**SUPPORTING STATEMENT**

**– INFORMATION COLLECTION REQUEST (ICR)**  **Federal Implementation Plans t o**  **Reduce Interstate Transport of Fine Particulate Matter and Ozone**  **( Final**  **Rule) 1.**  **0 I**  **dentification of the Information**  **C ollection**  **1.1 Title of the Information Collection**  Federal Implementation Plans to Reduce Interstate Transport of Fine Particulate Matter and Ozone , EPA ICR Number 239 1.0 2 , OMB Control Number 2060

-NEW
. **1.2 Short**  **Characterization/Abstract** The United States (U.S.) Environmental Protection Agency (EPA) is finalizing Federal Implementation Plans to Reduce Interstate Transport of Fine Particulate Matter and Ozone (Transport Rule) that will supersede the Clean Air Interstate Rule (CAIR) . It includes new reporting requirements , and combines these new requirements with existing requirements from the Emission Reporting Requirements for Ozone State Implementation Plan (SIP) Revisions Relating to Statewide Budgets for NO X Emissions to Reduce Regional Transport of Ozone (NO X SIP Call) and the Acid Rain Program (ARP) under Title IV of the C lean Air A ct (CAA) Amendments of 1990. Each of these existing requirements has an approved I CR in place
. The current I CRs are : CAIR ( EPA ICR Number 2152.04/OMB Control Number 2060
- 0570) , NO X SIP Call ( EPA ICR Number 1857.0 5 /OMB Control Number 2060
- 0445) and ARP ( EPA ICR Number 1633.15 /OMB Control Number 2060
- 0258)
. Thi s supporting statement and ICR are being submitted to account for the incremental burden associated with the Transport Rule (TR) as it supersedes CAIR beginning in 2012
. As such, this supporting statement references the burden anal ys is include d in EPA IC R Numbers 2152.0 4 , 1857.0 5 , and 1633.1 5 , and estimates the change in burden resulting from the TR beyond the scope of the existing IC Rs for the NO X SIP Call requirements and the Acid Rain Program
. The burden included in this ICR includes start

-up and capital costs for units newly affected b y an emissions trading program and/or whose reporting status has changed (e.g. , from ozone season only

to annual reporting) , annualized capital costs for units previously subject to the NO X SIP call requirement s or CAIR, as well as the incremental operation and maintenance costs for all TR
- affected units. Under the TR , the burden and costs accounted for under the CAIR ICR ( EPA ICR Number 2152.04) would no longer occur past 2011
. Instead, all those burdens and costs would be accounted for under this ICR as part of T R implementation. Inaddition to the state s and facilities li sted in the actual rule text, EPA h as included costs/burdens associated with TR ozone season
- affected unit s for the following s tate s: IA , KS, MI , MO, OK, and WI. The TR NO X O zone S eason Trading P rogram does not list these s tate s in the current rule package, however EPA propos es to add them as part of a future supplemental rule package to the Transport Rule
. Inanticipation of this rul emaking, the costs/burdens associate d with these facilities are included in the ICR to allow for a full accounting of the TR program at maturity. See Appendix A for a separate breakout of the cost/burdens associated with these f acilities. In the event that some or all of these s tate s are not included in the future rulemaking, EPA will amend this ICR accordingl y.Transport Rule ICR May 9, 2011

2 EPA has publish ed a Notice of Proposed Rulemaking in the Federal Re gister that detail s the additions and changes to reporting requirements associated with the TR
. These changes can be logically

divided in to two categories: ( 1 ) changes to existing requirements for emission reporting under the previous CAIR and NO X SIP Call , and ( 2 ) the addition of reporting requirements to support emissions trading and compliance in s tates covered by the TR
. Throughout this Supporting Statement, the burden anal ys is associated with these two categories will be discussed sequentially as " Emission Reporting Requirements " and " Emission Trading Requirements. " **Emission Reporting Requirements** Taken together, the existing emission reporting requirements under CAIR, the Acid Rain Program , and the previous NO X SIP Call cover many of the same sources and have similar or identical emission reporting requirements as the TR
. The incremental burden imposed by the TR in general is described below. First, sources located in Georgia and Texas are now required to report NO X emissions during the five

- month ozone seaso n, in addition to the existing requirement for reporting emissions for the full year . These states are not among the 21 s tates previously subject to the NO X SIP Call or the 26 state s subject to CAIR ozone season (CAIROS) reporting and as a result, these changes will require sources to modify DAHS reporting software. Second, sources located in Mississippi, Florida, and Louisiana , which under CAIR were required to report NO X and SO 2 emissions annually , are now onl y required to rep ort NO X for the TR ozone season . This requirement would not impose any additional start - up/ capital burden on s tate s, and is a reduction in reporting for sources subject to CAIR
. Third, sources located in Kansas, Minnesota , Nebraska, and Oklahoma are now affected under the TR. Specifically , sources in Minnesota and Nebraska are subject to TR NO X and SO 2 annual reporting, sources in Oklahoma are subject to TR NO X o zone season reporting, and sources in Kansas are subject to both the TR NO X and SO 2 annual and NO X o zone season reporting requirements. These sources were not previously subject to CAIR or the NO X SIP Call , and will need to install and operate CEMS (or an approved alternative) and meet 40 CFR p art 75 requirements for NO X and SO 2 , as applicab le. Fourth, sources located in Alabama, Illinois, Iowa, Indiana, Kentucky , Maryland, Missouri, Michigan, New Jersey , New York, North Carolina, Ohio, Pennsylvania, South Carolina, Tennessee, Virginia, West Virginia, and Wisconsin will continue to monitor and report NO X and SO 2 emissions on a year round b asis under the TR as currentl y required under CAIR. Sources located in Arkansas will , under the TR, continue to report for the o zone season only as currentl y required under CAIR.Transport Rule ICR May 9, 2011

3 **Emission Trading Requireme nts**  For this ICR, it is assumed that each s tate will eventually either adopt , in whole or in part, the relevant TR SO 2 , NO X annual , and /or NO X ozone season trading rules . Initiall y, however, EPA will administer the program s under the Federal Implementation Plan s (FIP) promulgated at 40 CFR Part 97. The trading program burden would include the paperwork burden related to (1) transferring and tracking allowances; ( 2 ) permitting; ( 3 ) annual year end compliance ; and (4 ) monitoring and reporting starting in 2014
. The monitoring and reporting requirements of a trading program will require capital and labor expenditures by industry , and these are evaluated , as are labor expenditures accrued by states and EPA, in managing the trading programs. Similar to the ARP , the NO X SIP Call , and CAIR , the ability to buy and sell (or transfer) allowances is expected to provide some economic benefits
. Allowance trading cannot be implemented, however, unless regulations governing emissions monitoring and permitting of sources are in place as well
. To ensure compliance with the state - specific e mission reduction requirements and to provide the consistency needed to foster the allowance market, the designated representative s of the owners and operators of each source with affected units are required to have TR requirements integrated into their Title V permits for the affected source and to certify that an approved NO X and SO 2 emissions monitoring system has been installed and is properl y operated at each affected unit. Emissions data reported under 40 CFR part 75 by TR
affected sources is also relied upon in part b y the Agency in determining allowance allocations to such TR

- affected sources. While many

sources have already

installed the necessary

emissions monitoring equipment due to requirements under other regulations, some sources will need to install new monitors or upgrade existing monitors. Capital costs also usually include the cost of initial certification of new or upgraded monitors , and this is included as part of start

-up costs. Capital costs addressed b y this ICR include costs borne by newly affected units under the TR and annualized capital costs for existing CAIR or NO X SIP Call units that are not subject to the ARP
. Emi ssions monitoring and reporting b y sources in the trading program s is fundamental to the allowance trading s ys tem and compliance with the TR
. EPA will use the data contained in the reports to verify

actual emissions
. Without accurate monitoring and reporting of emissions , the integrity of the allowance system would be undermined, and there would be no assurance that emissions had been reduced
. To meet the emission s monitoring, recordkeeping and reporting requirements, affected units are required to : ( 1) submit a monitoring plan and certification reports for each monitoring s ys tem, (2) record hourly emissions data, and (3) submit reports of their emissions and operating data to EPA
. All sources affected by the TR will be required to monitor and repo rt NO X and/or SO 2 emiss ions in accordance with 40 CFR p art 75
. Sources with monitors already certified under 40 CFR part 75 may be exempt from initial certification requirements. All participants in the Allowance Management S ys tem (AMS) are required to eithercomplete and submit an allowance transfer form for each allowance transfer , or to perform the transfer on

- line
. Part icipants in AMS that are not covered sources, such as allowanceTransport Rule ICR May 9, 2011

4 brokers, fuel suppliers , and environmental groups are also required to file a onetime account information application to establish accounts in AMS
. **2. 0**  **N eed**  **for and U**  **se of**  **the C**  **ollection 2.1**  **Need/Authority for the Collection** Emissions data are of vital importance to the EPA for fulfilling a host of monitoring, standard

