INFORMATION COLLECTION REQUEST RENEWAL

FOR THE NOx BUDGET TRADING PROGRAM TO REDUCE THE REGIONAL 

TRANSPORT OF OZONE

SUPPORTING STATEMENT

EPA ICR No. 1857.06, OMB Control No. 2060-0445

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Background

This Information Collection Request (ICR) addresses the labor hour burden and costs of 

State reporting requirements contained in the U.S. Environmental Protection Agency's (EPA) 

rule to control regional transport of ozone season NOx emissions contributing to exceedances of 

the Ozone National Ambient Air Quality Standard (NAAQS) in the eastern United States, which 

was published on October 27, 1998 (63 FR 57350). This rule is known informally as the NOx

SIP Call. These provisions are incorporated in 40 CFR 51.121 and 51.122. The reporting 

requirements of this rule under §51.122 are imposed directly on the States, not on industry. 

However, in order to meet the requirements of this rule, States will of necessity have to impose 

requirements on industry for installation of continuous emission monitors and for recordkeeping 

and reporting. Therefore, there will be an indirect record keeping and reporting burden on 

industry as a result of this rule, and this ICR estimates those burden hours and costs incurred by 

industry. 

The focus of this ICR is the monitoring and reporting burden for States and sources that 

remain affected by the NOx SIP Call and that are not subject to subsequent rulemaking and 

addressed in other ICRs. The rule originally encouraged an emissions trading program for fossil 

fuel-fired NOx sources serving electrical generators (EGUs) with a nameplate capacity greater 

than 25 MW or boilers, combustion turbines, or combined cycle units with maximum design heat 

input greater than 250 mm BTU/hr. Under the NOx SIP Call, many States elected to meet much 

of the required emission reductions through the NOx Budget Trading Program (NBP), a federally

administered emissions trading program. Most of the units that originally participated in the 

NBP now participate in an expanded emissions trading program established in conjunction with 

the Clean Air Interstate Rule (CAIR), and the burdens and costs for those units are covered under 

EPA ICR #2152.04, OMB Control Number 2060-0570. The only units still subject to this ICR 

are certain industrial combustion sources and EGUs that participated in the NBP but are not 

participating in CAIR. 

As part of the NOx SIP Call, States are required to report certain data to EPA on an 

annual or triennial basis. However, both the Air Emission Reporting Rule (AERR) for the 

national emission inventory and CAIR include similar reporting requirements, and all State 

burdens associated with this type of reporting are now addressed in either the AERR or CAIR

ICRs. Thus, the only burdens and costs addressed in this ICR are for the former NBP units that 

are not participating in CAIR as discussed above in this section (affected units). 
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1(b) Information to be Collected

To meet the emissions monitoring recordkeeping and reporting requirements, the affected 

units are required to: (1) submit a monitoring plan and certification of monitors; (2) monitor and 

record hourly pollutant and flow monitor data; and (3) submit electronic quarterly reports of their 

emissions data to EPA. 

In addition, while many sources have already installed necessary emissions monitoring 

equipment due to requirements under other regulations, some sources will need to either install 

new monitors or upgrade existing monitors. Capital costs also usually include the cost of initial 

certification of new or upgraded monitors as part of start-up costs.

The respondent reporting burden for the collection of information under the NOx SIP Call

is estimated to be 57,586 hours each year for the years 2013 through 2015. The burden to EPA 

is estimated to be 848 hours in each year for the years 2013 through 2015. 

1(c) Terms of Clearance

Terms of Clearance for the previous ICR renewal: None.

2. NEED FOR AND USE OF THE COLLECTION

This section describes EPA's need for the information collections described above and 

the legal authority for conducting collections. The users of collected information are also 

described.

2(a) Need/Authority for the Collection

The State reporting requirements included in the NOx SIP Call are necessary for EPA to 

carry out properly its evaluation of each State's compliance with its ozone season NOx emissions 

budget. The legal authority for the reporting requirements resides in Sections 110(a) and 301(a) 

of the Clean Air Act. Specifically, the requirement in Section 110(a)(2)(D) that SIPs include 

"adequate provisions" to mitigate certain transport effects on other States implicitly authorizes 

emissions inventory reporting to EPA, as needed and appropriate to verify that a State is in fact 

meeting its NOx budget. Section 110(a)(2)(F) provides additional authority for requiring that SIP 

call submissions include provisions for emissions reporting by sources to a State, correlation of 

source information by the State, and steps by the State to make the correlated information 

available to the public. Section 110(a)(2)(K), in turn, requires a State to submit to EPA as 

requested data related to modeling the effect of NOx and other emissions on ambient air quality. 

