### Appendix A-1 **LA BOR RA** 

**TES ***
**Contractor Rates [1]**

**2011 Hourly** Loaded

Labor Rate Overhead Total **$99.00** $47.22 2.1 $99.16
**Respondent Rates [2]**

**2011 Hourly** Loaded

Labor Rate Overhead Total **$66.00** $31.55 2.1 $66.26

**State/Local A gency** 

**Rates [3]**

**2011 Hourly** Loaded

Labor Rate Overhead Total **$85.00** $40.40 2.1 $84.84

**EPA Rates [4]** 

**2011 Hourly** Hourly Wage Rate Benefits Total **$46.00** $28.88 1.6 $46.21
[1] Respondent contractor rate obtained from "Employer Costs for Employee Compensation, Table 2: Employment Costs for Civilian Workers by Occupational and Industry Group (Professional and Related)" U.S. Dept. of Commerce, BLS, June 2011. (http://www.bls.gov/news.release/ecac.t02.htm accessed 9/19/11) 110% overhead assumed.

[3] State/Local rates obtained from "Employer Costs for Employee Compensation, Table 4: Employment Costs for State and Local Government Workers" U.S. Dept. of Commerce, BLS, June 2011. (http://www.bls.gov/news.release/ecac.t04.htm accessed 9/19/11) 110% overhead assumed.

[4] Federal Labor Cost obtained from U.S. Office of Personnel Management 2011 General [2] Respondent in-house rates obtained from "Employer Costs for Employee Compensation, Table 2: Employment Costs for Civilian Workers by Occupational and Industry Group (Construction, Extraction, Farming, Forestry, and Fishing)" U.S. Dept. of Commerce, BLS, June 2011. (http://www.bls.gov/news.release/ecac.t02.htm accessed 9/19/11) 110% overhead assumed.Appendix A-2
**Universe of Respondents Universe Estimates**  **Sources under EPA authority # New exploration sources**  **5** see below - 5 represents the number of expected primary permits to be issued during ICR period **# Existing exploration sources 5**  2012 added this row - see below; 5 represents the number of drill ships for which exploratory permits were issued in 2011 (2 in AK; 3 in Gulf) **# New development/production sources 0**  **# Existing sources 0**  this refers to existing development/production sources **# New alternative energy sources 4**  2 major source permits, 2 minor source permits **# Existing alternative energy sources 1**  2012 added this row - accounting for Cape Wind project which has been permitted (NA NSR) but not built
**Sources under State/local authority # New exploration sources**  **0 # New development/production sources**  **0 # Existing sources**  **23** include two sources making minor permit mods. **# Construction mod to existing sources 2**  the two minor mods above require minor NSR permits as well **# New alternative energy sources 0**  per Herkhof **Total Number of Sources 40** 
**New and existing exploration sources under EPA authority - 2012 renewal**  Alaska

Eastern Gulf 1 permit (PSD) for exploratory drilling issued in 2011. No burden for preconstruction permitting; burden for recordkeeping and reporting. **Counts as 1 existing source.**

2 additional permits assumed, each for one ship for multiple years, based on Herkhof estimate of 3-4 additional exploratory wells per year in the eastern Gulf of Mexico. **Counts as 2 new sources.** 2 PSD permits issued in 2011 for the same drill ship, one for Beaufort and one for Chukchi Sea, each covering an unspecified number of wells drilled over an unspecified number of years. Assuming will operate under only one of these permits (probably in the Chukchi) in any single year, so burden is as if one permit. No burden included for preconstruction permitting; burden is included for recordkeeping and reporting for one of the two permits for each year. **Counts as 1 existing source.** 1 exploratory permit (title V/mNSR) pending (completed public comment in Sep 2011) for same company as 2 PSD permits above; this one for the Beaufort Sea with stipulation that will not operate there at the same time as any other source permitted by same company. No burden included for preconstruction permitting (i.e., treat as existing); burden is included for recordkeeping and reporting. **Counts as 1 existing source.** 1 exploratory permit (title V) went through public comment in Sep 2011 but was then withdrawn. Expect to rework and resubmit, possibly in 2011. Is for an unspecified number of wells over multiple years in the Chukchi. Assuming permitting burden included in this ICR as well as recordkeeping and reporting. **Counts as 1 new source.** 2 additional permits assumed, each for one ship for multiple years, based on Herkhof estimate of 3-4 additional exploratory wells per year in the Arctic. **Counts as 2 new sources.**