- setting, rulemaking, reviewing, and reporting duties
. Section 110(a)(2)(D) of the CAA, often referred to as the “good neighbor” provision of the Act, requires states to prohibit certain emissions because of their impact on air quality in downwind states. Specifically , it requires all states, within 3 years of promulgation of new or revised NAAQS, to submit SIPs that prohibit certain emissions of air pollutants because of the impact they would have on air quality in other states. This action addresses the requirement in section 110(a)(2)(D)(i)(I) regarding the prohibition of emissions within a state that will significantly contribute to nonattainment or interfere with maintenance of NAAQS in any other state. EPA has previously issued two rules interpreting and clarifying the requirements of section 110(a)(2)(D)(i)(I). The NO X SIP Call, promulgated in 1998, was largel y upheld b y the U.S. Court of Appeals for the D.C. Circuit in Michigan ( 213 F.3d 663 ) . CAIR, promulgated in 2005, was remanded by the D.C. Circuit in North Carolina ( 531 F.3d 896 ) , and modified on rehearing , ( 550 F.3d. 1176 ) . These decisions provide additional guidance regarding the requirements of section 110(a)(2)(D)(i)(I) and are discussed later in this notice. Section 301(a)(1) of the CAA also gives the Administrator of EPA general authority to prescribe such regulations as are necessary to carry out her functions under the Act , 42 U.S.C. § 7601(a)(1). Pursuant to this section, EPA has the authority to clarify the applicability of CAA requirements. In this action, among other things, EPA is clarifying the applicability of section 110(a)(2)(D)(i)(I) b y identifying NO X and SO 2 emissions that must be prohibited with respect to the PM 2.5 NAAQS promulgated in 1997 and 2006 and the 8

- hour ozone NAAQS promulgated in 1997. In addition, section 110(k)(1)(A) calls for the Administrator to establish criteria for determining whether SIP submissions are complete , 42 U.S.C. sec. 7410(k)(1)(A). Among other things, this action helps to clarify what SIP submissions must contain to address the requirements of section 110(a)(2)(D)(i). Section 110(c)(1) of the Act also requires EPA to act in certain circumstances where state SIP deficiencies exist, regardless of the reason for the deficiency . EPA action may be required even if the SIP deficiency is not in any way the fault of the affected state, such as, for example, if the deficiency

is caused by

factors beyond the state’s control. Specifically, section 110(c)(1) requires the Administrator to promulgate a FIP at any time within two ye ars after the Administrator finds that (1) a s tate has failed to make a required SIP submission ; or (2) a SIP submission is incomplete ; or (3) the Administrator disapproves a SIP submission . The Administrator must promulgate a FIP in the above

- described scenarios unless the s tate corrects the deficiency

and the Administrator approves the SIP revision before the Administrator promulgates the relevant FIP
. 42 U.S.C. sec. 7410(c)(1).Transport Rule ICR May 9, 2011

5 **2 .2**  **Practical Utility/Users of the Data Emission Reporting Requirements**  Emission s data and related information on stationary point and nonpoint sources, as well as nonroad mobile and onroad mobile sources, are routinely used by OAP, OAQPS, and the EPA Regio nal Offices in carrying out a variety of activities
. These activities support regulatory functions as well as functions that are more programmatic in nature such as trends anal ys es . Such projects include:

● Evaluation of existing control strategies, such as the NO X SIP Call, for s tates and larger areas;
● Evaluation of proposed control strategies for s tates and larger areas, including applications of regional scale models;

● Development of national control strategies and preparation of Regulatory Impact Analyses (RIA s );

● Preparation and publication of national summaries of emissions , including trend anal ys es;
● As a data

base to assist in the identification of important source categories for future regulation; and

● Preparation of the stationary source portion of a report to Congress on SO 2 emissions
. This report is required b y Section 406 of the CAA and is due on a five ye ar cycle that began on January

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

data component in the application of regional scale models
. The EPA ' s Regional Offices use emission and other source parameters to support source inspections and in the anal ys es of the impact of new or modified sources within an area
. EPA ' s Emission Factor and Inventory Grou p (EFIG) use the data to assess and analyze trends in criteria pollutant emissions over time. In addition to supporting projects and initiatives internal to EPA, both OAQPS , and the Regional Offices respond to numerous requests for reports on emission s from sources . Ty picall y this is done under the Freedom of Information Act
. Most requests come from contractors and consultants involved in special studies; a smaller number come from the press, universities , and others involved in research. The collecti on of emissions data specific to nonattainment areas for certain criteria air pollutants is necessary

to comply

with requirements specified in Title I of the CAA
. States withTransport Rule ICR May 9, 2011

6 nonattainment areas rel y on current emissions informati on from point, nonpoint, and mobile sources to revise their SIPs and to plan for emission reductions mandated by the CAA
. In addition, a s tate - wide inventory compiled at least every three ye ars for all point, nonpoint, and mobile sources is considered to be a key tool to assist s tates in meeting CAA requirements that address emissions tracking, compliance issues, and mid

- course adjustments
. State
- wide emission inventories can be used b y s tates affected by pollution transport from upwind areas to develop more efficient control strategies to meet NAAQS
. State
- wide emission inventories that were developed b y EPA (the N ational Emissions Inventory , or NEI) are being used by the Regional Planning Organizations (RPOs) as the starting point for the development of s tate - wide emission inventories used in the regional haze program to define control strategies. **Emission Trading Requirements** Permit applications, including proposed compliance plans, are us ed b y s tates and EPA to issue operating permits
. A permit application is legall y bindin g on the owners, operators, and designated representative of a source until the permit is issued
. Affected sources rely on the permit for information regarding the applicable requirements with which they must compl y . Because permit applications and permits are public documents, they may be used by

the public to examine activities undertaken b y affected sources. Accurate data from emissions monitoring under 40 CFR part 75 is indispensable to successful implementation of the trading programs for two reasons:
● Accurate emissions data is integral in EPA and state assessment of the impact of the trading programs in reducing NO X and SO 2 emissions, and therefore in assisting s tates in meeting the ozone and fine particulate matter NAAQS. By reducing leve ls of NO X and SO 2 emissions, the trading programs reduce the adverse effects of the transport of ozone, ozone precursors , and fine particles from upwind s tates
. ● EPA enforce s the program (in part) by comparing emissions data measured, recorded, and reported under 40 CFR part 75 from affected sources with the number of allowances held in the respective compliance accounts of such affected sources
. In formation collected on allowance transfers is used by EPA to track allowances for the purpose of determining compliance with the NO X and SO 2 trading p rograms . In formation on allowance transfers is also used by participants in the allowance market and the public to evaluate the activities of affected sources, and b y EPA for program evaluation. Together, the AMS , operating permits, and emission s data help to provide the accountability

to allow the NO X and SO 2 trading p rograms to function without more stringent command and control approaches.Transport Rule ICR May 9, 2011

7 **3. 0**  **N onduplication**  **, C onsultations**  **, and Other**  **C ollection**  **C riteria**  **3 .1**  **Nonduplication Emission Reporting Requirements**  EPA will allow the direct reporting of point source data from sources to EPA to satisfy the requirement for s tates to report such data if the sources are subject to the monitoring and reporting requirements of 40 CFR p art 75. The direct reporting of data from sources to EPA will minimize the reporting burden on s tates. Also, direct reporting will avoid duplication of effort for sources subject to 40 CFR part 75 requirements. **Emission Trading Requirements**  Reporting requirements for affected sources for the TR NO X and SO 2 trading p rograms are integrated with existing reporting formats under 40 CFR part 75
. The se reporting formats are currentl y used by ARP
- affected units under Title IV of the Act , as well as by CAIR
- affected units. Thus, for units subject to Acid Rain or TR quarterl y reporting requirements, or both, only one submission will need to be made on a quarterly basis
. ( CAIR trading program reporting will be superseded b y TR reporting.) **3.2 Public Notice Required Prior to ICR Submission to OMB**  The preamble to the proposed rule w as provide d to the public with notice of and the opportunity

to comment on this ICR. **3 .3**  **Consultations Emission Reporting Requirements**  During the development of CAIR, discussions were held with the National Association of Clean Air Agencies (NACAA) to clarif y EPA ' s logic in developing the emissions reporting requirement s contained within the rule and to answer questions. Information ari s ing from those discussions, as well as the decision handed down in the North Carolina v. EPA court case related to CAIR (531 F.3d at 908) , were taken into consideration when developing the TR emission reporting requirements
. **Emission Trading Requirements** The requirements for the TR have been developed using the methodology found in existing trading programs , consultations with interested parties , and reflections on the decision handed down in the North Carolina court case (531 F.3d at 908)
. EPA modified the cap and trade strategy

used in the ARP , Ozone Transport Commission ' s NO X Budget Program, and the NO X SIP Call to address the court ' s concerns related to " emissions from sources that contributeTransport Rule ICR May 9, 2011

8 significantl y and interfere with maintenance " in another s tate
. North Carolina (531 F.3d at 908). This resulted in the development of an unlimited intrastate and limited interstate trading program based on state

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

uctions necessary

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

manner, data collected less frequentl y would be of little or no use. Quarterl y collections of emissions data allows for frequent checking of data for errors and provide s rapid feedback to industry of needed adjustments to data collection systems, thereb y promoting more accurate and reliable emissions data
. Also , existing federal and s tate emission monitoring programs often require quarterly reporting, or in some cases, monthly
. Less frequent collection, such as semi

- annuall y or annually , would increase the amount of preparation and review time at the end of the reporting period both for regulated sources and for EPA , and would slow down the process of compliance determination
. **3 .5**  **General Guidelines** This ICR does not violate any of OMB ' s guidelines for information collections. **3 .6**  **Confidentiality** Any data that is submitted to EPA under this rule will be considered in the public domain and cannot be treated as confidential.Transport Rule ICR May 9, 2011

9 As required b y Section 114 of the CAA , estimates or measurements of emissions must be treated as non

- confidential
. Under Agency procedures, data items relating to the computation of emissions may

