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SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility

Generating Units

(40 CFR Part 60, Subpart UUUU) 

July 2015

Part A of the Supporting Statement

1. Identification of the Information Collection

1(a) Title and Number of the Information Collection

“Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility

Generating Units (40 CFR Part 60, Subpart UUUU).” A new information collection request

(ICR) has been prepared in support of the guidelines being promulgated. The EPA ICR tracking 

number is 2503.02. This ICR was developed for the 3-year period following publication of the 

final rule.

1(b) Short Characterization/Abstract

Pursuant to Clean Air Act (CAA) section 111(d), the United States Environmental 

Protection Agency (EPA) is issuing rate-based goals for states and tribes regarding emissions of 

greenhouse gases, specifically carbon dioxide (CO2), from existing electric utility generating 

units (EGUs) burning fossil fuels, as well as emission guidelines for developing plans to attain 

these goals. For purposes of these guidelines, fossil fuel-fired EGUs include fossil fuel-fired 

steam generating units, integrated gasification combined cycle (IGCC) units, and stationary

combustion turbines that generate electricity for sale and are larger than 25 megawatts (MW). 

Existing sources include those EGUs that commenced construction on or before January 8, 2014.

The EPA is issuing these guidelines because CO2 is a greenhouse gas (GHG), and fossil 

fuel-fired power plants are the country’s largest stationary source emitters of GHGs. The EPA in 

2009 found that by causing or contributing to climate change, GHGs endanger both the public 

health and the public welfare of current and future generations.

This final action requires those states with one or more EGUs covered under this subpart

to develop plans to implement the emission guidelines and submit plans to the EPA for approval.

For areas of Indian country with affected sources, if the EPA determines that a plan is necessary

or appropriate, the EPA has the responsibility to establish a plan, unless a tribe on whose lands 

an affected source is located seeks and obtains authority from the EPA to establish a plan itself. 

If an approvable state or other jurisdictional plan is not submitted by the deadline for that plan,

the EPA will implement the emission guidelines in those states and tribal lands under a federal 

plan developed according to 40 CFR 60.27. Owners and operators of EGUs that are not covered 

by an approved jurisdictional plan must comply with the federal plan. The federal plan is an 

interim action and will be automatically withdrawn for a particular state or tribe when the 

jurisdictional plan is approved. If a federal plan is in place during the interim period beginning in 

2022 or the final period beginning in 2030, and the state submits and the EPA approves a 

jurisdictional plan, the federal plan will not be withdrawn until the end of the performance 
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period. Those states that have no EGUs for which construction commenced on or before January

8, 2014 would submit a negative declaration letter in place of the state plan. Tribal lands with no 

EGUs covered under this subpart would not be required to submit a negative declaration.

The emission guidelines include required components of the state plan, provisions for 

working with other states to develop a combined plan, timing requirements for submitting the 

plan, annual goals for CO2 emission performance, compliance schedules, and affected sources

(EGUs). Under the timing requirements provisions in the final guidelines, states and tribes (if 

they seek and obtain the authority to establish a plan) are given the option to submit their plans 

by the August 31, 2016 deadline or request a 2-year extension. If an extension is requested, an 

initial plan must be submitted in the first year that documents the reasons more time is needed 

and includes commitments to concrete steps that will ensure that a final plan will be submitted by

the third year. In addition, a progress report must be submitted in the second year to demonstrate 

ongoing progress in plan preparation.

This action imposes no new information collection burden on affected sources (EGUs) 

during the first 3 years after final rule promulgation beyond what those sources would already be 

subject to under the authorities of 40 CFR parts 75 and 98. The Office of Management and 

Budget (OMB) has previously approved the information collection requirements contained in the 

existing 40 CFR parts 75 and 98 regulations under the provisions of the Paperwork Reduction 

Act, 44 U.S.C. 3501 et seq. and has assigned OMB control numbers 2060-0626 and 2060-0629, 

respectively. There are no new information collection costs for these affected sources during the 

first 3 years, as the information required for these sources by the guidelines is already collected 

and reported by other regulatory programs during this period.

The only respondents expected to incur new information collection burden are those 

states and tribal lands with one or more EGUs covered under this subpart. Of the 48 contiguous 

states plus the District of Columbia, two (Vermont and the District of Columbia) have no EGUs 

covered under this subpart and are expected to submit negative declarations. The three tribal 

lands (Fort Mojave, Navajo Nation, and Ute) with EGUs covered under this subpart are expected 

to rely on the federal plan and not develop their own plan. One regional carbon management 

program, the Regional Greenhouse Gas Initiative (RGGI), is expected to submit a multi-state 

plan for the eight member states in their region that have EGUs covered under this subpart.

Without information to the contrary, plans from 41 states and one multi-state region are assumed 

to be submitted by August 31, 2016, unless a 2-year extension is requested. 

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under section 111(d) of the CAA to establish guidelines for existing

stationary sources. Section 111(d)(1) states:

“The Administrator shall prescribe regulations which shall 

establish a procedure similar to that provided by section 110 under 

which each State shall submit to the Administrator a plan which 

(A) establishes standards of performance for any existing source 

for any air pollutant (i) for which air quality criteria have not been 
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issued...but (ii) to which a standard of performance under this 

section would apply if such existing source were a new source, and 

(B) provides for the implementation and enforcement of such 

standards of performance.”

Subpart B of 40 CFR part 60 requires the plans to include monitoring, recordkeeping, and 

reporting provisions consistent with the emission guidelines. In addition, section 114(a) states

that the Administrator may require any owner or operator subject to any requirement of this Act 

to:

“(A) Establish and maintain such records; (B) make such reports; 

(C) install, use, and maintain such monitoring equipment, and use 

such audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with section 114(a)(3); and 

(G) provide such other information as the Administrator may

reasonably require.”

As previously stated, the EPA in 2009 found that by causing or contributing to climate 

change, GHGs endanger both the public health and the public welfare of current and future 

generations. Fossil fuel-fired power plants are the country’s largest stationary source emitters of 

GHGs. Therefore, emission guidelines for states concerning emissions of CO2 from existing 

sources in this category were proposed in June 2014 under 40 CFR part 60, subpart UUUU. A 

supplemental proposal for tribes was proposed in November 2014 under the same subpart. The

emission guidelines provide guidance for developing plans to attain the CO2 emission 

performance goals. As noted previously, 41 states and one multi-state region are expected to 

develop and submit their own plans, while the three affected tribes are expected to rely on the 

federal plan and not develop their own plan.