2 exploratory permits (PSD/title V) pending (completed public comment in Sep 2011). No burden included for preconstruction permitting (i.e., treat as existing); burden is included for recordkeeping and reporting. **Counts as 2 existing sources.** **EXHIBIT 1. NEW AND PREVIOUSLY PERMITTED EXPLORATION SOURCES UNDER EPA AUTHORITY**

**RESPONDENTS' ANNUAL BURDENS**

Collection Activities Number of

Respondents Number of

Occurrences for 3 years Occurrences

per year Hours per

Occurrence1 Cost per

Occurrence Contractors

Hours per Occurrence Contractors

Dollars per Occurrence Total

Hours per Year Total Cost

per Year O&M Costs

per Occurrence Capital

Costs per Occurrence Total O&M

Costs per Year Total

Capital Costs per Year Labor Rates **$66.00 $99.00** 
Read regulations2 5 1 1.67 5 330.00 0 $0.00 8 $550.00 $0.00 $0.00 $0.00 $0.00 Consult with EPA, or State and local agency2 5 1 1.67 5 330.00 0 $0.00 8 $550.00 $0.00 $0.00 $0.00 $0.00 Prepare a NOI to construct2 5 1 1.67 30 1,980.00 0 $0.00 50 $3,300.00 $0.00 $0.00 $0.00 $0.00 Prepare major source permit application3 3 1 1.00 50 3,300.00 293 $29,007.00 343 $32,307.00 $0.00 $0.00 $0.00 $0.00 Prepare minor source permit application3 2 1 0.67 25 1,650.00 146 $14,454.00 114 $10,736.00 $0.00 $0.00 $0.00 $0.00 Perform initial compliance test2 5 1 1.67 100 6,600.00 764 $75,636.00 1,440 $137,060.00 $0.00 $0.00 $0.00 $0.00 Prepare operating permit application4 5 1 1.67 42 2,772.00 0 $0.00 70 $4,620.00 $0.00 $0.00 $0.00 $0.00 Conduct record keeping and report data to EPA5 10 3 10.00 32 2,112.00 0 $0.00 320 $21,120.00 $0.00 $0.00 $0.00 $0.00 Responses per Year** 20.00 Burden 2,354 $210,243.00 $0.00 $0.00

1. Assumes hours per occurrence is the same as that in the 1998 ICR, except hours added for preparing permit applications



# Ex-1**EXHIBIT 2. NEW AND PREVIOUSLY PERMITTED ALTERNATIVE ENERGY SOURCES UNDER EPA AUTHORITY**

**RESPONDENTS' ANNUAL BURDENS**

Collection Activities Number of

Respondents Number of

Occurrences for 3 years Occurrences

per year Hours per

Occurrence1 Cost per

Occurrence Contractors

Hours per Occurrence Contractors

Dollars per Occurrence Total

Hours per Year Total Cost

per Year O&M Costs

per Occurrence Capital

Costs per Occurrence Total O&M

Costs per Year Total

Capital Costs per Year Labor Rates **$66.00 $99.00** 
Read regulations2 4 1 1.33 5 330.00 0 $0.00 7 $440.00 $0.00 $0.00 $0.00 $0.00 Consult with EPA, or State and local agency2 4 1 1.33 5 330.00 0 $0.00 7 $440.00 $0.00 $0.00 $0.00 $0.00 Prepare a NOI to construct2 4 1 1.33 30 1,980.00 0 $0.00 40 $2,640.00 $0.00 $0.00 $0.00 $0.00 Prepare major source permit application3 2 1 0.67 50 3,300.00 293 $29,007.00 229 $21,538.00 $0.00 $0.00 $0.00 $0.00 Prepare minor source permit application3 2 1 0.67 25 1,650.00 146 $14,454.00 114 $10,736.00 $0.00 $0.00 $0.00 $0.00 Prepare operating permit application4 3 1 1.00 42 2,772.00 0 $0.00 42 $2,772.00 $0.00 $0.00 $0.00 $0.00 Conduct record keeping and report data to EPA5 5 3 5.00 32 2,112.00 0 $0.00 160 $10,560.00 $0.00 $0.00 $0.00 $0.00 Responses per Year** 11.33 Burden 598 $49,126.00 $0.00 $0.00

