Information Collection Request

Supporting Statement for the

Fine Particulate Matter

National Ambient Air Quality Standards 

State Implementation Plan Requirements Rulemaking

EPA ICR Number 2258.03

OMB Control No. 2060-0611

Prepared by:

Office of Air Quality Planning and Standards 

Office of Air and Radiation

U.S. Environmental Protection Agency

Research Triangle Park, North Carolina 27711

May 27, 2015
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EPA Information Collection Request Renewal for the

Fine Particulate Matter National Ambient Air Quality Standards

State Implementation Plan Requirements Rule

Table of Contents

1. Identification of the Information Collection Request........................page 4

2. Need for and Use of the Collection..........................................page 5

3. Non-Duplication, Consultation, and other Collection Criteria......... page 7

4. The Respondents and the Information Requested.......................page 10

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

Information Management....................................................page 12

6. Estimating the Burden and Cost of the Collection........................page 13
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1. Identification of the Information Collection Request

1(a) Title of the Information Collection

The title of the Information Collection Request (ICR) is “Fine Particulate Matter (PM2.5) 

National Ambient Air Quality Standards (NAAQS) State Implementation Plan Requirements

(SIP) Rule,” ICR number 2258.03, and OMB Control Number 2060-0611, expiration date: the 

earlier of May 31, 2018 or the date of the finalization of the new ICR proposed on March 23, 

2015 (55 FR 15340).

1(b) Abstract/Executive Summary

The EPA has established a suite of PM2.5 ambient air quality standards based on evidence 

from numerous health studies demonstrating that serious health effects are associated with 

exposures to elevated levels of PM2.5. Estimates show that attainment of the PM2.5 standards 

would result in tens of thousands fewer premature deaths each year, tens of thousands fewer 

hospital admissions each year, and hundreds of thousands fewer doctor visits, absences from 

work and school, and respiratory illnesses in children annually. The EPA initially established 

annual and 24-hour PM2.5 standards in 1997. The 24-hour standard was subsequently revised in 

2006, and the annual standard was revised in 2012.

The EPA is planning to submit an information collection request (ICR), “Fine Particulate 

Matter (PM2.5) NAAQS Implementation Rule (Renewal)” (EPA ICR No. 2258.04, OMB Control 

No. 2060-0611) to the Office of Management and Budget (OMB) for review and approval in 

accordance with the Paperwork Reduction Act (44 U.S.C. 3501 et seq.). Before doing so, the 

EPA is soliciting public comments on specific aspects of the proposed information collection as 

described below. This is a proposed renewal of an existing ICR, which was originally established 

with the EPA’s now-remanded 2007 final rule addressing implementation-related requirements 

for the 1997 PM2.5 NAAQS. On March 23, 2015, the EPA proposed a new ICR associated with 

its Notice of Proposed Rulemaking that would replace the remanded 2007 PM2.5NAAQS 

Implementation Rule. Until that ICR is finalized, the existing ICR will remain in effect, subject 

to this proposed renewal.

The EPA is proposing in the PM2.5 NAAQS SIP Requirements Rule to describe the Clean Air 

Act (CAA) requirements that must be met by states with nonattainment areas required to develop 

attainment plans for attaining and maintaining the NAAQS. The intended effect of the SIP 

Requirements Rule is to provide clarity to state air agencies regarding their planning obligations. 

Only states with nonattainment areas are required to submit SIPs that meet the requirements of 

the rule. 

The information collection activities in PM2.5 NAAQS SIP Requirements Rule proposed rule 

have been submitted for approval to OMB under the Paperwork Reduction Act (PRA). The PRA

requires the EPA to assess the administrative burden (in hours and dollars) for state and local air 

agencies to develop plans to attain the PM2.5 NAAQS, and for the EPA to review and take action 
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on such plans. The current burden was estimated in the ICR (Reference number 201203-2060-

009) concluded on 4/9/2012. This ICR is a renewal of the previous ICR approved estimating the 

burden for the 6 areas remaining in nonattainment for the 2006 PM2.5 NAAQS as compared to 31 

nonattainment areas initially designated for that NAAQS. In addition, one of the six areas (San 

Joaquin Valley, CA) remains nonattainment for the 1997 PM2.5 NAAQS.

With respect to ongoing implementation of the 1997 and 2006 PM2.5 standards, the EPA 

estimates the total administrative burden for state air agencies with nonattainment areas during 

the ICR extension period to be 126,000 hours, and the estimated administrative burden for EPA 

to be 6,900 hours. In this analysis, fifty percent of the hours are assumed to be expended in the 

first year, with the remaining hours evenly divided between the second and third years of the 

ICR period. 

