SUPPORTING STATEMENT – INFORMATION COLLECTION REQUEST (ICR)

Federal Implementation Plans to Reduce Interstate Transport of 

Fine Particulate Matter and Ozone (Final Rule)

1.0 Identification of the Information Collection

1.1 Title of the Information Collection

Federal Implementation Plans to Reduce Interstate Transport of Fine Particulate Matter 

and Ozone, EPA ICR Number 2391.02, 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 NOX Emissions to Reduce Regional Transport of Ozone (NOX

SIP Call) and the Acid Rain Program (ARP) under Title IV of the Clean Air Act (CAA) 

Amendments of 1990. Each of these existing requirements has an approved ICR in place. The 

current ICRs are: CAIR (EPA ICR Number 2152.04/OMB Control Number 2060-0570), NOX

SIP Call (EPA ICR Number 1857.05/OMB Control Number 2060-0445) and ARP (EPA ICR 

Number 1633.15/OMB Control Number 2060-0258).

This 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 analysis included in EPA ICR Numbers

2152.04, 1857.05, and 1633.15, and estimates the change in burden resulting from the TR

beyond the scope of the existing ICRs for the NOX SIP Call requirements and the Acid Rain 

Program. The burden included in this ICR includes start-up and capital costs for units newly

affected by 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 NOX SIP call requirements 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 TR implementation.

In addition to the states and facilities listed in the actual rule text, EPA has included 

costs/burdens associated with TR ozone season-affected units for the following states: IA, KS, 

MI, MO, OK, and WI. The TR NOX Ozone Season Trading Program does not list these states in 

the current rule package, however EPA proposes to add them as part of a future supplemental 

rule package to the Transport Rule. In anticipation of this rulemaking, the costs/burdens 

associated 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 facilities. In the event that some or all of these states are not included in the future 

rulemaking, EPA will amend this ICR accordingly.
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EPA has published a Notice of Proposed Rulemaking in the Federal Register that details

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 NOX SIP Call, and (2) the addition of reporting 

requirements to support emissions trading and compliance in states covered by the TR. 

Throughout this Supporting Statement, the burden analysis 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 NOX 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 NOX emissions 

during the five-month ozone season, in addition to the existing requirement for reporting

emissions for the full year. These states are not among the 21 states previously subject to the 

NOX SIP Call or the 26 states 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 NOX and SO2 emissions annually, are now only required to report NOX for the 

TR ozone season. This requirement would not impose any additional start-up/ capital burden on 

states, 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 NOX and SO2

annual reporting, sources in Oklahoma are subject to TR NOX ozone season reporting, and 

sources in Kansas are subject to both the TR NOX and SO2 annual and NOX ozone season 

reporting requirements. These sources were not previously subject to CAIR or the NOX SIP Call,

and will need to install and operate CEMS (or an approved alternative) and meet 40 CFR part 75 

requirements for NOX and SO2, as applicable.

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 

NOX and SO2 emissions on a year round basis under the TR as currently required under CAIR. 

Sources located in Arkansas will, under the TR, continue to report for the ozone season only as

currently required under CAIR.
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Emission Trading Requirements

For this ICR, it is assumed that each state will eventually either adopt, in whole or in part,

the relevant TR SO2, NOX annual, and/or NOX ozone season trading rules. Initially, however,

EPA will administer the programs under the Federal Implementation Plans (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 NOX 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 emission reduction 

requirements and to provide the consistency needed to foster the allowance market, the 

designated representatives 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 NOX and SO2 emissions monitoring system has been installed and is 

properly operated at each affected unit. Emissions data reported under 40 CFR part 75 by TRaffected sources is also relied upon in part by 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 by this ICR include costs borne by newly affected units under the TR and 

annualized capital costs for existing CAIR or NOX SIP Call units that are not subject to the ARP. 

Emissions monitoring and reporting by sources in the trading programs is fundamental to 

the allowance trading system 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 emissions monitoring, recordkeeping and reporting

requirements, affected units are required to: (1) submit a monitoring plan and certification 

reports for each monitoring system, (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 report NOX and/or SO2 emissions in accordance with 40 CFR part 75. Sources with 

monitors already certified under 40 CFR part 75 may be exempt from initial certification 

requirements.

All participants in the Allowance Management System (AMS) are required to 

eithercomplete and submit an allowance transfer form for each allowance transfer, or to perform 

the transfer on-line. Participants in AMS that are not covered sources, such as allowance 
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brokers, fuel suppliers, and environmental groups are also required to file a onetime account 

information application to establish accounts in AMS. 