1. Assumes hours per occurrence is the same as that in the 1998 ICR, except hours added for preparing permit applications 2. Assumes all new

permittees must perform these tasks 3. Assumes 50% of new permits are major sources permits and 50% minor souce permits 4. Assumes that 50% of new and existing permittees must subsequently obtain an operating permit; rounding up to be conservative 5. Assumes that all new and existing permittees must conduct recordkeeping and reporting during each year of the ICR period



# Ex-2**EXHIBIT 3. NEW DEVELOPMENT/PRODUCTION SOURCES UNDER EPA AUTHORITY**

**RESPONDENTS' ANNUAL BURDENS**

Collection Activities Number of

Respondents Number of

Occurrences for 3 years Occurrences

per year Hours per

Occurrence 1 Cost per

Occurrence Contractors

Hours per Occurrence Contractors

Dollars per Occurrence Total

Hours per Year Total Cost

per Year O&M Costs

per Occurrence2 Capital

Costs per Occurrence3 Total O&M

Costs per Year Total Capital

Costs per Year Rates **$66.00 $99.00** 
Read regulations 0 1 0.00 5 330.00 0 $0.00 0 $0.00 $0.00 $0.00 $0.00 $0.00 Consult with EPA, or State and local agency 0 1 0.00 5 330.00 0 $0.00 0 $0.00 $0.00 $0.00 $0.00 $0.00 Prepare a NOI to construct 0 1 0.00 30 1,980.00 0 $0.00 0 $0.00 $0.00 $0.00 $0.00 $0.00 Prepare preconstruction permit application 0 1 0.00 100 6,600.00 585 $57,915.00 0 $0.00 $0.00 $0.00 $0.00 $0.00 Perform initial compliance test 0 1 0.00 100 6,600.00 764 $75,636.00 0 $0.00 $0.00 $0.00 $0.00 $0.00 Prepare operating permit application 0 1 0.00 42 2,772.00 0 $0.00 0 $0.00 $0.00 $0.00 $0.00 $0.00 Conduct record keeping and report data to EPA 0 1 0.00 64 858.00 0 $0.00 0 $0.00 $1,517.40 $30,348.00 $0.00 $0.00 Responses per Year** 0.00 Burden 0 $0.00 $1,517.40 $30,348.00 $0.00 $0.00

1. Assumes hours per occurrence is the same as that in the 1998 ICR. 2. Assumes O&M is 5 percent of capital costs 3. Capital costs calculated using the June 2011 (preliminary) index for process instruments (440.9) compared to the final December 1998 index (363.2) and applied to the 1998 estimate of $25,000
**This number is used in the summary (Exhibit 14)
Assume 0 new projects in any of the areas subject to EPA permitting.



# Ex-3**EXHIBIT 4. NEW EXPLORATION SOURCES UNDER STATE/LOCAL AUTHORITY**

**RESPONDENTS' ANNUAL BURDENS**

Collection Activities Number of

Respondents Number of

Occurrences for 3 years Occurrences

per year Hours per

Occurrence1 Cost per

Occurrence Contractors

Hours per Occurrence Contractors

Dollars per Occurrence Total Hours

per Year Total Cost

per Year O&M Costs

per Occurrence Capital Costs

per Occurrence Total O&M

Costs per Year Total Capital

Costs per Year Rates **$66.00 $99.00**  Read regulations 0 0 0.00 5 330.00 0 $0.00 0 $0.00 $0.00 $0.00 $0.00 $0.00 Consult with EPA, or State and local agency 0 0 0.00 5 330.00 0 $0.00 0 $0.00 $0.00 $0.00 $0.00 $0.00 Prepare a NOI to construct and permit application 0 0 0.00 70 4,620.00 0 $0.00 0 $0.00 $0.00 $0.00 $0.00 $0.00 Perform initial compliance test 0 0 0.00 100 6,600.00 748 $74,052.00 0 $0.00 $0.00 $0.00 $0.00 $0.00
Conduct record keeping and report data to local agency 0 0 0.00 64 4,224.00 0 $0.00 0 $0.00 $0.00 $0.00 $0.00 $0.00 Responses per Year 0 Burden 0 $0.00 $0.00 $0.00