For the remaining 1997 and 2006 PM2.5 nonattainment burden, the present value of the total 

additional costs for state air agencies, the respondents, estimated at $7.6 million for the extension

period. On an equivalent annual basis, that is approximately $2.5 million per year. 

For the remaining 1997 and 2006 PM2.5 nonattainment burden, the present value of the 

Agency administrative cost burden is estimated at $0.8 million dollars for the ICR extension 

period. This is roughly equivalent to $0.3 million per year. 

The incremental administrative burden for the areas and activities covered by this ICR is 

mitigated by the fact that these state air agencies all have experience with developing SIPs for 

previous revisions submitted for this and previous PM2.5 NAAQS. 

2. Need For and Use of the Collection

2(a) Need/Authority for the Collection

The CAA, which was last amended in 1990, requires the EPA to establish NAAQS for air 

pollutants that may reasonably be anticipated to endanger public health or welfare, and which 

result from numerous or diverse sources. On July 18, 1997, the EPA revised the NAAQS for 

particulate matter to add new standards for fine particulate matter (particles of solid and liquid 

material less than 2.5 microns in aerodynamic diameter), using PM2.5 as the indicator. The EPA

established health-based (primary) annual and 24-hour standards for PM2.5 (62 FR 38652). The 

annual standard was set a level of 15 micrograms per cubic meter, based on the 3-year average of 

annual mean PM2.5 concentrations. The 24-hour standard was set a level of 65 micrograms per 

cubic meter, based on the 3-year average of the 98th percentile of 24-hour concentrations. The 

welfare-based secondary standards were established identical to the primary standards.

The initial PM2.5 NAAQS Implementation Rule was proposed November 1, 2005 (70 FR 

65983) and was promulgated on April 25, 2007 (72 FR 20586). The preambles to the proposed 

and final rules addressed the administrative burden in general terms. The preamble to the final 

rule stated that an ICR would be prepared. The first ICR (No. 2258.01) covered a period from 

April 5, 2008 through April 4, 2011. A extension without change of the approved ICR was 

approved through April 30, 2012.
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On October 17, 2006, the EPA revised the NAAQS for fine particles. The EPA established 

new primary and secondary 24-hour standards for PM2.5 (71 FR 61144). The 24-hour standards

were set a level of 35 micrograms per cubic meter, based on the 3-year average of the 98th

percentile of 24-hour concentrations. The annual standard remained unchanged at a level of 15 

micrograms per cubic meter, based on the 3-year average of annual mean PM2.5 concentrations. 

On December 14, 2012, the EPA revised the NAAQS for fine particles. The EPA established 

a new primary annual PM2.5 standard at a level of 12 micrograms per cubic meter, based on the 

3-year average of annual mean PM2.5 concentrations (78 FR 3086). The 24-hour standards 

remained unchanged at a level of 35 micrograms per cubic meter, based on the 3-year average of 

the 98th percentile of 24-hour concentrations. 

On January 4, 2013, the U.S. Court of Appeals for the District of Columbia Circuit (D.C. 

Circuit) remanded the 2007 PM2.5 NAAQS Implementation Rule, concluding that the agency had 

erred in implementing the PM2.5 NAAQS according to only the general nonattainment area 

planning provisions of subpart 1, part D, title I of the CAA, rather than in accordance with the 

the PM-specific planning requirements of subpart 4, part D, title I of the CAA and certain 

general planning provisions in subpart 1. On March 23, 2015, the EPA proposed a new 

implementation rule (80 FR 15340) consistent with the attainment planning requirements under 

CAA subparts 1 and 4 of part D, title I, that would apply to ongoing implementation efforts by 

air agencies in areas designated nonattainment for the 1997, 2006, and most recent 2012 PM2.5

NAAQS. As part of its proposed implementation rule, the EPA also proposed a new ICR to 

account for the additional cost burden to air agencies developing attainment plans for areas 

designated nonattainment for the 2012 PM2.5 NAAQS, in addition to the burden associated with 

plan revisions related to ongoing implementation efforts for the 1997 and 2006 PM2.5 NAAQS. 

Once final, the new ICR will supersede the existing ICR for which the EPA is proposing renewal 

in the March 23, 2015 implementation rule action. 