The reported emissions inventory data will be used by EPA in air quality modeling to assess the 

effectiveness of the transport rulemaking's regional strategy. Finally, Section 301(a) grants EPA 

broad authority to prescribe such regulations as are necessary to carry out its functions under the 

Clean Air Act.

2(b) Practical Utility/Users of the Data 

The EPA believes it is essential that compliance with the regional control strategy be 

verified. Tracking emissions is the principal mechanism to ensure compliance with the budget 
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and to assure the downwind affected States and EPA that the ozone transport problem is being 

mitigated. 

If tracking and periodic reports indicate that a State is not implementing all of its NOx

control measures or is off track to meet its statewide budget, EPA will work with the State to 

determine the reasons for noncompliance and what course of remedial action is needed. The 

EPA will expect the State to submit a plan showing what steps it will take to correct the 

problems. Noncompliance with the NOx transport SIP may lead EPA to make a finding of 

failure to implement the SIP and potentially to implement sanctions, if the State does not take 

corrective action within a specified time period. 

The information collected by the industry sources subject to this ICR provides necessary

input data to the State emission inventory needed for tracking regional control strategy 

compliance.

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

This section describes: (1) efforts by EPA to learn whether the information requested is 

available from other sources; (2) consultations with respondents and data users to plan 

collections, monitor their usefulness, and minimize the collection burden; (3) effects of less 

frequent collections; and (4) justification for deviations from OMB's general guidelines.

3(a) Nonduplication

To minimize the reporting burden on State agencies, the reporting requirements for 40 

CFR 51.122 are based on existing annual and periodic emission inventory reporting requirements 

as much as possible. In large part, the emission inventory requirements under the NOx SIP Call 

are now met through the comparable requirements associated with CAIR, and the direct State 

burdens associated with inventory reporting for the regional control program are now included in 

the CAIR ICR. The only burdens remaining under this ICR reflect emissions reporting under the 

NOx SIP Call for sources not covered under CAIR that are part of the NOx SIP Call control 

strategy. 

Almost all information requested from respondents under this ICR renewal is not 

available from other sources. Where EPA needs information that has already been submitted, 

EPA is simply requiring the retransmission of stored electronic data.

3(b) Public Notice Required Prior to ICR Submission to OMB 

For the renewal ICR, a public notice was published in the Federal Register on September 

17, 2013 on availability of the draft supporting statement for the ICR renewal. A 60 day

comment period for public comments was provided in the notice. EPA received no comments in 

response to the public notice that was published in the Federal Register (see Docket ID No. EPAHQ-OAR-2006-0947).

3(c) Consultations
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As part of updating the previous ICR in 2010, EPA contacted via telephone three affected 

sources for comment on the respondent costs/burdens detailed in this ICR renewal. Specifically, 

EPA contacted Spring O’Mara with the Conoco Philips Trainer Refinery at 610-364-8058, 

Jennifer Marshall with the Tate and Lyle Facility at 217-421-2620, and Catherine Lanter with the 

Conoco Philips Wood River Refinery at 618-255-2505. Spring O’Mara and Jennifer Marshall 

responded and were provided a copy of the ICR supporting statement for review. Neither 

Jennifer Marshall nor Spring O’Mara had any comments regarding the costs/burdens detailed in 

this ICR renewal. No response was received from Catherine Lanter. 

Additionally, EPA held numerous consultations during initial development of the NBP, 

during development of CAIR, and during the ongoing development of a replacement rule for 

CAIR. The reduced burdens accounted for under this renewal ICR reflect that most of the 

reporting burden under the NOx SIP Call is now addressed under CAIR (or its replacement rule 

in the future).

For the initial rule development, on January 13, 1998, EPA held a one-day pre-proposal 

workshop with the States to discuss tracking issues. The objective of the workshop was to 

determine what type and frequency of inventory reporting is feasible for the different source 

sectors (power generating sources, other point sources, area sources, nonroad mobile, and 

highway mobile sources), to identify key reporting issues related to each sector, and to develop 

recommendations on reporting requirements to ensure compliance with the NOx budgets. The 

goal was to share information and ideas rather than to reach consensus. A summary of the 

meeting is contained in the docket (docket no. A-96-56, item V-B-18) for the NOx SIP Call

rulemaking. The reporting requirements included in 40 CFR 51.122 are based, in part, on the 

suggestions of participants in the workshop.