1. Assumes hours per occurrence is the same as that in the 1998 ICR.



## Ex-4**EXHIBIT 5. NEW ALTERNATIVE ENERGY SOURCES UNDER STATE/LOCAL AUTHORITY**

**RESPONDENTS' ANNUAL BURDENS**

Collection Activities Number of

Respondents Number of

Occurrences for 3 years Occurrences

per year Hours per

Occurrence1 Cost per

Occurrence Contractors

Hours per Occurrence Contractors

Dollars per Occurrence Total Hours

per Year Total Cost

per Year O&M Costs

per Occurrence Capital Costs

per Occurrence Total O&M

Costs per Year Total Capital

Costs per Year Rates **$66.00 $99.00**  Read regulations 0 1 0.00 5 330.00 0 $0.00 0 $0.00 $0.00 $0.00 $0.00 $0.00 Consult with EPA, or State and local agency 0 1 0.00 5 330.00 0 $0.00 0 $0.00 $0.00 $0.00 $0.00 $0.00 Prepare a NOI to construct and permit application 0 1 0.00 70 4,620.00 0 $0.00 0 $0.00 $0.00 $0.00 $0.00 $0.00 Perform initial compliance test 0 1 0.00 100 6,600.00 748 $74,052.00 0 $0.00 $0.00 $0.00 $0.00 $0.00
Conduct record keeping and report data to local agency 0 1 0.00 64 4,224.00 0 $0.00 0 $0.00 $0.00 $0.00 $0.00 $0.00 Responses per Year 0.00 Burden 0 $0.00 $0.00 $0.00

1. Assumes hours per occurrence is the same as that in the 1998 ICR.



## Ex-5**EXHIBIT 6. EXISTING SOURCES UNDER STATE/LOCAL AUTHORITY**

**RESPONDENTS' ANNUAL BURDENS**

Collection Activities Number of

Respondents Number of

Occurrences for 3 years Occurrences

per year Hours per

Occurrence1 Cost per

Occurrence Contractors

Hours per Occurrence Contractors

Dollars per Occurrence Total

Hours per Year Total Cost per

Year O&M Costs

per Occurrence2 Capital Costs

per Occurrence Total O&M

Costs per Year Total Capital

Costs per Year Rates **$66.00 $99.00**  Prepare permit to operate application3 5 3 5 42 2,772.00 0 $0.00 210 $13,860.00 $0.00 $0.00 $0.00 $0.00 Perform annual compliance test 23 3 23 100 6,600.00 764 $75,636.00 19,872 $1,891,428.00 $0.00 $0.00 $0.00 $0.00 Conduct record keeping and report data to EPA 23 3 23 64 858.00 0 $0.00 1,472 $19,734.00 $1,517.40 $0.00 $34,900.20 $0.00 Prepare a NOI to construct4 2 1 0.67 30 1,980.00 0 $0.00 20 $1,320.00 $0.00 $0.00 $0.00 $0.00 Prepare minor source permit application4 2 1 0.67 50 3,300.00 293 $29,007.00 229 $21,538.00 $0.00 $0.00 $0.00 $0.00 Prepare major source permit application 0 1 0.00 100 6,600.00 585 $57,915.00 0 $0.00 $0.00 $0.00 $0.00 $0.00 Responses per Year 52.33 Burden 21,803 $1,947,880.00 $1,517.40 $0.00 $34,900.20 $0.00

1. Assumes hours per occurrence is the same as that in the 1998 ICR, except that hours for minor preconstruction permit are half the major source level. 2. O&M costs equal those calculated in Exhibit 3. 3. Assumes 5 sources will apply to renew their permits to operate each year. (In the 2009 ICR renewal, assumed all these 23 existing sources would renew these 5-year title V permits, so would be excessive to do so again.)



## Ex-6

## EXHIBIT 7. NEW EXPLORA **TION SOURCES UNDER STA TE/LOCA** **L A UTHORITY**  **STA TE A** **ND LOCA L A** **GENCIES' A NNUA** **L BURDENS**

Collection Activities Number of Respondents Number of

Occurrences for 3 years Occurrences

per year Hours per

Occurrence* Cost per

Occurrence Total

Hours per Year Total Cost

per Year Rates **$85.00** Consult with sources 0 1 0.00 5 $425.00 0 $0.00 Review NOI to construct 0 1 0.00 55 $4,675.00 0 $0.00 Review permit to operate application 0 1 0.00 40 $3,400.00 0 $0.00 Oversee initial compliance test 0 1 0.00 67 $5,695.00 0 $0.00 Conduct inspections 0 2 0.00 16 $1,360.00 0 $0.00 Review data reports 0 1 0.00 8 $680.00 0 $0.00 Burden 0 $0.00 0.00 * Assumes hours per occurrence is the same as that in the 1998 ICR.