However, in the meantime, while the EPA completes its current rulemaking and finalizes the 

new ICR, the agency is hereby proposing a renewal of the existing ICR that would continue to 

apply during this interim period. The time period covered in the current approved ICR (2258.02) 

was a 3 year period from May 1, 2012 through April 30, 2015. The time period that was to be 

covered in this third ICR (2258.03) was anticipated to be a 3 year period from May 1, 2015

through April 30, 2018. The renewal of the existing ICR period will extend the time period 

covered until the final approval action of the March 23, 2015 implementation rule.

2(b) User/Users of the Data 

The data collected from state or local air agency respondents will include the nonattainment 

SIP elements required by the CAA, many of which are described in more detail in the PM2.5 SIP 

requirements rule (72 FR 20586). The PM2.5 attainment plan must contain state rules and other 

requirements designed to achieve the NAAQS by the deadlines established under the CAA. 

The PM2.5 attainment plan(s) to be submitted by the state must include the various 

requirements in subpart 1, such as:
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 Baseline emissions inventory for stationary, mobile, and area emissions sources in the 

nonattainment area consistent with 40 CFR 51.1008 of the rule.

 A proposed attainment date consistent with section 51.1004 of the rule. 

 An attainment demonstration with air quality modeling showing that existing federal and 

state emissions reduction programs, plus any new emissions reduction programs adopted 

by the state, will result in expeditious attainment by the attainment date, consistent with 

section 51.1011 of the rule. The attainment demonstration must meet the requirements of 

40 CFR 51.112 and Part 51, Appendix W, and must include emissions inventory

projections, modeling results, and emissions reduction analyses on which the state has 

based its projected attainment date. The attainment demonstration and supporting air 

quality modeling should be consistent with the EPA’s PM2.5 modeling guidance

 A plan showing that annual emissions reductions will provide for reasonable further 

progress (RFP) toward attainment of the standard for the period prior to the area’s 

attainment date, consistent with section 51.1012 of the rule; and reporting every 3 years 

on quantitative milestones showing such progress through the implementation of the 

attainment plan and associated control measures, consistent with section 51.1013 of the 

rule. 

The state air agencies use this information and analysis to fulfill federal obligations under 

Title I, Subpart D of the Clean Air Act and the PM2.5 Implementation Rule. They also use the 

attainment demonstrations, RFP, reasonably available control technology (RACT) and 

reasonably available control mechanisms (RACM) determinations to inform their citizenry, 

including potentially regulated entities. The potentially regulated entities use this information in 

assessing future emissions reduction requirements. 

The EPA regional and headquarters offices will use the submitted information in determining 

the adequacy of the various elements of the PM2.5 attainment plan. After a state submits a SIP

with the appropriate technical supporting documentation, the EPA is required under the CAA to 

approve or disapprove the SIP within 12 months. Emissions reduction regulations developed by 

the state air agencies become federally enforceable when approved by the EPA.

3. Non-Duplication, Consultations, and Other Collection Criteria

3(a) Non-Duplication

As noted in section 2(b) above, the state air agency respondent will submit an attainment plan for 

each nonattainment area that will need to include a number of separate and unique elements. For 

example, each attainment plan will need to include a unique RACM/RACT analysis, attainment 

demonstration, and RFP plan. 

However, there are other activities covered by existing ICRs which complement the elements 

required in the PM2.5 attainment plan. For example, the existing fine particle monitoring network, 

covered under a separate, existing ICR, provides essential data for use by state air agencies and

the EPA in identifying key categories of emissions and tracking progress toward attainment.
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The EPA encourages state air agencies to account for control measures and expected 

emission reductions from existing regulations and implementation planning processes, such as 

for the 1997 and 2006 PM2.5 NAAQS, the 2008 ozone NAAQS, the regional haze program, the 

cross state air pollution rule (CSAPR), and the Mercury and Air Toxics Standards. Taking such 

steps, where appropriate, may enable state air agencies to reduce the incremental administrative 

burden associated with this rule and enable identification of control strategies that achieve multipollutant environmental progress at a lower cost.

Relevant ICRs and their titles are identified below. 