The recordkeeping and reporting requirements in §51.122 were included in the 

supplemental proposal (63 FR 25902, May 11, 1998) on which public comments were solicited. 

Comments received were reviewed and where appropriate were incorporated into the rule 

requirements as currently given in 40 CFR 51.122.

Finally, as part of updating the ICR for the Acid Rain Program (Part 75) monitoring 

requirements, EPA also contacted various affected parties to gather information on CEM capital 

costs, CEM operation and maintenance costs, fuel meter capital costs, and CEM/fuel meter 

testing costs. That information has been used in this ICR where appropriate.

3(d) Effects of Less Frequent Collection 

If this information collection were not carried out annually for sources being controlled to 

meet the NOx budgets, EPA would not be able to verify that NOx emission reductions necessary

to meet each State's NOx emission budget were being achieved. 

Quarterly collection of emissions data for the affected units allows the opportunity to 

check data for errors and provide rapid feedback on needed adjustments to data collection 

systems, and thereby promoted accurate and reliable emissions data. For this same reason, 

existing Federal and State emission monitoring programs often require quarterly reporting, or in 

some cases, monthly. Less frequent collection, such as semi-annually or annually, would 

increase the amount of preparation and review time at the end of the reporting period both for 
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regulated sources and for EPA. This would slow down the process for the verification of 

compliance.

As an option for this program, EPA will allow for ozone season reporting instead of 

quarterly reports for the entire calendar year. Under this option, units would only be required to 

submit two reports per year (covering the second and third calendar quarters). However, because 

the Agency believes that full-year quarterly reporting will be beneficial for both the source and 

the Agency, this ICR assumes most units will elect to comply with the standard quarterly 

reporting requirement.

3(e) General Guidelines 

This ICR does not violate any of OMB's guidelines for information collections. 

3(f) Confidentiality

As required by Section 114 of the Clean Air Act, estimates or measurements of emissions 

must be treated as nonconfidential. Under Agency procedures, data items relating to the 

computation of emissions may be identified as sensitive by a State and are then treated as "Statesensitive" by EPA. The potentially State-sensitive items include the following: process rate, 

boiler design capacity, emission estimation codes, percent space heat, operating rate, and 

maximum operation rate/hour. Where Federal and State requirements are inconsistent, EPA 

Regional Office should be consulted for final reconciliation.

3(g) Sensitive Questions

Not applicable. This information collection does not ask any questions concerning sexual 

behavior or attitudes, religious beliefs, or other matters usually considered private. 

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

This section lists the major categories of businesses that formerly participated in the NOx

Budget Trading Program and that continue to have reporting obligations under their states’ NOx 

SIP Call rules that are not duplicated under other rules, the data items requested from program 

participants, and the activities in which the participants must engage to assemble or submit the 

required data items.

4(a) Respondents/SIC Codes 

This ICR estimates the burden for affected industry sources to monitor NOx mass 

emissions so that states and EPA can track compliance with state emission budgets and NOx

control measures. Sources may report data directly to EPA if a source is required to meet the 

monitoring and reporting requirements of Subpart H of Part 75. Electric utility combustion 

sources are generally classified as either SIC 4911 - Electric Services, or 4931 - Electric and 

Other Services Combined [NAICS 221112 Electric Power Distribution]. Large industrial 

combustion sources (e.g., boilers, turbines, and internal combustion engines) are expected to fall 
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under SIC codes for the manufacturing sector, i.e., SIC Major Groups 29-40 [NAICS 31-33 

Manufacturing]. 

4(b) Information Requested 

This section describes the industry reporting requirements needed to enable state agencies 

to meet their reporting and recordkeeping requirements in §51.122. States must report NOx

emissions data as specified in 40 CFR §51.122. 

(i) Data Items, Including Recordkeeping Requirements

The affected units will continue to monitor NOx mass emissions, and record and report 

emissions data using the requirements of 40 CFR Part 75. The emissions monitoring 

requirements specify that affected sources must: (1) submit a monitoring plan for each affected 

unit at a source; (2) submit data for certification of each monitor; and (3) record hourly 

operational, pollutant monitor, and flow monitor data for each affected unit and submit quarterly 

reports of their emissions data to EPA. Appendices A and B to the CAIR ICR (EPA ICR # 

2152.04) contain a list of the data items required by the recordkeeping and reporting provisions 

of Part 75.