2.0 Need for and Use of the Collection

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 NOX SIP Call, 

promulgated in 1998, was largely upheld by 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) by identifying NOX and SO2 emissions that must be prohibited with respect to 

the PM2.5 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 years after the 

Administrator finds that (1) a state 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 state 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).
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2.2 Practical Utility/Users of the Data

Emission Reporting Requirements

Emissions 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

Regional 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 analyses. 

Such projects include:

● Evaluation of existing control strategies, such as the NOX SIP Call, for states and larger

areas;

● Evaluation of proposed control strategies for states and larger areas, including

applications of regional scale models;

● Development of national control strategies and preparation of Regulatory Impact

Analyses (RIAs);

● Preparation and publication of national summaries of emissions, including trend analyses;

● As a database 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 SO2 emissions. 

This report is required by Section 406 of the CAA and is due on a five year cycle that

began on January 1, 1995. The report must contain an inventory of national annual SO2

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 analyses of the impact of new or modified

sources within an area. EPA's Emission Factor and Inventory Group (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 emissions from sources. Typically 

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 collection 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 with
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nonattainment areas rely on current emissions information from point, nonpoint, and mobile 

sources to revise their SIPs and to plan for emission reductions mandated by the CAA. In 

addition, a state-wide inventory compiled at least every three years for all point, nonpoint, and 

mobile sources is considered to be a key tool to assist states in meeting CAA requirements that 

address emissions tracking, compliance issues, and mid-course adjustments. State-wide 

emission inventories can be used by states affected by pollution transport from upwind areas to 

develop more efficient control strategies to meet NAAQS. State-wide emission inventories that 

were developed by EPA (the National Emissions Inventory, or NEI) are being used by the 

Regional Planning Organizations (RPOs) as the starting point for the development of state-wide 

emission inventories used in the regional haze program to define control strategies.

Emission Trading Requirements

Permit applications, including proposed compliance plans, are used by states and EPA to

issue operating permits. A permit application is legally binding 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 comply. 

Because permit applications and permits are public documents, they may be used by the public to 

examine activities undertaken by 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 NOX and SO2 emissions, and therefore in assisting states in 

meeting the ozone and fine particulate matter NAAQS. By reducing levels of NOX and 

SO2 emissions, the trading programs reduce the adverse effects of the transport of ozone, 

ozone precursors, and fine particles from upwind states.

● EPA enforces 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.

Information collected on allowance transfers is used by EPA to track allowances for the 

purpose of determining compliance with the NOX and SO2 trading programs. Information on 

allowance transfers is also used by participants in the allowance market and the public to 

evaluate the activities of affected sources, and by EPA for program evaluation.

Together, the AMS, operating permits, and emissions data help to provide the 

accountability to allow the NOX and SO2 trading programs to function without more stringent 

command and control approaches.
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3.0 Nonduplication, Consultations, and Other Collection Criteria

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 states to report such data if the sources are subject to the monitoring and 

reporting requirements of 40 CFR part 75. The direct reporting of data from sources to EPA will 

minimize the reporting burden on states. 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 NOX and SO2 trading programs

are integrated with existing reporting formats under 40 CFR part 75. These reporting formats are 

currently 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 quarterly reporting requirements, or both, only

one submission will need to be made on a quarterly basis. (CAIR trading program reporting will 

be superseded by TR reporting.)

3.2 Public Notice Required Prior to ICR Submission to OMB

The preamble to the proposed rule was provided 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 clarify EPA's logic in developing the emissions reporting 

requirements contained within the rule and to answer questions. Information arising 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 NOX Budget Program, and the 

NOX SIP Call to address the court's concerns related to "emissions from sources that contribute 
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significantly and interfere with maintenance" in another state. 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 states that participated in the NOX SIP Call or OTC 

programs to discuss lessons learned in those programs when formulating the emission trading 

requirements of CAIR. Additionally, EPA has had frequent interaction with affected sources and 

states in the course of implementing the Acid Rain, NOX 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 ICR, as appropriate.

3.4 Effects of Less Frequent Collection

Emission Reporting and Trading Requirements

Submittal of 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 exceeded. If this information collection were not carried out annually for

sources subject to the TR, EPA would not be able to verify that emission reductions necessary to 

meet each state's NOX and SO2 emission budgets were being achieved. Because the NOX and 

SO2 budgets prescribed have been deemed essential in order to aid downwind states in attaining 

the NAAQS in a timely manner, data collected less frequently would be of little or no use.

