______________________________________________________________________________

Supporting Statement

Ambient Oxides of Sulfur Monitoring Regulations: 

Revisions to Network Design Requirements

EPA ICR # 2370.01

PART A

1. Identification of the Information Collection

 (a) Title of the Information Collection

 “Ambient Oxides of Sulfur Monitoring Regulations: Revisions to Network Design 

Requirements – Proposal”

(b) Short Characterization/Abstract

This Information Collection Request (ICR) includes ambient air monitoring data 

reporting and recordkeeping activities associated with the 40 CFR part 58 Ambient Air Quality

Surveillance regulations. These data and information are collected by State and local air quality

management agencies and reported to the U.S. Environmental Protection Agency (EPA). 

The EPA is proposing to revise the network design requirements for the oxides of sulfur

(SOX), specifically sulfur dioxide (SO2), to support the proposed changes to the primary National 

Ambient Air Quality Standards (NAAQS) for SO2. Presently, state agencies, and local agencies 

when delegated by the state, are required to operate minimum numbers of EPA-approved SO2

monitors based on (1) the population of each of their Core Based Statistical Areas (CBSA) and 

the amount of SO2 emissions within those CBSAs and (2) the amount of SO2 emissions emitted 

within each state. 

EPA is proposing a two-pronged monitoring network design. The two prongs are 

designed to: 1) monitor in CBSAs where there is an increased coincidence of population and SO2

emissions and 2) to proportionally require monitors in states corresponding to the amount of SO2

emissions that state contributes to the national emissions inventory. The proposed network 

design corresponds to the proposal of the new NAAQS based on peak 1-hour daily maximum

concentrations, or 1-hour NAAQS, and the associated proposed range of levels from 50 to 100 

parts per billion (ppb). The introduction of the 1-hour NAAQS and the range of levels are 

intended to protect against peak, shorter term exposure risks. 

In the first prong of the SO2 network design, EPA is proposing minimum SO2 monitoring 

requirements which call for monitors in CBSA by developing a Population Weighted Emissions

Index (PWEI) that uses population and emissions inventory data at the CBSA1level to assign 

required monitoring for a given CBSA (population and emissions being obvious relevant factors 

in prioritizing numbers of required monitors). The PWEI for a particular CBSA is calculated by

 

1 CBSAs are defined by the U.S. Census Bureau, and are comprised of both Metropolitan Statistical Areas and 

Micropolitan Statistical Areas (http://www.census.gov). 
2

multiplying the population (using the latest Census Bureau estimates) of a CBSA by the total 

amount of SO2 emissions in that CBSA. The CBSA emission value is in tons per year, and is 

calculated by aggregating the county level emissions for each county in a CBSA. We then 

normalize by dividing the resulting product of CBSA population and CBSA SO2 emissions by

1,000,000 to provide a PWEI value, the units of which are millions of people-tons per year. 

Those CBSAs with a PWEI value of 1,000,000 or more would be required to operate three 

monitors within that CBSA. Those CBSAs with a PWEI value between 1,000,000 and 10,000 

would be required to operate two monitors within that CBSA. Those CBSAs with a PWEI value 

between 10,000 and 5,000 would be required to operate one monitor within that CBSA. In 

summary, EPA estimates that this first prong of the proposed SO2 network design will require 

231 monitoring sites in 132 CBSAs.

In the second prong of the proposed monitoring network design, EPA is proposing to 

require a monitor or monitors in each state, allocated by state-level SO2 emissions. In this prong, 

EPA proposes to distribute approximately 114 sites, based on the corresponding percent 

contribution of each individual state to the national anthropogenic SO2 emission inventory. This 

prong of the network design is intended to allow a portion of the overall required monitors to be 

placed where needed, independent of the PWEI, inside or outside of CBSAs. EPA proposes to 

require monitors, using states as the geographic unit for allocation purposes, in proportion to a 

state’s SO2 emissions, i.e., a state with higher emissions will be required to have a proportionally 

higher number of monitors. The proposed percent contribution of individual states is based on 

the most recent National Emissions Inventory, with SO2 emissions being aggregated by state. 

