 33 198 2,312.75. 13,876.52 $689,240.78

(60-349 major sources)

Large Delegated agencies 12 72 4,571.00 27,425.98 $1,472,320.36

(greater than or equal to 350 major sources)

Totals 99 594 8,568.75 51,412.50 $2,688,900.69

Total Cost is taken from Department of Labor statistics found at: http://stats.bls.gov/NEWS.RELEASE/ECEC.T04.HTM

Costs include median dollar amounts for travel costs to data management meetings and workshops.
42

WORKSHEET 2

FEDERAL ANNUAL AGENCY BURDEN 

ESTIMATES (2010; EPA-HQ-OECA-2010-0777; EPA ICR 

No. 0107.10, OMB Control No. 2096-0096.)

EPA REGION

# OF 

RESPONSES

HOURS PER 

RESPONSE

TOTAL 

HOURS

HOURLY 

COST

FULLY 

LOADED 

COST TOTAL COST

REGION 1 12 260.00 3,120.00 $40.85 $65.36 $205,923.20 Boston, MA

REGION 2 12 260.00 3,120.00 $42.13 $67.41 $212,312.96 New York, NY

REGION 3 12 260.00 3,120.00 $39.86 $63.78 $200,981.12 Philadelphia, PA

REGION 4 12 260.00 3,120.00 $39.05 $62.48 $196,937.60 Atlanta, GA

REGION 5 12 260.00 3,120.00 $40.95 $65.52 $206,422.40 Chicago, IL

REGION 6 12 260.00 3,120.00 $39.50 $63.20 $199,184.00 Dallas, TX

REGION 7 12 260.00 3,120.00 $37.37 $59.79 $188,551.04 Kansas City, MO

REGION 8 12 260.00 3,120.00 $40.10 $64.16 $202,179.20 Denver, CO

REGION 9 12 260.00 3,120.00 $44.24 $70.78 $222,846.08 San Francisco, CA

REGION 10 12 260.00 3,120.00 $39.87 $63.79 $201,031.04 Seattle, WA

Totals 120 2,600.00 31,200.00 $2,036,368.64

EPA HEADQUARTERS

# OF 

RESPONSES

HOURS PER 

RESPONSE

TOTAL 

HOURS

HOURLY 

COST

FULLY 

LOADED 

COST TOTAL COST

SYSTEM 

ADMINISTRATOR 12 173.33 2,080.00 $57.13 $91.41 $192,128.64 GS-14/5

SECURITY MANAGER 12 173.33 2,080.00 $48.35 $77.36 $162,908.80 GS-13/5

Totals 24 346.67 4,160.00 $355,037.44

Total Federal Burden 144 2,946.67 35,360.00 $2,391,406.08

Federal Wage Scales found at: http://www.opm.gov/oca/10tables/indexGS.asp

Fully loaded wage is hourly wage multiplied by 1.6. Total cost includes travel costs for meetings and workshops.
43

(d) ESTIMATING RESPONDENT UNIVERSE AND TOTAL BURDEN 

See Worksheet 1 (above).

(e) BOTTOM LINE BURDEN HOURS AND COSTS

Worksheet 3 summarizes the total annual burden hours and costs for AFS collection

activity. The data for Worksheet 3 represents totals computed across activities identified in 

Worksheets 1 and 2.

WORKSHEET 3

TOTAL BURDEN HOURS AND COSTS (2010; EPA-HQ-OECA-2010-0777; EPA 

ICR No. 0107.10, OMB Control No. 2096-0096.)

Respondent Type Total Hours Total Costs

1. Delegated agencies 51,412 $ 2,688,900

2. EPA Regions 31,200 $ 2,036,369

3. EPA Headquarters 4,160 $ 355,037

Totals 86,772 $ 5,080,306

(f) REASONS FOR CHANGE IN BURDEN

Under the previous renewal ICR (2010; EPA ICR No. 0107.10, OMB Control No. 2060-

0096.), total annual delegated agency respondent burden was 54,384 hours. In this renewal, the 

total estimated annual decrease in respondent burden is 2,972 hours. The decrease occurred as a 

result of slight shifts in the distribution of agencies by size (see Worksheet 1), due to a continued 

reduction in the universe of major air sources. 

(g) BURDEN STATEMENT

The average burden per response for this collection of information is estimated to be 92

hours, though this estimate varies according to the type of respondent. Reporting by delegated

agencies on source compliance and enforcement actions is estimated based on the number of 

major sources. It is estimated that agencies will collectively spend a total of 51,412 hours per 

year for the transmittal, management and quality assurance of their data. The EPA will require a 

total of 35,360 hours per year for EPA oversight, data quality assurance, reporting, and other 

Agency activities, for an overall total of 86,772 hours for both Federal and delegated agency

effort. These estimates are completely extrapolated based on data submitted under the previous 

ICR renewal. 
44

Burden means the total time, effort, or financial resources expended by persons to 

generate, maintain, retain, or disclose or provide information to or for a Federal agency. This 

includes the time needed to review instructions; develop, acquire, install, and utilize technology

and systems for the purposes of collecting, validating, and verifying information; adjust the 

existing ways to comply with any previously applicable instructions and requirements; train 

personnel to be able to respond to a collection of information; search data sources; complete and 

review the collection of information; and transmit or otherwise disclose the information. An 

agency may not conduct or sponsor, and a person is not required to respond to, a collection of 

information unless it displays a currently valid OMB control number. The OMB control 

numbers for EPA regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency’s need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, the EPA has established a public docket for this ICR 

under Docket ID No. EPA-HQ-OECA-2014-0523, which is available for online viewing at 

www.regulations.gov, or in person viewing at the OECA Docket in the EPA Docket Center 