Respondents are required by 40 CFR 75.64 to submit the quarterly NOx mass emissions 

data electronically, by direct electronic submission to EPA, and must also include a certification 

statement by the designated representative of the unit. All monitoring records are to be kept for 

three years, with one possible exception under a voluntary option for fuel flowmeter calibration 

testing. 

(ii) Respondent Activities

 The affected units will (1) complete and submit appropriate monitoring plan forms for 

each affected source and each affected unit at a source; (2) conduct tests to certify the operation 

of monitors, and submitting test results to EPA; (3) record hourly emissions data (this activity 

generally is performed electronically); (4) conduct operation and maintenance activities 

associated with the monitoring, including quality assurance activities; (5) assure data quality, 

prepare quarterly reports of emissions data and submit these reports to EPA; and (6) respond to 

error messages generated by EPA. In addition, respondents will have to purchase the necessary

monitoring hardware and purchase the electronic data reporting software (or software upgrades). 

5. THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

The first part of this section describes Agency (EPA) activities related to the acquisition, 

analysis, storage, and distribution of the information collected from sources that are required to 

submit monitoring and test data. The second part describes the information management 

techniques employed to increase the efficiency of collections. The third part discusses the 

burden or benefits of the collection activities described in this ICR to small entities. The last part 

outlines the schedule for collecting information.
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5(a) Agency Activities 

The tasks that will be performed by EPA include processing, reviewing, and evaluating 

emissions data reports submitted by the affected units, and conducting appropriate audit 

activities to verify the information provided.

5(b) Collection Methodology and Management 

Several computer systems and associated databases have been developed to record

quarterly emissions monitoring data under Part 75. The systems and databases are designed to 

coordinate the information for easy access and use by the Agency, States, regulated community, 

and the public.

The EPA also has established a Clean Air Markets Home Page on the internet, which 

includes detailed information collected from emissions reports. The Data and Maps section of 

the EPA's Clean Air Markets Home Page on the internet includes detailed information collected 

from emissions reports, and facility or source data. Those without access to the Internet may use 

the Clean Air Markets Hotline to request information.

5(c) Small Entity Flexibility 

The rulemaking, which EPA published by notice in 63 FR 57356 (October 8, 1998), 

would simply require States to develop, adopt, and submit SIP revisions. Pursuant to 5 U.S.C. 

605(b), in the rulemaking, the Administrator certified that the rule will not have a significant 

economic impact on a substantial number of small entities.

In addition, under Part 75, there are options for reduced monitoring that may assist 

smaller sources. The low mass emitter exception (40 CFR 75.19), allows optional reduced 

monitoring, quality assurance, and reporting requirements for units that combust natural gas 

and/or fuel oil and that emit no more than 50 tons of NOx annually (or, at the source's election, 

25 tons per ozone season) and that calculate no more than the same amount based on specified 

procedures for calculating and reporting emissions. Qualifying sources are not required to keep 

monitoring equipment installed on (or conduct fuel sampling for) low mass emissions units, nor 

are they required to perform quality assurance or quality control tests. Moreover, emissions 

reporting requirements are significantly simplified for these units.

Even if a gas- or oil-fired unit does not qualify for the "low mass emissions unit"

exception, the monitoring provisions of Part 75 do allow for the use of alternative methods to 

determine emissions. As discussed in the Regulatory Impact Analysis (RIA) of the final Acid 

Rain Implementation Regulations (October 19, 1992), smaller utilities are more likely to be 

dependent on these oil- and gas-fired units, especially very small utilities (see p. 5–14 of that 

RIA document).

5(d) Collection Schedule 

Affected units conduct ongoing monitoring, with quarterly reporting. 
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6. ESTIMATING THE BURDEN AND COST OF COLLECTIONS

6(a) Determining Wage Rates

 In estimating labor costs for industry, EPA used the following amounts: $99.75 per 

hour for managers and $69.03 per hour for technicians. These rates were updated from the 

previous NBP ICR rates based on the Current Employment Cost Index, June 2013 

(http://www.bls.gov/schedule/archives/eci_nr.htm#2013).