 Requirements for Preparation, Adoption, and Submittal of Implementation Plans

o 51.121-51.122 NOx SIP Call...................................2060-0445

o 51.160-51.166 New Source Review................................2060-0003

o 51.321-51.323 Air Quality Data Reporting..................2060-0088

o 51.353-51.354 Inspection/Maintenance......................2060-0252

o 51.365-51.366 Inspection/Maintenance......................2060-0252

 Approval and Promulgation of Implementation Plans

o 52.21 Prevention of Significant Deterioration.................2060-0003

 Ambient Air Monitoring Reference and Equivalent Methods

o 53.4 .................................................................2080-0005

o 53.9(f),(h),(i).......................................................2080-0005

o 53.14................................................................2080-0005

o 53.15 ...............................................................2080-0005

o 53.16(a)-(d),(f).....................................................2080-0005

 Outer Continental Shelf Air Regulations

o 55.4-55.8 ...........................................................2060-0249

o 55.11-55.14 ........................................................2060-0249

 Ambient Air Quality Surveillance

o 58.11-58.14 ........................................................2060-0084

o 58.20-58.23 ........................................................2060-0084

o 58.25-58.28 ........................................................2060-0084

o 58.30-58.31 ........................................................2060-0084

o 58.33 ................................................................2060-0084

o 58.35 ................................................................2060-0084

o 58.40-58.41 .........................................................2060-0084

o 58.43 ................................................................2060-0084

o 58.45 ................................................................2060-0084

o 58.50 ................................................................2060-0084

 Determining Conformity of Federal Actions to State or Federal Implementation Plans

o 91.150-93.160 .....................................................2060-0279

 8-hour Ozone National Ambient Air Quality Standard Implementation Rule

o 2236.02.............................................................2060 – 0594
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3(b) Public Notice Required Prior to ICR Submission to the Office of 

Management and Budget (OMB)

This is a renewal of an existing rule-related ICR. Comments on this ICR will be 

requested when the ICR renewal is proposed in the Federal Register in May 2015. The ICR 

renewal was published for public notice and comments on May XX, 2015 

(http://edocket.access.gpo.gov/2015/pdf/2015-XXXX.pdf)

3(c) Consultations

The EPA is soliciting comment on the proposed renewal of the ICR for the PM2.5 SIP 

requirements rule. 

3(d) Effects of Less Frequent Collection

The collections under this rule (as reviewed in section 2.b) are necessary to comply with 

Clean Air Act requirements and provide assurances that identified levels of emission reductions 

are adequate to ensure timely attainment and maintenance of the PM2.5 NAAQS.

3(c) General Guidelines

The reporting and recordkeeping requirements in this proposed rule do not violate any of the 

regulations promulgated by OMB under 5 CFR part 1320, section 1320.5. This submission meets 

the current Paperwork Reduction Act guidelines set forth by OMB. Those guidelines reflect the 

requirements of 5 CFR 1320.6. The PM2.5 NAAQS SIP requirements rule does not require:

 reporting more than once a year;

 respondents to participate in a statistical survey; 

 responses to Agency inquiries in less than 30 days;

 respondents to receive remuneration for preparation of reports; 

 records to be kept more than 3 years;

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 manual methods of reporting.

3(f) Confidentiality

 

The information requested from the state air agencies to fulfill CAA requirements as 

described in section 2(b) will rely on emissions levels and control efficiency data provided by 

certain facilities in the private and public sectors. This information is available from a variety of 

sources and state air agencies should already have information from emission sources, as 

facilities should have provided this information to meet other NAAQS SIP requirements, 

operating permits, and/or emissions reporting requirements. It is the assimilation and analysis of 

that data (e.g., for RACM/RACT control measure determinations, the attainment demonstration, 

etc.) that is required by this rule. 

 

1 However, the states may choose to retain the information for more than 3 years.
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Emissions and control technology information from emissions sources generally does not 

reveal the details of production processes. But, to the extent that it may, the affected facilities are 

protected. Specifically, the provision of the emissions and control efficiency information that is 

confidential, proprietary, and trade secret is protected from disclosure under the requirements of 

subsections 503(e) and 114(c) of the Clean Air Act.

3(g) Sensitive Information

The requested PM2.5 SIP requirements rule submissions do not include questions whose 

answers would require sensitive information.

4.0 The Respondents and the Information Requested

4(a) Respondents and Nonattainment areas

State and local air agencies2are the primary respondents under this ICR. Table 1 lists the 

nonattainment areas and state air agencies with remaining SIP submittals for the 1997 PM2.5 

NAAQS and the 2006 PM2.5 NAAQS that potentially could be required during the ICR 

period. For purposes of this draft analysis, it has been assumed that for the 1997 PM2.5

NAAQS, a revised attainment plan will be required during the ICR period for one 

nonattainment area. It also has been assumed that for the 2006 PM2.5 NAAQS, a revised 

attainment plan will be required during the ICR period for six nonattainment areas. (Note that 

these assumptions have been made only for the purposes of this draft analysis, and a number 

of factors and future state or EPA actions could change the assumptions put forth here.) 

