1 **SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units **(40 CFR P**  **art 6 0**  **, S**  **ubpart 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 6 0 , Subpart UUUU).” A new information collection request (ICR) has been prepared in support of the guidelines being promulgated

. The EPA ICR tracking number is 2503.0 2
. 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 (CO 2 ), from existing electric utility generating units (EGUs) burning fossil fuel s, as well as emission guidelines for developing plans to attain these goals

. For purposes of th ese guidelines , fossil fuel

- fired EGUs include fossil fuel

- fired steam generating units , integrated gasification combined cycle ( IGCC ) units , and stationary combustion turbine s 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 beca use CO 2 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 s tates 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 s tates 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 f

ederal plan. The f

ederal plan is an interim action and will be automaticall y 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 performance2

period. Those s tates 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 CO 2 emission performance, compliance schedules, and affected sources (EGUs)

. Under the timing requirements provisions in the final guidelines , s tates 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

- ye ar 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 sub mitted in the second year to demonstrate ongoing progress in plan preparation. This action impose s no n ew 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 part s 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, respectivel y. 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 b y other regulatory programs during this period. The only respondents expected to incur new information collection burden are those s tates and tribal lands with one or more EGUs covered under this subpart. Of the 48 contiguous s tates 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

- s tate plan for the eight member s tates in th eir region that have EGUs covered under this subpart

. Without information to the contrary, plans from 41 states and one multi

- s tate region are assumed to be submitted by August 31, 2016 , unless a 2

- ye ar 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 been3 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

. Inaddition, 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, pro duction 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 reasonabl y 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 CO 2 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 CO 2 emission performance goals

. As noted previously , 41 states and one multi

- state region are expected to develop and submit their own plans, while th e three affected tribes are expected to rel y 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 level s and demonstrating how they will be achieved ; i dentif

ying emission standards and compliance requirements for each affected entity ; and specifying program implementatio n 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 impose s no new information collection burden on affected sources (EGUs ) during the first 3 years after final rule promulgation , beyond what those4

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 b y th ese guidelines is already collected and reported by other regulatory programs. Therefore, no duplication exists for the affected industry

. If a state p lan is disapproved, the respondent ( s tate ) can respond to EPA’s concerns and submit a revised plan. If an approvable p lan is not submitted by the state , the EPA will implement a f

ederal p lan that applies to existing sources in the s tate. As noted previousl y, 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 r egional office, until such time as the s tate or tribe is delegated this authority

. Therefore, no duplication exists for s tates and tribes

. 3 (b ) Public Notice Required Prior to ICR Submission to OMB This section is not applicable because this is a rule

- related IC R
. 3 (c) Consultations Th e June 2014 proposed rule and the Nov ember 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 reduci ng carbon pollution from existing power plants. From consumer groups to s tates 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 establi sh 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 s tate and tribal officials, “Building a Common Understanding: Clean Air Act and Upcoming Carbon Po llution 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 b y offering four national teleconference calls with representatives from s tates, 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 a gency

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

-pollution

standards

- 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/carbon

pollution

- standards. The EPA has received more than 2,000 emails offering input into the development of these guidelines.5

The a gency

has encouraged, organized, and participated in hundred s of meetings about CAA section 111(d) and reducing carbon pollution from existing power plants. Attendees at these various meetings have included s tates and tribes, members of the public, and representatives from multiple industries, labor leaders, environmental groups and other non

governmental organizations. The direct engagement has brought together a variety of s tates 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 a genc y’ 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 p roposal 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 a gency provided multiple opportunities for s tates to inform these guidelines . In addition, the EPA organized, encouraged and attended meetings to discuss multi

s tate planning efforts. The meetings provided s tate 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 s tates, including from s tates with a wide range of experience in reducing carbon pollution from power plants. The a gency has collected policy

papers from s tates with overarching energy goal s and technical details on the s tates’ electricity

sector. The a gency

has engaged, and will continue to engage , with all of the 50 s tates 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