Federal Agency labor rates were assumed to be $50.12 per hour. This labor rate was 

derived from the Federal government's 2012 U.S. Office of Personnel Management General 

Schedule "Salary Table 2012-GS" (http://archive.opm.gov/oca/12tables/pdf/gs.pdf) using the 

factors in the following table. 

Table 6-1: Determination of Federal Wage Rates

Annual Salary of Technical Staff, GS 11, Step 3 $53,639

Annual Cost of Supervisory Staff, GS 13, Step 3 $76,452

Factor (1/11) 0.09

$6,881

Annual Cost of Support Staff, GS 6, Step 6 $35,672

Factor (1/8) 0.13

$4,637

Annual Applicable Salary of Permit Staff 65157

Benefits 1.6

Total Cost per FTE $104,251

Total Hourly Cost (total per FTE dividend divided by 2,080 hours per year) $50.12

6(b) Estimating Respondent Burden for Affected NBP Units 

This section estimates the paperwork burden and cost of submitting monitoring plans, 

obtaining certification of each monitoring system, conducting monitor quality assurance 

activities, and recording and reporting data from CEM systems (or approved alternatives), and 

other ancillary activities (such as responding to EPA generated error messages, or responding to 

EPA audits). This applies to the affected units that continue to monitor in accordance with Part 

75 under the NOx SIP Call.

To estimate the burden and/or cost, EPA has relied on the estimates included in the most 

recent Acid Rain Program ICR (OMB Control Number 2060-0258) renewal for labor hour 

estimates of each activity. In addition, the hourly labor rates for managerial, technical, and 

clerical staff reflect the 2009 labor rates used in the Acid Rain ICR adjusted to 2012 dollars 

consistent with Agency ICR guidance.
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Affected sources are required to complete and submit a monitoring plan and obtain 

certification of each monitor (on standard forms) for each affected unit at the source. These 

plans and certifications, which are only submitted once, have already been submitted for most 

units. Sources, however, may need to submit revised plans or even recertify if they change some 

aspect of their existing plan. New units will still need to submit plans and certifications for the 

first time. In addition, all affected units are required to submit quarterly reports of their 

emissions data to EPA. These reports include much of the basic monitoring plan data as well.

To develop this renewal ICR, EPA relied primarily on the extensive efforts to identify

and calculate burdens for the prior two ICR renewals and the CAIR ICR (OMB Control Number 

2060-0570). 

Estimating Respondent Burden

The primary tasks performed by owners and operators of affected units are: 

(1) reviewing the regulations, forms and instructions; (2) responding to EPA generated error 

messages and audits; (3) reprogramming a DAHS and debugging the software; (4) completing 

and submitting monitoring plans for each unit at the source; (5) performing appropriate tests and 

providing test results to certify each monitor; (6) performing quality assurance testing and 

maintenance upon monitors; (7) assuring the quality of emissions data, preparing quarterly

reports of emissions data, and submitting reports to EPA; and (8) fuel sampling. 

(i) Regulatory Review. 

The estimate for time to review instructions and requirements remains consistent with the 

labor estimates used in previous ICRs (four manager hours and four technician hours) where no 

substantial changes have been made to the Rule. EPA continues to make available online fully

searchable versions of the Part 75 Emissions Monitoring Policy Manual and the Emissions 

Collection and Monitoring Plan System (ECMPS) Reporting Instructions and searchable version 

of Part 75. In addition, EPA in 2005 posted online a text version of its Plain English Guide to 

Part 75. 

(ii) Response to Error Messages/Audits. 

The EPA provides feedback to sources so that suspected errors in submissions by sources 

are noted and corrected. With the use of the ECMPS software, EPA believes that the burdens for 

this activity have decreased over time. At the same time, however, EPA has increased its audit 

oversight and expects to conduct a number of electronic and field audits of facilities over the 

next few years. In particular, EPA anticipates making significant use of electronic audits as a 

means to provide continuous data quality improvement. This effort will result in increased 

burdens for respondents. 

(iii) DAHS Debugging.

Each source must purchase (or create) and install computer software designed to 

implement the electronic data reporting formats required under the Acid Rain Program. EPA 

promulgated revisions to Part 75 in late 2007 to accommodate changes in EPA's data systems 

that manage the data submitted by respondents. These data system changes were necessary to 
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modernize EPA's data systems and streamline reporting. The costs of the required upgrade were

analyzed in a separate ICR that was issued in conjunction with the Part 75 revisions. For the 

time period of this ICR, 2013-2015, no other changes would require a DAHS upgrade and 

therefore there are no burden hours for this activity.