Quarterly collections of emissions data allows for frequent checking of data for errors 

and provides rapid feedback to industry of needed adjustments to data collection systems, 

thereby promoting more accurate and reliable emissions data. Also, existing federal and state

emission monitoring programs often require quarterly reporting, or in some cases, monthly. Less 

frequent collection, such as semi-annually or annually, would increase the amount of preparation 

and review time at the end of the reporting period both for 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.
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As required by 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 state and are then treated as "state-sensitive" by

EPA. The potentially state-sensitive items include the following: Process rate, boiler design 

capacity, emission estimation codes, percent space heat, operating rate, and maximum operation 

rate/hour. Where federal and state requirements are inconsistent, 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 The Respondents and the Information Requested

4.1 Respondents/Standard Industrial Classification (SIC) Codes

Emission Reporting and Trading Requirements

This ICR estimates a burden for affected industry sources to monitor NOX and SO2 mass

emissions and demonstrate compliance with NOX and SO2 control measures. Sources report data 

directly to EPA as required to meet the monitoring and reporting requirements of 40 CFR part 

75. This rule affects large electric utility sources which are generally 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 NOX 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 the previously accounted for reporting burden 

would also change. Only the incremental changes to the ARP and NOX 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 Tracking
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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 

§§ 97.416, 97.516, 97.616, and 97.716, a complete certificate of representation includes:

● Identification of the source and unit;

● Dates on which the unit commenced commercial operation;

● Name and contact information for the TR designated representative and alternate (if 

applicable);

● A list of the owners and operators 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 years 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 nonTitle V source could be affected under the TR, all TR-affected sources are assumed to be Title V 

sources for purposes of this ICR. 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 separately 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 NOX and SO2 mass emissions, and record 

and report emissions data using the requirements of 40 CFR part 75. The emissions monitoring 

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

unit at a source, (2) submit data for certification of each monitor, (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 quarterly NOX and SO2 mass

emissions data via direct electronic submission to EPA. Such data must include a certification 

statement by the designated representative of the facility attesting to the accuracy, truthfulness, 
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and completeness of the submission. Generally, all monitoring records are required to be kept 

for three years.

(ii) Respondent Activities

The primary tasks that will be performed by respondents to meet the emissions 

monitoring requirements are: (1) completing and submitting 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 hourly emissions data (this activity is 

generally performed electronically); (4) performing operation and maintenance activities

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

preparing quarterly reports of emissions data, and submitting these reports to EPA; and (6)

responding to error messages generated by such submissions. In addition, respondents will have 

to purchase the necessary monitoring hardware and electronic data reporting software (or

software upgrades).

5.0 The Information Collected – Agency Activities, Collection Methods, 

and Information 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 NOX and SO2 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 quarterly emissions 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 state's progress toward meeting its budgets and creating a summary

report of emissions. EPA uses a computer system to track and maintain monitoring and 

emissions information, and will also answer respondent questions and conduct audits of data 

submissions.
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5.2 Collection Methodology and Management

Emission Reporting Requirements

The EPA has established a central repository of inventory data for all states termed the

National Emissions Inventory (NEI) database. Emissions inventory data reported electronically

is stored in the NEI database and used by the EPA and by states 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 states, but the data must be supplied by the states in an electronic format. The EPA 

currently requires that states 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 quarterly emissions monitoring data, and (3) calculate the number 

of allowances to be deducted each year. These systems and databases are designed to provide 

easy access to information for use by the Agency, states, 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 sources and the de 

minimis nature of their emissions. In addition, some cogeneration units and solid waste 

incinerators are exempt from the TR if they meet 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 NOX annually, 50 tons of NOX
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during the ozone season (May 1 – September 30), 25 tons of SO2 annually, and calculate no 

more than these same amounts 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 sampling, and perform quality assurance or quality control 

tests. Moreover, emissions reporting requirements are significantly simplified for these units.

Gas- or oil-fired units that do not qualify for the low mass emissions unit provisions

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 Analysis of the final ARP regulations

(October 19, 1992), smaller utilities are more likely to be dependent on these oil- and gas-fired 

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 quarterly. 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 Estimating the Burden and Cost of the Collection

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, year-end compliance 

activities, submittal of monitoring plans, obtaining certification of each monitoring system, 

conducting monitor quality assurance activities, and recording and reporting data from CEM 

systems (or approved alternatives).