Each one percent (after rounding) would correspond to one required monitor. Further, EPA 

proposes that each state have at least one monitor required as part of this second prong, even if a 

particular state contributes less than 0.5% of the total anthropogenic, non-fire national emissions 

inventory.

In addition to the two prongs of the proposed SO2 network design, we propose that the 

Regional Administrator will have discretion to require monitoring above these minimum 

requirements under prongs 1 and 2, as necessary to address situations where the minimum 

monitoring requirements are not sufficient to meet monitoring objectives noted above. EPA 

recognizes that the minimum required monitors in the proposed network design under the two 

prongs described above are based on indicators that may not provide for all the monitoring that 

may be necessary in an area.

EPA anticipates that there will likely be a need for capital funding to allow for up to twothirds of the minimally required monitors to be established as new monitoring sites or cause 

some existing sites to be relocated under the proposed network design. The establishment costs 

of monitoring sites can include property access or leasing fees, power and telecom services, site 

security, a climate controlled monitoring shelter, pollutant analyzers, supporting quality 

assurance hardware and consumables, and data collection and dissemination hardware and 

software.

EPA has also proposed the requirement that State and local air quality management 

agencies shall report the 1-hour average and the maximum 5-minute average concentration of the 

twelve 5-minute block averages in each hour. The requirement to report the maximum 5-minute 
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average that exist in an hour impose an increased burden by increasing the data quality assurance 

and validation workload and by through increased data processing in the field, which may not be 

a large burden for those State and local agencies utilizing digital data acquisition methods. 

EPA and others (e.g., State and local air quality management agencies, environmental 

groups, academic institutions, and industrial groups) use the collected monitoring data for many 

purposes. Some of the more prominent uses include informing the public and other interested 

parties of an area’s air quality, judging an area=s (e.g., county, city, neighborhood) air quality in 

comparison with the established health or welfare standards (including both national and local 

standards), evaluating an air quality management agency’s progress in achieving or maintaining 

air pollutant levels below the national and local standards, developing and revising State 

Implementation Plans (SIPs) in accordance with 40 CFR part 51, evaluating air pollutant control 

strategies, developing or revising national control policies, providing data for air quality model 

development and validation, supporting enforcement actions, documenting episodes and 

initiating episode controls, air quality trends assessment, and air pollution research.

The State and local air quality management agencies with responsibility for reporting 

ambient air quality data and information as requested in this ICR submit these data electronically 

to the EPA’s Air Quality System (AQS) and AIRNow databases. Quality assurance/quality

control records and monitoring network documentation are also maintained by each State and 

local agency, in AQS electronic format where possible.

Although the State and local air quality management agencies are responsible for the 

operation of the air monitoring networks, the EPA funds a portion of the total costs through 

federal grants. Some of these grants require an appropriate level of contribution, or match, from 

the State/local air quality management agencies. The costs shown in this ICR are the total costs 

incurred for the monitoring program regardless of the source of the funding. 

For the purpose of this ICR, we have estimated the maximum potential burden for the 

options being considered. The ICR estimates for the final rule will present the burden estimate 

based on the requirements contained in the final rule. The burden estimates are for the 3-year 

period of 2011 through 2013.

This Information Collection is estimated to involve 93 respondents for a total 

approximate cost of $13,863,950 (total capital, and labor and non-labor operation and 

maintenance) and a total burden of 172,449 hours. The labor costs associated with these hours is

$9,247,885. Included in the $13,863,950 total are other costs of non-labor operations and

maintenance of $903,787 and equipment and contract costs of $3,712,278. In addition to the

costs at the State and local air quality management agencies, there is a burden to EPA of total of

5,431 hours and $ 382,786.

2. Need for and Use of the Collection

(a) Need/Authority for the Collection
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The information requirements included within this ICR are necessary to provide the EPA 

with ambient air quality surveillance data to determine the United States air quality status, to 

make attainment decisions with respect to the NAAQS, to assist in developing necessary control 

strategies to ensure attainment of the NAAQS, to assess national trends in air pollution, to inform 

the public of air quality, and to determine the population’s exposure to various ambient air 

pollutants. The EPA’s goal of attaining the NAAQS in all areas of the United States is directly 

dependent upon the availability of ambient air quality data requested in this information 

collection. Additionally, the EPA, State, and local air quality management agencies, 

environmental groups, industrial groups, and academic organizations use these data to study

atmospheric chemistry, e.g., the formation and fate of SO2, to determine the most appropriate 

and effective control strategies necessary to reduce air pollution.