(EPA/DC), William Jefferson Clinton West, Room 3334, 1301 Constitution Ave., NW, 

Washington, DC. The EPA/DC 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 OECA Docket is (202)566-1752. An electronic 

version of the public docket is available at www.regulations.gov. This site can be used to submit 

or view public comments, access the index listing of the contents of the public docket, and to 

access those documents in the public docket that are available electronically. When in the 

system, select “search,” then key in the Docket ID Number identified above. Also, you can send 

comments to the Office of Information and Regulatory Affairs, Office of Management and 

Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please 

include the EPA Docket ID Number EPA-HQ-OECA-2014-0523 and OMB Control Number 

2060-0096 in any correspondence.
45

APPENDIX 1

DELEGATED AGENCY CLASSIFICATION BY SIZE

99 AGENCIES

AGENCY MAJORS Synthetic Minor Minors AGENCY MAJORS Synthetic Minors Minors

SMALL AGENCIES < 59 MAJORS

AMERICAN SAMOA 0 0 0 CA-MONTEREY BAY 19 1 0

NV-WASHOE 2 4 0 OR-LANE 18 16 0

WA-BENTON 2 4 0 AL-HUNTSVILLE 6 12 1

MARIANNAS 

PROTECTORATE 4 2 0 WA-NORTHWEST 22 10 0

WA-YAKIMA 4 1 0 VI 10 3 0

CA-FEATHER RIVER 5 0 3 VT 14 84 1

CA-KERN 6 1 0 CA-SAN DIEGO 27 8 0

CA-SAN LUIS OBISPO 6 11 0 CA-VENTURA 24 7 0

IA-POLK 18 420 5 NV-CLARK 27 6 0

NM-ALBUQUERQUE 9 15 2 NC-ASHEVILLE 31 73 0

WA-SPOKANE 9 19 0 NV 29 35 0

NC-FORSYTH 10 22 5 WA-PUGET SOUND 32 75 33

CA-IMPERIAL 11 7 0 DC 40 0 16

IA-LINN 17 124 3 PA-ALLEGHENY 30 37 24

NC-MECKLENBURG 9 76 5 TN-MEMPHIS 30 105 1

AZ-PINAL 16 3 0 KY-JEFFERSON 35 100 0

CA-YOLO SOLANO 14 0 0 AL-JEFFERSON 35 101 2

AZ-PIMA 15 4 0 AZ-MARICOPA 33 46 17

CA-SACRAMENTO 15 6 0 PA-PHILADELPHIA 32 75 19

TN – KNOX 8 40 5 TN – NASHVILLE 11 94 1
46

WA – OLYMPIC 12 9 1 WA – SOUTHWEST 14 20 1

NE – LINCOLN 16 30 1 GU 18 3 1

WA 28 19 1 NH 35 119 72

RI 37 87 6 PR 40 14 10

CA – MOJAVE DESERT 51 1 0 ID 45 200 22

ME 57 168 6 AZ 58 72 12

CA – CARB 48 21 2 NE – OMAHA 15 35 1

MEDIUM = 60 – 349 MAJORS

MT 66 170 14 ND 76 102 8

CA – SANTA BARBARA 75 53 0 CT 72 194 25

SD 89 66 1 CA – BAY AREA 84 30 2

NE 98 96 18 UT 99 212 53

MD 120 211 15 HI 133 6 2

OR 110 21 0 MA 140 924 150

AK 144 213 10 DE 60 80 3

WY 125 30 90 NM 145 407 73

WV 163 62 30 AR 196 623 65

CA – SAN JOAQUIN 303 180 1 VA 254 1588 9

IA 249 1473 5 CO 236 1266 290

MS 276 278 17 KY 278 356 3

KS 307 759 55 MN 287 230 58

OK 291 2141 6 TN 230 405 108

MO 268 232 57 NJ 279 1024 56

SC 271 402 11 NC 332 763 16

AL 315 253 12

LARGE = > 350 MAJORS SOURCES
47

FL 372 562 13 GA 376 1270 23

NY 423 2954 104 MI 390 853 7

CA – SOUTH COAST 441 0 32 WI 419 248 8

IL 480 225 251 LA 517 82 568

PA 523 721 217 IN 600 550 23

OH 605 847 57 TX 1310 0 207
48

APPENDIX 2: Business Processes for Reporting Stationary Source information into Data System of Record

NOTE: The ICIS-air processes listed in this document, have been described in just one way. Users may navigate through ICIS-air and enter or change records via alternative routes

Process # Process Relative Degree of 

Use Explanation Steps needed to Achieve Process in AFS

Amount of time 

taken to 

perform process 

in AFS

Steps needed to Achieve 

Process in ICIS-Air

Amount of 

time taken to 

perform 

process in 

ICIS-air

1

Download and install 

Host on Demand (HOD) Infrequent

This software 

necessary to 

communicate with the 

mainframe

Go to https://trex.rtpnc.epa.gov and follow 

download and installation. 

2-10 minutes 

depending on 

connection 

speed

Not needed for ICIS-air N/A

2

Download and install 

Host on Demand (HOD) Infrequent Periodic upgrades to HOD

Go to https://trex.rtpnc.epa.gov and follow 

instructions to remove previous version and then 

install new version. 