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

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

ederal and s tate requirements are inconsistent, the appropriate EPA Regional Office should be consulted. **3 .7**  **Sensitive Questions** This information collection does not ask any questions concerning sexual behavior or attitudes, religious beliefs, or other matters usually considered private. **4. 0**  **T he**  **R espon**  **d e**  **n ts**  **and the**  **I nformation**  **R equested**  **4.1 Respondents/Standard Industrial Classification (SIC) Codes**  **Emission Reporting and**  **Trading Requirements**  This ICR estimates a burden for affected industry sources to monitor NO X and SO 2 mass emissions and demonstrate compliance with NO X and SO 2 control measures
. Sources report data directly to EPA as required to meet the monito ring and reporting requirement s of 40 CFR p art 75
. This rule affects large el ectric utility sources which are generall y classified as either SIC 4911
- Electric Services, or 4931
- Electric and Other Services Combined [NAICS 221112 Electric Power Distribution]. **4.2 Information**  **Requested Emission Reporting Requirements**  The ARP and NO X SIP Call established the basic emission reporting requirements
. CAIR modified these requirements and the TR would continue to implement the changes included in the CAIR requirements such that th e previously accounted for reporting burden would also change
. Only the incremental changes to the ARP and NO X SIP Call reporting requirements that would change reporting burden are discussed here. **Emission Trading Requirements** This section describes the data items requested from affected sources for the collections described in this ICR
. This section also defines the activities in which respondents must engage to assemble, submit, or store these data items. (i) Data Items, Including Recordkeeping Requirements (a) Allowance TrackingTransport Rule ICR May 9, 2011

10 There are several data items required for allowance tracking activities
. For each affected source , the designated representative must submit a certificate of representation
. Under 40 CFR §§ 97.41 6 , 97 .51 6 , 97. 61 6 , and 97.716 , a complete certificate of representation include s :
● Id enti fication of the source and unit;

● Dates on which the unit commenced commercial operation;

● Name and contact information for the TR designat ed representative and alternate (if applicable) ;
● A list of the owners and op erators of each unit; and

● A certification statement and signature of the TR designated representative and alternate (if applicable)
. Certification applications are to be kept for a period of five ye ars pursuant to the general requirements imposed for Title V permitted facilities. Second, sources and other trading program participants must submit allowance transfer, allowance deduction, and compliance assurance information, as necessary.

(b) Permitting The basic requirement for permitting is an application for a permit revision to a source ' s operating permit issued under Title V of the Act
. Although there is some possibility that a non

Title V source could be affected under the TR , all TR
- affected sources are assumed to be Title V sources for purposes of this I CR
. It is assumed the permit revision application and all other monitoring, reporting , or recordkeeping requirements associated with Title V permitting are either part of the baseline Title V requirements or are covered separatel y under section 4(c)
. Title V permit applications must be kept for five years pursuant to Title V recordkeeping requirements
.

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

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

the designated representative of th e facility attesting to the accuracy , truthfulness,Transport Rule ICR May 9, 2011

11 and completeness of the submission
. Generally , all monitoring records are required to be kept for three ye ars. (ii) Respondent Activities The primary

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

**– A**  **gency A**  **ctivities ,**  **C ollection Methods**  **, and**  **I nformation Management**  **5.1 Agency Activities**  **Emission Reporting Requirements** The EPA activities associated with the rule include:

● Receiving, reviewing, and storing emission inventory data submitted by

each source ;
● Processing and updating data submitted by sources , including performing quality assurance of data, and coordination of efforts to resolve errors and anomalies; and

● Fulfilling information requests. **Emission Trading Requirements** The major EPA activities related to the TR include (1) allocation of allowances to affected units, (2) maintenance and administration of the NO X and SO 2 Allowance Management System , ( 3 ) reviewing and processing certificates of representation, (4) reviewing permit applications, (4 ) reviewing monitoring plans and certification applications, ( 5 ) processing, reviewing , and evaluating reports of quarterl y emission s data from affected units, ( 6 ) calculating/reviewing annual emissions from affected sources , and aggregating such annual emissions for compliance assurance purposes , and ( 7 ) reviewing total annual emissions data submitted to track each s tate ' s progress toward meeting its budgets and creating a summary report of emissions. EPA use s a computer system to track and maintain monitoring and emissions information , and will also answer respondent questions and conduct audits of data submissions.Transport Rule ICR May 9, 2011

12 **5 .2**  **Collection Methodology and Management Emission Reporting Requirements**  The EPA has establish ed a central repository of inventory

data for all s tates termed the National Emissions Inventory (NEI) database
. Emissions inventory data reported electronicall y is stored in the NEI database and us ed b y the EPA and by s tates for air modeling, tracking progress in meeting CAA requirements, setting policy , and answering questions from the public. The EPA has created and maintains the NEI database as a central repository of inventory data for all s tates, but the data must be supplied b y the s tates in an electronic form at
. The EPA currentl y requires that s tates use the Consolidated Emissions Reporting Schema (CERS) for electronic data reporting (EDR). **Emission Trading Requirements** To ensure consistency

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

will rely on these electronic means to disseminate information about the TR as the program is implemented. **5 .3**  **Small Entity Flexibility Emission Reporting**  **and Trading Requirements**  The TR applies to fossil fuel

- fired units (stationary boilers and combustion turbines) that serve an electrical generator with nameplate capacity greater than 25 MWe
. Units with a lower capacity ( such as those with an annual generating capacity of less than four million kWh) are not subject to the TR because of the high cost of monitoring emissions from these sourc es and the de minimis nature of their emissions. Inaddition, some cogeneration units and solid waste incinerators are exempt from the TR if they me et certain criteria. The low mass emissions provisions under 40 CFR 75.19 provide for optional reduced monitoring, quality

assurance, and reporting requirements for units that combust natural gas and/or fuel oil . Such units must emit no more than 100 tons of NO X annually , 50 tons of NO XTransport Rule ICR May 9, 2011

13 during the ozone season (May 1

– September 30) , 25 tons of SO 2 annuall y , and calculate no more than the se same amount s based on specified procedures for calculating and reporting emissions
. Units that qualify are exempted from certain requirements to install and operate monitoring equipment, conduct fuel sampl ing, and perfo rm quality assurance or quality control tests
. Moreover, emissions reporting requirements are significantl y simplified for these units. G as - or oil

- fired unit s that do not qualify for the low mass emissions unit p rovisions under 40 CFR part 75 may still meet criteria that allows for the use of alternative methods to measure emissions
. As discussed in the Regulatory Impact Anal ys is of the final ARP regulations (October 19, 1992), smaller utilities are more like ly to be dependent on these oil

- and gas

- fire d units, especially

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

under the TR is on a quarterly basis. All affected industry sources will use ECMPS to submit monitoring plan, quality assurance, certification test, and emissions data to EPA quarterl y . In addition, the TR requires the collection of allowance trading information as transfers are submitted , as well as information regarding other " event " submissions made on a one - time or annual basis
. **6. 0**  **E stimating**  **the B**  **urden and**  **C ost**  **of the C**  **ollection 6.1**  **Estimating Respondent Burden Emission**  **Reporting and Trading Requirements**  This section estimates the paperwork burden and cost of submitting permit applications, certificates of representation, allowance tracking and transfer materials , ye ar- end compliance activities , submittal of monitoring plans, obtaining certification of each monitoring s ys tem, conducting monitor quality assurance activities, and recording and reporting data from CEM systems (or app roved alternatives). To estimate the burden and/or cost of each requirement, EPA utilized prior estimates of the costs of activities, estimates provided by affec ted utilities in comments to the Agency , and /or estimates base d on the Agency' s experience in implementing existing trading programs. For the purposes of this analysis, the trading sources are grouped into the following categories:

● Trading units located in SO 2 Group 1 ( Georgia, Illinois, Indiana, Iowa, Kentucky , Michigan, Missouri, New York, North Carolina, Ohio, Pennsylvania, Tennessee, Virginia, West Virginia, and Wisconsin) ;
● Trading units located in SO 2 Group 2 (Alabama, Kansas, Maryland, Minnesota, Nebraska, New Jersey , and South Carolina);Transport Rule ICR May 9, 2011

14 ● Trading units located in a TR NO X Annual state (Alabama, Illinois, Iowa, Indiana, Kentucky, Maryl and, Missouri, Michigan, New Jersey , New York, North Carolina, Ohio, Pennsylvania, South Carolina, Tennessee, Virginia, West Virginia, Wisconsin, Georgia, Texas, Kansas, Minnesota, and Nebraska);and

● Trading units located in a TR NO X ozone s tate
. The TR requires all affected sources to monitor their NO X emission rate, SO 2 emission rate , and heat input in order to determine NO X mass emissions and SO 2 mass emissions
. Coal

fired units use NO X , SO 2 , and flow CEMS to meet those requirement s. Oil and gas units have alternatives. For SO 2 , these units can use fuel sampling and analysis (or an SO 2 default factor for pipeline natural gas) combined with a fuel flowmeter. In addition, peaking units that burn natural gas and/or fuel oil may use an alternative method for calculating NO X emission rates
. EPA will also allow certain low mass emissions units to use assumed emissions factors together with operational data to calculate emissions. For purpo ses of thi s ICR, burdens and costs are calculated only in terms of incremental impacts for units located in TR s tates or subject to the ARP
. Under the TR , and for purposes of this ICR, the incremental ozone s eason burdens were limited to GA, KS, MN, NE, O K, and TX
. Several states in the NO X SIP Call region are excluded from the TR ' s NO X O zone S eason Trading P rogram : CT, DC, DE, and MA
. Similarly , units sub ject to the ARP already have much of the monitoring and reporting capability required under the TR
. Finall y, sources not subject to the TR could still have existing requirements for CEMS in some cases
. Thus, it should be noted that the labor hour s and cost estimates per unit identified in this document represent the weighted average burden and cost for all units and do not represent the actual burden and cost for a particular unit
. See the following table for a grap hical reference of s tate reporting classifications related to CAIR, the NO X SIP Call, and the TR
.Transport Rule ICR May 9, 2011

15 **Table 6 -**  **1 :**  **State Reporting Classifi cations for the NO**  **X SIP Call, CAIR, and**  **the TR**