(iv) Monitoring Plans. 

Consistent with the existing ICR, completing and submitting monitoring plans is 

estimated to require an average of about 20 hours per unit initially. For existing units, initial 

monitoring plan submissions will be received prior to the time period covered in this renewal 

ICR, and, consistent with the existing ICR, EPA does not include burden hours for existing units 

under this initial monitoring plan development task area during 2013 – 2015. The burden 

associated with revising the monitoring plan is included in the time for preparing and submitting 

each quarterly emissions report.

For new units, EPA has used an estimated number of new units as a projection for the 

average number of new units expected in 2013 – 2015. These units have a separate line item for 

initial monitoring plan preparation.

(v) Monitor Certification. 

For existing units, only recertifications are included in the estimated activities for 2013 –

2015. The Agency estimates a labor burden of 50 hours and a contractor cost of $3,400 per 

respondent. The cost and burden figures exclude the costs and burdens associated with 

conducting a RATA as part of the recertification process because those costs are incorporated 

within the annual QA costs for previously certified monitoring systems. 

Under Part 75, sources are required to recertify the monitoring systems whenever the 

source makes a replacement, modification, or change in a certified CEMS or continuous opacity 

monitoring system that may significantly affect the ability of the system to accurately measure or 

record the NOx concentration, stack gas volumetric flow rate, NOx emission rate, percent 

moisture, or to meet the QA and QC requirements. Recertification is also necessary whenever 

the source makes a replacement, modification, or change to the flue gas handling system or the 

unit operation that may significantly change the flow or concentration profile. Examples of 

changes which require recertification include: replacement of the analyzer, change in location or 

orientation of the sampling probe or site; and complete replacement of an existing CEMS or 

continuous opacity monitoring system.

For new units, the monitor certification costs are included in the capital/startup costs.

(vi) Quality Assurance. 

Quality assurance (QA) testing and maintenance upon monitoring systems is the largest 

burden item under the monitoring, reporting and recordkeeping requirements. The requirements 

include daily, quarterly and annual QA requirements, depending on the monitoring approach 

being used. For reporting units that use flow and NOx CEMS, the Agency has developed a per 

unit labor burden based primarily on information gathered from affected sources. For units that 

rely on the excepted methods under both Appendix D and E (i.e., units without CEMS), the 
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burden estimates are reduced further because no CEMS QA is required. For the relatively small 

number of units that require moisture correction, labor burdens for moisture monitoring QA 

activities have been added based on information supplied by an affected utility (see Docket A97-35, Item II-D-94). 

(vii) Quarterly Reports. 

Tasks performed by utilities in preparing quarterly reports include: (1) assuring the 

quality of the data; (2) preparing the quarterly report; (3) revising the monitoring plan, if 

necessary; (4) preparation of hard copy documentation accompanying the quarterly reports; and 

(5) managerial review. EPA has been improving electronic file transfer procedures over the past 

few years and has been developing automated tools that allow sources to quality assure their 

reports. EPA believes these efforts have reduced the average burdens per report over time. In 

addition, because the program is maturing, the respondents have developed procedures and 

methods to increase their efficiency with reporting. 

Estimating Respondent Costs

Table 6-4 summarizes the annual respondent costs. The following discussion describes 

how those costs were derived.

(i) Estimating Total Capital and Annual Operations and Maintenance Costs

Capital/start-up costs include the cost of installing required CEMS or alternatives. The 

Agency developed the capital cost estimates for the CEM and other equipment based on EPA 

CEM cost models, existing ICRs, and comments from various affected utilities. The cost 

estimates vary depending on the number and type of monitors that are required. These 

annualized capital costs are from the Rule to Reduce Interstate Transport of Fine Particulate 

Matter and Ozone (Clean Air Interstate Rule) EPA ICR #2152.04. The annualized costs ranged 

from $28,879 for units with a full set of CEMS, to $18,750 for a unit that uses NOx CEMS and 

Appendix D methods, to $2,250 for units that use both Appendix D and Appendix E methods 

without any CEMS. There are no capital/start-up costs for LME units. A discussion of how the 

capital/start-up costs were annualized follows in Section (iii), below.