2-10 minutes 

depending on 

connection 

speed

Not needed for ICIS-air N/A

Execute Host On 

Demand (HOD) Frequent

Necessary to 

communicate with the 

AFS

Execute Host on Demand

15 seconds - 2 

minutes 

depending on 

connection 

speed

Not needed for ICIS-air N/A

3 Logon to application Frequent use Used each time a user 

logs onto AFS

Access the mainframe using HOD. Enter AIRS on 

the Command line and the User ID and password 

on mainframe screen

15 seconds - 2 

minutes 

depending on 

connection 

speed

Go to 

//https://icisairtest.epa.gov/icis 

and logon using WAM User ID 

and password

1 minute
49

4 Add a facility Moderate use

Used when a federally 

reportable facility is 

added

If not already logged into AFS, execute HOD and 

logon to mainframe. Go to AIRS main menu and 

select Update AFS Online. Supply the State, 

County & Plant ID. Enter information for Plant 

General fields (Plant Name, Street Address, City 

Name, Zip Code, NAICS & Governmental Facility 

Code); Air Program fields (Air program code and Air 

Program Status) & Air Program Pollutant fields (Air 

Program, Pollutant Code, State Compliance Status, 

State Classification and State Attainment 

Indicator). Press ENTER to SAVE

8 minutes

If not already logged into ICISair, point browser to 

https://icisairtest.epa.gov/icis 

and logon using WAM User ID 

and password. Select AIR then 

ADD A FACILITY; provide

Programmatic ID, Facility Site 

Name, State, Zip Code, 

Address, City, County Name & 

Primary NAICS. Select SAVE 

AND ADD AIR PROGRAM; 

Provide Air Program, Operating 

Status and any applicable 

subparts. Select SAVE. Select 

ADD POLLUTANT. Provide 

Pollutant and Classification. 

Select SAVE. 

3 minutes

If already logged into AFS, go to AIRS main menu 

and select Update AFS Online. Supply the State, 

County & Plant ID. Enter information for Plant 

General fields (Plant Name, Street Address, City 

Name, Zip Code, NAICS & Governmental Facility 

Code); Air Program fields (Air program code and Air 

Program Status) & Air Program Pollutant fields (Air 

Program, Pollutant Code, State Compliance Status, 

State Classification and State Attainment 

Indicator). Press ENTER to SAVE

5 minutes

If already logged into ICIS-air, 

select AIR then ADD A FACILITY; 

provide Programmatic ID, 

Facility Site Name, State, Zip 

Code, Address, City, County 

Name & Primary NAICS. Select 

SAVE AND ADD AIR PROGRAM; 

Provide Air Program, Operating 

Status and any applicable 

subparts. Select SAVE. Select 

ADD POLLUTANT. Provide 

Pollutant and Classification. 

Select SAVE. 

2 minutes

5

Add Regulated Air 

Program Infrequent

Used whenever a 

Regulated AIR 

Program is added to 

an existing facility

If not already logged into AFS, execute HOD and 

logon to mainframe. Go to AIRS main menu and 

select Update AFS Online. Supply the State, 

County & Plant ID. Enter information for Air 

Program fields (Air program code and Air Program 

Status) & Air Program Pollutant fields (Air Program, 

Pollutant Code, State Compliance Status, State 

Classification and State Attainment Indicator). 

Press ENTER to SAVE

4minutes

If not already logged into ICISair, point browser to 

https://icisairtest.epa.gov/icis 

and logon using WAM User ID 

and password. Select AIR then 

Search for Facility. Select 

facility from Search list. Select 

ADD AIR PROGRAM; Provide 

Air Program, Operating Status 

and any applicable subparts. 

Select SAVE. 

2 minutes
50

If already logged into AFS, go to AIRS main menu 

and select Update AFS Online. Supply the State, 

County & Plant ID. Enter information for Air 

Program fields (Air program code and Air Program 

Status) & Air Program Pollutant fields (Air Program, 

Pollutant Code, State Compliance Status, State 

Classification and State Attainment Indicator). 

Press ENTER to SAVE

2 minutes

If already logged into ICIS-air, 

select AIR then Search for 

Facility. Select facility from 

Search list. Select ADD AIR 

PROGRAM; Provide Air 

Program, Operating Status and 

any applicable subparts. Select 

SAVE. 

1minute

6

Add a regulated 

Pollutant Infrequent

Used whenever a new 

pollutant is added to 

an air program on an 

existing facility

If not already logged into AFS, execute HOD and 

logon to mainframe. Go to AIRS main menu and 

select Update AFS Online. Supply the State, 

County & Plant ID. Enter information for Air 

Program Pollutant fields (Air Program, Pollutant, 

State Compliance Status, State Classification & 

State Attainment Indicator). Press ENTER to SAVE

4minutes

If not already logged into ICISair, point browser to 

https://icisairtest.epa.gov/icis 

and logon using WAM User ID 

and password. Select AIR then 

search for desired facility. 

Select facility from search list. 

Select ADD POLLUTANT. 

Provide Pollutant and 

Classification. Select SAVE. 

3 minutes

If already logged into AFS, goto AIRS Main Menu 

and select Update AFS Online. Update Plant Air 

Program Pollutant fields (Air Program, Pollutant, 

State Compliance Status, State Classification & 

State Attainment Indicator). Press ENTER to SAVE

2 minutes

If logged into ICIS-air, search 

for desired facility. Select AIR 

then search for desired facility. 

Select facility from search list. 

Select ADD POLLUTANT. 

Provide Pollutant and 

Classification. Select SAVE. 

1.5 minutes
51

7

Add a Compliance 

Monitoring action Frequent use

Used to add PCE's, 

FCE's, Stack Tests, 

TVACC & 

Investigations to an 

existing facility

If not already logged into AFS, execute HOD and 

logon to mainframe. Go to AIRS main menu and 

select Update AFS Online. Supply the State, 

County & Plant ID. Supply information for Plant 

Action (Action Number, Action Air Program(s), 

Action Type, Date Achieved, and possibly Results 

code, RDE8 and Pollutant Code). Press ENTER to 

SAVE.