The principal legal authority for this information collection is the Clean Air Act 42 

U.S.C. 7403, 7410, and 7511a, from which the 40 CFR part 58 regulations were promulgated.

Under 7403 (c), the Administrator is required to conduct a program of research, testing, 

and development of methods for sampling, measurement, monitoring, analysis, and modeling of 

air pollutants, specifically including a requirement to establish a national network to monitor, 

collect, and compile data with quantification of certainty in the status and trends of air emissions 

and air quality. This program will also include the development of improved methods and 

technologies to increase understanding of the sources of nitrogen oxides, its formation, transport, 

regional influences and trends, and interactions with other pollutants. 

Section 7410 (a) contains the SIP requirements, which include a requirement that each 

State submit a SIP that provides for the establishment and operation of appropriate devices, 

methods, systems, and procedures necessary to monitor, compile, analyze, and make available to 

the Administrator data on ambient air quality. 

2(b) Practical Utility/Users of the Data

The EPA Office of Air Quality Planning and Standards (OAQPS) uses the ambient air 

quality data included within this collection to make attainment decisions with respect to each air 

pollutant subject to NAAQS. For those areas that do not attain the NAAQS for one or more 

pollutants, the OAQPS, the affected EPA Regional Office, and the affected State or local air 

quality management agency will work to develop an appropriate SIP to address how the area=s 

air quality can be improved to meet the applicable NAAQS.

To identify how the nation is progressing in improving air quality, the OAQPS prepares 

annually the National Air Quality and Emissions Trends report (http://www.epa.gov/airtrends) 

using the ambient air quality data collected through this ICR. The State and local air quality 

management agencies use these data for multiple purposes including tracking their progress 

toward achieving and maintaining air quality within the established NAAQS and any statewide 

standards they have established. For example, the State of California has established a separate 

statewide ozone air quality standard that is more stringent than the NAAQS for ozone; therefore, 

they use ambient air data to determine compliance with both standards. 
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3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a) Non-duplication

This collection is not unnecessarily duplicative of information otherwise reasonably

accessible to the agency. The AQS and AIRNow systems, which contain information based 

solely on this collection, are the only national air quality data repositories available to the EPA. 

The ambient air quality surveillance data and related information collected through this 

information collection are not otherwise reasonably accessible to the EPA.

A few State and local air quality management agencies have their own data storage 

systems (e.g., the California Air Resources Board); however, most State and local air quality 

management agencies use the AQS and AIRNow as their primary repositories for all air quality

data.

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

The 1995 Paperwork Reduction Act requires that any agency developing a non-rule 

related ICR must solicit public comments for a 60-day period prior to submitting the ICR to 

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

3(c) Consultations

Through the course of planning, monitoring, and improving upon this collection and its 

associated regulation, the EPA regularly consults with affected State and local air quality 

management agencies through various methods including the regulatory process, regular 

meetings, and training courses. The EPA conducts annual work shops and training on the AQS 

reporting system, e.g., the annual AQS Conference. The EPA Regional Offices conduct annual 

ambient air monitoring meetings with their affected State and local air quality management 

agencies to assist these affected agencies with this collection and its associated regulation. The 

EPA’s OAQPS also meets regularly with leading State and local air monitoring managers to 

discuss the Nation’s ambient air monitoring program and this collection, via large monthly phone 

calls and smaller in person meeting two or three times per year. Starting in 1999, the Clean Air 

Scientific Advisory Committee (CASAC) established the subcommittee on fine particle 

monitoring to provide advice to EPA on various implementation aspects of the PM monitoring 

networks. In addition, CASAC also has established a monitoring strategy subcommittee to 

extend consultation to the entire network.