In addition to capital/start-up costs, respondents incur operation and maintenance costs 

(exclusive of labor costs) that reflect ongoing costs to a unit. These costs include both contractor 

costs for the required recertification, diagnostic, and quality assurance (QA) testing, and other 

direct maintenance-related expenses (e.g., spare parts and calibration gases). The cost estimates 

used in this renewal ICR are generally the same as the Rule to Reduce Interstate Transport of 

Fine Particulate Matter and Ozone (Clean Air Interstate Rule) EPA ICR #2152.04, and have been 

derived from EPA CEM cost models, existing ICRs, Agency staff experience under the Acid 

Rain Program, information gathered during development of the 1999 and 2002 Part 75 revisions, 

and supplemental estimates provided by affected utilities and others related to the various cost 

items (see, e.g., EPA Air Docket A-97-35, Item II-D-48). The total cost for these operation and 

maintenance cost items (other than fuel sampling) is estimated at $31,200 for a unit with a full 

set of CEMS, while units that use alternate methodologies have reduced costs. 
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Note that testing contractor costs for certification, recertification, and annual RATAs also 

are presented as other direct costs and are not converted to equivalent source labor hours. This 

approach is consistent with the common business practice for obtaining outside contractors to 

conduct certification/recertification tests and annual relative accuracy test audits. For initial 

certification, the certification test costs are commonly bundled with equipment purchase 

contracts, according to information provided by a range of CEMS equipment vendors. For 

RATAs that are conducted either as part of the annual quality assurance requirements or as part 

of recertification, industry contacts have indicated that RATA testing is usually performed under 

a fixed price contract basis, except for travel costs that may be billed on an hourly basis beyond 

the basic contract cost. For annual RATAs, the sources indicated that an annual contract 

between a testing company and utility is often used. One municipal utility representative 

indicated that the applicable municipal regulations required that outside contracts be on a flat fee, 

not hourly, basis.

(ii) Capital/Start-up vs. Operating and Maintenance (O & M) Costs

Capital costs reflect one-time costs for purchase of equipment which will be used over a 

period of years. Conversely, operating and maintenance costs are those costs which are incurred 

on an annual or other scheduled basis. For instance, costs associated with quality assurance 

activities, such as spare parts or contractor costs for work, will be incurred on an annual basis. 

(iii) Annualizing Capital Costs

The relevant capital costs for the emissions trading portion of this ICR were annualized at 

a rate of seven percent (i.e., the annualized capital cost was calculated assuming money to 

purchase the capital equipment was borrowed at a seven percent annual interest rate). The cost 

of the loan was amortized over the life of the loan to repay original borrowed amount plus 

interest. The result is the annualized capital cost reported.) The annualized cost of the necessary

capital purchases varies from $2,250 to $ 28,879, per year, per unit, depending on the type of 

monitoring methodology. The capital costs are from the Rule to Reduce Interstate Transport of 

Fine Particulate Matter and Ozone (Clean Air Interstate Rule), EPA ICR #2152.02.

(iv) Fuel Sampling

To calculate heat input where the source is using the fuel flowmeter option for an oil or 

gas-fired unit, the source must obtain gross calorific value (GCV) data from sampling in 

accordance with Appendix D of Part 75. For purposes of this ICR, it is assumed that the GCV 

data would be collected as part of standard business operating procedures to assure compliance 

with contractual specifications. Thus no additional fuel sampling burdens or costs should be 

incurred. This is consistent with the Rule to Reduce Interstate Transport of Fine Particulate 

Matter and Ozone (Clean Air Interstate Rule), EPA ICR #2152.04.

Estimating the Respondent Universe and Total Burden and Costs for Affected NBP Units

EPA estimates that there are 122 affected units that will continue to conduct monitoring 

in accordance with Part 75 solely under the NOx SIP Call. Table 6-4 shows the total burden and 

total cost for this respondent universe.
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Estimating Agency Burden and Cost

The tasks that will be performed by EPA include processing, reviewing, and evaluating 

emissions data reports submitted by the affected units, and conducting appropriate audit 

activities to verify the information provided. Assuming that the affected units will submit an 

average of 106 emission reports to EPA per quarter, the total annual burden incurred by the 

Agency will be 848 hours. (The annual total of 424 emissions reports is based on 90 quarterly 

reporting and an additional 32 Ozone Season only reporting facility counts.) The total annual 

cost to EPA for processing, reviewing, and evaluating these quarterly emissions reports will be 

approximately $42,502. Table 6-5 summarizes the Agency burden and costs associated with 

emissions reporting.
14

TABLE 6-4: ANNUAL RESPONDENT BURDEN/COST ESTIMATES FOR AFFECTED UNITS

Information Collection 

Activity

Mgr. 