5 minutes

If not already logged into ICISair, point browser to 

https://icisairtest.epa.gov/icis 

and logon using WAM User ID 

and password. Select 

Compliance MonitoringInspection/Evaluation for State. 

Supply information for 

Compliance Monitoring 

Identifier, Compliance 

Monitoring Type, Linked 

facilities, Actual End Date, Air 

Program(s). If the CM activity 

is a stack test, provide Stack 

Test Status. Scroll to bottom 

and select SAVE. 

3 minutes

If already in AFS, Update Plant Action (Action 

Number, Action Air Program(s), Action Type, Date 

Achieved, and possibly Results code, RDE8 and 

Pollutant Code). Press ENTER to SAVE.

3 minutes

If already logged into ICIS-air, 

select Compliance MonitoringInspection/Evaluation for State. 

Supply information for 

Compliance Monitoring 

Identifier, Compliance 

Monitoring Type, Linked 

facilities, Actual End Date and 

Air Program(s). If the CM 

activity is a Stack Test, provide 

Stack Test Status. Scroll to 

bottom and select SAVE. 

2 minutes
52

8 Add a Enforcement 

action Frequent use

Used to add Informal 

and formal 

enforcement actions 

to an existing facility

If not already logged into AFS, execute HOD and 

logon to mainframe. Go to AIRS main menu and 

select Update AFS Online. Supply the State, 

County & Plant ID. Supply information for Plant 

Action (Action Number, Action Air Program(s), 

Action Type, Date Achieved, possibly Results code,

RDE8 and Pollutant Code. Press ENTER to SAVE.

5 minutes

If not already logged into ICISair, point browser to 

https://icisairtest.epa.gov/icis 

and logon using WAM User ID 

and password. Select 

Enforcement Actions and 

choose Formal, Judicial or 

Informal for your agency. For 

a Formal Enforcement action, 

(1) check Administrative Order, 

link facility(s) and provide Air 

Program(s) Violated. Click 

SAVE; (2) Select ADD FINAL 

ORDER sublink. Supply Final 

Order Type & Issued date. Click 

SAVE; (3) Select PENALTY 

sublink, supply Assessed cash 

Penalty in the Penalty to be 

Paid to field. Click SAVE. (4) 

Select Milestones sublink. 

Provide Complaint 

Filed/Proposed Order Final 

Date. Click SAVE

4 minutes
53

If already logged into AFS, Update Plant Action 

(Action Number, Action Air Program(s), Action 

Type, Date Achieved, possibly Results code, RDE8 

and Pollutant Code. Press ENTER to SAVE.

3 minutes

If already logged into ICIS-air 

select Enforcement Actions and 

choose Formal, Judicial or 

Informal for your agency. For 

a Formal Enforcement action, 

(1) check Administrative Order, 

link facility(s) and provide Air 

Program(s) Violated. Click 

SAVE; (2) Select ADD FINAL 

ORDER sublink. Supply Final 

Order Type & Issued date. Click 

SAVE; (3) Select PENALTY 

sublink, supply Assessed cash 

Penalty in the Penalty to be 

Paid to field. Click SAVE. (4) 

Select Milestones sublink. 

Provide Complaint 

Filed/Proposed Order Final 

Date. Click SAVE

3 minutes
54

9 Add Comments to a 

Facility or Action Infrequent use

Used whenever a 

comment is added to 

either a facility or an 

action

If not already logged into AFS, execute HOD and 

logon to mainframe. Go to AIRS main menu and 

select Update AFS Online. Supply the State, 

County & Plant ID. Supply information for Plant 

Comment (Action Number (if for an action), 

Comment number and Comment text). Press 

ENTER to SAVE

5 minutes

If not already logged into ICISair, point browser to 

https://icisairtest.epa.gov/icis 

and logon using WAM User ID 

and password. Search for and 

select the CM activity or 

Enforcement active that is 

receiving the comment. If the 

Comment is non-sensitive, 

scroll down to the Comment 

field on the activity record. 

Enter Comment and click SAVE. 

If the Comment is sensitive, 

select the Sensitive Comment 

sublink of the activity receiving 

the comment. Enter Comment 

text and click SAVE.

2 minutes

If already logged into AFS, Update Plant Comment 

by providing an Action Number (if for an action), 

Comment Number and Comment Text). Press 

ENTER to SAVE.

2 minutes

If already logged into ICIS-air, 

search for and select the CM 

activity or Enforcement active 

that is receiving the comment. 

If the Comment is nonsensitive, scroll down to the 

Comment field on the activity 

record. Enter Comment and 

click SAVE. If the Comment is 

sensitive, select the Sensitive 

Comment sublink of the activity 

receiving the comment. Enter 

Comment text and click SAVE.

1 minute
55

10 Add a facility to CMS

Once a year or 

whenever CMS Plan 

is modified

Used whenever a 

facility is added to the 

biannual CMS Plan

If not already logged into AFS, execute HOD and 

logon to mainframe. Go to AIRS main menu and 

select Update AFS Online. Supply the State, 

County & Plant ID. Supply information for Plant 

CMS (CMS Category and CMS Frequency). Press 

ENTER to SAVE.

4 minutes

If not already logged into ICISair, point browser to 

https://icisairtest.epa.gov/icis 

and logon using WAM User ID 

and password. Select AIR then 

search for desired facility. 

Select facility from search list. 

Select CMS. Select ADD CMS. 

Enter CMS Source Category and 

CMS Minimum Frequency. 

Select SAVE. 

2 minutes

If already logged into AFS, Update Plant CMS (CMS 

Category and CMS Frequency). Press ENTER to 

SAVE.