2(b) Use/Users of the Data

The data collected from respondents include the state plans expected to be developed in 

response to the emission guidelines. The data from states provide the foundation for identifying 

their emission performance levels and demonstrating how they will be achieved; identifying

emission standards and compliance requirements for each affected entity; and specifying

program implementation milestones. These emission performance levels, standards, compliance 

requirements, and milestones will be developed during the course of this ICR period.

3. Nonduplication, Consultations, and Other Collection Criteria

3(a) Nonduplication

As previously stated, this action imposes no new information collection burden on 

affected sources (EGUs) during the first 3 years after final rule promulgation, beyond what those 
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sources would already be subject to under the authorities of 40 CFR parts 75 and 98. There are 

no new information collection costs; the information required by these guidelines is already 

collected and reported by other regulatory programs. Therefore, no duplication exists for the 

affected industry.

If a state plan is disapproved, the respondent (state) can respond to EPA’s concerns and 

submit a revised plan. If an approvable plan is not submitted by the state, the EPA will

implement a federal plan that applies to existing sources in the state. As noted previously, the 

three affected tribes are expected to rely on the federal plan and not develop their own plan. 

Consequently, the information would be submitted to the appropriate EPA regional office, until 

such time as the state or tribe is delegated this authority. Therefore, no duplication exists for 

states and tribes. 

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

This section is not applicable because this is a rule-related ICR.

3(c) Consultations

The June 2014 proposed rule and the November 2014 supplemental proposal were

developed after extensive and vigorous outreach to stakeholders and the general public. To carry

out this stakeholder outreach, the EPA embarked on an unprecedented outreach effort to parties 

with an interest in reducing carbon pollution from existing power plants. From consumer groups 

to states to power plants to technology innovators, the EPA sought input from all perspectives.

The EPA began the outreach efforts with a webinar and associated teleconferences to 

establish a common understanding of the basic requirements and process of CAA section 111(d). 

The August 27, 2013 overview presentation was offered as a webinar for state and tribal 

officials, “Building a Common Understanding: Clean Air Act and Upcoming Carbon Pollution 

Guidelines for Existing Power Plants.” More than 360 people from across the country

participated in the August webinar presentation--primarily from state environmental and energy

offices.

The overview presentation was also posted on the EPA website. The EPA followed up on 

the presentation by offering four national teleconference calls with representatives from states, 

tribes, industry, environmental justice organizations, community organizations and 

environmental representatives. The teleconferences offered a venue for stakeholders to ask 

questions of the EPA about the overview presentation and for the EPA to gather initial reactions 

from stakeholders. Stakeholders and members of the public continued to view and refer to the 

overview presentation throughout the outreach process. 

The agency also provided mechanisms for anyone from the public to provide input during 

the pre-proposal development of this action. The EPA set up two user-friendly options to accept 

input during the pre-proposal period–a new email account: carbonpollutioninput@epa.gov; and a 

web-based form: http://www2.epa.gov/carbon-pollution-standards/forms/carbon-pollutionstandards-contact-us. These links, along with policy, program, and technical information about 

this rulemaking effort, are available on the EPA’s website at: http://www2.epa.gov/carbonpollution-standards. The EPA has received more than 2,000 emails offering input into the 

development of these guidelines. 
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The agency has encouraged, organized, and participated in hundreds of meetings about 

CAA section 111(d) and reducing carbon pollution from existing power plants. Attendees at 

these various meetings have included states and tribes, members of the public, and 

representatives from multiple industries, labor leaders, environmental groups and other nongovernmental organizations. The direct engagement has brought together a variety of states and 

stakeholders to discuss a wide range of issues related to the electricity sector and the 

development of emission guidelines under CAA section 111(d). The meetings occurred in 

Washington, DC, and at locations across the country. The meetings were attended by the EPA 

Regional Administrators, managers and staff and who will play key roles in developing and 

implementing the rule.

Part of this effort included the agency’s holding of 11 public listening sessions: one 

national listening session in Washington, DC and 10 listening sessions in locations in the EPA 

Regional offices across the country. Additionally, in July and August 2014, the EPA held four

2-day public hearings on the proposed emission guidelines. In November 2014, the EPA held a 

public hearing on the supplemental proposal in Phoenix, Arizona. All of the outreach meetings 

were designed to solicit policy ideas, concerns and technical information from stakeholders 

about using CAA section 111(d).

Since fall 2013, the agency provided multiple opportunities for states to inform these 

guidelines. In addition, the EPA organized, encouraged and attended meetings to discuss multistate planning efforts. The meetings provided state leaders, including governors, environmental 

commissioners, energy officers, public utility commissioners, and air directors, opportunities to

engage with the EPA officials.

Agency officials listened to ideas, concerns and details from states, including from states 

with a wide range of experience in reducing carbon pollution from power plants. The agency has 

collected policy papers from states with overarching energy goals and technical details on the 

states’ electricity sector. The agency has engaged, and will continue to engage, with all of the 50 

states throughout the rulemaking process. 

While tribes are not required to, but may, develop or adopt Clean Air programs, the EPA 

conducted significant outreach to tribes. The EPA is aware of three coal-fired power plants and 

one natural gas plant located in Indian country but is not aware of any power plants owned or 

operated by tribal entities. 

The EPA conducted outreach to tribal environmental staff and offered consultation with 

tribal officials in developing this action. Because the EPA is aware of tribal interest in this rule, 

the EPA offered consultation with tribal officials early in the process of developing the 

regulation to permit tribes to have meaningful and timely input into its development. The EPA 

sent consultation letters to 566 leaders of federally recognized tribes. The letters provided 

information regarding the EPA’s development of emission guidelines for existing power plants 

and offered consultation.

Tribes were invited to participate in the national informational webinar held August 27, 

2013. In addition, a consultation/outreach meeting was held on September 9, 2013, with tribal 

representatives from some of the 566 tribes. The EPA representatives also met with tribal 

environmental staff with the National Tribal Air Association, by teleconference, on July 25, 

2013; December 19, 2013; June 26, 2014; and August 4, 2014. In those teleconferences, the EPA 

provided background information on the GHG emission guidelines being developed and a 
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summary of issues being explored by the agency. In addition, the EPA held a series of listening 

sessions prior to development of the June 2014 proposed rule and November 2014 supplemental 

proposal. Tribes participated in a session on September 9, 2013 with the state agencies, as well 

as in a separate session for tribes on September 26, 2013.