pow er plants owned or operated b y 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 5 66 leaders of federall y recognized trib es . The letters provided information regarding the EPA’s development of emission guidelines for existing power plants and offe red 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 repres entatives from some of the 5 66 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 a6

summary of issues being explored by the a gency . In addition, the EPA held a series of listening sessions prior to development of th e June 2014 proposed rule and November 2014 supplemental proposal . Tribes participated in a session on September 9, 2013 with the s tate 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 th e June 2014 proposed rule , November 2014 supplemental proposal , and this final rule . The outreach efforts far ex ceeded what is required of the a gency

in the normal course of a rulemaking process , and the EPA expects that a dialog with s tates 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 s tates and tribes , to en sure a clear and common understanding of the role the s tates 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

- ye ar ICR period do no t include EGU facilities, and annual reports from states will be submitted after the 3

- ye ar IC R 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 b y 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 Re**  **quested** 4 (a ) Respondents/NAICS C odes The respondents that would be expected to incur new information collection burden under subpart UUUU are those s tates and tribal lands with one or more EGUs covered under this subpart. A s noted previously , an estimated 41 individual state plans and 1 multi

- s tate plan are7

expected to be submitted by August 31 , 2016 , unless a 2

- year extension is requested

. N egative declarations are expected from one s tate (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 rel y on the federal plan. The applicable North American Industry Classification System (NAI CS ) code is 999200 , “ State Government, excluding school s 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 b y these guidelines is already collected and reported by other regulatory programs (40 CFR parts 75 and 98). The onl y new information collection costs are for those s tates with one or more EGUs covered under this subpart. Respondents must make the following reports:

**Requirem ent**  **Guidelines Citation**  **by Section** P lan to implement and enforce emission guidelines 60. 5710 and 60.23(a) Negative declaration letter documenting there are no affected EGUs in the s tate that are covered under the emission guidelines 60.5710 Request for extension to deadline for submitting a plan (as part of plan submittal) 60.576 0 Report s documenting progress towards meeting the emission performance rate/ goal 60. 58 3 0 Notification of public hearing on the p lan 60.23(d) Certificatio n that public hearing on the p lan conducted according to subpart B procedures 60.23(f) State respondents must also keep the following records:

**Requirement Guidelines**  **Citation by Section**  Records of hourl y values for each affected source to support the calculation of the annual emission performance goal 60. 58 2 5 (c) Records of public hearing conducted on th e p lan 60.23(e) (ii) Respondent Activities The respondent activities required b y 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 progress8

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 hearing s 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 a gency , specificall y the EPA Headquarters and the EPA Regions, will incur burden associated with the reporting requirements for s tates, including: (1) providing support and outreach to s tates regarding the implementation of the emissi on guidelines and preparation of th e plans, (2) reviewing and approving th e plans, ( 3 ) reviewing negative declarations f rom s tates with no EGUs covered under the emission guidelines, (4 ) reviewing and approving extension requests, ( 5 ) reviewing notifications from s tates regarding public hearings on th e plans, and ( 6 ) reviewing certifications from s tates 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 b y s tates 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 b y the EPA :
 Id entification of affected EGUs covered b y the plan and all affected EGUs in the state that meet the applicability criteria in the emission guidelines, including an inventory of CO 2 emissions from affected EGUs during the most recent calendar ye ar for which data is available prior to the submission of the plan.  Id entification 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 CO 2 emission performance rates described in the emission guidelines.  If the plan includes state measures, the p lan 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.  Id entification of applicab le 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 f or state reporting to the EPA about plan implementation and progress , including information required under the emission guidelines

.9

 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 federall y enforceable plan upon approval b y 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

.  Id entification of CO 2 emission performance rates or equivalent statewide emission goals that the affecte d EGUs will achieved through implementation of the plan.  A demonstration that the affected EGUs covered by the plan are projected to achieve the CO 2 emission performance rates or CO 2 emission goals described in the emission guidelines