**State NO**  **X SIP Call** 

**Ozone CAIR** 

**Ozone CAIR** 

**Annual (NO**  **X & SO**  **2 )**  **TR Ozone**  **TR Annual**  **(NO X**  **& SO 2** **) No Change in Classification**  Arkansas X X Alabama X X X X X Illinois X X X X X Iowa X X X X Indiana X X X X X Kentucky X X X X X Maryland X X X X X Missouri X X X X X Michigan X X X X X New Jersey X X X X X New York X X X X X North Carolina X X X X X Ohio X X X X X Pennsylvania X X X X X South Carolina X X X X X Tennessee X X X X X Virginia X X X X X West Virginia X X X X X Wisconsin X X X X **Annual Reporters with Ozone Status Changes** Georgia X X X Texas X X X (cont.)Transport Rule ICR May 9, 2011

16 **Table 6 -**  **1 :**  **State Reporting Classifications for the NO X**  **SIP Call, CAIR, and the TR**  **(cont.)**

**State NO**  **X SIP Call** 

**Ozone CAIR** 

**Ozone CAIR** 

**Annual (NO**  **X & SO**  **2 )**  **TR Ozone**  **TR Annual**  **(NO X**  **& SO 2** **) Now Ozone**  **- Only**  Mississippi X X X Florida X X X Louisiana X X X **New States** Kansas X X Minnesota X Nebraska X Oklahoma X **States No t Covered under the**  **TR** Connecticut X X Delaware X X X District of Columbia X X X Massachusetts X X The following discussion highlights some of the basic differences for the categories of units
. Included in this discussion is the consideration of monitoring and reporting that is done by many of th ese sources under the ARP and CAIR Program s . Trading units in NO X/ SO 2 annual and ozone season states, in NO X/ SO 2 annual

- only s tates in the CAIR region , or which report for the ARP , will hav e the smallest incremental burden with regard to monitoring and reporting
. Acid Rain

- affected units are already m onitoring and reporting both NO X and SO 2 emissions on a year round basis and will not incur additional burdens (or capital , operating , and maintenance costs) as a result of the TR since they have already installed and are operating a CEMS (or approved alternative) and meet 40 CFR part 75 requirements for both NO X and SO 2 . Similarly, CAIR annual units will not incur any additional capital costs as they

have already installed and operate a CEMS (or approved alternative) and meet 40 CFR part 75 requirements for both NO X and SO 2 . However, this ICR incorporates the burden and costs associated with monitoring at these CAIR units, including annualized capital costs that w ould continue to be born under the TR
.Transport Rule ICR May 9, 2011

17 Sources that are not affected by the ARP but were subject to the NO X SIP call are already monitoring and reporting NO X emissions during the ozone season . In a TR
- affected NO X/SO 2 annual s tate , these sources will need to extend their monitoring and reporting throughout the ye ar and add SO 2 monitoring for the TR
. These units will have a small additional burden associated with permit applications and certain allowance transactions. T R
- affected units in NO X/SO 2 annual and ozone season states , or NO X/SO 2 - only states not in the NO X SIP Call or CAIR region are similarly impacted by the TR reporting requirements
. These s tates have ARP
- affected units that are already monitoring and reporting SO 2 emissions and NO X rates on a ye ar round basis and in accordance with 40 CFR part 75
. These sources will need to report NO X mass emissions year round and , for the NO X/SO 2 annual and ozone season states , must also report ozone season NO X mass emissions
. These sources are already measuring and reporting SO 2 mass emissions, which requires heat input measurement that can be used with the NO X emission rate information to calculate NO X mass emissions
. Therefore, these sources would need to make minor modifications to their reporting practices in order to report NO X mass emissions under the TR , but would not likely need to purchase additional monitoring equipment
. The non

- ARP
- affected units in these s tate s were required to monitor under 40 CFR part 75 with the implementation of CAIR , and these requirements continue under the TR
. The monitoring burden depend s in part on the typ e of fuel combusted and the amount of time the unit is operated
. Therefore, the costs will vary depending on what monitoring alternative is appropriate for the unit and what monitoring requirements appl y to the unit under other regulatory programs . This ICR includes updated estimates for all units previously

affected under CAIR and adds newl y a ffected sources in TR states
. T R
- affected units in TR ozone season s tates that are in CAIR will continue monitoring NO X under 40 CFR part 75 during the ozone season. The burdens and costs associated with monitoring and reporting were previousl y reflected in the CAIR ICR but are now included in this ICR . TR
- affected units in TR ozone season s tates that are not subject to the ARP, CAIR, or in the NO X SIP Call region must install NO X monitoring s ys tems to comply with 40 CFR part 75 during the ozone season. Sources will be subject to TR NO X and SO 2 monitoring and reporting requirements starting in 2012
. Table 6
- 5 shows the burden associated with monitoring NO X and SO 2 under the TR at various ty

pes of sources. The primary

tasks performed by

owners and operators of affected units are (1) permitting, (2) monitoring, recording, and reporting emissions data, and (3) allowance trading activities. (i) Respondent Permitting Activities Some sources will also be required to construct additional facilities, and therefore will need to complete a permit to construct application
. Based on the existing CAIR ICR, the Agency estimates that this task will take 20 hours of managerial and 20 hours of technician time , per permit.Transport Rule ICR May 9, 2011

18 Under the TR, the designated representative for e ach affected source must submit a certificate of representation to EPA
. Since most existing TR

- affected sources are already subject to the ARP and/or CAIR, the Agency believes that the DRs for most TR

- affected sources will only need to revise their certi ficates of representation, and that such revision s are routine
. The Agency therefore estimates that, on a per unit basis, about one half hour of managerial time and one half hour of technical time will be required to revise the certificate of representation . (ii ) Agency Permitting Activities Agency permitting activities include receiving and processing certificates of representation and retired unit exemptions. The Agency estimates that these activities will require 2,992 hours per year (see Table 6

- 6 )
. (ii i ) Respondent Monitoring Activities For monitoring, the burdens differ greatl y based on the amount and type of monitoring the unit is already subject to and the particular subtask of monitoring being conducted
. The specific elements of this burden are described below. Start

- up Activities A large part of start

-up activities involves both capital expenditures and labor costs associated with the acquisition, installation, and testing of monitoring equipment, as foll o ws : 1) For Acid Rain units in CAIR OS states , the TR imposes no start

-up burdens beyond existing programs. 2) For Acid Rain units in other TR ozone season s tates, the owner or operator will incur some small amount of burden and costs associated with DAHS upgrades for reporting oz one season emissions
. 3) For the non

- Acid Rain units in NO X/SO 2 annual and ozone season TR s tates that are in the CAIR region , the burdens and costs reflect arranging for SO 2 CEMS purchase (as required) and oversight of the certification process. 4) For non
- Acid Rain/CAIR annual units in NO X/SO 2 annual and ozone season TR s tates burdens reflect purchase and certification of NO X and SO 2 monitoring systems. Note that where the start

- up burdens were already incurred as a result of CAIR, this ICR reflects minimal burden hours or non

- capital costs, but continues to account for annualized capital costs. Regulatory Review The ICR includes an allocation of time for the man agerial and technical staff to review the regulatory

requirements as well as the XML formats and instructions associated withTransport Rule ICR May 9, 2011

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

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

estimates that for each unit not previously included in the Acid Rain or CAIR , an owner or operator will spend approximately four hours of managerial time and eight hours of technician time responding to these error messages each ye ar . (The time for the other sources is accounted for in other ICRs.) DAHS Debugging Based on experience with the ARP and CAIR Program s , some effort will be involved to fix problems with the DAHS software used to report in the 40 CFR part 75 formats
. This burden is assumed to fall primarily on units that have not previously been affected under the ARP, CAIR, or NO X SIP Call programs
. Consistent with the existing 40 CFR part 75 IC R, the Agency estimates that about 1 4 managerial and 80 technician hours will be spent on this task in the first ye ar of implementation, and then one managerial and four technician hours will be required in the second and subsequent years of implementation
. Units that are subject to the ARP, and/or were previousl y subject to CAIR , are expected to incur the " subsequent ye ars " burden. Monitoring Plans The regulations req

uire submittal of monitoring plans
. Because most of the monitoring plan elements are now part of the reporting format, the effort involved in developing and maintaining the plans are incorporated into the overall reporting burden estimate. Monitor Certification/Recertification Initial certification burdens and costs for new monitoring equipment are addressed above under start

-up activities since these costs are often part of the overall purchase expense for the equipment
. For some non
- ARP
- affecte d units, however, there will be burdens associated with certifying existing monito rs used under other programs , as well as burdens for recertification to the extent a change in a monitoring system requires recertification
. Based on the current CAIR ICR, E PA estimates that approximately ten percent of all units will have to recertify each ye ar following the ye ar in which the initial certification occurs . The ICR incorporates a labor burden estimate generally

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

area (see the following subsection)
. The doub le counting would occur because a portion of the labor incurredTransport Rule ICR May 9, 2011

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

because the quality

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

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

estimates that these activities will require 4,500 hours per ye ar (see Table 6

- 10)
. (v) Respondent Allowance Transaction A ctivities The Agency

anticipates the average number of additional allowance transactions will be approximately 7,500 per year beginning in 2012
. This estimate is based on transaction data associated with the current CAIR trading programs. A portion of all sources will likely conduct transactions in each year solely as a result of this program. The Agency believe s that each transaction will involve about one hour each of managerial and technician time. (vi ) Agency

Allowance Transaction A ctivitiesTransport Rule ICR May 9, 2011

21 Agency activities related to allowance transactions include allocating allowances to existing and new units, reviewing allowance transfer information, recording transfers , notifying transfer participants, entering deduction data and deducting allowances , and ensuring compliance assurance provisions are met. In the event that compliance assurance provisions are not met it is estimated that the burden for each s tate exceeding compliance assurance levels would be 160 hours, however the agency assumes that zero s tate s would exceed the limit during the 2012