3(d) Effects of Less Frequent Collection

State and local air quality management agencies would collect and report ambient air 

quality data without the 40 CFR 58 regulations associated with this collection. Sanctions do not 

automatically accrue to State or local air quality management agencies that fail to meet these 

requirements. The 40 CFR part 58 regulations and this associated collection do provide for a 

consistent system for reporting and record keeping that would not exist without these 
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requirements. The effects of less frequent collection include:

• A national database that is not consistently updated and available for public 

consumption;

• Less timely attainment designations with respect to the NAAQS;

• More difficultly in identifying and repairing problems with an ambient air monitor--

i.e., data are used as to check a monitor’s operating condition, and reporting data less 

frequently would delay a State or local agency’s ability to recognize a problem with a 

monitor or a laboratory procedure; and

• The EPA would not be able to consistently answer questions from the public in a 

timely fashion regarding air quality in various areas of the country.

3(e) General Guidelines

All of the OMB’s general guidelines for information collections in 5 CFR 1320.6 are met 

by this ICR. None of the guidelines are exceeded.

• Data reporting on a quarterly basis is the requirement. Nearly all respondents 

voluntarily report on a monthly basis.

• Record retention is for no more than 3 years (most records are kept by the EPA data 

repository, not the affected State and local air quality management agencies)

• Information is maintained and reported in the standardized electronic AQS format.

3(f) Confidentiality

Information that is considered personal, private, proprietary, or confidential is not 

required for this collection. One purpose of collecting ambient air data through AQS and 

AIRNow is to inform the public of general air quality in ambient air (air considered generally 

accessible to the public), and as such, does not present a need for maintaining a confidential 

nature. Security measures are taken to prevent tampering with the AQS electronic database by 

limiting the access to the AQS mainframe only to authorized users

3(g) Sensitive Questions

This section is not applicable to this ICR because no information involving matters of a 

sensitive nature is collected.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents/SIC Codes
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This ICR affects State and local governments (SIC code 951, Administration of 

Environmental Quality Program) that are currently operating and maintaining established 

ambient air quality networks. The 40 CFR part 58 regulations associated with this request 

require that State and local air quality management agencies conduct the ambient air quality

surveillance and report the data to the EPA’s AQS. Although industrial, environmental, and 

research organizations may use the data available through the AQS, they are not required to 

report any information for this information collection. Data submittal to AIRNow is voluntary 

for all organizations, but most State and local agencies reporting to AQS also report to AIRNow.

4(b) Information Requested

(i) Data items, including record keeping requirements

These data items are submitted electronically to EPA’s AQS as required by 40 CFR part 

58. These data are stored electronically within the EPA’s AQS, and separate records kept by the 

State or local air quality management agency are not required.

• Hourly and sub-hourly (5-minute) ambient air pollutant concentrations of SO2

collected at SLAMS/PAMS sites.

• Precision and accuracy data for all SLAMS sites, PAMS, and Special Purpose 

Monitors (SPM).

• SLAMS monitoring network description information, including the site AQS 

identification number, site location, sampling and analysis method, operating 

schedule, monitoring objective, site’s scale of representation, identity of the urban 

area represented, and quality assurance plan.

• Results of the annual ambient air monitoring network and quality assurance plan 

review.

• Annual SLAMS summary report which includes the location, date, pollution source, 

and duration of each incident of air pollution during which ambient levels of a 

pollutant reached or exceeded the significant harm levels as defined in 40 CFR 

51.151, the certification of the report’s accuracy by a designated State air pollution 

control officer, and various other summary statistics as provided by the AQS system.

(ii) Respondent Activities

A model respondent would engage in the following activities to comply with this 

information request:

• Read the 40 CFR part 58 regulatory provisions and other EPA guidance (for example, 

please reference our Internet site at www.epa.gov/ttn/amtic.)
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• Plan ambient air monitoring activities, such as developing a quality assurance plan 

for the network operation and maintenance, developing and reviewing the ambient air 

quality surveillance network design, planning where to locate sites, plan how to 

maintain and operate each site, develop a data reporting and validation plan.

• Write the quality assurance plan for network operation and maintenance, the ambient 

air quality surveillance network plan, and the data reporting and validation plan. 

Submit these plans to the EPA Regional or Headquarters office for review, and 

approval if appropriate.

• Obtain on-site leases or agreements to locate ambient air quality surveillance 

equipment.