1 minute

If logged into ICIS-air, search 

for desired facility. Select AIR 

then search for desired facility. 

Select facility from search list. 

Select CMS. Select ADD CMS. 

Enter CMS Source Category and 

CMS Minimum Frequency. 

Select SAVE. 

1 minute
56

11 Add HPV Frequently used Used whenever an 

HPV is added

If not already logged into AFS, execute HOD and 

logon to mainframe. Go to AIRS main menu and 

select Update AFS Online. Supply the State, CNTY, 

PCDS. Update Plant Action as a Key action by 

providing Action Number, Air Program(s), Action 

Type, Date Achieved, Pollutant Code and linking 

information that may include Discovering Agency, 

and Violation Type Code(s). Press ENTER to SAVE.

6 minutes

If not already logged into ICISair, point browser to 

https://icisairtest.epa.gov/icis 

and logon using WAM User ID 

and password. Select AIR then 

search for desired facility. 

Select facility from search list. 

Select Case Files. (1) Select 

ADD CASE FILE. Provide Case 

File Identifier, Link facility if 

needed, Air Program(s), 

Applicable Pollutants. Scroll to 

bottom and click SAVE AND 

ADD AIR VIOLATIONS. (2) Enter 

HPV/FRV details by clicking on 

the ADD AIR VIOLATION link on 

the Air HPV/FRV Details TAB. 

Select Violation Type, Pollutant 

& Program from drop down 

list. Enter FRV or HPV date. 

Select SAVE.

4 minutes
57

If already logged into AFS, Update Plant Action as a 

Key action by providing Action Number, Air 

Program(s), Action Type, Date Achieved, Pollutant 

Code and linking information that may include 

Discovering Agency and Violation Type Code(s). 

Press ENTER to SAVE.

3 minutes

If already logged into ICIS-air, 

select AIR then search for 

desired facility. Select facility 

from search list. Select Case 

Files. (1) Select ADD CASE FILE. 

Provide Case File Identifier, 

Link facility if needed, Air 

Program(s), Applicable 

Pollutants. Scroll to bottom and 

click SAVE AND ADD AIR 

VIOLATIONS. (2) Enter HPV/FRV 

details by clicking on the ADD 

AIR VIOLATION link on the Air 

HPV/FRV Details TAB. Select 

Violation Type, Pollutant & 

Program from drop down list. 

Enter FRV or HPV date. Select 

SAVE.

3 minutes

12 Add/Link Discovery 

action to Day Zero Frequently used

Used whenever a 

Discovery action is 

linked to it is Day Zero

If not already logged into AFS, execute HOD and 

logon to mainframe. Go to AIRS main menu and 

select Update AFS Online. Supply the State, 

County and Plant ID. Update Plant Action by 

providing the Key action Number, Action Type & 

Date Achieved of the Discovery Action on the 

action linking screen. Press ENTER to SAVE.

4 minutes

If not already logged into ICISair, point browser to 

https://icisairtest.epa.gov/icis 

and logon using WAM User ID 

and password. Select AIR then 

search for desired facility. If 

Discovery action has already 

been entered, Click Case Files. 

Select Case File Id from list. 

Click Compliance Monitoring 

activities. Click LIST TO LINK. 

Select desired CM activities to 

be linked to Case file. Click 

LINK. If Discovery action has 

not already been entered, first 

add CM activity and then link it 

to the Case File.

2 minutes if 

Discovery 

action already 

exists; 3.5 

minutes if 

Discovery 

action does 

not exist
58

If already logged into AFS, Update Plant Action by 

providing the Key action Number, Action Type & 

Date Achieved of the Discovery Action on the 

action linking screen. Press ENTER to SAVE.

1 minute

If already logged into ICIS-air, 

select AIR then search for 

desired facility. If Discovery 

action has already been 

entered, Click Case Files. Select 

Case File Id from list. Click 

Compliance Monitoring 

activities. Click LIST TO LINK. 

Select desired CM activities to 

be linked to Case file. Click 

LINK. If Discovery action has 

not already been entered, first 

add CM activity and then link it 

to the Case File.

1 minutes if 

Discovery 

action already 

exists; 1.5 

minutes if 

Discovery 

action does 

not exist

13 Add/Link NOV action to 

Day Zero Frequently used

Used whenever an 

NOV is Added/linked 

to it is Day Zero

If not already logged into AFS, execute HOD and 

logon to mainframe. Go to AIRS main menu and 

select Update AFS Online. Supply the State, 

County & Plant ID. Update Plant Action by 

providing the Key action Number, Action Type & 

Date Achieved of the NOV Action on the action 

linking screen. Press ENTER to SAVE.

4 minutes

If not already logged into ICISair, point browser to 

https://icisairtest.epa.gov/icis 

and logon using WAM User ID 

and password. Select AIR then 

search for desired facility. If 

NOV action has already been 

entered, Click Case Files. Select 

Case File Id from list. Click 

Enforcement activities. Click 

LIST TO LINK. Select desired 

Informal Enforcement activities 

to be linked to Case file. Click 

LINK. If NOV action has not 

already been entered, first add 

NOV activity and then link it to 

the Case File.

2 minutes if 

NOV action 

already exists; 

3.5 minutes if 

NOV action 

does not exist
59

If already logged into AFS, Update Plant Action by 

providing the Key action Number, Action Type & 

Date Achieved of the NOV Action on the action 

linking screen. Press ENTER to SAVE.

1 minute

If already logged into ICIS-air, 

select AIR then search for 

desired facility. If NOV action 

has already been entered, Click 

Case Files. Select Case File Id 

from list. Click Enforcement 

activities. Click LIST TO LINK. 