- 2013 time period. The Agency estimates that these activities will require 290 hours per ye ar (see Tables 6

- 8 and 6
- 9 )
. **6 .2**  **Estimating Respondent Costs** Table 6

- 4 presents s tate and local respondent annualized hours and costs for each information collection activity
. To estimate annualized hours and costs for one

- time activities, the burden estimate is divided by three to estimate the burden over a three

- ye ar period
. Table 6
- 5 summarizes the annual industry respondent costs
. The following discussion describes how the costs were derived. (i) Estimating Labor Costs For this ICR, the labor rate used for technical staff at s tate agencies is $ 40.28 per hour, and the labor rate for managerial employees at s tate agencies is $ 48. 93
. These labor rates include benefits and overhead , and are derived from data shown on the Bureau of Labor Statistics web site at http://stats.bls.gov/news.release/ecec.toc.htm
. Wage and salary rates are shown at the link “T able 3: State and local government, by major occupation and industry group (Dec ember 20 10 ). " The wage and salary rates from this table account for benefits provided to workers
. When considering both technical and man agerial hours, labor costs for s tate and territorial agencies are estimated to be $53,000 per year per respondent, and labor costs for local agencies are estimated to be $34 ,000 per ye ar per respondent for the emissions reporting requirements
. In estimating labor costs for industry , EPA use d the following amounts: $ 94.04 per hour for managers and $ 65.21 per hour for technicians
. These rates were used in the existing ARP ICR ( EPA ICR Number 1633.15 ) and are the consistent with the Current Employ ment Cost Index year 20 10
. Federal Agency labor rates were assumed to be $ 49. 49 per hour
. This labor rate was derived from the federal government ' s 2009 U.S. Office of Personnel Management General Schedule " Salary

Table 20 11
- GS " (http://opm.gov/oca/ 11 tables/html/gs.asp) u sing the factors in Table 6

- 2 below
.Transport Rule ICR May 9, 2011

22 **Table 6 -**  **2: Determination of Federal Wage Rates**  **Labor Category Factors**  **Total** Annual Salary of Technical Staff, GS 11 Step 3 $ 53,639 Annual Cos t of Supervisory Staff, GS 13, S tep 3 $76,452 Factor (1/11) 0.09 $6,881 Annual Cost of Support Staff, GS 6, S tep 6 $35,672 Factor (1/8) 0.13 $4,637 Annual Applicable Salary of Permit Staff $65,157 Benefits 1.6 Total Cost per FTE $102,948 Total Hourly Cost (total per FTE dividend divided by 2,080 hours per year) $49.49 ( ii) Estimating Capital and Operations and Maintenance Costs **Emission Reporting Requirements** Consistent with the CAIR I CR, EPA has concluded that the Capital and Operations and Maintenance Costs estimated under the NO X SIP Call are sufficient to accommodate the modest changes in reporting burden for the TR
. Therefore, no further estimate of Capital and Operations and Maintenance Costs were made for this ICR. **Emission Trading Requirements** Capital/start

-up costs include the cost of installing required CEMS or alternatives
. Operation and maintenance costs (exclusive of labor costs) reflect ongoing costs to a unit and include both contractor costs for the required recertification, diagnostic, and quality assurance (QA) testing, and other direct maintenance

- related expenses (e.g., spare parts and calibration gases)
. These cost estimates have been derived from EPA CEM cost models, existing ICRs, Agency staff experience under the Acid Rain , CAIR, and NO X SIP Call programs, and supplemental estimates provided by affected utilities and others related to the various cost items. ARP
- affected units in CAIR s tate s are not expected to incur any non - labor costs associated with this program . Based on the existing CAIR ICR, th e total non

- labor cost for capital/start

-up items for Acid Rain units in other s tate s that would be subject to the TR is estimated at $ 4 ,000 per unit for CAIR
- affected units that are not in the NO X SIP Call region (to account for a DAHS upgrade)
. For non
- Acid Rain/CAIR annual units, most units will require a DAHS upgrade ( estimated at $ 4 ,000 per unit) and an SO 2 analyzer (estimated at $42,525 )
. ForTransport Rule ICR May 9, 2011

23 non - Acid Rain units not in the CAIR region, the units using fuel flowmeters are expected to incur DAHS and SO 2 analy zer costs, while the other units will require some combination of a NO X diluent, SO 2 , and/or flow CEMS
. The costs for these units ranges from $15,000 to $192,000

. Cost variance is due to the monitoring methodology used and what monitoring equipment may

already be in place at the unit. Note that testing contractor costs for certification, recertification and annual relative accuracy test audits (RATAs) are presented as other direct costs and are not converted to equivalent source labor hours
. This approach is consistent with the common business practice for obtaining outside contractors to conduct certification/recertification tests and annual RATAs
. For initial certification, the certification test costs are commonl y bundled with equipment purchase contracts, according to information provided by a range of CEMS equipment vendors
. For RATAs that are conducted either as part of the annual quality assurance requirements or as part of recertification, industry contac ts have indicated that RATA tes ting is usually performed under a fixed price contract basis, except for travel costs that may be billed on an hourl y basis beyond the basic contract cost. The Agency

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

the TR are already required to have CEMS under other regulatory programs . Therefore, to the extent that no new equipment is needed b y these sources, capital costs are not included because those costs were included in the ICRs of those other programs
. Thus, the capital and other costs included in Table 6
- 5 represent weighted average costs for each respondent, not the total individual cost for any particular respondent. EPA has concluded that the Capital and Operations and Maintenance Costs estimated for the Agency under the ARP ICR are sufficient to accommodate the modest changes in reporting burden for the TR . Therefore, no further estimate of Capital and Operations and M aintenance Costs for the Agency were made for this ICR. ( iii) Capital/Start

-up vs. Operating and Maintenance (O & M) Costs Capital costs for emissions trading reflect one

- time costs for purchase of equipment which will be used over a period of ye ars . C onversely , operating and maintenance costs are those costs which are incurred on an annual or other scheduled basis
. For instance, costs associated with quality assurance activities, such as spare parts or contractor costs for work, will be incurred on an annual basis. (iv) Annualizing Capital Costs The relevant capital costs for the emissions trading portion of this ICR were annualized at a rate of seven percent , ( i.e., the annualized capital cost was calculated assuming money to purchase the capital equipment was borrowed at a seven percent annual interest rate )
. The cost of the loan was amortized over the life of the loan to repay the borrowed amount plus interest
. The result is the annualized capital cost reported. ) The annualized cost of the necessary capitalTransport Rule ICR May 9, 2011

24 purchases varies from $ 2,304 to $ 29,572 per year per unit, depending on the ty pe of monitoring methodology
. Table 6
- 5 contains a breakdown of annual costs b y monitoring methodology. **6.3 Estimating**  **the Respondent Universe and Total Burden and Costs Emission Reporting Requirements**  The number of non - industry respondents is estimated to be 5 0 s tates and the District of Columbia , four territories and 49 local agencies, totaling 104 respondents
. Table 6
- 4 details state, territory , and local agency burdens associated with reading the rule upon publication. **Emission Trading Requirements** The number of industry

respondents varies depending on the activity in question
. Activities such as T itle V permit application submission or allowance transfers can involve nearl y two thousand sources
. The number of units which will be required to install a particular ty pe of monitoring equipment is fewer since many already have the necessary monitoring equipment , especiall y if they are ARP units and/or are in CAIR s tate s . Table 6
- 5 gives estimates of annual industry burden s beginning in 20 1 2
. These burden s include monitoring, reporting , and other activities involved in participating in an emissions trading program
. The total number of respondents is estimated to be 1,2 0 1 facilities. Table s 6
- 6 through 6

- 10 give estimates of Agency

burden s associated with permitting and managing the emissions trading programs. **6.4 Bottom**  **Line Burden Hours and Cost Table** Table 6

- 3 summarizes the bottom line burden and costs for state, industry , and Agency respondents. **Table 6 -** **3 :**  **Total Estimated Emissions Trading**  **Respondent Burden and Cost Summary**

**Number of Respondents**  **Total Hours Per Year** 

**(All Respondents) Total Costs Per Year**  **(All Respondents)** State Respondents 104 69 $ 3, 016 Industry Respondents 1,201 185,132 $26,225, 946 Agency 1 7,716 $380,306Transport Rule ICR May 9, 2011

25 **6.5 Reasons for Change in Burden**  **Emission Reporting and Trading**  **Requirements** The large st burden associated with this rule is the cost of monitoring, certifying , quality assuring and reporting emissions data from the large electric generating units regulated under the TR
. This burden is tempered , however , by the integration of thes e monitoring and reporting requirements with those already required under the ARP and CAIR
. Otherwise, the burden would be significantly

higher and the number of sources would be greater. **6.6 Burden Statement**  The annual public reporting and recordkeeping burden for this collection of information is estimated to average 11 hours per response. Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, disclose or provide information to , or for , a f ederal agency
. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information ; processing , maintaining, disclosing , and providing information; adjusting the existing ways to comply with any previously applicable instructions and requirements; training personnel to be able to respond to a collection of information; searching data sources; completing and reviewing the collection of information; and transmitting or otherwise disclos ing the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currentl y valid OM B control number
. The OMB control numbers for EPA ' s regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15. To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID No. EPA
- HQ
- OAR
- 2009
- 0491 , which is available for public viewing at the Air and Radiation Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number f or the Reading Room is (202) 566

- 1744, and the telephone number for the Air and Radiation Docket and Information Center is (202) 566