To estimate the burden and/or cost of each requirement, EPA utilized prior estimates of 

the costs of activities, estimates provided by affected utilities in comments to the Agency, and/or

estimates based 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 SO2 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 SO2 Group 2 (Alabama, Kansas, Maryland, Minnesota, 

Nebraska, New Jersey, and South Carolina);
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● Trading units located in a TR NOX Annual state (Alabama, Illinois, Iowa, Indiana, 

Kentucky, Maryland, 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 NOX ozone state .

The TR requires all affected sources to monitor their NOX emission rate, SO2 emission 

rate, and heat input in order to determine NOX mass emissions and SO2 mass emissions. Coalfired units use NOX, SO2, and flow CEMS to meet those requirements. Oil and gas units have 

alternatives. For SO2, these units can use fuel sampling and analysis (or an SO2 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 NOX emission rates. 

EPA will also allow certain low mass emissions units to use assumed emissions factors together 

with operational data to calculate emissions.

For purposes of this ICR, burdens and costs are calculated only in terms of incremental 

impacts for units located in TR states or subject to the ARP. Under the TR, and for purposes of

this ICR, the incremental ozone season burdens were limited to GA, KS, MN, NE, OK, and TX. 

Several states in the NOX SIP Call region are excluded from the TR's NOX Ozone Season 

Trading Program: CT, DC, DE, and MA. Similarly, units subject to the ARP already have much 

of the monitoring and reporting capability required under the TR. Finally, sources not subject to 

the TR could still have existing requirements for CEMS in some cases. Thus, it should be noted 

that the labor hours 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 graphical reference of state reporting classifications 

related to CAIR, the NOX SIP Call, and the TR.
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15

Table 6-1: 

State Reporting Classifications for the NOX SIP Call, CAIR, and the TR

State

NOX SIP Call 

Ozone

CAIR 

Ozone

CAIR 

Annual

(NOX & SO2) TR Ozone

TR Annual

(NOX & SO2)

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.)
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May 9, 2011

16

Table 6-1: 

State Reporting Classifications for the NOX SIP Call, CAIR, and the TR (cont.)

State

NOX SIP Call 

Ozone

CAIR 

Ozone

CAIR 

Annual

(NOX & SO2) TR Ozone

TR Annual

(NOX & SO2)

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 Not 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 these sources under the ARP and CAIR Programs.

Trading units in NOX/SO2 annual and ozone season states, in NOX/SO2 annual-only states 

in the CAIR region, or which report for the ARP, will have the smallest incremental burden with 

regard to monitoring and reporting. Acid Rain-affected units are already monitoring and 

reporting both NOX and SO2 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 NOX and SO2. 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 NOX and SO2. However, this ICR incorporates the 

burden and costs associated with monitoring at these CAIR units, including annualized capital 

costs that would continue to be born under the TR.
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May 9, 2011

17

Sources that are not affected by the ARP but were subject to the NOX SIP call are already

monitoring and reporting NOX emissions during the ozone season. In a TR-affected NOX/SO2

annual state, these sources will need to extend their monitoring and reporting throughout the year 

and add SO2 monitoring for the TR. These units will have a small additional burden associated 

with permit applications and certain allowance transactions.

TR-affected units in NOX/SO2 annual and ozone season states, or NOX/SO2-only states 

not in the NOX SIP Call or CAIR region are similarly impacted by the TR reporting 

requirements. These states have ARP-affected units that are already monitoring and reporting 

SO2 emissions and NOX rates on a year round basis and in accordance with 40 CFR part 75. 

These sources will need to report NOX mass emissions year round and, for the NOX/SO2 annual 

and ozone season states, must also report ozone season NOX mass emissions. These sources are 

already measuring and reporting SO2 mass emissions, which requires heat input measurement 

that can be used with the NOX emission rate information to calculate NOX mass emissions. 

Therefore, these sources would need to make minor modifications to their reporting practices in 

order to report NOX mass emissions under the TR, but would not likely need to purchase 

additional monitoring equipment. The non-ARP-affected units in these states were required to 

monitor under 40 CFR part 75 with the implementation of CAIR, and these requirements

continue under the TR. The monitoring burden depends in part on the type 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 apply to the 

unit under other regulatory programs. This ICR includes updated estimates for all units 

previously affected under CAIR and adds newly affected sources in TR states.