The EPA also held a consultation with the Ute Tribe, Crow Tribe, and Mandan, Hidatsa 

and Arikara (MHA) Nation on July 18, 2014; a consultation with the Fort Mojave Tribe on 

August 22, 2014; a consultation with the Navajo Nation, Inter Tribal Council of Arizona (ITCA), 

Hopi Tribe, Fort Mojave Tribe, Fort McDowell Yavapai Nation, and Ak-Chin Indian 

Community on November 18, 2014; a consultation with the Ute Tribe on December 16, 2014; a 

consultation with the Gila River Indian Community on January 15, 2015; and a consultation with 

the Navajo Nation on April 28, 2015.

This outreach process has produced a wealth of information. The EPA has taken 

information from these meetings and used it to inform the June 2014 proposed rule, November 

2014 supplemental proposal, and this final rule. The outreach efforts far exceeded what is 

required of the agency in the normal course of a rulemaking process, and the EPA expects that a 

dialog with states and other stakeholders will continue even after the rule is finalized. The EPA 

recognizes the importance of working with all stakeholders, and in particular with the states and 

tribes, to ensure a clear and common understanding of the role the states and tribes will play in 

addressing carbon pollution from power plants.

3(d) Effects of Less Frequent Collection

This section is not applicable because respondents for this 3-year ICR period do not 

include EGU facilities, and annual reports from states will be submitted after the 3-year ICR 

period.

3(e) General Guidelines

None of the guidelines in 5 CFR 1320.5 are being exceeded.

3(f) Confidentiality

All information submitted to the agency for which a claim of confidentiality is made will 

be safeguarded according to the agency policies set forth in Title 40, Chapter 1, part 2, subpart 

B–Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976; 

amended by 43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR 

17674, March 23, 1979).

3(g) Sensitive Questions

This section is not applicable because this ICR does not involve matters of a sensitive 

nature.

4. The Respondents and the Information Requested

4(a) Respondents/NAICS Codes

The respondents that would be expected to incur new information collection burden

under subpart UUUU are those states and tribal lands with one or more EGUs covered under this

subpart. As noted previously, an estimated 41 individual state plans and 1 multi-state plan are 
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expected to be submitted by August 31, 2016, unless a 2-year extension is requested. Negative 

declarations are expected from one state (Vermont) and the District of Columbia. Tribes with 

one or more EGUs covered under this subpart (Fort Mojave, Navajo Nation, and Ute) are 

expected to rely on the federal plan. The applicable North American Industry Classification 

System (NAICS) code is 999200, “State Government, excluding schools and hospitals.”

4(b) Information Requested

(i) Data Items, Including Recordkeeping Requirements

There are no new information collection costs for the affected industry, as the 

information required by these guidelines is already collected and reported by other regulatory

programs (40 CFR parts 75 and 98). The only new information collection costs are for those 

states with one or more EGUs covered under this subpart.

Respondents must make the following reports:

Requirement Guidelines Citation 

by Section

Plan to implement and enforce emission guidelines 60.5710 and 60.23(a)

Negative declaration letter documenting there are no affected EGUs in 

the state that are covered under the emission guidelines 60.5710

Request for extension to deadline for submitting a plan (as part of plan 

submittal) 60.5760

Reports documenting progress towards meeting the emission 

performance rate/goal 60.5830

Notification of public hearing on the plan 60.23(d)

Certification that public hearing on the plan conducted according to 

subpart B procedures 60.23(f)

State respondents must also keep the following records:

Requirement Guidelines Citation 

by Section

Records of hourly values for each affected source to support the 

calculation of the annual emission performance goal 60.5825(c)

Records of public hearing conducted on the plan 60.23(e)

(ii) Respondent Activities

The respondent activities required by the emission guidelines are described in the tables 

and footnotes in Exhibits 1a and 1b at the end of this document. Exhibits 1a and 1b include the 

respondent activities associated with developing and implementing the plans. Exhibit 1a 

accounts for states already having active energy efficiency programs in place for achieving their 

emission performance goals, whereas Exhibit 1b does not account for existing energy efficiency

programs. The recordkeeping and reporting activities associated with documenting progress 
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towards the annual emission performance goal would occur after the 3-year period of this ICR 

and, therefore, are not included in these tables.

(iii) Summary of Requirements

The guidelines require states covered under the emission guidelines to prepare and submit 

plans to implement the guidelines and conduct public hearings on the plans as necessary, 

according to the procedures in 40 CFR part 60, subpart B.

5. The Information Collected: Agency Activities, Collection Methodology, and 

Information Management (covering the first 3 years following final rule promulgation)

5(a) Agency Activities

The agency, specifically the EPA Headquarters and the EPA Regions, will incur burden 

associated with the reporting requirements for states, including: (1) providing support and 

outreach to states regarding the implementation of the emission guidelines and preparation of the 

plans, (2) reviewing and approving the plans, (3) reviewing negative declarations from states

with no EGUs covered under the emission guidelines, (4) reviewing and approving extension 

requests, (5) reviewing notifications from states regarding public hearings on the plans, and 

(6) reviewing certifications from states that the public hearings were conducted according to 40 

CFR part 60, subpart B procedures. 

5(b) Collection Methodology and Management

The plans expected to be prepared by states will set forth the specifics regarding the 

actual collection methodology and management. The plan submittal must include the following 

components, which will be codified as part of the federally enforceable plan upon approval by 

the EPA:

 Identification of affected EGUs covered by the plan and all affected EGUs in the state 

that meet the applicability criteria in the emission guidelines, including an inventory

of CO2 emissions from affected EGUs during the most recent calendar year for which 

data is available prior to the submission of the plan.

 Identification of all emission standards for each affected EGU, compliance periods 

for each emission standard according to the emission guidelines, and a demonstration 

that the emission standards are, when taken together, sufficiently protective to meet 

the applicable CO2 emission performance rates described in the emission guidelines.

 If the plan includes state measures, the plan must include a federally enforceable 

backstop that identifies emission standards for affected EGUs that will be put into 

place if there is an exceedance of 10 percent or greater of any interim step goal or 

final goal period.