# Ex-7

## EXHIBIT 8. NEW A**LTERNA TIVE ENERGY SOURCES UNDER STA**  **TE/LOCA L A** **UTHORITY STA**  **TE A ND LOCA** **L A GENCIES' A** **NNUA L BURDENS** 

Collection Activities Number of Respondents Number of

Occurrences for 3 years Occurrences

per year Hours per

Occurrence* Cost per

Occurrence Total

Hours per Year Total Cost

per Year Rates **$85.00** Consult with sources 0 1 0.00 5 $425.00 0 $0.00 Review NOI to construct 0 1 0.00 55 $4,675.00 0 $0.00 Review permit to operate application 0 1 0.00 40 $3,400.00 0 $0.00 Oversee initial compliance test 0 1 0.00 67 $5,695.00 0 $0.00 Conduct inspections 0 2 0.00 16 $1,360.00 0 $0.00 Review data reports 0 1 0.00 8 $680.00 0 $0.00 Burden 0 $0.00 0.00 * Assumes hours per occurrence is the same as that in the 1998 ICR.



# Ex-8**EXHIBIT 9. EXISTING SOURCES UNDERSTA TE/LOCA** **L A UTHORITY**  **STA TE A** **ND LOCA L A** **GENCIES' A NNUAL BURDENS** 

Collection Activities Number of Respondents Number of

Occurrences for 3 years Occurrences

per year Hours per

Occurrence 1 Cost per

Occurrence Total

Hours per Year Total Cost

per Year Rates **$85.00** Oversee annual compliance test 23 3 23 67 $5,695.00 1,541 $130,985.00 Conduct inspections 23 12 92 16 $1,360.00 1,472 $125,120.00 Review permit to operate application2 5 3 5 40 $3,400.00 200 $17,000.00 Review data reports 23 3 23 8 $680.00 184 $15,640.00 Review NOI to construct and permit application3 2 1 0.67 35 $2,975.00 23 $1,983.33 Burden 3,420 $290,728.33 143.666667 1. Assumes hours per occurrence is the same as that in the 1998 ICR. 2. Assumes 5 sources will apply to renew their permits to operate each year. (In the 2009 ICR renewal, assumed all these 23 existing sources would renew these 5-year title V permits, so would be excessive to do so again.) 3. Assumes 2 of the existing sources will undergo minor NSR preconstruction permitting for changes at their facilities.



### Ex-92. Assumes 5 sources will apply to renew their permits to operate each year. (In the 2009 ICR renewal, assumed all these 23 existing sources would renew these 5-year title V permits, so would be excessive to do so again.)



### Ex-9

## EXHIBIT 10. NEW A**ND PREVIOUSLY PERMITTED EXPLORA TION SOURCES UNDER EPA**  **A UTHORITY**  **EPA 'S A** **NNUA L BURDEN** 

Collection Activities Number of Respondents Number of

Occurrences for 3 years Occurrences

per year Hours per

Occurrence1 

## Cost per

Occurrence Total

Hours per Year Total Cost

per Year Rates **$46.00** Consult with sources2 

## 5 1 1.67 5 $230.00 8 $383.33 Review NOI to construct and minor permit application3 

## 2 1 0.67 35 $1,610.00 23 $1,073.33 Review NOI to construct and major permit application3 

## 3 1 1.00 263 $12,098.00 263 $12,098.00 Oversee initial compliance test2 

## 5 1 1.67 67 $3,082.00 112 $5,136.67 Review data reports4 

## 10 3 10.00 8 $368.00 80 $3,680.00 Burden 486 $22,371.33

1

## Assumes hours per occurrence is the same as that in the 1998 ICR, except assumed same burden for major source application as in Exhibit 11.