Table 1 also includes an estimated 18,000 burden hours for each revised attainment plan and 

an estimated total weighted direct and indirect hourly equivalent salary cost of $65.10 per hour. 

Section 6 provides more details on these estimates.

 

2 Local, state, and federal agencies are part of the North American Industrial Classification 

System code number 924110, which includes “administration of air and water resources, and 

solid waste management programs.” See http://www.census.gov/naics.
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Table 1. Remaining 1997 PM2.5 and 2006 PM2.5 Nonattainment Areas with Estimated 

Burden for SIP Revision or Redesignation Action 

Area Name State EPA

Reg.

Potential Actions 

during ICR Extension

Hours for SIP 

Revision 

3-year Burden 

Estimate 

(Dollars)

Fairbanks AK 10 2006 PM2.5 revised 

attainment plan

18,000 $1,171,800

Imperial County CA 9 2006 PM2.5 revised 

attainment plan

18,000 $1,171,800

Liberty-Clairton PA 3 2006 PM2.5 revised 

attainment plan

18,000 $1,171,800

Provo UT 8 2006 PM2.5 revised 

attainment plan

18,000 $1,171,800

Salt Lake City UT 8 2006 PM2.5 revised 

attainment plan

18,000 $1,171,800

San Joaquin 

Valley

CA 9 1997 PM2.5 revised 

attainment plan

18,000 $1,171,800

San Joaquin 

Valley

CA 9 2006 PM2.5 revised 

attainment plan

18,000 $1,171,800

TOTAL 126,000 $8,202,600

 4(b) Information Requested

The information requested under this proposed rule, as described in section 2(b) of this ICR, 

is required to meet the requirements of the CAA. The implementation framework set forth in the 

regulation does not adopt a “one-size-fits all” approach to meeting these requirements. This 

additional flexibility enables the State air agencies to customize, to the extent allowed by the 

Clean Air Act, their approach to attaining and maintaining the PM2.5 NAAQS.

Data Items. The emissions and control efficiency data required for the attainment 

demonstration, RFP, RACT, and RACM is assumed to have been collected as a result of 

reporting activities required by other OMB-approved ICRs. For example, the collection of 

emissions information for many stationary sources is required under other program requirements, 

such as the Air Emissions Reporting Rule (AERR) Rule (see http://www.epa.gov/ttnchie1/aerr/). 

In developing PM2.5 SIPs, air agencies are expected to use a range of other readily available data 

sources, such as existing federal rules that are expected to reduce future emissions of particulate 

matter precursors, and economic and population growth rates.

Respondents’ Activities. The state air agecies will compile and reference the data, set forth 

the analytical methodology, conduct control technology, emission reduction and air quality 

modeling analyses, develop initial drafts, hold hearings, adopt rules, regulations, and programs, 
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have discussions with EPA staff as appropriate, refine the draft attainment demonstration as 

appropriate, adopt the SIP, and formally submit the SIP to the EPA.

Agency Activities. The EPA staff in the regional offices will facilitate timely receipt of the 

attainment demonstration, RFP, RACT, and RACM requirements by reviewing materials and 

answering questions from the state air agencies regarding regulatory requirements, potential data 

sources, analytical tools, the draft attainment demonstration, and other draft SIP elements. The 

EPA Regional Offices will evaluate the formal SIP submissions and take rulemaking actions to 

approve or disapprove the SIP revisions. The EPA headquarters staff will facilitate policy 

coordination and national consistency in the timely review and evaluation of plans from state air 

agencies around the country. They will also facilitate information flow among the regions and 

states to promote the development of acceptable demonstrations and SIP submissions.

Reporting Protocols. The dates for plan submissions and milestone reports are as set forth in 

subpart 4 of Part D of the CAA (sections 188-190), and in the proposed PM2.5 SIP Requirements 

Rule.

5.0 The Information Collected—Agency Activities, Collection 

Methodology, and Information Management

 

 5(a) States, EPA Regional Offices, and EPA Headquarters Offices

States. The state air agencies’ activities include:

 Develop baseline emissions inventory and projection year inventory.

 Conduct analyses of economic and technological feasibility of potential control 

measures and adopt state rules requiring emission reductions to ensure attainment of 

the standard “as expeditiously as practicable.”

 Develop and evaluate emissions reduction strategies, and conduct air quality 

modeling showing that existing federal and state emission reduction programs, plus 

any new emission reduction programs adopted by the state, will result in expeditious 

attainment by the attainment date.