• Investigate vendors, and procure equipment necessary to meet the ambient air quality

network plan.

• Receive training for site operation and maintenance, quality assurance procedures, 

and data processing and reporting.

• Make arrangements for appropriate utility hookups for each ambient air quality

surveillance site, i.e., electricity, telephones, data lines for electronic submission of 

concentrations from automated analyzers.

• Install ambient air quality surveillance equipment and equipment shelter. Ensure 

security of the site.

• Conduct ambient air quality monitoring, incorporating all appropriate quality

assurance procedures such as calibrations, precision and accuracy checks, and, if 

necessary, concurrent monitoring.

• Validate the ambient air data for quality assurance considerations.

• Electronically submit the complete and validated ambient air data to the AQS and/or 

AIRNow data repositories.

• Prepare and submit to EPA annually the SLAMS sites summary report. 

Each of these activities are conducted using existing reporting and recordkeeping 

practices, including electronic submittal to the AQS and to AIRNow . If the 40 CFR part 58 

regulations did not exist, and presumably the related AQS and AIRNow, the quality assurance 

procedures, and the siting guidance did not exist, the State and local air quality management 

agencies would in a majority of cases conduct monitoring; however, methods used by each 

agency would vary and data would not be readily available to EPA and the public. The influence 

of the 40 CFR part 58 regulations has been to provide a nationally consistent mechanism for 

collecting ambient air quality data including uniform quality assurance procedures, data 
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collection and storage mediums (AQS), and uniform methodology. Without this regulations and 

associated ICR, managing and maintaining a national air quality program would be extremely

difficult, if possible.

5. THE INFORMATION COLLECTED--AGENCY ACTIVITIES, COLLECTION

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

The EPA conducts the following activities to implement this ICR and associated 

regulation:

• Periodically review the 40 CFR part 58 regulations to update the information 

collection and monitoring requirements in light of new technological developments 

or new air pollutant standards. Develop revisions to the regulations in response to 

legislative action and program changes.

• Establish, maintain, and support the AQS and AIRNow as the national repositories 

for all State and local air quality management agency ambient air quality data and 

monitoring information. Periodically evaluate and improve upon this system as new 

technologies, and new regulatory requirements would dictate.

• Answer respondent (generally State and local air quality management agencies, but 

also industrial organizations, environmental groups, and others) questions about 

ambient air monitoring, the 40 CFR part 58 regulatory requirements, and the AQS 

and AIRNow. This includes the establishment of the Ambient Monitoring 

Technology Information Center bulletin board, the AQS toll-free hotline, and other 

written or verbal communication.

• Support the quality assurance program by working within the EPA and with the 

respondents to evaluate precision and accuracy data, oversee the National 

Performance Audit Program, participate in systems audits, and conduct data 

validation checks on the AQS data submittal.

• Provide within the AQS mechanisms for statistical calculations, such as the number 

of times a particular ambient air quality monitoring site exceeds the NAAQS. 

Distribute the AQS data in various ways including upon written request, by Freedom 

of Information Act request, by press release, and in the annual National Air Quality

and Emissions Trends Report. 

• Provide adequate electronic storage space within the AQS for all ambient air quality

surveillance data and information.

• Provide various reports and graphics for users of AIRNow.
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5(b) Collection Methodology and Management

All State and local ambient air monitoring networks have access to and use wellestablished quality assurance procedures as defined in the Quality Assurance Handbook for Air 

Pollution Measurement Systems, Volumes I and II, EPA/600/R-94/038a & b. These documents 

ensure that all ambient air quality data are accurate and reliable. 

The EPA has provided and will continue to provide resources for the maintenance and 

operation of the AQS and AIRNow national data repositories. All data required by this 

collection are submitted electronically to reduce the burden of the collection and to improve data 

quality, agency efficiency, and responsiveness to the public. Various statistical and graphical 

summaries are also provided by the AQS and AIRNow systems which enhance the utility of the 

information for consumption by the public and all affected State and local air quality

management agencies. In submitting ambient air data into the AQS and AIRNow national 

repositories, we ensure that the data are publicly available, electronically stored, and 

electronically retrievable. State and local air quality management agencies and the EPA have 

been submitting data to the AQS since its inception in 1987.