TR-affected units in TR ozone season states that are in CAIR will continue monitoring 

NOX under 40 CFR part 75 during the ozone season. The burdens and costs associated with 

monitoring and reporting were previously reflected in the CAIR ICR but are now included in this 

ICR. TR-affected units in TR ozone season states that are not subject to the ARP, CAIR, or in 

the NOX SIP Call region must install NOX monitoring systems to comply with 40 CFR part 75

during the ozone season.

Sources will be subject to TR NOX and SO2 monitoring and reporting requirements 

starting in 2012. Table 6-5 shows the burden associated with monitoring NOX and SO2 under the 

TR at various types 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.
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18

Under the TR, the designated representative for each 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 certificates of representation, and that such revisions 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).

(iii) Respondent Monitoring Activities

For monitoring, the burdens differ greatly 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 follows:

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 states, the owner or operator will incur

some small amount of burden and costs associated with DAHS upgrades for reporting 

ozone season emissions. 

3) For the non-Acid Rain units in NOX/SO2 annual and ozone season TR states that are in 

the CAIR region, the burdens and costs reflect arranging for SO2 CEMS purchase (as 

required) and oversight of the certification process. 

4) For non-Acid Rain/CAIR annual units in NOX/SO2 annual and ozone season TR states 

burdens reflect purchase and certification of NOX and SO2 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 managerial and technical staff to review

the regulatory requirements as well as the XML formats and instructions associated with 
Transport 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 ICR -- 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 per year after year 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 year. (The time for the other 

sources is accounted for in other ICRs.)

DAHS Debugging

Based on experience with the ARP and CAIR Programs, 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 NOX SIP Call programs. Consistent with the existing 40 CFR part 75 ICR, the Agency

estimates that about 14 managerial and 80 technician hours will be spent on this task in the first 

year 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 previously subject to CAIR, are expected to incur the "subsequent years" burden.

Monitoring Plans

The regulations require 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-affected units, however, there will be burdens associated with 

certifying existing monitors 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, EPA estimates that approximately ten percent of all units will have to recertify each year 

following the year in which the initial certification occurs. The ICR incorporates a labor burden 

estimate generally consistent with existing Agency models for the labor 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 double counting would occur because a portion of the labor incurred
Transport Rule ICR

May 9, 2011

20

for the certification or recertification event replaces the labor burden that is generally allocated to

the annual relative accuracy test audit (RATA) in the year in which the certification event occurs.

Quality Assurance

Quality assurance (QA) activities and other routine maintenance for monitoring systems 

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 ICR, 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 rely 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 ICRs, the labor burden is expected to 

be almost entirely technician labor.

Quarterly Reports

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

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

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

(5) managerial review. The existing Acid 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 quarterly emissions data from affected units. 

The Agency estimates that these activities will require 4,500 hours per year (see Table 6-10).

(v) Respondent Allowance Transaction Activities

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 believes that each 

transaction will involve about one hour each of managerial and technician time.

(vi) Agency Allowance Transaction Activities
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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 state exceeding compliance assurance levels would be 160 

hours, however the agency assumes that zero states would exceed the limit during the 2012-2013 

time period. The Agency estimates that these activities will require 290 hours per year (see 

Tables 6-8 and 6-9).

6.2 Estimating Respondent Costs

Table 6-4 presents state 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-year 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 state agencies is $40.28 per hour, 

and the labor rate for managerial employees at state agencies is $48.93. These labor rates 

include benefits and overhead, and are derived from data shown on the Bureau of Labor 

Statistics website at http://stats.bls.gov/news.release/ecec.toc.htm. Wage and salary rates are 

shown at the link “Table 3: State and local government, by major occupation and industry group 

(December 2010)." The wage and salary rates from this table account for benefits provided to 

workers. When considering both technical and managerial hours, labor costs for state 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 year per respondent for the emissions reporting 

requirements.

In estimating labor costs for industry, EPA used 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 Employment Cost 

Index year 2010.

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 2011-GS" (http://opm.gov/oca/11tables/html/gs.asp) using the factors in 

Table 6-2 below.
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Table 6-2: 

Determination of Federal Wage Rates

Labor Category Factors Total

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

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

Factor (1/11) 0.09

$6,881 

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

Factor (1/8) 0.13

$4,637 

Annual Applicable Salary of Permit Staff $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 ICR, EPA has concluded that the Capital and Operations and 

Maintenance Costs estimated under the NOX 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 NOX SIP Call programs, and 

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

ARP-affected units in CAIR states are not expected to incur any non-labor costs 

associated with this program. Based on the existing CAIR ICR, the total non-labor cost for 

capital/start-up items for Acid Rain units in other states that would be subject to the TR is 

estimated at $4,000 per unit for CAIR-affected units that are not in the NOX 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 SO2 analyzer (estimated at $42,525). For 
Transport 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 SO2 analyzer costs, while the other units will require some combination of a 

NOX diluent, SO2, 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 commonly bundled with equipment 

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

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

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

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

beyond the basic contract cost.