 Identification of applicable monitoring, reporting, and recordkeeping requirements for 

each affected EGU. These requirements must be consistent with or no less stringent 

than the requirements specified in the emission guidelines.

 Description of the process, contents, and schedule for state reporting to the EPA 

about plan implementation and progress, including information required under the 

emission guidelines.
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 A requirement for a report to be submitted by July 1, 2021, that demonstrates that the 

state has met the programmatic milestone steps that it indicated it would take from the 

submittal of the final plan through the end of 2020, and that the state is on track to 

implement the plan as of January 1, 2022.

In addition to the components of the plan listed above, a final plan submittal to the EPA 

must include the following information, which must be submitted to the EPA but will not be 

codified as part of the federally enforceable plan upon approval by the EPA:

 A description of plan approach and the geographic scope of the plan (i.e., state or 

multi-state, geographic boundaries related to the plan elements), including, if 

applicable, identification of multi-state plan participants.

 Identification of CO2 emission performance rates or equivalent statewide emission 

goals that the affected EGUs will achieved through implementation of the plan.

 A demonstration that the affected EGUs covered by the plan are projected to achieve 

the CO2 emission performance rates or CO2 emission goals described in the emission 

guidelines.

 A demonstration that each affected EGU’s emission standard is quantifiable, nonduplicative, permanent, verifiable, and enforceable according to the emission 

guidelines.

 If the plan includes only emission standards on the affected EGUs to meet either the 

CO2 emission performance rates or CO2 emission goals, the final plan submittal must 

include a demonstration, if necessary, that the standards will meet the CO2 emission 

performance rates or CO2 emission goals.

 If the plan includes state measures, in addition to or in lieu of the emission standards 

required in the emission guidelines, the final plan submittal must include (1) a 

description of the state measures, the applicable state laws or regulations, and 

identification of parties or entities implementing such state measures; (2) the schedule 

and milestones for the implementation of the state measures and a demonstration of 

the minimum emission, monitoring and verification requirements if the state 

measures rely upon renewable energy or demand-side energy efficiency programs and 

projects; (3) a demonstration that the federally enforceable emission standards and 

state measures are sufficient to attain the CO2 emission performance rates or CO2

emission goal for the interim and final periods; (4) a CO2 performance projection of 

the state measures that shows how the measures will achieve the future CO2

performance at affected EGUs; (5) a demonstration that the state measures will 

require affected EGUs to meet the CO2 emission performance rate or rate-based CO2

emission goal (if applicable); and (6) a demonstration that combined state-enforceable 

measures, along with any federally enforceable CO2 emission standards, will achieve 

the state mass-based CO2 emission goal (if applicable).

 The final plan submittal must demonstrate any regional information considered in 

developing the assumptions.

 The final plan submittal must include a demonstration that the reliability of the 

electrical grid has been thoroughly considered.
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 Certification that a hearing required under §60.23(c)(1) on the plan was held, a list of 

witnesses and their organizational affiliations, if any, appearing at the hearing, and a 

brief written summary of each presentation or written submission.

 Supporting material for the plan, including (1) materials demonstrating the state’s 

legal authority to carry out each component of its plan, including emission standards

or state measures; (2) materials supporting that the CO2 emission performance rates 

or CO2 emission goals will be achieved by affected EGUs under the plan; 

(3) materials supporting any calculations for CO2 emission goals calculated under the 

plan; and (4) materials necessary to support evaluation of the plan by the EPA.

5(c) Small Entity Flexibility

The EPA is aware that there is substantial interest in the rule among small entities 

(municipal and rural electric cooperatives). The EPA has conducted an unprecedented amount of 

stakeholder outreach on setting emission guidelines for existing EGUs. While formulating the 

provisions of the rule, the EPA considered the input provided over the course of the stakeholder 

outreach. As part of that outreach, agency officials participated in many meetings with individual 

utilities, as well as meetings with electric utility associations. Specifically, the EPA 

Administrator, Gina McCarthy, participated in separate meetings with both the National Rural 

Electric Cooperative Association (NRECA) and the American Public Power Association 

(APPA). The meetings brought together leaders of the rural cooperatives and public power 

utilities from across the country. The Administrator discussed and exchanged information on the 

unique challenges, in particular the financial structure, of NRECA and APPA member utilities.

The EPA also participated in roundtable discussions with small business owners.

In addition, the EPA conducted outreach to representatives of small entities while 

formulating the provisions of the standards for new sources in the electric utility industry (40 

CFR part 60, subpart TTTT). Although only new EGUs are affected by those standards, the 

outreach regarded planned actions for new and existing sources. The EPA conducted outreach 

with representatives from 20 various small entities that potentially would be affected by the 

planned actions. The representatives included small entity municipalities, cooperatives, and 

private investors. We distributed outreach materials to the small entity representatives; these 

materials included background, an overview of affected sources and GHG emissions from the 

power sector, an overview of CAA section 111, an assessment of CO2 emission control 

technologies, potential impacts on small entities, and a summary of the listening sessions. We 

met with eight of the small entity representatives, as well as three participants from organizations 

representing power producers, on June 17, 2011, to discuss the outreach materials, potential 

requirements of the planned rules, and regulatory areas where the EPA has discretion and could 

potentially provide flexibility.

A second outreach meeting was conducted on July 13, 2011. We met with nine of the 

small entity representatives, as well as three participants from organizations representing power 

producers. During the second outreach meeting, various small entity representatives and 

participants from organizations representing power producers presented information regarding 

issues of concern with respect to development of the planned rules for GHG emissions.
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5(d) Collection Schedule

The specific frequency for each information collection activity within this request is 

shown in Exhibits 1a and 1b for the first 3 years following promulgation of the emission 

guidelines.

6. Estimating the Burden and Cost of the Collection

Exhibits 1a and 1b document the lower and upper bounds, respectively, of individual 

burdens for the reporting requirements applicable to states for the first 3 years. The lower bounds 

account for states already having active energy efficiency programs in place for achieving their 

emission performance goals, while the upper bounds do not account for existing energy

efficiency programs. By accounting for existing programs, the burden estimates in Exhibit 1a are 

lower than those in Exhibit 1b. Table 1 below presents the range of the respondent burden hours 

and costs (detailed in Exhibit 1c).