 Develop plans to ensure that future emission reductions will provide for reasonable 

further progress toward attainment of the standard for the period prior to the area’s 

attainment date. 

EPA Regional Offices. The regional office activities include:

 Respond to inquiries from the air agencies and provide guidance on SIP development.

 Review technical data, analyses, and draft SIP elements developed by the air 

agencies. 

 Evaluate the formal SIP submissions and conduct rulemaking actions approving or 

disapproving the SIP submissions.

EPA Headquarters. The EPA headquarters office activities include:
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 Answer questions regarding application and interpretation of rule provisions.

 Facilitate policy coordination and national consistency in the timely review and 

evaluation of plans from state air agencies around the country. 

 Coordinate information flow amongst the regions and states to promote the 

development of acceptable demonstrations and SIP submissions.

5(b) Collection Methodology and Management

The PM2.5 attainment plan submitted by the air agency will set forth the data sources, 

analytical methods, and the emission reduction and air quality improvement verification 

procedures used in its development and implementation. 

 5(c) Small Entity Flexibility

For an approved ICR, the Agency must demonstrate that it has taken all practical steps to 

develop separate and simplified requirements for small businesses and other small entities. 

See 5 CFR 1320.6(h). The proposed PM2.5 NAAQS implementation regulations do not 

provide a direct administrative burden on small entities. 

 5(d) Collection Schedule 

The SIP deadlines for implementing the PM2.5 NAAQS under Subparts 1 and 4 were 

proposed in proposed PM2.5 SIP Requirements Rule consistent with CAA requirements. 

Moderate area SIPs will be due within 18 months of the effective date of nonattainment area 

designation. The proposed rule requests comment on due dates for certain elements of Serious 

area SIPs; however, under all proposed options BACM/BACT requirements would be due within 

18 months of the date an area is reclassified as Serious. Quantitative milestone reports, as 

required under the CAA, would be due every 3 years. 

6. Estimating the Burden of the Collection

This section provides information on the hours and costs associated with the information 

collection for the respondents (the affected state and local air agencies) and EPA (regional and 

headquarters offices). Hours and costs are presented for the activities associated with each 

collection item for a nonattainment area (or portion thereof) in a given state, as well as the 

equivalent annual and present value cost estimates.

6(a) Estimating Respondent Burden

The estimated respondent burden represents the estimated staff time associated with the 

activities required to develop the relevant PM2.5 SIP and implement the plan each year. 

The estimated burden in this ICR is incremental to the estimated burden of other EPA 

environmental reporting obligations. The actual incremental burden is expected to vary across 

areas for a number of reasons, such as the severity of the nonattainment problem and whether 
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existing federal and state emission reduction programs are projected to bring the area into 

attainment. 

Burden Estimate for Remaining Nonattainment Areas for 1997 and 2006 PM2.5 NAAQS

Table 1 provides the list of areas and states still implementing the 1997 and 2006 PM2.5

NAAQS requirements that potentially could be responsible for developing Serious area SIP 

revisions during the extension of the ICR period. For the purpose of this analysis, it is assumed 

that one of the original 39 nonattainment areas for the 1997 PM2.5 standard (San Joaquin Valley, 

CA) will still need to develop a Serious area plan during the ICR period. The estimated burden 

hours for development of the remaining Serious area SIP is 18,000 hours. The presumed 

allocation of total incremental burden across the three years is 50% in year 1, 25% in year 2, and 

25% in year 3. 

Of the 32 areas designated as nonattainment for the 2006 PM2.5 standard, Table 1

identifies six areas that potentially could be reclassified from Moderate to Serious during the 

extension of the ICR period, and that could have a Serious area SIP (or portions thereof) due 

within 18 months (also within the period for this ICR). For the purposes of this analysis, the 

estimated burden for development of the SIP revisions to address the Serious area 

requirements is 18,000 hours. Using the information in Table 1, Table 2 below provides a 3-

year breakdown of expected burden hours by state and by year.

Table 2. Nonattainment Areas for 1997 and 2006 PM2.5 NAAQS: 

Estimated Incremental Burden Hours by State and Year

State

EPA 

Region

Additional 

hours Year 1

Additional 

hours Year 2

Additional 

hours Year 3

AK 10 9,000 4,500 4,500

CA 9 27,000 13,500 13,500

PA 10 9,000 4,500 4,500

UT 8 18,000 9,000 9,000

6(b) Estimating Respondent Cost

Labor costs are estimated for state air agencies using the total of projected additional 

hours for the areas. These estimates do not reflect staff experience and economies of scale. The 

hourly rates are the result of estimated direct and indirect cost per employee. The main source of 

the information is http://www.opm.gov/oca/payrates/index.htm

The estimated weighted direct salary cost per employee is $35.88 per hour. This results 

from a summation of the professional, managerial, and support staff components. 