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 by 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 Maintenance 

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 years. Conversely, operating and maintenance costs are 

those costs which are incurred on an annual or other scheduled basis. For instance, costs 

associated with quality assurance activities, such as spare parts or contractor costs for work, will 

be incurred on an annual basis.

(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 capital 
Transport Rule ICR

May 9, 2011

24

purchases varies from $2,304 to $29,572 per year per unit, depending on the type of monitoring

methodology. Table 6-5 contains a breakdown of annual costs by 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 50 states 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 Title V permit application submission or allowance transfers can involve 

nearly two thousand sources. The number of units which will be required to install a particular 

type of monitoring equipment is fewer since many already have the necessary monitoring 

equipment, especially if they are ARP units and/or are in CAIR states. Table 6-5 gives 

estimates of annual industry burdens beginning in 2012. These burdens include monitoring, 

reporting, and other activities involved in participating in an emissions trading program. The 

total number of respondents is estimated to be 1,201 facilities. Tables 6-6 through 6-10 give 

estimates of Agency burdens 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 $380,306
Transport Rule ICR

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6.5 Reasons for Change in Burden

Emission Reporting and Trading Requirements

The largest 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 these 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 by persons to generate, maintain, retain, disclose or provide information to,

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

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

verifying information; processing, 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 disclosing 

the information. An agency may not conduct or sponsor, and a person is not required to respond 

to, a collection of information unless it displays a currently valid OMB control number. The 

OMB control numbers for EPA's regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.

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

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

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

Docket ID 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 for 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 electronically. 

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

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

Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office 

for EPA. Please include EPA Docket ID No. EPA-HQ-OAR-2009-0491 and OMB Control 

Number 2060-NEW in any correspondence.
Transport Rule ICR

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Table 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/Hr1

Tech. 

$40.28/Hr1

Respondent 

Hours/Yr

Labor 

Cost/Yr

Number of 

Respondents

Total 

Hours/Yr2

Total 

Cost/Yr3

One-time (Annualized)

Read the reporting 

requirements of the 

rule 0.33 0.33 0.66 $29 104 69 $3,016

Total 104 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

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Table 6-5:

Annual Industry Respondent Burden and Cost by Activity

Respondent

Labor 

Cost/Year

Annual Capital

Manager 

$94.04

Per Hour 

(2010)

Technical 

$65.21

Per Hour 

(2010)

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, Oklahoma (Previously Not Affected)

a. DAHS modification 

(facilities) 2 4 6 $449 $1,333 35 210 $62,367

b. Solid Fuel: SO2, NOX, 

and Flow CEMS (units) 34 23 57 $4,697 $29,752 7 399 $241,144

c. Gas-Oil: NOX CEMS 

and Appendix D fuel 

monitoring (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 30 $2,533 $2,304 29 870 $140,270

(cont.)
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May 9, 2011

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Table 6-5:

Annual Industry Respondent Burden and Cost by Activity (cont.)

Respondent

Labor 

Cost/Year

Annual Capital

Manager 

$94.04

Per Hour 

(2010)

Technical 

$65.21

Per Hour 

(2010)

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 Remains)

a. DAHS modification 

(facilities) 2 4 6 $449 $600 161 966 $168,876

b. Solid Fuel: NOX, and 

Flow CEMS (units) 0 0 0 $0 $29,752 1 0 $29,752

c. Gas-Oil: NOX CEMS 

and Appendix D fuel 

monitoring (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

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Table 6-5:

Annual Industry Respondent Burden and Cost by Activity (cont.)