Table 1. Lower to Upper Range of Respondent Burden and Costs

(3-year period following final rule publication)

Year Total Annual Labor Burden (hours) Total Annual Labor Costs ($)

3-Year Total 1.52 - 2.46 million $107 - $174 million

Average Annual 505,000 - 821,000 $35.8 - $58.1 million

Average Annual per 

Respondent 41,000 - 73,900 $2.90 - $5.23 million

The individual burdens are expressed under standardized headings believed to be 

consistent with the concept of burden under the Paperwork Reduction Act. Where appropriate, 

specific tasks and major assumptions have been identified; responses to this information 

collection are mandatory.

The 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.

6(a) Estimating Respondent Burden

The average annual burden over the 3-year period of this ICR from these reporting 

requirements is estimated to range from approximately 505,000 to 821,000 hours per year

(detailed in Exhibit 1c). These hours are based on agency studies and background documents 

from the development of the regulation, agency knowledge and experience with part 60 and 

other regulations, the previously approved ICR for subpart TTTT, and other sources.

1

																																																							

1 According to one source, the average person can proofread at about 200 words per minute on paper and 180 words 

per minute on a monitor. (Reference: Ziefle, M. (December 1988). “Effects of Display Resolution on Visual 

Performance.” Human Factors 40 (4): 554-68). Due to the highly technical nature of the rule requirements in subpart 

UUUU, a more conservative estimate of 100 words per minute was used to determine the burden estimate for 

reading and understanding rule requirements.
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6(b) Estimating Respondent Costs

Respondent costs are typically divided into three categories. These categories include 

labor costs, operation and maintenance (O&M) costs, and annualized capital costs. Labor costs

and O&M costs are the only respondent costs associated with this ICR. 

(i) Estimating Labor Costs

The average annual labor costs over the 3-year period of this ICR from these reporting 

requirements are estimated to range from approximately $35.8 to $58.1 million per year (detailed 

in Exhibit 1c). Labor rates and associated costs are based on Bureau of Labor Statistics (BLS) 

data. Technical, managerial, and clerical average hourly rates for state government workers were 

based on the Bureau of Labor Statistics, Occupational Employment Statistics, May 2013

National Industry-Specific Occupational Employment and Wage Estimates for state government 

(NAICS code 999200). The state government labor rates from BLS were multiplied by an 

overhead multiplier of 110 percent to estimate loaded labor rates of $74.05 per hour for 

technical, $89.67 per hour for managerial, and $35.09 per hour for clerical.

(ii) Estimating Annualized Capital Costs

There are no annualized capital costs associated with this ICR.

(iii) Estimating Operations and Maintenance (O&M) Costs

The annual O&M costs associated with this ICR are the costs associated with the 

paperwork requirements incurred continuously over the life of the ICR (e.g., storing hard copy 

records, electronic data storage, and miscellaneous annual supplies) (see Exhibits 1a and 1b). 

The average annual O&M costs associated with this ICR are approximately $58,000 (detailed in 

Exhibit 1c).

6(c) Estimating Agency Burden and Cost

Because the information collection requirements were developed as an incidental part of 

standards development, no costs can be attributed to the development of the information 

collection requirements. Because reporting and recordkeeping requirements on the part of the 

respondents are required under section 111 of the CAA, no operational costs will be incurred by 

the federal government. Publication and distribution of the information are part of the 

Compliance Data System, with the result that no federal costs can be directly attributed to the 

ICR. Examination of records to be maintained by the respondents will occur incidentally as part 

of EPA’s overall compliance and enforcement program, and, therefore, is not attributable to the 

ICR. The only costs to the federal government, specifically the EPA Headquarters and the EPA 

Regions, under this ICR are those costs associated with the support and outreach to states; the 

review of the plans, negative declarations, extension requests for plan submittals, progress 

reports and public hearing notifications/certifications; and miscellaneous administrative charges.

Exhibit 2a presents the average annual agency burden and cost estimates for the first 3 years after 

promulgation of the emission guidelines. Table 2 below contains a summary of the 3-year total 

and average annual agency burden hours and costs (detailed in Exhibit 2b).
13

Table 2. Summary of Agency Burden and Costs

(3-year period following final rule publication)

Year Total Annual Labor Burden (hours) Total Annual Labor Costs ($)

3-Year Total 162,000 $8.99 million

Average Annual 54,000 $3.00 million

Technical, managerial, and clerical average hourly rates for EPA Headquarters staff and 

EPA Regional staff were selected from the U.S. Office of Personnel Management Salary Table 

2012-GS (accessed at http://www.opm.gov/oca/12tables/pdf/gs_h.pdf). These rates were 

increased by 60 percent to include fringe benefits and overhead. For EPA Headquarters staff, the 

loaded labor rates are $62.27 per hour for technical (GS-13, Step 5), $86.56 per hour for 

managerial (GS-15, Step 5), and $36.11 per hour for clerical (GS-9, Step 5). For EPA Regional 

staff, the loaded labor rates are $52.37 per hour for technical (GS-12, Step 5), $86.56 per hour 

for managerial (GS-15, Step 5), and $29.52 per hour for clerical (GS-7, Step 5). 

The agency cost estimates also include annual costs of $1,000 for miscellaneous 

administrative charges (e.g., telephone, photocopies, and postage) incurred during the first 

3 years after promulgation.

6(d) Estimating the Respondent Universe and Total Burden and Costs.

Forty-eight states, three areas of Indian country and the District of Columbia will be 

subject to the requirements of the emission guidelines. Two (Vermont and the District of 

Columbia) have no EGUs covered under this subpart, and thus are expected to submit negative 

declarations. Thirty-nine states are expected to submit their own individual plans, while the three 

tribes are expected to rely on the federal plan. One regional carbon management program

(RGGI) is expected to submit a multi-state plan for the eight member states in that region that 

have EGUs covered under this subpart.

The total number of responses for the monitoring, recordkeeping, and reporting 

guidelines in subpart UUUU over the 3-year ICR period is estimated to be 136. The average 

number of annual responses over the 3-year ICR period is 45.3 per year. The total labor burden 

over the 3-year ICR period is estimated to range from approximately 1.52 to 2.46 million personhours. The total labor costs over the 3-year ICR period are estimated to range from 

approximately $107 to $174 million.