Select desired Informal 

Enforcement activities to be 

linked to Case file. Click LINK. If 

NOV action has not already 

been entered, first add NOV 

activity and then link it to the 

Case File.

1 minutes if 

NOV action 

already exists; 

1.5 minutes if 

NOV action 

does not exist

14 Add/Link Addressing 

action to Day Zero Frequently used

Used whenever an 

Addressing is 

Added/linked to it is 

Day Zero

If not already logged into AFS, execute HOD and 

logon to mainframe. Go to AIRS main menu and 

select Update AFS Online. Supply the State, 

County & Plant ID. Update Plant Action by 

providing the Key action Number, Action Type & 

Date Achieved of the Addressing action on the 

linking screen. Press ENTER to SAVE.

4 minutes

If not already logged into ICISair, point browser to 

https://icisairtest.epa.gov/icis 

and logon using WAM User ID 

and password. Select AIR then 

search for desired facility. If 

Addressing action has already 

been entered, Click Case Files. 

Select Case File Id from list. 

Click Enforcement activities. 

Click LIST TO LINK. Select 

desired Enforcement activities 

to be linked to Case file. Click 

LINK. If Addressing action has 

not already been entered, first 

add addressing activity and 

then link it to the Case File.

2 minutes if 

addressing 

action already 

exists; 3.5 

minutes if 

addressing 

action does 

not exist
60

If already logged into AFS, Update Plant Action by 

providing the Key action Number, Action Type & 

Date Achieved of the Addressing action on the 

action linking screen. Press ENTER to SAVE.

1 minute

If already logged into ICIS-air, 

select AIR then search for

desired facility. If Addressing 

action has already been 

entered, Click Case Files. Select 

Case File Id from list. Click 

Enforcement activities. Click 

LIST TO LINK. Select desired 

Enforcement activities to be 

linked to Case file. Click LINK. If 

Addressing action has not 

already been entered, first add 

addressing activity and then 

link it to the Case File.

1 minute if 

addressing 

action already 

exists; 3.5 

minutes if 

addressing 

action does 

not exist

15 Add/Link Resolution 

action to Day Zero Frequently used

Used whenever a 

Resolution action is 

Added/linked to it is 

Day Zero

If not already logged into AFS, execute HOD and 

logon to mainframe. Go to AIRS main menu and 

select Update AFS Online. Supply the State, 

County & Plant ID. Update Plant Action by 

providing the Key action Number, Action Type & 

Date Achieved of the Resolution action on the 

linking screen. Press ENTER to SAVE.

4 minutes

If not already logged into ICISair, point browser to 

https://icisairtest.epa.gov/icis 

and logon using WAM User ID 

and password. Select AIR then 

search for desired facility. Click 

Case File. Select desired Case 

file. Scroll down to Pathway 

Activities. Click on the 

Addressing Action to edit the 

record and navigate to the 

Final Order sublink. Click the 

desired Final Order and an Air 

Resolved date on the Dates 

tab. Scroll to bottom of page 

and click SAVE.

2.5 minutes
61

If already logged into AFS, Update Plant Action by 

providing the Key action Number, Action Type & 

Date Achieved of the Resolution action on the 

linking screen. Press ENTER to SAVE.

1 minute

If logged into ICIS-air, select AIR 

then search for desired facility. 

Click Case File. Select desired 

Case file. Scroll down to 

Pathway Activities. Click on the 

Addressing Action to edit the 

record and navigate to the 

Final Order sublink. Click the 

desired Final Order and an Air 

Resolved date on the Dates 

tab. Scroll to bottom of page 

and click SAVE.

1.5 minute

16 Add/Link Lead change 

action to Day Zero infrequently used

Used whenever a Lead 

changes takes place 

for an HPV

If not already logged into AFS, execute HOD and 

logon to mainframe. Go to AIRS main menu and 

select Update AFS Online. Supply the State, 

County & Plant ID. Update Plant Action by 

providing the Key action Number, Action Type & 

Date Achieved of the Lead Change action on the 

linking screen. Press ENTER to SAVE.

4 minutes

If not already logged into ICISair, point browser to 

https://icisairtest.epa.gov/icis 

and logon using WAM User ID 

and password. Select AIR then 

search for desired facility. Click

Case File. Select desired Case 

file. Scroll down to Pathway 

Activities. If Case has not been 

Addressed, point to the 

Addressing Action and to the 

pull down list for OTHER. 

Select LEAD CHANGE & supply 

a date. Scroll to bottom of 

page and click SAVE. If Case has 

already been Addressed, point 

to the Resolving Action and to 

the pull down list for OTHER. 

Select LEAD CHANGE & supply 

a date. Scroll to bottom of 

page and click SAVE.

2.5 minutes
62

If already logged into AFS, Update Plant Action by 

providing the Key action Number, Action Type & 

Date Achieved of the Lead Change action on the 

linking screen. Press ENTER to SAVE.

1 minute

If already logged into ICIS-air, 

select AIR then search for 

desired facility. Click Case File. 

Select desired Case file. Scroll 

down to Pathway Activities. If 

Case has not been Addressed, 

point to the Addressing Action 

and to the pull down list for 

OTHER. Select LEAD CHANGE & 

supply a date. Scroll to bottom 

of page and click SAVE. If Case 

has already been Addressed,

point to the Resolving Action 

and to the pull down list for 

OTHER. Select LEAD CHANGE & 

supply a date. Scroll to bottom 

of page and click SAVE.