Respondent

Labor 

Cost/Year

Annual Capital

Manager 

$94.04

Per Hour 

(2010)

Technical 

$65.21

Per Hour 

(2010)

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: NOX, and 

Flow CEMS (units) 0 0 0 $0 $22,500 6 0 $135,000

c. Gas-Oil: NOX CEMS 

and Appendix D fuel 

monitoring (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: NOX, and 

Flow CEMS (units) 0 0 0 $0 $29,752 64 0 $1,904,128

b. Gas-Oil: NOX CEMS 

and Appendix D fuel 

monitoring (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

Manager 

$94.04

Per Hour 

(2010)

Technical 

$65.21

Per Hour 

(2010)

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 $637 261 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

Manager 

$94.04

Per Hour 

(2010)

Technical 

$65.21

Per Hour 

(2010)

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

Manager 

$94.04

Per Hour 

(2010)

Technical 

$65.21

Per Hour 

(2010)

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, Oklahoma (Previously Not Affected)

a. Solid Fuel: SO2, NOX, 

and Flow CEMS (units) 15 48 63 $4,541 $2,800 1 63 $7,341

b. Gas-Oil: NOX CEMS 

and Appendix D fuel 

monitoring (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

Manager 

$94.04

Per Hour 

(2010)

Technical 

$65.21

Per Hour 

(2010)

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 Remains)

a. Solid Fuel: SO2, NOX, 

and Flow CEMS (units) 15 48 63 $4,541 $2,800 1 63 $7,341

b. Gas-Oil: NOX CEMS 

and Appendix D fuel 

monitoring (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

Mississippi, Florida, and Louisiana (Now Ozone Season Only)

a. Solid Fuel: SO2, NOX, 

and Flow CEMS (units) 15 48 63 $4,541 $2,800 1 63 $7,341

a. Gas-Oil: NOX CEMS 

and Appendix D fuel 

monitoring (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

Manager 

$94.04

Per Hour 

(2010)

Technical 

$65.21

Per Hour 

(2010)

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: NOX, and 

Flow CEMS (units) 15 48 63 $4,541 $2,800 6 378 $44,044

b. Gas-Oil: NOX CEMS 

and Appendix D fuel 

monitoring (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, Oklahoma (Previously Not Affected)

a. Solid Fuel: SO2, NOX, 

and Flow CEMS (units) 50 600 650 $43,828 $31,949 7 4,550 $530,439

b. Gas-Oil: NOX CEMS 

and Appendix D fuel 

monitoring (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

Manager 

$94.04

Per Hour 

(2010)

Technical 

$65.21

Per Hour 

(2010)

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 Remains)

a. Solid Fuel: NOX, and 

Flow CEMS (units) 40 400 440 $29,846 $31,949 1 440 $61,795

b. Gas-Oil: NOX CEMS 

and Appendix D fuel 

monitoring (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

Mississippi, Florida and Louisiana (Now Ozone Season Only)

a. Solid Fuel: NOX, and 

Flow CEMS (units) 40 400 440 $29,846 $31,949 6 2,640 $370,768

b. Gas-Oil: NOX CEMS 

and Appendix D fuel 

monitoring (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 

$94.04

Per Hour 

(2010)

Technical 

$65.21

Per Hour 

(2010)

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: NOX, and 

Flow CEMS (units) 40 400 440 $29,846 $31,949 64 28,160 $3,954,854

b. Gas-Oil: NOX CEMS 

and Appendix D fuel 

monitoring (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

Manager 

$94.04

Per Hour 

(2010)

Technical 

$65.21

Per Hour 

(2010)

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

Compliance Assurance 

Activites1. .5 1 1.5 $112 0 0 0

TOTAL 185,132 $26,225,946

1. Assumes that no States 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 

Source1

Total Burden 

(Hours) Total Cost

EPA reviews certificates of 

representation and records 

information.20.5 $24.75 600 $29,628

Review 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. 2011 dollars.

2. Assumes 1201 sources submit a certificate of representation.

3. Assumes 240 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 Report1

Number 

of

Reports2

Total Burden 

per Year 

(Hours)

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 (Hours) 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 

Occurrence1

Total Burden2

(Hours) Total Cost

Review 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 

Compliance Assurance Provisions31 $49.49 40 $1,980 

TOTAL 90 $3,217

1. 2011 dollars.

2. Assumes 20 transfers and 100 optional deduction forms are submitted annually.

3. Assumes zero states would exceed the limit during the time period 2012-2013.

Table 6-10:

Agency Burden – Aggregate

Information Collection Activity Total Burden (Hours) Total Cost1

Annual allocation of allowances to existing and new 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 states and facilities listed in the final rule text, EPA has included costs/ 

burdens associated with TR NOX Ozone Season Trading Program for the following states: IA, 

KS, MI, MO, OK, and WI. The TR NOX Ozone Season Trading Program does not list these 

states in the current rule package, however EPA will propose, as part of a future supplemental 

rule package, that these states be covered by the TR NOX Ozone Season Trading Program. In 

anticipation of this rule making, the costs/burdens associated with this Program in these states

are included in the ICR to allow for a full accounting for the TR program at maturity. In the 

event that some or all of these states are not included in the future rulemaking, EPA will amend 

this ICR accordingly.