6(e) Bottom Line Burden Hours and Cost Tables

The bottom line labor hours and costs are shown in Exhibits 1a and 1b for respondents 

and Exhibit 2a for EPA. The labor hours and costs are summarized in Exhibit 1c for respondents 

and Exhibit 2b for EPA.

6(f) Reasons for Change in Burden

The increase in burden is due to this being a new ICR associated with a new subpart.

6(g) Burden Statement

The annual public reporting and recordkeeping burden (as listed in Section 5(b) above)

for this collection of information is estimated to range from approximately 11,100 to 18,100

hours per response. Burden means the total time, effort, or financial resources expended by
14

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 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 in 40 CFR part 60 are listed in 40 CFR part 9.

PART B

This section is not applicable because statistical methods are not used in data collection 

associated with these guidelines.
15

ATTACHMENTS

Exhibit 1a. Lower Bound Respondent Burden and Cost of Reporting and Recordkeeping 

Requirements, Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric 

Utility Generating Units (40 CFR Part 60, Subpart UUUU)

Exhibit 1b. Upper Bound Respondent Burden and Cost of Reporting and Recordkeeping 

Requirements, Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric 

Utility Generating Units (40 CFR Part 60, Subpart UUUU)

Exhibit 1c. Summary of Respondent Burden and Cost of Reporting and Recordkeeping 

Requirements, Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric 

Utility Generating Units (40 CFR Part 60, Subpart UUUU)

Exhibit 2a. Burden and Cost to the Agency, Carbon Pollution Emission Guidelines for Existing 

Stationary Sources: Electric Utility Generating Units (40 CFR Part 60, Subpart UUUU)

Exhibit 2b. Summary of Agency Burden and Cost, Carbon Pollution Emission Guidelines for 

Existing Stationary Sources: Electric Utility Generating Units (40 CFR Part 60, Subpart UUUU)
16

Exhibit 1a. Lower Bound Respondent Burden and Cost of Reporting and Recordkeeping Requirements, Carbon Pollution Emission 

Guidelines for Existing Stationary Sources: Electric Utility Generating Units (40 CFR Part 60, Subpart UUUU)

Burden Item

(A)

Hours/ 

Occurrence

(B)

Occurrences/ 

Respondent/

Year

(C)

Hours/ 

Respondent/Year

(A x B)

(D)

Respondents/Year

(E)

Total 

Hours/ 

Year

(C x D)

(F)

Technical 

Hours/Year

(E x 0.79)

(G)

Managerial 

Hours/Year

(E x 0.09)

(H)

Clerical 

Hours/Year

(E x 0.12)

(I)

Cost/Year

1. REPORTING REQUIREMENTS

A. Read and Understand Rule Requirements a,b 50 1 50 16.3 817 408 408 0 $66,851

B. Required Activities

Develop initial submittal/progress report c,d 12,480 1 12,480 15.7 195,520 154,461 17,597 23,462 $13,838,429

Develop final plan

 Individual plan e,f 11,440 1 11,440 26 297,440 234,978 26,770 35,693 $21,052,077

 Multi-state plan g,h 17,056 1 17,056 0.7 11,371 8,983 1,023 1,364 $804,788

C. Create Information Incl. in 1B

D. Gather Information Incl. in 1B

E. Report Preparation

Initial/final plan Incl. in 1B

Negative declaration i1 1 1.0 0.7 0.7 0.5 0.06 0.08 $47

AVERAGE ANNUAL LABOR BURDEN

AND COST 505,148 417,470 45,798 60,520 $35,762,192

AVERAGE ANNUALIZED COSTS (O&M)

(Reporting/recordkeeping supplies) $58,045

a Assumes one-time burden of 50 hours (based on an average reading rate of 100 words/minute) to read and understand rule requirements, divided equally among technical and managerial staff.

b Respondents include all 48 contiguous states, plus the District of Columbia, averaged over the 3-year ICR period (49/3=16.3).

c Assumes 6 FTEs per state per year for team leadership, political outreach, general coordination of plans, energy and policy analysis, coordination between energy office and air office, energy efficiency

programs liaison, modeling, data analysis, extension requests, and 2017 progress reports.

d Respondents include 47 states with EGUs expected to develop an initial submittal over the first year and progress report over the second year, averaged over the 3-year ICR period (47*1/3=15.7).

e Assumes 5.5 FTEs per state per year for team leadership, political outreach, general coordination of plans, energy and policy analysis, coordination between energy office and air office, energy 

efficiency programs liaison, modeling, and data analysis.

f Respondents include those 39 states with EGUs expected to develop a final individual plan over the remaining 2 years, averaged over the 3-year ICR period (39*2/3=26).

g Assumes 1 FTE per year for multi-state plan staff providing team leadership, political outreach, outreach to participating states, modeling, and data analysis, and 0.9 FTE for each participating state in 

the region.

h Respondent is the regional carbon management program (RGGI) expected to develop a final multi-state plan for its 8 member states with EGUs over the remaining 2 years, averaged over the 3-year 

ICR period (1*2/3=0.7).

i Respondents include the 1 state and District of Columbia without EGUs expected to submit a one-time negative declaration, averaged over the 3-year ICR period (2/3=0.7).

Nationwide Respondent Assumptions

Breakdown of Respondents No.

Resp. Notes

Total no. respondents 49 48 states, DC

No. expected to submit negative declaration 2 VT, DC

No. expected to submit plan a47 47 states

No. expected to submit individual plan a39 39 states

No. expected to submit multi-state plan 1 Regional Greenhouse Gas Initiative (RGGI)

No. states included in multi-state plan 8 Includes the 8 states in RGGI with EGUs

a Tribes expected to rely on federal plan.
17

Respondent Labor Rates

Labor Category Respondent Labor Rates (May 2013)

Unloadeda Overhead Multiplier (110%) Loaded

Technical $35.26 2.1 $74.05

Managerial $42.70 2.1 $89.67

Clerical $16.71 2.1 $35.09

a Unloaded labor rates from U.S. Department of Labor, Bureau of Labor Statistics,

Occupational Employment Statistics, May 2013 National Industry-Specific Occupational

Employment and Wage Estimates, NAICS 999200 - State Government, excluding schools

and hospitals (OES Designation) <http://www.bls.gov/oes/2013/may/naics4_999200.htm>

Recordkeeping/Reporting Supplies (Annual O&M Costs) a

Supply Item Price/ 

Item

No./ 

Resp.

