Appendix A-1

LABOR RATES *

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 Agency 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 

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 

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 EXPLORATION SOURCES UNDER STATE/LOCAL AUTHORITY

STATE AND LOCAL AGENCIES' ANNUAL 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 ALTERNATIVE ENERGY SOURCES UNDER STATE/LOCAL AUTHORITY

STATE AND LOCAL AGENCIES' ANNUAL 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 UNDERSTATE/LOCAL AUTHORITY

STATE AND LOCAL AGENCIES' ANNUAL BURDENS

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 $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-9
sive to do so again.)

Ex-9
EXHIBIT 10. NEW AND PREVIOUSLY PERMITTED EXPLORATION SOURCES UNDER EPA AUTHORITY

 EPA'S ANNUAL 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 AND PREVIOUSLY PERMITTED ALTERNATIVE ENERGY SOURCES UNDER EPA AUTHORITY

 EPA'S ANNUAL 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 AUTHORITY 

 EPA'S ANNUAL 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 UPDATES AND OVERSEEING STATE/LOCAL ACTIVITIES

 EPA'S ANNUAL 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 AIR REGULATIONS INFORMATION COLLECTION BURDEN

SUMMARY OF ANNUAL BURDENS AND 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