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 $22,074
Transport Rule ICR

May 9, 2011

41

Table 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/Hr1

Tech. 

$40.28/Hr1

Respondent 

Hours/Yr

Labor 

Cost/Yr

Number of 

Respondents

Total 

Hours/Yr2

Total 

Cost/Yr3

One-time (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 

Source1

Total Burden 

(Hours) Total Cost

EPA reviews certificates of 

representation and records 

information.2

0.5 $25 24 $1,188

Review 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 $6,830

1. 2011 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 Report1

Number 

of

Reports2

Total Burden 

per Year 

(Hours)

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 (Hours) Total Cost

Initial and annual allocation of allowances to 

existing and new units.10 $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 

Occurrence1

Total Burden2

(Hours) Total Cost

Review 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 

Compliance Assurance Provisions.

3

160 7901 0 0

TOTAL 20 $741

1. 2011 dollars.

2. Assumes 10 transfers and 10 optional deduction forms are submitted annually.

3. Assumes zero states would exceed the limit during the time period 2012-2013.

Table A-7:

Agency Burden – Aggregate

Information Collection Activity Total Burden (Hours) Total Cost1

Annual Allocation of Allowances to existing and new 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. 2011 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

Manager 

$94.04

Per Hour 

(2010)

Technical 

$65.21

Per Hour 

(2010)

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 $3,114

Certificate of 

Representation 0.50 0.50 1.00 $80 48.00 48.00 $3,736

Startup/Capital Items

Kansas, Minnesota, Nebraska, Oklahoma (Previously Not Affected)

a. DAHS modification 

(facilities) 2.00 4.00 6.00 $449 $1,333 10 60 $17,819

b. Solid Fuel: SO2, NOX, 

and Flow CEMS (units) 34.00 23.00 57.00 $4,697 $29,752 4 228 $137,797

c. Gas-Oil: NOX CEMS 

and Appendix D fuel 

monitoring (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 $91,901

(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

Manager 

$94.04

Per Hour 

(2010)

Technical 

$65.21

Per Hour 

(2010)

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: NOX, and 

Flow CEMS (units) 0.00 0.00 0.00 $0 $29,752 6 0 $178,512

c. Gas-Oil: NOX CEMS 

and Appendix D fuel 

monitoring (units) 0.00 0.00 0.00 $0 $19,200 34 0 $652,800

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

Manager 

$94.04

Per Hour 

(2010)

Technical 

$65.21

Per Hour 

(2010)

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 $83,425

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 $83,425

(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 

$94.04

Per Hour 

(2010)

Technical 

$65.21

Per Hour 

(2010)

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, NOX, 

and Flow CEMS (units) 15 48 63 $4,541 $2,800 1 63 $7,341

b. Gas-Oil: NOX CEMS 

and Appendix D fuel 

monitoring (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 $24,635

(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

Manager 

$94.04

Per Hour 

(2010)

Technical 

$65.21

Per Hour 

(2010)

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, NOX, 

and Flow CEMS (units) 15 48 63 $4,541 $2,800 1 63 $7,341

b. Gas-Oil: NOX CEMS 

and Appendix D fuel 

monitoring (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 Oklahoma

a. Solid Fuel: SO2, NOX, 

and Flow CEMS (units) 50 600 650 $43,828 $31,949 4.00 2600 $303,108

b. Gas-Oil: NOX CEMS 

and Appendix D fuel 

monitoring (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 

$94.04

Per Hour 

(2010)

Technical 

$65.21

Per Hour 

(2010)

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 $81,121

Iowa, Michigan, Missouri, Wisconsin (Ozone Season Status Changes, Annual Status Remains)

a. Solid Fuel: NOX, and 

Flow CEMS (units) 40 400 440 $29,846 $31,949 6.00 2640 $370,768

b. Gas-Oil: NOX CEMS 

and Appendix D fuel 

monitoring (units) 20 375 395 $26,335 $17,818 34.00 13430 $1,501,187

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 $132,355

(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

Manager 

$94.04

Per Hour 

(2010)

Technical 

$65.21

Per Hour 

(2010)

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 $42,435

Allowance Transfers

1 1 2 $159 500 1,000 $79,625

TOTAL

31,538 $4,461,492