.  A demonstration that each affected EGU’s emission standard is quantifiable, non

duplicative, permanent, verifiable, and enforceable according to the emission guidelines

.  If the plan includes onl y emission standards on the affected EGUs to meet either the CO 2 emission performance rates or CO 2 emis s ion goals , the final plan submittal must include a demonstration, if necessary , that the standards will meet the CO 2 emission performance rates or CO 2 emis s ion 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 rel y upon renewable energy or demand

- side energy effi ciency

programs and projects; (3) a demonstration that the federally enforceable emission standards and state measures are sufficient to attain the CO 2 emission performance rates or CO 2 emission goal for the interim and final periods; (4) a CO 2 performance projection of the state measures that shows how the measures will achieve the future CO 2 performance at affected EGUs ; (5) a demonstration that the state measures will require affected EGUs to meet the CO 2 emission performance rate or rate
-based CO 2 emission goal (if applicable); and (6) a demonstration that combined state
- enforceable measures , along with any federally enforceable CO 2 emission standards, will achieve the state mass

-based CO 2 emission goal (if applicable)

.  The final plan submittal mus t 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 thoroughl y considered.10

 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) material s 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 CO 2 emission performance rates or CO 2 emission goals will be achieved b y affected EGUs under the plan; (3) materials supporting any calculations for CO 2 emission goal s 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 i s 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, a genc y officials participated in many m eetings with individual utilities , as well as meetings with electric utility associations. Specif

icall y, 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 onl y new EGUs are affected b y 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 b y th e 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 CO 2 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 parti cipants from organizations representing power producers, on June 17, 2011, to discuss the outreach materials, potential requirements of the planned rule s , 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.11

5 (d ) Collection Schedule The specific frequency

for each information coll ection activity within this request is shown in Exhibits 1a and 1b for the first 3 ye ars following promulgation of the emission guidelines

. **6. Estimating the Burden and Cost of the Collection**  Exhibit s 1a and 1b document the lower and upper bounds , respectivel y, of individual burdens for the reporting requirements applicable to s tates for the first 3 ye ars . The lower bounds account for states already having active energy efficiency programs in place f or achieving their emission performance goals , while the upper bounds do not account for existing energy efficiency program s . 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 c osts ( detailed in Exhibit 1 c )

.

**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 a gency

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 burd en over the 3

- year period of this I CR from these reporting requirements is estimated to range from approximately 505 ,000 to 821 ,000 hours per ye ar ( detailed in Exhibit 1 c ) . These hours are based on agency studies and background documents from the development of the regulation, a gency 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 techn ical 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

.12

6 (b ) Estimating Respondent Costs Respondent costs are ty

pically 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 IC R
. (i ) Estimating Labor Costs The average annual labor costs over the 3

- ye ar period of this I CR from these reporting requirements are estimated to range from approximately $ 35.8 to $ 58.1 million per year ( detailed in Exhibit 1 c )

. Labor rates and associated costs are based on Bureau of Labor Statistics (BL S) data

. Technical, managerial , and clerical average hourly rates for s tate government workers were based on the Bureau of Labor Statistics, Occupational Employ ment Statistics, May 20 1 3 National Industry

- Specific Occupation al Employ ment and Wage Estimates for s tate government (NAICS code 999200) . The s tate 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 cop y records, electronic data storage, and miscellaneous annual supplies ) (see Exhibits 1a and 1b)

. The average annual O& M costs associated with this I CR 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 b y the f ederal g overnment. Publication and distribution of the information are part of the Compliance Data S ys tem, with the result that no f ederal cos ts can be directly attributed to the ICR. Examination of records to be maintained b y the respondents will occur incidentally as part of EPA ’ s overall compliance and enforcement program, and, therefore, is not attributable to the ICR. The onl y costs to the f ederal government , specificall y the EPA Headquarters and the EPA Regions, under this IC R are those costs associated with the support and outreach to s tates; 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 present s the average annual a gency burden and cost estimates for the first 3 years after promulgation of the emission guidelines. Table 2 below contains a summary of the 3