No. of 

Resp. Total

File cabinet to store hard copy records $235 1 47 $11,045

Electronic data storage device $500 1 47 $23,500

Miscellaneous annual supplies $500 1 47 $23,500

Average Annual Cost $58,045

a Costs based on estimates initially prepared for 40 CFR part 60, subpart TTTT.
18

Exhibit 1b. Upper Bound Respondent Burden and Cost of Reporting and Recordkeeping Requirements, Carbon Pollution Emission 

Guidelines for Existing Stationary Sources: Electric Utility Generating Units (40 CFR Part 60, Subpart UUUU)

Burden Item

(A)

Hours/ 

Occurrence

(B)

Occurrences/ 

Respondent/

Year

(C)

Hours/ 

Respondent/Year

(A x B)

(D)

Respondents/Year

(E)

Total 

Hours/ 

Year

(C x D)

(F)

Technical 

Hours/Year

(E x 0.79)

(G)

Managerial 

Hours/Year

(E x 0.09)

(H)

Clerical 

Hours/Year

(E x 0.12)

(I)

Cost/Year

1. REPORTING REQUIREMENTS

A. Read and Understand Rule Requirements a,b 50 1 50 16.3 817 408 408 0 $66,851

B. Required Activities

Develop initial submittal/progress report c,d 19,760 1 19,760 15.7 309,573 244,563 27,862 37,149 $21,910,845

Develop final plan

 Individual plan e,f 18,720 1 18,720 26 486,720 384,509 43,805 58,406 $34,448,854

 Multi-state plan g,h 35,360 1 35,360 0.7 23,573 18,623 2,122 2,829 $1,668,463

C. Create Information Incl. in 1B

D. Gather Information Incl. in 1B

E. Report Preparation

Initial/final plan Incl. in 1B

Negative declaration i1 1 1.0 0.7 0.7 0.5 0.06 0.08 $47

AVERAGE ANNUAL LABOR BURDEN

AND COST 820,684 648,104 74,196 98,384 $58,095,060

AVERAGE ANNUALIZED COSTS (O&M)

(Reporting/recordkeeping supplies) $58,045

a Assumes one-time burden of 50 hours (based on an average reading rate of 100 words/minute) to read and understand rule requirements, divided equally among technical and managerial staff.

b Respondents include all 48 contiguous states, plus the District of Columbia, averaged over the 3-year ICR period (49/3=16.3).

c Assumes 9.5 FTEs per state per year for team leadership, political outreach, general coordination of plans, energy and policy analysis, coordination between energy office and air office, energy 

efficiency programs liaison, modeling, data analysis, extension requests, and 2017 progress reports.

d Respondents include 47 states with EGUs expected to develop an initial submittal over the first year and progress report over the second year, averaged over the 3-year ICR period (47*1/3=15.7).

e Assumes 9 FTEs per state per year for team leadership, political outreach, general coordination of plans, energy and policy analysis, coordination between energy office and air office, energy efficiency

programs liaison, modeling, and data analysis.

f Respondents include those 39 states with EGUs expected to develop a final individual plan over the remaining 2 years, averaged over the 3-year ICR period (39*2/3=26).

g Assumes 1 FTE per year for multi-state plan staff providing team leadership, political outreach, outreach to participating states, modeling, and data analysis, and 0.9 FTE for each participating state in 

the region.

h Respondent is the regional carbon management program (RGGI) expected to develop a final multi-state plan for its 8 member states with EGUs over the remaining 2 years, averaged over the 3-year 

ICR period (1*2/3=0.7).

i Respondents include the 1 state and District of Columbia without EGUs expected to submit a one-time negative declaration, averaged over the 3-year ICR period (2/3=0.7).

Nationwide Respondent Assumptions

Breakdown of Respondents No. 

Resp. Notes

Total no. respondents 49 48 states, DC

No. expected to submit negative declaration 2 VT, DC

No. expected to submit plan a47 47 states

No. expected to submit individual plan a39 39 states

No. expected to submit multi-state plan 1 Regional Greenhouse Gas Initiative (RGGI)

No. states included in multi-state plan 8 Includes the 8 states in RGGI with EGUs

a Tribes expected to rely on federal plan.
19

Respondent Labor Rates

Labor Category Respondent Labor Rates (May 2013)

Unloadeda Overhead Multiplier (110%) Loaded

Technical $35.26 2.1 $74.05

Managerial $42.70 2.1 $89.67

Clerical $16.71 2.1 $35.09

a Unloaded labor rates from U.S. Department of Labor, Bureau of Labor Statistics,

Occupational Employment Statistics, May 2013 National Industry-Specific Occupational

Employment and Wage Estimates, NAICS 999200 - State Government, excluding schools

and hospitals (OES Designation) <http://www.bls.gov/oes/2013/may/naics4_999200.htm>

Recordkeeping/Reporting Supplies (Annual O&M Costs) a

Supply Item Price/ 

Item

No./ 

Resp.

No. of 

Resp. Total

File cabinet to store hard copy records $235 1 47 $11,045

Electronic data storage device $500 1 47 $23,500

Miscellaneous annual supplies $500 1 47 $23,500

Average Annual Cost $58,045

a Costs based on estimates initially prepared for 40 CFR part 60, subpart TTTT.
20

Exhibit 1c. Summary of Respondent Burden and Cost of Reporting and Recordkeeping Requirements,

Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units

(40 CFR Part 60, Subpart UUUU)

Summary of Respondent Burden and Cost

Totals

Annual Labor 

Burden 

(Hours)

Annual

Labor Costs

Annualized

Capital 

Costs

Annual

O&M

Costs

Total 

Annualized 

Costs

Total Annual 

Respondent 

Costs

Lower Bound Estimates

3-Year Total 1,515,444 $107,286,576 $0 $174,135 $174,135 $107,460,711

Average Annual 505,148 $35,762,192 $0 $58,045 $58,045 $35,820,237

Average Annual per Respondent a41,027 $2,904,345 $0 $1,235 $1,235 $2,905,580

Upper Bound Estimates

3-Year Total 2,462,052 $174,285,180 $0 $174,135 $174,135 $174,459,315

Average Annual 820,684 $58,095,060 $0 $58,045 $58,045 $58,153,105

Average Annual per Respondent

b

73,891 $5,230,379 $0 $1,235 $1,235 $5,231,614

a Equal to average annual estimate for each burden item in Exhibit 1a divided by the number of respondents in Exhibit 1a for that burden item, summed for all burden items.

b Equal to average annual estimate for each burden item in Exhibit 1b divided by the number of respondents in Exhibit 1b for that burden item, summed for all burden items.