 Hourly equivalent 2012 Salary of Permanent Professional Staff at GS 11, Step 3 is 

$33.34. This is the average of hourly equivalent rates for the San Francisco, CA and 

Washington, D.C. areas.
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 To account for permanent managerial staff, 1/11 or 9% of the hourly rate for GS 13, 

Step 3 is added to the professional staff hourly rates. The average hourly equivalent 

rate for GS-13 using rates for San Francisco, CA and Washington, D.C. is $47.51.

Nine percent of that is $4.32.

 To account for permanent support staff at GS-6, Step 6, 1/8 or 16% of the hourly rate 

is added to the professional staff hourly rates. The average hourly equivalent rate for 

GS-6, Step 6 using rates for San Francisco, CA and Washington, D.C. is $22.17. 

Sixteen percent of that is $3.55. 

The estimated hourly indirect cost per employee is $23.90. This amount is the sum of the 

following:

 Benefits at 16% of the weighted direct hourly equivalent salary cost per employee, or 

$6.59.

 Sick and annual leave at 10% of the weighted direct hourly equivalent salary cost per 

employee, or $4.12.

 General overhead at 32% of the weighed direct hourly equivalent salary cost per 

employee, or $13.18.

The estimated total weighted direct and indirect hourly equivalent salary cost per employee is 

$65.10. The ICR cost estimates are in 2012 dollars. Federal hourly pay rates did not change 

between 2010 and 2012. The estimated total incremental respondent burden for the state 

respondents to meet the new 2012 PM2.5 SIP requirements and complete the remaining 1997 and 

2006 SIP requirements is provided in Table 5.

Table 3. Estimated Incremental Cost and Hour Burden for the State Air Agencies

(Respondents) to complete the remaining 1997 and 2006 SIP Submittal 

Requirements.

NAAQS

Additional 

Cost for 

Year 1

Additional 

Cost for 

Year 2

Additional 

Cost for 

Year 3

Burden for the 

3-year ICR 

period (hrs)

1997/2006 $4.1 million $1.8 million $1.7 million 126,000

 

6(c) Estimating Agency Burden and Cost

The estimated Agency burden is derived from the same estimates used for estimating 

respondent costs in section 6(b). Draft estimates were developed by the headquarters staff with 

review by regional office staff and subsequent refinement of the Agency burden and cost 

estimates.

The respondent burden was summed by the EPA regional offices and a percentage was 

applied to the yearly burden estimate to reflect the actions taken on the part of the regional 
16

offices. Once yearly burdens were estimated for the Agency’s Regional Offices, a percentage of 

those amounts are specified to derive estimates for the Agency’s Headquarters Office Burdens.

Agency Regional Office Burden. Table 4 includes estimates of total incremental 

Agency Regional Office burden. The summary of total incremental respondent burden 

comes from Tables 1. The Agency Regional Office burden is presumed to be 10% of the 

estimated total incremental burden for respondent by the EPA Regional Office. The total 

incremental burden allocation for the Agency Regional Offices is 50% in year 1, 25% in 

year 2, and 25% in year 3.

Agency Headquarters Burden. Table 4 also summarizes total incremental Agency 

headquarters burden. The Regional Office burden estimates for years 1, 2, and 3 are 

multiplied by 10% to arrive at an estimate for headquarters burden for the same 3 years. 

Total Incremental Burden for the Agency. The regional and headquarters office burden 

estimate for year 1 for the 1997 and 2006 NAAQS is 8,000 hours. The estimates for 

years 2 and 3 are 4,000 hours each year.

Total Cost for the Agency. Using the weighted direct and indirect salary equivalent hour 

rate derived in section 6(b), the total incremental burden hours are multiplied by that rate. 

The result is the total cost estimate for the Agency provided in Table 4.

Table 4. Estimated Total Incremental Cost and Hour Burden for the EPA Regions 

and Headquarters to complete the remaining 1997 and 2006 SIP Submittal 

Requirements.