1.5 minutes

17

Change Plant General Moderate use

Used when a Plant 

Name, Street address, 

City Name, Zip Code, 

NAICS or 

Governmental Facility 

Code changes are 

needed in AFS

If not already logged into AFS, execute HOD and 

logon to mainframe. Go to AIRS main menu and 

select Update AFS Online. Supply the State, 

County & Plant ID. Update Plant Identification and 

Update desired Plant General fields (Plant Name, 

Street Address, City Name, Zip Code, NAICS or 

Governmental Facility Code. Press ENTER to SAVE.

5 minutes

If not already logged into ICISair, point browser to 

https://icisairtest.epa.gov/icis 

and logon using WAM User ID 

and password. Select AIR then 

Search for Facility. Select 

facility from Search list. 

Update Plant Name, Street 

Address and Zip Code. Select 

SAVE. 

3 minutes

If already logged into AFS, Update desired Plant 

General fields (Plant Name, Street Address, City 

Name, Zip Code, NAICS or Governmental Facility 

Code. Press ENTER to SAVE.

2 minutes

If logged into ICIS-air, search 

for desired facility. Select AIR 

then search for desired facility. 

Select facility from search list. 

Update Plant Name, Street 

Address and Zip Code. Select 

SAVE. 

1.5 minutes
63

18 Change to Operating 

status

Moderate use

Used whenever the 

operating status of a 

regulated air program 

changes

If not already logged into AFS, execute HOD and 

logon to mainframe. Go to AIRS main menu and 

select Update AFS Online. Supply the State, 

County & Plant ID. Go to Plant Air Program and 

supply the desired air program. Update the 

Operating Status field. Press ENTER to SAVE.

4 minutes

If not already logged into ICISair, point browser to 

https://icisairtest.epa.gov/icis 

and logon using WAM User ID 

and password. Select AIR then 

Search for Facility. Select 

facility from Search list. Select 

Air Programs. Select the Air 

Programs Description link. 

Enter Operating Status in Edit

Current Operating Status. 

Select SAVE. 

3 minutes

If already in desired facility, go to Update Plant Air 

Program and supply the desired Air Program. 

Update the Operating Status field. Press ENTER to 

SAVE.

1 minute

If logged into ICIS-air, search 

for desired facility. Select AIR 

then search for desired facility. 

Select facility from search list. 

Select Air Programs. Select the 

Air Programs Description link. 

Enter new Operating Status in 

Edit Current Operating Status. 

Select SAVE. 

1 minute

19 Change Compliance 

Status Frequent

Used whenever the 

Compliance status of a 

pollutant or facility 

changes

If not already logged into AFS, execute HOD and 

logon to mainframe. Go to AIRS main menu and 

select Update AFS Online. Supply the State, 

County & Plant ID. Go to Update Plant Air Program 

Pollutant, supply Air Program and Air Program 

Pollutant and update State Pollutant Compliance 

Status. Press ENTER to SAVE.

4 minutes Not needed for ICIS-air N/A
64

If already in desired facility, go to Update Plant Air 

Program Pollutant, supply Air Program and Air 

Program Pollutant and update State Pollutant 

Compliance Status. Press ENTER to SAVE.

1 minute

20 Change a Compliance 

Monitoring action Moderate use

Used to modify the 

results of a stack test 

or add the received 

date to a TVACC; also 

used to correct data 

entry errors on an 

action

If not already logged into AFS, execute HOD and 

logon to mainframe. Go to AIRS main menu and 

select Update AFS Online. Supply the State, 

County & Plant ID. Go to Update Plant Action, 

supply Action Number, update Results Code and 

Date Achieved. Press ENTER to SAVE.

4 minutes

If not already logged into ICISair, point browser to 

https://icisairtest.epa.gov/icis 

and logon using WAM User ID 

and password. Select AIR then 

Search for Facility. Select 

facility from Search list. Select 

Compliance Monitoring. Filter 

to find Stack Tests. Select 

Compliance Monitoring 

ID/Activity Id from filtered list. 

Select new Stack Test Status. 

Select SAVE. 

3.5 minutes

If already in desired facility, go to Update Plant 

Action, supply Action Number, update Results 

Code and Date Achieved. Press ENTER to SAVE.

1 minute

If logged into ICIS-air, search 

for desired facility. Select AIR 

then search for desired facility. 

Select facility from search list. 

Select Compliance Monitoring. 

Filter to find Stack Tests. Select 

Compliance Monitoring 

ID/Activity Id from filtered list. 

Select new Stack Test Status. 

Select SAVE. 

1 minute
65

21 Modify CMS data for a 

facility Moderate use

Used to modify CMS 

Category (class 

changes)

If not already logged into AFS, execute HOD and 

logon to mainframe. Go to AIRS main menu and 

select Update AFS Online. Supply the State, 

County and Plant ID. Go to Compliance Monitoring 

Strategy and update CMS Category. Press ENTER 

to SAVE.

4 minutes

If not already logged into ICISair, point browser to 

https://icisairtest.epa.gov/icis 

and logon using WAM User ID 

and password. Select AIR then 

Search for Facility. Select 

facility from Search list. Select 

CMS. Select CMS Start Date 

link. Change CMS Category. 

Select SAVE. 

3 minutes

If already in desired facility, go to Compliance 

Monitoring Strategy and update CMS Category. 

Press ENTER to SAVE.

1 minute

If logged into ICIS-air, search 

for desired facility. Select AIR 

then search for desired facility. 

Select facility from search list 

Select CMS. Select CMS Start 

Date link. Change CMS 

Category. Select SAVE. 

1 minute

22 Archive/Dearchive a 

facility Infrequent use

Used when a facility 

has inactive for >5 

years

If not logged on, use HOD to LOGON to the 

mainframe, select Update AFS Online and Select 

Option 4 of the Main Menu than Utility Menu 

Option 6 (Archive) or Option 7 (De-archive). Supply 

State, County and Plant ID. Press ENTER to SAVE. If 

manual Utility User, select Option 11 (submit 

Current Utility File to process the file.