- 1742. An electronic version of the public docket is available at www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronicall y. When in the system, select “search,” then key in the Docket ID Number identified ab ove. Also, yo u can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Please include EPA Docket ID No. EPA
- HQ
- OAR
- 2009
- 0491 and OM B Control Number 2060

-NEW in any correspondence.Transport Rule ICR May 9, 2011

26 **T able 6**  **- 4**  **: Annual State Respondent Burden and Cost by Activity**  **Hours and Costs Per Respondent Total Hours and Costs**  **Information Collection or**  **Trading Rule Activity**  **Mgr.**

**$ 48.**  **93 /Hr**  **1 Tech.** 

**$ 40.28** **/Hr 1**  **Respondent**

**Hours/Yr Labor** 

**Cost/Yr Number of** 

**Respondents Total** 

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

**Cost/Yr 3**  **One -**  **tim e (Annualized)**  Read the reporting requirements of the rule 0.33 0.33 0.66 $29 10 4 69 $3, 016 **Total** 10 4 69 $ 3, 016
1 See Section 6 .2 (i) for labor and overhead rates. 2 Hours per year are rounded to the nearest hour. 3 Costs per year are rounded to the nearest dollar.Transport Rule ICR May 9, 2011

27 **Table 6 -**  **5 :**  **Annual Industry Respondent Burden and Cost by Activity** 
**Respondent Labor**  **Cost/Year Annual Capital**  **Man ager**  **$9 4**  **. 0**  **4 Per Hour**  **( 20**  **10 )**  **Technical**

**$ 65.21**  **Per Hour (**  **20 10**  **) Respondent** 

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

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

**Hours/Year Total** 

**Cost/Year**
Permit to Construct (units) 20 20 40 $3,185 8 317 $25,257 Certificate of Representation 0.50 0.50 1 $80 1201 1,201 $95,630 **Startup/ Capital Items**  **Kansas, Minnesota, Nebraska, Oklahom a**  **(Previously Not Affected)**
a. DAHS modification (facilities) 2 4 6 $449 $1,333 35 210 $62,367 b. Solid Fuel: SO 2 , NO X , and Flow CEMS (units) 34 2 3 57 $4,697 $29,752 7 399 $241,144 c . Gas
- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 64 10 74 $6,671 $19,200 17 1,258 $439,801 d . Gas
- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 20 10 3 0 $2,533 $2,304 29 870 $140,270 (cont.)Transport Rule ICR May 9, 2011

28 **Table 6**  **- 5**  **: Annual Industry Respondent Burden and Cost by Activity**  **(cont.)**
**Respondent Labor**  **Cost/Year Annual Capital**  **Man ager**  **$9 4**  **. 0**  **4 Per Hour**  **(20 10** **) Technical** 

**$ 65.21**  **Per Hour (20**  **10 )**  **Respondent**

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

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

**Hours/Year Total** 

**Cost/Year Startup/** **Capital Items (cont.)**  **Georgia and Texas**  **(Ozone Status Changes, Annual Status R em**  **ains)** a. DAHS modification (facilities) 2 4 6 $449 $600 161 966 $168,876 b . Solid Fuel: NO X , and Flow CEMS (units) 0 0 0 $0 $29,752 1 0 $29,752 c . Gas
- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 0 0 0 $0 $19,200 38 0 $729,600 d
. Gas
- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 0 0 0 $0 $2,304 39 0 $89,856 (cont.)Transport Rule ICR May 9, 2011

29 **Table 6**  **- 5**  **: Annual Industry Respondent Burden and Cost by Activity**  **(cont.)**
**Respondent Labor**  **Cost/Year Annual Capital**  **Man ager**  **$9 4**  **. 0**  **4 Per Hour**  **(20 10** **) Technical** 

**$ 65.21**  **Per Hour (20**  **10 )**  **Respondent**

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

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

**Hours/Year Total** 

**Cost/Year Startup/** **Capital Items (cont.)**  **Mississippi ,**  **Florida ,**  **and Louisiana**  **(Now Ozone Season Only)** a. DAHS modification (facilities) 2 4 6 $449 $600 27 162 $28,321 b . Solid Fuel: NO X , and Flow CEMS (units) 0 0 0 $0 $22,500 6 0 $135,000 c . Gas
- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 0 0 0 $0 $19,200 6 0 $115,200 d . Gas
- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 0 0 0 $0 $2,304 62 0 $142,848 **States with No Change in Classification** a . Solid Fuel: NO X , and Flow CEMS (units) 0 0 0 $0 $29,752 64 0 $1,904,128 b
. Gas
- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 0 0 0 $0 $19,200 67 0 $1,286,400 c . Gas
- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 0 0 0 $0 $2,304 533 0 $1,228,032 (cont.)Transport Rule ICR May 9, 2011

30 **Table 6**  **- 5**  **: Annual Industry**  **Respondent Burden and Cost by Activity (cont.)** 
**Respondent Labor**  **Cost/Year Annual Capital**  **Man ager**  **$9 4**  **. 0**  **4 Per Hour**  **(20 10** **) Technical** 

**$ 65.21**  **Per Hour (20**  **10 )**  **Respondent**

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

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

**Hours/Year Total** 

**Cost/Year Review Instructions and Requirements**  States with No Change in Classification 4 4 8 $637 26 1 2,088 $166,257 States in which Ozone Season Status Changes, Annual Status Remains 4 4 8 $637 161 1,288 $102,557 States now

Ozone Season Only

- Mississippi, Florida, Louisiana 4 4 8 $637 27 216 $17,199 States Not Previously Covered

- Kansas, Minnesota, Nebraska, Oklahoma 8 8 16 $1,274 35 560 $44,590 (cont.)Transport Rule ICR May 9, 2011

31 **Table 6**  **- 5**  **: Annual Industry Respondent Burden and Cost by Activity**  **(cont.)**
**Respondent Labor**  **Cost/Year Annual Capital**  **Man ager**  **$9 4**  **. 0**  **4 Per Hour**  **(20 10** **) Technical** 

**$ 65.21**  **Per Hour (20**  **10 )**  **Respondent**

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

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

**Hours/Year Total** 

**Cost/Year Respond to EPA Generated Error Messages**  States with No Change in Classification 6 18 24 $1,738 261 6,264 $453,623 States in which Ozone Season Status Changes, Annual Status Remains 6 18 24 $1,738 161 3,864 $279,821 States now

Ozone Season Only

– Mississippi, Florida, Louisiana 6 18 24 $1,738 27 648 $46,927 States Not Previously Covered

- Kansas, Minnesota, Nebraska, Oklahoma 6 18 24 $1,738 35 840 $60,831 **Debug Computer Software** States with No Change in Classification 1 4 5 $355 261 1,305 $92,624 States in which Ozone Season Status Changes, Annual Status Remains 6 18 24 $1,738 161 3,864 $279,821 (cont.)Transport Rule ICR May 9, 2011

32 **Table 6**  **- 5**  **: Annual Industry Respondent Burden and Cost by Activity**  **(cont.)**
**Respondent Labor**  **Cost/Year Annual Capital**  **Man ager**  **$9 4**  **. 0**  **4 Per Hour**  **(20 10** **) Technical** 

**$ 65.21**  **Per Hour (20**  **10 )**  **Respondent**

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

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

**Hours/Year Total** 

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

Ozone Season Only

- Mississippi, Florida, Louisiana 1 4 5 $355 27 135 $9,582 States Not Previously Covered

- Kansas, Minnesota, Nebraska, Oklahoma 16 88 104 $7,243 35 3,640 $253,509 **Certify Monitors Kansas, Minnesota, Nebraska, Oklahom**  **a (Previously Not Affected)**  a. Solid Fuel: SO 2 , NO X , and Flow CEMS (units) 15 48 63 $4,541 $2,800 1 63 $7,341 b. Gas

- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 10 32 42 $3,027 $2,800 1 42 $5,827 c. Gas
- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 8 24 32 $2,317 $10,000 5 160 $61,587 (cont.)Transport Rule ICR May 9, 2011

33 **Table 6**  **- 5**  **: Annual Industry Respondent Burden and Cost by Activity**  **(cont.)**
**Respondent Labor**  **Cost/Year Annual Capital**  **Man ager**  **$9 4**  **. 0**  **4 Per Hour**  **(20 10** **) Technical** 

**$ 65.21**  **Per Hour (20**  **10 )**  **Respondent**

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

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

**Hours/Year Total** 

**Cost/Year Certify Monitors**  **(cont.) Georgia**  **and Texas (Ozone Status Changes, Annual Status R** **em ains)**  a. Solid Fuel: SO 2 , NO X , and Flow CEMS (units) 15 48 63 $4,541 $2,800 1 63 $7,341 b. Gas

- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 10 32 42 $3,027 $2,800 4 168 $23,308 c. Gas
- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 8 24 32 $2,317 $10,000 4 128 $49,269 **Mi ssissippi**  **, Florida ,**  **and Louisiana (Now Ozone Season O**  **nly)** a. Solid Fuel: SO2, NO X , and Flow CEMS (units) 15 48 63 $4,541 $2,800 1 63 $7,341 a. Gas
- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 10 32 42 $3,027 $2,800 1 42 $5,827 b. Gas

- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 8 24 32 $2,317 $10,000 6 192 $73,904 (cont.)Transport Rule ICR May 9, 2011

34 **Table 6**  **- 5**  **: Annual Industry**  **Respondent Burden and Cost by Activity (cont.)** 
**Respondent Labor**  **Cost/Year Annual Capital**  **Man ager**  **$9 4**  **. 0**  **4 Per Hour**  **(20 10** **) Technical** 

**$ 65.21**  **Per Hour (20**  **10 )**  **Respondent**

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

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

**Hours/Year Total** 

**Cost/Year Certify Monitors**  **(cont.) States With No Change in Classification**  a. Solid Fuel: NO X , and Flow CEMS (units) 15 48 63 $4,541 $2,800 6 378 $44,044 b. Gas

- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 10 32 42 $3,027 $2,800 7 294 $40,790 c. Gas
- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 8 24 32 $2,317 $10,000 50 1,600 $615,868 **Perform QA Testing and Maintenance**  **Kansas, Minnesota, Nebraska, Oklahom a**  **(Previously Not Affected)** a. Solid Fuel: SO 2 , NO X , and Flow CEMS (units) 50 600 650 $43,828 $31,949 7 4,550 $530,439 b. Gas

- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 20 375 395 $26,335 $17,818 17 6,715 $750,593 c. Gas
- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 5 30 35 $2,427 $1,843 29 1,015 $123,816 (cont.)Transport Rule ICR May 9, 2011

35 **Table 6**  **- 5**  **: Annual**  **Industry Respondent Burden and Cost by Activity (cont.)** 
**Respondent Labor**  **Cost/Year Annual Capital**  **Man ager**  **$9 4**  **. 0**  **4 Per Hour**  **(20 10** **) Technical** 

**$ 65.21**  **Per Hour (20**  **10 )**  **Respondent**

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

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

**Hours/Year Total** 

**Cost/Year**
**Perform QA Testing and Maintenance**  **(cont.) Georgia**  **and Texas (Ozone**  **Season Status**  **Changes, Annual Status R em**  **ains)** a. Solid Fuel: NO X , and Flow CEMS (units) 40 400 440 $29,846 $31,949 1 440 $61,795 b. Gas

- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 20 375 395 $26,335 $17,818 38 15,010 $1,677,797 c. Gas
- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 5 30 35 $2,427 $1,843 39 1,365 $166,511 **Mi ssissippi**  **, Florida and Louisiana**  **(Now Ozone Season O nly)**  a. Solid Fuel: NO X , and Flow CEMS (units) 40 400 440 $29,846 $31,949 6 2,640 $370,768 b. Gas

- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 20 375 395 $26,335 $17,818 6 2,370 $264,915 c. Gas
- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 5 30 35 $2,427 $2,209 62 2,170 $287,401 (cont.)Transport Rule ICR May 9, 2011

36 **Table 6**  **- 5**  **: Annual Industry Respondent Burden and Cost by Activity**  **(cont.)**
**Respondent Labor**  **Cost/Year Annual Capital**  **Manager $9**  **4 .**  **0 4**  **Per Hour (20**  **10 )**  **Technical**

**$ 65.21**  **Per Hour (20**  **10 )**  **Respondent**

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

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

**Hours/Year Total** 

**Cost/Year**
**Perform QA Testing and Maintenance**  **(cont.) States With No Change in Classification**  a. Solid Fuel: NO X , and Flow CEMS (units) 40 400 440 $29,846 $31,949 64 28,160 $3,954,854 b. Gas

- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 20 375 395 $26,335 $17,818 67 26,465 $2,958,221 c. Gas
- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 5 30 35 $2,427 $1,843 533 18,655 $2,275,644 **Assure Data Quality, Prepare Reports, Submit Reports** States with No Change in Classification 16 42 58 $4,243 261 15,138 $1,107,543 States in which Ozone Season Status Changes, Annual Status Remains 16 42 58 $4,243 161 9,338 $683,197 (cont.)Transport Rule ICR May 9, 2011

37 **Table 6**  **- 5**  **: Annual Industry Respondent Burden and Cost by Activity**  **(cont.)**
**Respondent Labor**  **Cost/Year Annual Capital**  **Man ager**  **$9 4**  **. 0**  **4 Per Hour**  **(20 10** **) Technical** 

**$ 65.21**  **Per Hour (20**  **10 )**  **Respondent**

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

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

**Hours/Year Total** 

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

Ozone Season Only

- Texas and Mississippi 8 21 29 $2,122 27 783 $57,287 States Not Previously Covered

- Kansas, Minnesota, Nebraska, Oklahoma 16 42 58 $4,243 35 2,030 $148,521 **Other Trading Program Activities**  Allowance Transfers 1 1 2 $159 7500 15,000 $1,194,375 Com pl iance Assurance Activites 1. .5 1 1.5 $112 0 0 0 **TOTAL** 185,1 32 $26,2 25 , 946 1. Assumes that no State s will exceed their limits for the years covered by this ICR (i.e., compliance years 2012 and 2013), so, overall there would be zero burden for these provisions to industry.Transport Rule ICR May 9, 2011

38 **Table 6**  **- 6**  **: Agency Burden** 

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

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

**(H ours)**  **Total Cost**  EPA reviews certificates of representation and records information. 2 0.5 $24.75 600 $29,628 Revie w permit application, and issue draft, proposed, and final permit. 3 Permitting Authority action
. 8 $395.92 2,000 $98,760 EPA review
. 1 $49.38 240 $11,851 Receive and process retired unit exemptions
. 4 Permitting Authority action
. 2 $98.98 66 $3,259 EPA review
. 0.3 $14.85 20 $988 **TOTAL 2,926**  **$144,486** 1. 20 11 dollars
. 2
. Assumes 12 0 1 sources submit a certificate of representation. 3. Assumes 2 4 0 sources (approximately 20% of all affected sources) will submit a permit application each year. 4. Assumes 33 retired unit exemptions are submitted each year.
**Table 6**  **- 7**  **: Agency Burden** 

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

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

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

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

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

**Cost** Process, review , and evaluate quarterly report and issue feedback letter. 1 $49.49 4,500 4,500 $222,705 1
. Based on an average total compensation rate of $ 49. 49 per hour. 2
. Assumes 1125 TR only emissions data reports are submitted each quarter.Transport Rule ICR May 9, 2011

39 **Table 6**  **- 8**  **: Agency Burden**  **- Allowance Allocations**  **Information Collection Activity**  **Total Burden (H**  **ours) Total Cost**  Initial and annual allocation of allowances to existing and new units. 200 $9,898
**Table 6**  **- 9**  **: Agency Burden** 

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

**per Occurrence Cost per** 

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

**(H ours)**  **Total Cost** Revie w allowance transfer information, record transfer, and notify transfer participants. 1 $49.49 40 $1,980 Enter deduction data and deduct allowances. 0.5 $24.75 50 $1,237 Com pliance Assurance Provisions 3 1 $49.49 40 $1,980 **TOTAL 90**  **$3,21 7**  1. 2011 dollars. 2. Assumes 20 transfers and 100 optional deduction forms are submitted annually. 3. Assumes zero s tate s would exceed the limit during the time period 201 2
- 2013.
**Table 6**  **- 10**  **: Agency**  **Burden**

**– Aggregate**  **Information Collection Activity Total Burden (H**  **ours) Total Cost**  **1** Annual allocation of allowances to existing and ne w units. 200 $9,898 Allowance transfers and deductions. 90 $3,217 Permits. Permitting Authority
. 2,066 $102,019 EPA
. 860 $42,467 Emissions reporting. 4,500 $222,705 **TOTAL 7,716**  **$380,306** 1. 2011 dollars.Transport Rule ICR May 9, 2011

40 **SUPPORTING STATEMENT Rule To**  **Reduce Interstate Transport of Fine Particulate Matter and Ozone (Final Rule)**  **Appendix A** In addition to the s tate s and facilities lis ted in the final rule text, EPA ha s included costs/ burdens associated with TR NO X O zone S eason Trading Program for the following s tate s: IA, KS, MI , MO, OK, and WI. The TR NO X Ozone Season Trading P rogram does not list these s tate s in the current rule package , however EPA will propose , as part of a future supplemental rule package , that these s tates be covered b y the TR NO X Ozone Season Trading Program. In anticipation of this rule making, the costs/burdens associate d with this Program in these states are included in the IC R to allow for a full accounting for the TR program at maturity
. In the event that some or all of these s tate s are not included in the future rulemaking, EPA will amend this ICR accordingl y.
**Table A -**  **1 :**  **Total Estimated Emissions Trading**  **Respondent Burden and Cost Summary** 

**Number of Respondents**  **Total Hours Per Year**

**(All Respondents) Total Costs Per Year**  **(All Respondents)** Industry Respondents 58 31,538 4,412,094 Agency 1 452 $22,074Transport Rule ICR May 9, 2011

41 **T able**  **A -**  **2 :**  **Annual State Respondent Burden and Cost by Activity Hours and**  **Costs Per Respondent Total Hours and Costs**  **Information Collection or**  **Trading Rule Activity**  **Mgr.**

**$48. 93**  **/Hr 1**  **Tech.**

**$40.28 /Hr**  **1 Respondent** 

**Hours/Yr Labor** 

**Cost/Yr Number of** 

**Respondents Total** 

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

**Cost/Yr 3**  **One -**  **tim e (Annualized)**  Read the reporting requirements of the rule
. 0.33 0.33 0.66 $29 2 69 $ 59 **Total** 749 30,645.48 2 3,749 $ 49,391
1 See Section 6 .2 (i) for labor and overhead rates. 2 Hours per year are rounded to the nearest hour. 3 Costs per year are rounded to the nearest dollar.Transport Rule ICR May 9, 2011

42 **Table A -** **3 Agency Burden** 

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

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

**(H ours)**  **Total Cost** EPA reviews certificates of representation and records information. 2 0.5 $25 24 $1,188

Revie w permit application, and issue draft, proposed, and final permit. 3 $0 Permitting Authority action
. 8 $395 80 $3,959 EPA review
. 1 $49 10 $495 Receive and process retired and new unit exemptions
. 4 $0 Permitting Authority action
. 2 $99 4 $198 EPA review
. 0.3 $15 20 $990 **TOTAL 138**  **$ 6,8**  **30** 1. 20 11 dollars
. 2
. Assumes 48 sources submit a certificate of representation. 3. Assumes ten sources (approximately 20% of all affected sources) will submit a permit application each year. 4. Assumes two retired and two new unit exemptions are submitted each year.
**Table A -**  **4 :**  **Agency Burden**