5(c) Small Entity Flexibility

This collection contains a minimum amount of information in order to manage the air 

quality program for the United States. The smallest entities affected by this collection are local 

air quality management agencies, typically consisting of the governing agencies for a county or 

group of counties, or a smaller metropolitan area (e.g., cities with a population of 50,000). This 

collection reduces to the extent practicable and appropriate the burden on entities that provide 

ambient air quality data and information to or for the EPA, including with respect to small 

entities, as defined in the Regulatory Flexibility Act (5 U.S.C. 601(6)), the use of such 

techniques as:

• Establishing differing compliance or reporting requirements or timetables that 

account for the resources available to those who are to respond (e.g., the monitoring 

and reporting requirements decrease as the population of an area decreases, and 

various timetables for deploying ambient air monitoring stations are negotiated 

between the affected State or local air quality management agency and the EPA with 

consideration of the respondent’s resources); 

• Clarification, consolidation, or simplification of compliance and reporting 

requirements (e.g., by establishing, maintaining, and improving as needed the AQS 

and AIRNow national repositories for ambient air quality data and information);

• Exemption from coverage of the collection of information, or any part thereof (e.g., 

the EPA negotiates with State and local air quality management agencies to 

determine the most effective and most efficient ambient air quality networks with 

respect to the monitoring needs, technical abilities, and resources available to each 

affected agency).
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5(d) Collection Schedule

Ambient air quality surveillance data and precision and accuracy data for criteria air 

pollutants are submitted according to the schedule defined in 40 CFR 58.16. These current 

regulations require that State and local air quality management agencies report their data within 

90 days after the end of the quarter during which the data were collected. 

The annual SLAMS report is submitted by May 1 (effective 2010) of each year for data 

collected from January 1 through December 31 of the previous year in accordance with 40 CFR 

58.15. This certification applies to all SLAMS and all SPM monitoring data that have been 

submitted by May 1. 

The annual air quality surveillance network reviews are conducted and reports are 

submitted to the EPA on a schedule that is determined by the affected State or local air quality

management agency and the EPA Regional Office. 

Ambient air quality data and information are made available to the public at any time in 

various ways, including:

• Upon request to the appropriate EPA Regional office, or to the OAQPS;

• By Freedom of Information Act Request to the appropriate EPA Regional Office or 

the OAQPS;

• From the State or local air quality management agency responsible for collecting the 

ambient air quality data and information; 

• By obtaining access, through appropriate EPA channels, to the AQS and AIRNow to 

obtain the data electronically; 

• Through EPA public reports, such as the annual ANational Air Quality and Emissions 

Trends Report@; or

• Through the AIRNow data base and the AQI reporting mechanisms which include 

newspaper, television, Internet and other publicly available notices (see 

www.epa.gov/airnow).

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden

All activities listed with section 4 (b) (ii) of this ICR Supporting Statement are presented 

in Worksheet 1. The detailed burden and cost estimates for the different types of monitors are 
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based on information provided in the updated version of Guidance for Estimating Ambient Air 

Monitoring Costs for Criteria Pollutants and Selected Air Toxic Pollutants (prepared by Desert 

Research Institute for the EPA Office of Air Quality Planning and Standards, Air Quality

Assessment Division, Ambient Air Monitoring Group, January 2005). The cost estimates 

presented in this guidance document are based on existing literature and direct monitoring 

experience. The costs for equipment and supplies were verified with vendors. The monitoring 

costs are based on vendor quotes for the monitor type that EPA expects respondents to use to 

comply with the requirements. Costs for level of effort estimates are verified with selected State 

and local agencies. All cost values presented in the guidance document are adjusted to 2004 

dollars. 

For use in preparing the burden estimates for this ICR, costs for the monitoring 

requirements were inflated to 2011, 2012, and 2013. The cost escalation factors were estimated 

based on the appropriate Gross Domestic Product (GDP) price indices as reported in the report 

available at http://www.jsc.nasa.gov/bu2/inflateGDP.html. Tables showing the detailed burden 

estimate calculations are presented below. A summary of the average annual respondent burden 

costs follows.