$99.75/ 

Hour

Tech. 

$69.03/ 

Hour

Respondent 

Hours/Year

Labor 

Cost/Year

Cont./ 

O&M

Cost

Capital/ 

Startup 

Cost

Number of 

Respondents

Total 

Hours/

Year

Total 

Cost/Year

1. Review Instructions and 

Requirements 4 4 8 $675 $0 $0 53 424 $35,775

2. Respond to EPA Generated 

Error Messages, Field 

Audits 6 18 24 $1,841 $0 $0 122 2,928 $224,602

3. DAHS Debugging 4 12 16 $1,227 $0 $0 122 1,952 $149,694

4. New Unit Monitoring Plans 10 10 20 $1,688 $0 $0 12 240 $20,256

5. Recertify Monitors 38 12 50 $4,619 $3,400 $0 12 600 $96,228

6. Startup/Capital Items and 

Perform QA Testing and 

Maintenance

(a) NOx and Flow CEMS 50 480 530 $38,122 $31,200 $28,879 0 0 $0 

(b) NOx CEM and 

Fuelmeter 20 375 395 $27,881 $17,400 $18,750 101 39,895 6,467,131

(c) App. E and Fuelmeter 5 30 35 $2,570 $1,800 $2,250 21 735 $139,020

7. Assure Data Quality, 

Prepare Reports (inc. 

monitor plan update), 

Submit Reportsa20 82 102 $7,655 $0 $0 122 10,812 $933,910

TOTAL: 57,586 $8,066,616

a Based on an assumption of 90 annual reporting and 32 Ozone Season only reporting facilities.
15

TABLE 6-5: ANNUAL AGENCY BURDEN/COST ESTIMATES 

FOR AFFECTED UNITS

Tasks

Quarterly Burden 

Hours per Report

Quarterly Cost per 

Reporta

Number of 

Reportsb

Total Burden per Year 

(hours) 

(2010–2012) Total Cost

Process, review, and 

evaluate quarterly 

report and issue 

feedback letter. 2 $100.24 424 848 $42,502

a Based on an average total compensation rate of $50.12 per hour.

b Based on an assumption of 90 annual reporting and 32 Ozone Season only reporting facilities.

6(d) Summary of Burden Hours and Costs

Table 6-6 summarizes the annual aggregate burden and cost estimates to both the 

respondents and the agency for the period of 2013 through 2015. 

TABLE 6-6: AGGREGATE ANNUAL RESPONDENT AND AGENCY BURDEN AND 

COST OF COLLECTIONS (2013 – 2015)

Program

Total Annual Burden 

(Hours) Total Annual Costsa

Annual Industry Respondent Burden 57,586 $8,066,616

Annual Agency Burden 848 $43,350

TOTAL 58,434 $8,109,966

a

2009 dollars.

6(d) Reasons for Change in Burden

Hourly burden estimates in this ICR renewal are the same as those in the previous ICR. 

Industry and government wage rates are higher based on the Employee Cost Index and General 

Schedule. Total annual costs for industry respondents are higher than those in the previous ICR 

due to corrections to the previous ICR cost summation.

6(e) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information

is estimated to average 136 hours per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or disclose or provide information 

to or for a Federal agency. This includes the time needed to review instructions; develop, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable instructions and 
16

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's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15. 

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-OAR-2006-0947, which is available for online viewing at 

www.regulations.gov, or in person viewing at the Air and Radiation docket in the EPA Docket 

Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. 

The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday

through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 

566-1744, and the telephone number for the Air and Radiation docket is (202) 566-1742. An 

electronic version of the public docket is available at www.regulations.gov. This site can be 

used to submit or view public comments, access the index listing of the contents of the public 

docket, and to access those documents in the public docket that are available electronically. 

When in the system, select "search," then key in the Docket ID Number identified above. Also, 

you can send comments to the Office of Information and Regulatory Affairs, Office of 

Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk 

Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OAR-2006-0947 and 

OMB Control Number 2060-0445 any correspondence.