NAAQS

Total State 

Respondents' 

burden (hrs)

Regions 

Burden 

(hrs)

HQ 

Burden 

(hrs)

Additional 

Cost for 

Year 1

Additional 

Cost for 

Year 2

Additional 

Cost for 

Year 3

1997/2006 126,000 6,300 630 $0.5 

million

$0.2 

million

$0.2 

million

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

The incremental respondent universe burden and cost estimates are presented in 

Tables 5. 
17

Table 5. 1997 PM2.5 and 2006 PM2.5 NAAQS Incremental Respondent & Agency 

Universe Burden and Cost Estimates 

Entity

Average Yearly 

Burden (hours)

3-Year Burden 

(hrs)

Present Value of Costs 

for 3-Year Burden

States 42,000 126,000 $7.6 million

Agency 4,620 6,930 $0.83 million

Total 46,620 132,930 $8.4 million

*The estimates are in current year (2012) dollars. Costs for years 2 and 3 are calculated 

using the equation Present Value = Future Value/ (1 + interest rate)t ,where “t” is the 

number of years hence (i.e., 0 for year 1, 1 for year 2, 2 for year 3). The adjusted values 

for years 1, 2, and 3 are then summed.

6(e) Reason for Change in Burden

We are requesting an decrease in burden to 126,000 hours from the 175,400. The 126,000 

hours is an extension to implement the remaining requirements for the 1997 PM2.5 and 2006 

PM2.5 NAAQS. This burden estimate is lower than the estimate for the previous PM2.5

Implementation ICR renewal primarily because the extension estimates the burden for the 6 

areas remaining in nonattainment for the 2006 PM2.5 NAAQS as compared to 31 nonattainment 

areas initially designated for that NAAQS. In addition, one of the six areas (San Joaquin Valley, 

CA) remains nonattainment for the 1997 PM2.5 NAAQS. The estimates have been calculated 

using 2012 dollars and some assumptions regarding overhead, O&M costs, and capital costs 

have been adjusted to meet current guidelines and common procedures for preparing ICRs.

6(f) Burden Statement

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

for the 1997 and 2006 NAAQS is estimated to average 6,000 hours, which is the 42,000 hours 

average yearly burden for the state air agencies identified in Table 1, and dividing by 7, the 

number of affected state responses.

Burden means the total time, effort, or financial resources expended by persons to 

generate, maintain, retain, disclose, or provide information, or for a Federal agency other than 

the EPA, to do so. This estimate includes the time and burden needed to conduct the tasks 

associated with each state submitting the PM2.5 SIP required for each PM2.5 nonattainment area. 

The PM2.5 SIPs due during this ICR extension period will need to include several elements, 

including the attainment demonstration, RFP plan, RACT and RACM. In meeting these 

milestones, such incremental efforts may include reviewing instructions as well as verifying, 

processing, maintaining, and disclosing information. Such efforts may require incremental 

development, acquisition, installation, and/or utilization of technological systems for several 

purposes. These purposes include collecting, verifying, validating, processing, maintaining and 

disclosing information associated with the each milestone. The incremental efforts may result 

from adjusting the ways to comply with the previously applicable instructions associated with 
18

other NAAQS such as 8-hr ozone and PM10. Consequently, in meeting the milestones, there 

could be some incremental burden associated with learning/training, searching data sources, and 

transmitting the deliverables.

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 the EPA’s regulations are listed in 40 CFR part 9 and 48 CFR chapter 15. 

When this ICR is approved by OMB, the Agency will publish a technical amendment to 40 CFR 

part 9 in the Federal Register to display the OMB control number for the approved information 

collection requirements contained in the final implementation rule. However, as was stated in the 

April 2007 Federal Register Notice for the PM2.5 Implementation Rule, “.. the failure to have an 

approved ICR for this rule does not affect the statutory obligation for the state air agencies to 

submit SIPs as required under part D of the CAA.”

The Agency established a docket for the PM2.5 NAAQS State Implementation Requirements

Rule under Docket ID No.OAR-2007-0265. All documents in the docket are listed in the 

EDOCKET index at http://www.epa.gov/epahome/dockets.htm or http://www.regulations.gov. 

Although listed in the index, some information such as Confidential Business Information is not 

publicly available. Other information such as copyrighted materials are not placed on the 

internet, but are available in hard copy form at the EPA Docket Center (Air Docket), EPA/DC, 

EPA West, Room B102, 1301 Constitution Ave., NW., Washington, DC. The 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 Public Reading Room is (202) 566-1744. The telephone number 

for the Office of Air and Radiation Docket and Information Center is (202) 566-1742.