- ye ar total and average annual a gency burden hours and costs ( detailed in Exhibit 2 b )

.13 **Table 2**  **. Summary of**  **Agency Burden**  **and Costs (3**  **- year period following final rule publication)**  **Year Total Annual Labor Burden (hours)**  **To tal Annual Labor Costs ($)**  3

- Year Total 162 ,000 $ 8.99 million Average Annual 54, 0 00 $ 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 201 2

- GS (accessed at http://www.opm.gov/oca/1 2 tables/pdf/gs_h.pdf). These rates were increased b y 60 percent to include fringe benefits and overhead. For EPA Headquarters staff, the l oaded labor rates are $ 62.27 per hour for technical (GS

- 1 3 , 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, S tep 5) , $86.56 per hour for managerial ( GS

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

- 7, Step 5 ). The a gency

cost estimates also include annual costs of $1,000 for miscellaneous administrative charges (e.g., telephone, photocopies, and postage) incurred during the first 3 ye ars after promulgation

. 6 (d ) Estimating the Respondent Universe and Total Burden and Costs. Forty- eight s tates , 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

- s tate plan for the eight member s tates in that region that have EGUs covered under this subpart. The total number of responses for the monito ring, 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

- ye ar ICR period is 45.3 per ye ar . The total labor burden over the 3

- ye ar IC R period is estimated to range from approximately 1.52 to 2.46 million person hours. The total labor costs over the 3

- ye ar 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 Exhibit s 1a and 1b for respondents and Exhibit 2a for EPA. The labor hours and costs are summarized in Exhibit 1 c for respondents and Exhibit 2b for EPA

. 6 (f ) Reasons for Cha nge 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, 1 00 to 18,100 hours per response. Burden means the total time, effort, or financial resources expended by14

persons to generate, maintain, retain, or disclose or provide information to or for a f ederal agency . This includes the time needed to review instructions; develop, acquire, install, and utilize technology

and systems for the purposes of collecting, validating, and verifyinginformation, processing and maintaining information, and disclosing and providing information; adjust the existing ways to compl y with any previously

appl icable 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 conduc t 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 6 0 are listed in 40 CFR part 9. **PART B** This section i s not applicable because statistical methods are not used in data collection associated with these guidelines

.15 ATTACHMENTS
Exhibit 1a. Lo wer Bound Respondent Burden and Cost of Reporting and Recordkeeping Requirements, Carbon Pollution Emission Guidelin es for Existing Stationary Sources: Electric Utility Generating Units (40 CFR P art 6 0 , S ubpart 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 P art 6 0 , S ubpart 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 P art 60, S ubpart UUUU) Exhibit 2a. Burden and Cost to the Agency , Carbon Pollution Emission Guidelines for Existing Stationary

Sources: Electric Utility

Generating Units (40 CFR P art 6 0 , S ubpart UUUU ) Exhibit 2b. Summary

of Agency

Burden and Cost , Carbon Pollution Emission Guidelines for Existing Stationary

Sources: Electric Utility

Generating Units (40 CFR P art 60, S ubpart 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 P art 60, S ubpart UUUU)

**Burden Item (A)**  **Hours/ Occurrence**  **(B)**

**Occurrences/ Respondent/**  **Year (C)** 

**Hours/ Respond**  **** **ent/Year (A x B)**  **(D)**

**Respond**   ** ents/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** 5 0 1 5 0 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 In dividual 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 i 1 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/recordk**

**eeping 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, c oordination between energy office and air office, energy ef ficiency programs liaison, modeling, data analysis , extension requests, and 2017 progress report s . 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 sta ff 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 Break**  **down of Respondents No.**  **Resp. Not**  **es** Total no. respondents 49 48 states , DC No. expected to submit negative declaration 2 VT , D C No. expected to submit plan a 47 47 states No. expected to submit individual plan a 39 39 states No. expected to submit multi