Summary of Responses

Information Collection Activity

Occurrence 

per 

Respondent

Respondents Total

Responses

Average 

Annual

Lower Bound Estimates

REPORT REQUIREMENTS

 Initial submittal 1 47 47

 Progress report 1 47 47

 Final individual plan 1 39 39

 Final multi-state plan 1 1 1

 Negative declaration 1 2 2

3-Year Total Responses 136

Average Annual Number of Responses = 45.3

Average Annual Responses per Respondent = 0.9

Average Annual Hours per Response = 11,143

Upper Bound Estimates

REPORT REQUIREMENTS

 Initial submittal 1 47 47

 Progress report 1 47 47

 Final individual plan 1 39 39

 Final multi-state plan 1 1 1

 Negative declaration 1 2 2

3-Year Total Responses 136

Average Annual Number of Responses = 45.3

Average Annual Responses per Respondent = 0.9

Average Annual Hours per Response = 18,103
21

Exhibit 2a. Burden and Cost to the Agency, Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility

Generating Units (40 CFR Part 60, Subpart UUUU)

Activity

(A)

Hours/

Occurrence

(B) 

Occurrences/

Facility/

Year

(C)

Hours/ 

Facility/

Year 

(A x B)

(D)

Facilities/ 

Year

(E)

EPA Total 

Hours/

Year

(C x D)

(F)

EPA Technical 

Hours/ Year

(E x 0.79)

(G)

EPA

Managerial

Hours/Year

(E x 0.09)

(H)

EPA

Clerical

Hours/ Year

(E x 0.12)

(I)

Cost, $

1. SUPPORT/OUTREACH

EPA Headquarters a,b 434 1 414 40 17,368 13,721 1,563 2,084 $1,064,984 

EPA Regions b,c 475 1 452 40 18,980 14,994 1,708 2,278 $1,000,313 

2. REPORT REVIEW g

Review negative declarations h1 1 1.0 0.7 0.7 0.5 0.1 0.1 $35 

Review progress reports i100 1 100 15.7 1,567 1,238 141 188 $82,569

Coordination on submitting individual plans j160 1 160 13 2,080 1,643 187 250 $109,623

Coordination on submitting multi-state plan k320 1 320 0.3 107 84 10 13 $5,622 

Review notifications of public hearings on plans l2 1 2.0 15.7 31 25 2.8 3.8 $1,651

Review certifications that public hearings on plans

conducted according to subpart B procedures l 2 1 2.0 15.7 31 25 2.8 3.8 $1,651

Review/approve plans b,m1,040 1 1,040 13.3 13,867 10,955 1,248 1,664 $730,822

AVERAGE ANNUAL LABOR BURDEN AND COST 54,031 42,685 4,863 6,484 $2,997,270

AVERAGE ANNUAL OTHER DIRECT COSTS

 Miscellaneous cost (e.g., telephone, photocopies, postage) $1,000

TOTAL AVERAGE ANNUAL COST (Average Annual Labor Cost + Average Annual Other Direct Costs) $2,998,270

a Assumes 8.35 FTEs per year to oversee the entire program and help with outreach/state/enforceability questions and regional assistance, divided by the total number of respondents.

b

Includes those 39 states expected to develop individual state plans and 1 multi-state carbon management program expected to develop a multi-state plan for 8 states, for a total of 40.

c Assumes 36.5 hours per week of outreach per EPA Region, divided by the total number of respondents.

d One-time activities, averaged over the 3-year ICR period.

e

Includes the 1 state and District of Columbia without EGUs expected to submit a negative declaration, averaged over the 3-year ICR period (2/3=0.7).

f Assumes 2.5 weeks to review each 2017 progress report; respondents include all 47 states submitting 2017 progress reports, averaged over the 3-year ICR period (47/3=15.7).

g Assumes 4 weeks to coordinate with states to advise on their development of individual plans and extension requests; respondents include these 39 states, averaged over the 3-year ICR period 

(39/3=13).

k Assumes 8 weeks to coordinate with RGGI representatives to advise on their development of a multi-state plan and extension request; respondent includes RGGI, averaged over the 3-year ICR period 

(1/3=0.3).

l

Includes all 47 states for which a state plan was developed (including individual RGGI states), averaged over the 3-year ICR period (47/3=15.7).

m Assumes 6 full months for EPA Regions to review each state plan, with some coordination with EPA Headquarters; respondents for this one-time activity averaged over the 3-year period (40/3=13.3).

EPA Staff Labor Rates

Labor Category Labor Rates (2013)

Unloadeda Overhead Multiplier (60%) Loaded

EPA Headquarters

Technical (Grade 13, Step 5) $38.92 1.6 $62.27

Managerial (Grade 15, Step 5) $54.10 1.6 $86.56

Clerical (Grade 9, Step 5) $22.57 1.6 $36.11

EPA Regions

Technical (Grade 12, Step 5) $32.73 1.6 $52.37

Managerial (Grade 15, Step 5) $54.10 1.6 $86.56

Clerical (Grade 7, Step 5) $18.45 1.6 $29.52

a Unloaded labor rates from U.S. Office of Personnel Management < http://www.opm.gov/oca/13tables/pdf/gs_h.pdf>
22

Other Direct Costs

Expense Item Cost a

Miscellaneous cost (e.g., telephone, photocopies, postage) $1,000

a Cost based on estimate initially prepared for 40 CFR part 60, subpart TTTT.
23

Exhibit 2b. Summary of Agency Burden and Cost, Carbon

Pollution Emission Guidelines for Existing Stationary Sources:

Electric Utility Generating Units (40 CFR Part 60, Subpart UUUU)

Totals Annual Labor 

Burden (Hours) Annual Costs

3-Year Total 162,094 $8,994,811

Average Annual 54,031 $2,998,270

Average Annual Agency Hour Burden per Response = 1,192

Average Annual Agency Cost Burden per Response = $66,138