5 minutes Not needed for ICIS-air N/A
66

If already logged onto the mainframe, Select 

Option 4 of the Main Menu than Option 6 (Archive) 

or Option 7 (De-archive) on the Utility menu. 

Supply State, County and Plant ID. Press ENTER to 

SAVE. If manual Utility User, select Option 11 

(submit Current Utility File) to process the file.

2 minutes

23 Delete information Moderate use

Used to remove 

duplicates or data 

entry errors

If not logged on, use HOD to LOGON to the 

mainframe, select Update AFS Online and Select 

Option 4 of the Main Menu than Utility Menu

Option 2 (Delete Information), Plant Level. Supply 

the State, County & Plant ID. If not deleting the 

entire facility, also provide key information for 

desired record. Press ENTER to SAVE. If manual 

Utility User, select Option 11 (submit Current 

Utility File) to process the file.

5 minutes

If not already logged into ICISair, point browser to 

https://icisairtest.epa.gov/icis 

and logon using WAM User ID 

and password. Select AIR then 

Search for Facility. Select 

facility from Search list. Select 

Compliance Monitoring. Filter 

to find action. Select Delete for 

action to be deleted on filtered 

list. Select YES to delete. 

4 minutes
67

If already logged onto the mainframe, select 

Update AFS Online and Option 4 of the Main 

Menu; Select Utility Menu Option 2 (Delete 

Information), Plant Level. Supply the State, 

County & Plant ID. If not deleting the entire 

facility, also provide key information for desired 

record. Press ENTER to SAVE. If manual Utility 

User, select Option 11 (submit Current Utility File) 

to process the file.

2 minutes

If logged into ICIS-air, search 

for desired facility. Select AIR 

then search for desired facility. 

Select facility from search list 

Select Compliance Monitoring. 

Filter to find action. Select 

Delete for action to be deleted 

on filtered list. Select YES to 

delete. 

2 minutes

24 Source Swap Infrequent use

Used to change the 

geographic location or 

plant ID

If not logged on, use HOD to LOGON to the 

mainframe, select Update AFS Online and Option 4 

of the Main Menu than Utility Menu Option 5 

(Source Swap). Supply current State, County and 

Plant ID and new State, County and Plant ID. 

Press ENTER to SAVE. If manual Utility User, select 

Option 11 (submit Current Utility File) to process 

the file.

5 minutes

Not needed for ICIS-air N/A

If already logged onto the mainframe, Select 

Option 4 of the Main Menu than Option 5 (Source 

Swap) on the Utility menu. Supply current State, 

County and Plant ID and new State, County and 

Plant ID. Press ENTER to SAVE. If manual Utility 

User, select Option 11 (submit Current Utility File) 

to process the file.

2 minutes
68

25

User JCL Parameters Infrequent use

Used to provide or 

changes defaults user 

JCL parameters

If not logged on, use HOD to LOGON to the 

mainframe, select Update AFS Online and Select 

Option 4 of the Main Menu; Option Utility Menu 

Option 8 (User JCL Parameters). Enter new JCL 

parameters. Press ENTER to SAVE.

6 minutes

Not needed for ICIS-air

N/A

If already logged onto the mainframe, Select 

Option 4 of the Main Menu; Option Option 8 (User 

JCL Parameters) on the Utility menu. Enter new 

JCL parameters. Press ENTER to SAVE.

3 minutes

26 Table File Lookup Frequent use

Used to obtain valid 

table values either 

online or hard copy

If not logged on, use HOD to LOGON to the 

mainframe, select Update AFS Online and Select 

Option 4 of the Main Menu than Utility Menu 

Option 9 (Table File Lookup). Select desired table, 

List On-line or Batch. Supply desired filter fields. 

Press ENTER to view table values or run batch 

report.

5 minutes

Not needed for ICIS-air N/A

If already logged onto the mainframe, select 

Option 4 of the Main Menu than Utility Menu 

Option 9 (Table File Lookup). Select desired table, 

List On-line or Batch. Supply desired filter fields. 

Press ENTER to view table values or run batch 

report.

2 minutes
69

27 Update AFS Plant ID Infrequent use

Used to add/change 

an AFS ID for a facility 

(used for TV Permit 

information 

If not logged on, use HOD to LOGON to the 

mainframe, select Update AFS Online and Select 

Option 4 of the Main Menu than Utility Menu 

Option 10 (Update AFS Plant ID). Supply current 

and new AFS ids. Press ENTER to SAVE. If a 

manual Utility user, select Option 11 from the Utilit 

menu to process the request.

4 minutes

Not needed for ICIS-air N/A

If already logged onto the mainframe, Select 

Option 4 of the Main Menu than Option 10 

(Update AFS Plant ID). Supply current and new AFS 

ids. Press ENTER to SAVE. If a manual Utility user, 

select Option 11 from the Utility menu to process 

the request.

2 minutes

28 Submit Utility File Moderate use

Used whenever a 

Manual Utility User 

needs to submit a 

utility request

If not logged on, use HOD to LOGON to the 

mainframe, select Option 4 of the Main Menu than 

Utility Menu Option 11 (Submit Current Utility 

File). Supply Utility file name or accept default 

name, supply reject file name. Press ENTER to 

continue to JCL page to process.

5 minutes Not needed for ICIS-air N/A 
70

If already logged onto the mainframe, Select 

Option 4 of the Main Menu than Option 11 (Submit 

Current Utility File). Supply Utility file name or 

accept default name, supply reject file name. 

Press ENTER to continue to JCL page to process. 

2 minutes