Worksheet 1: Annual Average Respondent Burden Estimates

Collection

Activities

Total Labor Hours

Per Respondent Per Year

(93 respondents)

1. Network design 6

2. Site installation 14

3. Sampling & analysis 504

4. Maintenance & repairs 285

5. Data management 491

6. Quality assurance 334

7. Supervision 220

8. Meteorological 

Instrumentation 0

TOTAL 1854

6(b) Estimating Respondent Costs

All activities listed with section 4 (b) (ii) of this ICR Supporting Statement are included 

in the Worksheet 2. A summary of the average annual respondent burden costs follows.
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Worksheet 2: Annual Average Respondent Cost Estimates

Collection

Activities

Total Labor Cost 

Per Respondent Per Year 

(93 respondents)

1. Network design $363

2. Site installation $617

3. Sampling & analysis $25,388

4. Maintenance & repairs $15,310

5. Data management $26,134

6. Quality assurance $18,590

7. Supervision $13035

8. Meteorological 

Instrumentation $0

TOTAL $99,437

6(c) Estimating Agency Burden and Cost

We estimated the Agency burden and cost by using current burden and cost of the 

ambient air monitoring program related to this collection. We included burden and cost for the 

OAQPS, the ten Regional Offices, and associated contract activities. The in-house activities for 

this collection are completed by a variety of individuals with a variety of salaries; therefore, we 

used the actual salary as an average for computing the program costs. Actual contractor 

expenses were used for those activities completed using extramural resources. We estimated a 

total of 14,147 hours and $858,280 total agency burden.

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

Worksheet 3 shows the total respondent hourly burdens and costs which was taken from 

section 6(b) above for the estimated 93 respondents. The total labor burden for the respondents 

was estimated to be 172,449 hours at a total cost of $9,247,885.
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Worksheet 3: Annual Total Respondent Labor Burden/Cost Estimates

Collection

Activities

Total Labor Hours

Per Year

Total Labor Cost

Per Year

1. Network design 532 $33,796

2. Site installation 1,337 $57,396

3. Sampling & analysis 46,904 $2,361,123

4. Maintenance & repairs 26,520 $1,423,837

5. Data management 45,637 $2,430,494

6. Quality assurance 31,044 $1,728,939

7. Supervision 20,475 $1,212,300

8. Meteorological 

Instrumentation

0 0

TOTAL 172,449 $9,247,885

6(e) Bottom Line Burden Hours and Cost Tables

(i) Respondent Tally

Respondent Total Annual Burden =172,449 hours

Respondent Total Annual Labor Cost for O & M = $9,247,885

Respondent Total Annual Cost for Non-labor O & M = $903,787

Respondent Total Equipment/Contract Dollars = $3,712,278

Total Respondent Tally = $13,863,950

(ii) The Agency Tally

Agency Total Annual Burden = 14,147 hours

Agency Total Annual Cost = $858,280

(iii) Variations In The Annual Bottom Line.

We do not expect any significant variations in the annual bottom line for the ambient air 

monitoring networks for the clearance period requested.
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6(f) Reasons for Change in Burden

N/A

6(g) Burden Statement

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

is estimated to average 193 hours per respondent. Burden means the total time, effort, or 

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

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

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

validating, and verifying information, processing and maintaining information, and disclosing 

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

instructions and requirements; train personnel to be able to respond to a collection of 

information; search data sources; complete and review the collection of information; and 

transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a 

person is not required to respond to, a collection of information unless it displays a currently

valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 

CFR part 9 and 48 CFR chapter 15. 

To allow 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 established a public docket for this 

ICR under Docket ID No. OAR-2008-0338 which has been available for public viewing at the 

Air and Radiation Docket and Information Center Docket in the EPA Docket Center (EPA/DC), 

EPA West, Room B102, 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 Docket is (202) 

566-1742. An electronic version of the public docket was made available through EPA Dockets 

(EDOCKET) at http://www.epa.gov/edocket. The public was able to use EDOCKET 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 have been available electronically. The public 

was also advised to 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.

PART B OF SUPPORTING STATEMENT

This section is not applicable to this ICR because statistical methods are not used in the 

data collection associated with the rule amendments.