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

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

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

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

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

**Cost** Process, review , and evaluate quarterly report and issue feedback letter. 1 $49.49 318 318 $15,738 1
. Based on an average total compensation rate of $49. 49 per hour. 2
. Assumes 318 Ozone emissions data reports are submitted each year .Transport Rule ICR May 9, 2011

43 **Table A -**  **5 :**  **Agency Burden -**  **Allowance Allocations Information Collection Activity**  **Total Burden (H**  **ours) Total Cost**  Initial and annual allocation of allowances to existing and new units. 1 0 $ 0 1. Assumes the allocation for these units would be performed as part of the TR allocations.
**Table A -**  **6 :**  **Agency Burden**

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

**per Occurrence Cost per** 

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

**(H ours)**  **Total Cost** Revie w allowance transfer information, record transfer, and notify transfer participants. 1 $49.49 10 $495 Enter deduction data and deduct allowances. 0.5 $24.75 10 $248 Com pliance Assurance Provisions
. 3 160 7901 0 0 **TOTAL 20**  **$ 741**  1. 20 11 dollars. 2. Assumes 10 transfers and 10 optional deduction forms are submitted annually. 3. Assumes zero s tate s would exceed the limit during the time period 2012

- 2013.
**Table A -**  **7 :**  **Agency Burden**

**– Aggregate**  **Information Collection Activity Total Burden (H**  **ours) Total Cost**  **1** Annual Allocation of Allowances to existing and ne w units. 20 $742 Allowance transfers and deductions. Permits. 84 $4,157 Permitting Authority
. 54 $2,672 EPA
. 318 $15,738 Emissions reporting. 476 $23,310 **TOTAL** 20 $742 1. 20 11 dollars.Transport Rule ICR May 9, 2011

44 **Table A** **- 8**  **: Annual Industry Respondent Burden and Cost by Activity** 
**Respondent Labor**  **Cost/Year Annual Capital**  **Man ager**  **$9 4**  **. 0**  **4 Per Hour**  **(20 10** **) Technical** 

**$ 65.21**  **Per Hour (20**  **10 )**  **Respondent**

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

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

**Hours/Year Total** 

**Cost/Year**
Permit to Construct (units) 20.00 20.00 40.00 $3,185 1.00 40.00 $ 3 , 11 4 Certificate of Representation 0.50 0.50 1.00 $80 48.00 48.00 $ 3 , 736 **Startup/ Capital Items**  **Kansas, Minnesota, Nebraska, Oklahom a**  **(Previously Not Affected)** a. DAHS modification (facilities) 2.00 4.00 6.00 $449 $1,333 10 60 $17,819 b. Solid Fuel: SO2, NO X , and Flow CEMS (units) 34.00 23.00 57.00 $4,697 $29,752 4 228 $137,79 7 c. Gas
- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 64.00 10.00 74.00 $6,671 $19,200 2 148 $51,741 d. Gas

- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 20.00 10.00 30.00 $2,533 $2,304 19 570 $91,90 1 (cont.)Transport Rule ICR May 9, 2011

45 **Table A** **- 8**  **: Annual Industry Respondent Burden and Cost by Activity**  **(cont.)**
**Respondent Labor**  **Cost/Year Annual Capital**  **Man ager**  **$9 4**  **. 0**  **4 Per Hour**  **(20 10** **) Technical** 

**$ 65.21**  **Per Hour (20**  **10 )**  **Respondent**

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

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

**Hours/Year Total** 

**Cost/Year Startup/** **Capital Items (cont.)**  **Iowa, Michigan, Missouri, Wisconsin (Ozone Status Changes, Annual Status Remains)**  a. DAHS modification (facilities) 2.00 4.00 6.00 $449 $600 48 288 $50,348 b. Solid Fuel: NO X , and Flow CEMS (units) 0.00 0.00 0.00 $0 $29,752 6 0 $178,512 c. Gas
- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 0.00 0.00 0.00 $0 $19,200 34 0 $652,8 00 d. Gas

- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 0.00 0.00 0.00 $0 $2,304 31 0 $71,424 (cont.)Transport Rule ICR May 9, 2011

46 **Table A** **- 8**  **: Annual Industry Respondent Burden and Cost by Activity**  **(cont.)**
**Respondent Labor**  **Cost/Year Annual Capital**  **Man ager**  **$9 4**  **. 0**  **4 Per Hour**  **(20 10** **) Technical** 

**$ 65.21**  **Per Hour (20**  **10 )**  **Respondent**

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

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

**Hours/Year Total** 

**Cost/Year Review Instructions and Requirements**  States in which Ozone Season Status Changes, Annual Status Remains 4.00 4.00 8.00 $637 48 384 $30,576 States Not Previously Covered

- Kansas and Oklahoma 8.00 8.00 16.00 $1,274 10 160 $12,740 **Respond to EPA Generated Error Messages** States in which Ozone Season Status Changes, Annual Status Remains 6 18 24 $1,738 48 1152 $83,42 5 States Not Previously Covered

- Kansas and Oklahoma 6 18 24 $1,738 10 240 $17,380 **Debug Computer Software** States in which Ozone Season Status Changes, Annual Status Remains 6 18 24 $1,738 48 1152 $83,42 5 (cont
. )Transport Rule ICR May 9, 2011

47 **Table A** **- 8**  **: Annual Industry Respondent Burden and Cost by Activity (cont.)** 
**Respondent Labor**  **Cost/Year Annual Capital**  **Manager $9**  **4 .**  **0 4**  **Per Hour (20**  **10 )**  **Technical**

**$ 65.21**  **Per Hour (20**  **10 )**  **Respondent**

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

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

**Hours/Year Total** 

**Cost/Year Debug Computer Software (cont.)**  States Not Previously Covered

- Kansas and Oklahoma 16 88 104 $7,243 10 1040 $72,431 **Certify Monitors Kansas and Oklahoma (Previously Not Affected)**  a. Solid Fuel: SO2, NO X , and Flow CEMS (units) 15 48 63 $4,541 $2,800 1 63 $7,34 1 b. Gas

- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 10 32 42 $3,027 $2,800 1 42 $5,827 c. Gas
- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 8 24 32 $2,317 $10,000 2 64 $24,63 5 (cont.)Transport Rule ICR May 9, 2011

48 **Table A** **- 8**  **: Annual Industry**  **Respondent Burden and Cost by Activity (cont.)**
**Respondent Labor**  **Cost/Year Annual Capital**  **Man ager**  **$9 4**  **. 0**  **4 Per Hour**  **(20 10** **) Technical** 

**$ 65.21**  **Per Hour (20**  **10 )**  **Respondent**

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

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

**Hours/Year Total** 

**Cost/Year Certify Monitors (cont.)**  **Iowa, Michigan, Missouri, Wisconsin (Ozone Status Changes, Annual Status Remains)**  a. Solid Fuel: SO2, NO X , and Flow CEMS (units) 15 48 63 $4,541 $2,800 1 63 $7,34 1 b. Gas

- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 10 32 42 $3,027 $2,800 3 126 $17,481 c. Gas
- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 8 24 32 $2,317 $10,000 3 96 $36,952 **Perform QA Testing and Maintenance**  **States Not Previously**  **Covered -**  **Kansas and Oklahom a**  a. Solid Fuel: SO2, NO X , and Flow CEMS (units) 50 600 650 $43,828 $31,949 4.00 2600 $303,108 b. Gas

- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 20 375 395 $26,335 $17,818 2.00 790 $88,305 (cont.)Transport Rule ICR May 9, 2011

49 **Table A** **- 8**  **: Annual Industry Respondent Burden and Cost by Activity**  **(cont.)**
**Respondent Labor**  **Cost/Year Annual**  **Capital Manager**  **$9 4**  **. 0**  **4 Per Hour**  **(20 10** **) Technical** 

**$ 65.21**  **Per Hour (20**  **10 )**  **Respondent**

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

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

**Hours/Year Total** 

**Cost/Year**
**Perform QA Testing and Maintenance**  **(cont.)** c. Gas
- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 5 30 35 $2,427 $1,843 19.00 665 $81,12 1 **Iowa, Michigan, Missouri, Wisconsin (Ozone Season**  **Status Changes, Annual Status Remains)** a. Solid Fuel: NO X , and Flow CEMS (units) 40 400 440 $29,846 $31,949 6.00 2640 $370,76 8 b. Gas

- Oil: NO X CEMS and Appendix D fuel mo nitoring (units) 20 375 395 $26,335 $17,818 34.00 13430 $1,501,18 7 c. Gas
- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 5 30 35 $2,427 $1,843 31.00 1085 $132,35 5 (cont.)Transport Rule ICR May 9, 2011

50 **Table A** **- 8**  **: Annual Industry Respondent Burden and Cost by Activity**  **(cont.)**
**Respondent Labor**  **Cost/Year Annual Capital**  **Man ager**  **$9 4**  **. 0**  **4 Per Hour**  **(20 10** **) Technical** 

**$ 65.21**  **Per Hour (20**  **10 )**  **Respondent**

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

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

**Hours/Year Total** 

**Cost/Year Assure Data Quality, Prepare Reports, Submit Reports**  States in which Ozone Season Status Changes, Annual Status Remains 16 42 58 $4,243 48 2,784 $203,686 States Not Previously Covered

- Kansas and Oklahoma 16 42 58 $4,243 10 580 $42,43 5 Allowance Transfers 1 1 2 $159 500 1,000 $79,625 TO TAL 31,538 $4,461,49 2