- state plan 1 Regional Greenhouse Gas I nitiative (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 201 3**  **)**

**Unloaded a**  **Overhead Multiplier**  **(110%) Loaded**  Technical $3 5.26 2.1 $ 74.05 Managerial $4 2.70 2.1 $89 .67 Clerical $16. 71 2.1 $35

. 0 9 a Unloaded labor rates from U.S. Department of Labor, Bureau of Labor Statistics, Occupational Employment Statistics, May 2013 National In dustry

- 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> **Recordk eeping/Reporting Supplies (Annual O&M Costs)**  **a Supply Item**  **Price /**  **Item N**  **o./ R** **esp .**  **N o. 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 1 b

. 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 P art 60, S ubpart UUUU)

**Burden Item (A)**  **Hours/ Occurrence**  **(B)**

**Occurrences/ Respondent/**  **Year (C)** 

**Hours/ Respond**  **** **ent/Year (A x B)**  **(D)**

**Respond**   ** ents/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 p lan In dividual 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 i 1 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/recordk**

**eeping 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, c oordination between energy o ffice and air office, energy efficiency programs liaison, modeling, data analysis , extension requests, and 2017 progress report s . 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, c oordination 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 Break**  **down of Respondents No.**  **Resp. Notes**  Total no. respondents 49 48 states , DC No. expected to submit negative declaration 2 VT , D C No. expected to submit plan a 47 47 states No. expected to submit individual plan a 39 39 states No. expected to submit multi

- state plan 1 Regional Greenhouse Gas I nitiative (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 201**  **3 )** 

**Unloaded a**  **Overhead Multiplier (110%)**  **Loaded** Technical $3 5.26 2.1 $ 74.05 Managerial $4 2.70 2.1 $89 .67 Clerical $16. 71 2.1 $35

. 0 9 a Unloaded labor rates from U.S. Department of Labor, Bureau of Labor Statistics, Occupational Employment Statistics, May 2013 National I ndustry

- Specific Occupational Employment and Wage Estimates, NAICS 999200

- State Government, excluding schools and hospitals (OES Designation) <http://www.bls.gov/oes/2013/may/naics4_99920 0.htm> **Recordk eeping/Reporting Supplies (Annual O&M Costs)**  **a Supply Item**  **Price /**  **Item N**  **o./ R** **esp .**  **N o. 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 P art 60, S ubpart 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 a 41,027 $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** In itial 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**  In itial 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 P art 60, S ubpart UUUU)
**Activity (A)**  **Hours/ Occur**  **** **rence (B)** 

**Occur**   ** rences/** **Facility/ Year**  **(C)**

**Hours/ Facility/**  **Year (A x B)**  **(D)**

**Facili**   ** ties/** **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 h 1 1 1.0 0.7 0.7 0.5 0.1 0.1 $35 Review progress reports i 100 1 100 15.7 1,567 1,238 141 188 $82,569 Coordination on submitting individual plans j 160 1 160 13 2,080 1,643 187 250 $109,623 Coordination on submitting multi

- state plan k 320 1 320 0.3 107 84 10 13 $5,622 Review notifications of public hearings on plans l 2 1 2.0 15.7 31 25 2.8 3.8 $1,651 Review certification s that public hearings on plans conduct ed according to subpart B procedures l 2 1 2.0 15.7 31 25 2.8 3.8 $1,651 Review/approve plans b, m 1,040 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 8.3 5 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 In cludes 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 , averag ed over the 3

- year ICR period

. e In cludes th e 1 state and District of Columbia without EGU s 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 In cludes 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 (201 3**  **) Unloaded**  **a 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/1 3 tables/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 P art 60, S ubpart 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 Age ncy Hour Burden per Response = 1,192 Average Annual Agency Cost Burden per Response = $66,138