# Ex-10

## EXHIBIT 11. NEW A**ND PREVIOUSLY PERMITTED A LTERNA**  **TIVE ENERGY SOURCES UNDER EPA A** **UTHORITY EPA** **'S A NNUA** **L BURDEN**

Collection Activities Number of Respondents Number of

Occurrences for 3 years Occurrences

per year Hours per

Occurrence1 Cost per

Occurrence Total

Hours per Year Total Cost

per Year Rates **$46.00** Consult with sources 4 1 1.33 5 $230.00 7 $306.67 Review NOI to construct and minor permit application 2 1 0.67 35 $1,610.00 23 $1,073.33 Review NOI to construct and major permit application 2 1 0.67 263 $12,098.00 175 $8,065.33 Review data reports 5 3 5.00 8 $368.00 40 $1,840.00 Burden 245 $11,285.33

* Assumes hours per occurrence is the same as that in the 1998 ICR.



# Ex-11

## EXHIBIT 12. NEW and EXISTING DEVELOPMENT/PRODUCTION SOURCES UNDER EPA **A UTHORITY**  **EPA 'S A** **NNUA L BURDEN** 

Collection Activities Number of Respondents Number of

Occurrences for 3 years Occurrences

per year Hours per

Occurrence* Costs per

Occurrence Total

Hours per Year Total Cost

per Year Rates **$46.00** Consult with sources 0 1 0.00 5 $230.00 0 $0.00 Review NOI to construct and permit application 0 1 0.00 263 $12,098.00 0 $0.00 Review preconstruction permit application 0 1 0.00 100 $4,600.00 0 $0.00 Oversee initial compliance test 0 1 0.00 67 $3,082.00 0 $0.00 Review operating permit application 0 1 0.00 40 $9,200.00 0 $0.00 Review data reports 0 1 0.00 8 $598.00 0 $0.00 Burden 0 $0.00

* Assumes hours per occurrence is the same as that in the 1998 ICR.



# Ex-12

## EXHIBIT 13. CONSISTENCY UPDA **TES A ND OVERSEEING STA**  **TE/LOCA L A** **CTIVITIES EPA** **'S A NNUA** **L BURDEN**

Collection Activities Number of Respondents Number of

Occurrences for 3 years Occurrences

per year Hours per

Occurrence* Cost per

Occurrence Total

Hours per Year Total Cost

per Year Rates **$46.00** Annual Consistency

Reviews 15 3 15 4 184.00 60 $2,760.00 Major NOI/Regulatory

Changes Review 5 1 1.666666667 150 6,900.00 250 $11,500.00 Minor NOI/Regulatory

Changes Review 4 1 1.333333333 40 1,840.00 53 $2,453.33 Burden 363 $16,713.33

* Assumes hours per occurrence is the same as that in the 1998 ICR, except we have added concept of "minor" review



# Ex-13

## EXHIBIT 14. OCS A**IR REGULA TIONS INFORMA** 

**TION COLLECTION BURDEN SUM** **MA RY OF A** **NNUA L BURDENS A** **ND COSTS**

Responses Respondent

Hours Respondent

Costs O&M

Costs Capital

Costs Agency

Hours Agency

Costs New and Previously

Permitted Exploration Sources Under EPA Authority (Exhibit 1) 20.0 2,354 $210,243 $0 $0 New and Previously

Permitted Alternative Energy Sources under EPA Authority (Exhibit 2) 11.3 598 $49,126 $0 $0 New Development / Production Sources Under EPA Authority

Exhibit 3) 0.0 0 $0 $0 $0 New Exploration Sources Under Local Authority (Exhibit 4) 0.0 0 $0 $0 $0 New Alternative Energy Sources under Local Authority (Exhibit 5) 0.0 0 $0 $0 $0 Existing Development / Production Sources Under Local Authority

(Exhibit 6) 52.3 21,803 $1,947,880 $34,900 $0 Subtotal of Industry

Burden (rounded) 84.0 24,754 $2,207,249 $34,900 $0 New Exploration Sources (Exhibit 7) 0.0 0 $0 New Alternative Energy Sources (Exhibit 8) 0.0 0 0 Existing Development/ Production Sources (Exhibit 9) 143.7 3,420 $290,728 Subtotal of State/Local Burden (rounded) 144.0 3,420 $290,728 New Exploration Sources (Exhibit 10) 486 $22,371 New Alternative Energy Sources (Exhibit 11) 245 $11,285 New and Existing Development/ Production Sources (Exhibit 12) 0 $0 Consistency

Updates (Exhibit 13) 363 $16,713 Subtotal of EPA Burden 1,095 $50,370
Total Annual Cost /Burden for the Outer Continental Shelf Air Regulations 228 28,174 $2,497,977 $34,900 $0 1,095 $50,370



# Ex-14