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PART A OF THE SUPPORTING STATEMENT

1. Identification of the Information Collection

1(a) Title and Number of the Information Collection.

“Information Collection Request Survey for the Aerospace Manufacturing and 

Rework Industry.” This is a new information collection request (ICR), and the EPA ICR 

number 2395.01. The OMB Control number is 2060-NEW.

1(b) Short Characterization.

This information collection survey for aerospace manufacturing and rework 

facilities was prepared by EPA’s Sector Policies and Programs Division (SPPD) in the 

Office of Air Quality Planning and Standards (OAQPS), and they are the intended users 

of the collected data. Respondents are owners or operators of aerospace manufacturing 

and rework facilities. Aerospace manufacturing and rework was listed as a source 

category under the Clean Air Act (CAA) on July 16, 1992 (57 FR 31576). The CAA

requires that a risk and technology review (RTR) be conducted for this source category

by September 1, 2003. This information collection will provide SPPD with the data 

necessary to conduct the RTR. 

This survey was developed specifically for aerospace manufacturing and rework 

facilities. This information collection has been tailored to the processes at aerospace 

facilities and uses an electronic submission approach that will be less burdensome for 

both the facilities that must respond and for EPA personnel who must compile the 

responses. Respondents are asked to complete simple forms from available information 

and no request is made to create or develop emission estimates from information in the 

literature. 
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Information is requested from approximately 1,000 aerospace manufacturing and 

rework facilities on general facility information, coatings and spray booth information, 

other process information (e.g., storage tanks, composite processing, etc.), emission 

control devices in place and their basic design and operating features, quantity of air 

emissions, pollution prevention programs at each facility, and information regarding 

startup and shutdown events. This information is necessary for EPA to adequately

characterize residual risk at these facilities, to characterize emissions and control 

measures for operations not currently regulated, and to develop standards for new and 

existing aerospace facilities under section 112 of the CAA, if appropriate. The 

information will be collected from the electronic completion of simple forms, which will 

be compiled to develop a computer database. The completed forms and the computer 

database will become part of the rulemaking docket. 

EPA estimates that there will be roughly 1,000 survey respondents and that they

will incur a total burden of 46,955 hours at an estimated cost of $2,261,288 as a result of 

this one-time collection. The cost to the Agency is estimated to be approximately

$47,633.

2. Need For and Use of the Collection

2(a) Need/Authority for the Collection.

The EPA is charged under section 112 of the CAA with developing national 

emission standards for 189 listed HAP. The Aerospace Manufacturing and Rework 

Facilities Maximum Achievable Control Technology (Aerospace MACT) standard (40 

CFR 63, subpart GG), is a National Emission Standard for Hazardous Air Pollutants 

(NESHAP) developed under the authority of section 112(d) of the CAA. EPA is required 
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to review each MACT standard and to revise them “as necessary (taking into account 

developments in practices, processes and control technologies)” no less frequently than 

every eight years. These reviews are commonly referred to as “technology reviews.” In 

addition, EPA is required to assess the risk remaining (residual risk) after each MACT 

standard and promulgate more stringent standards if they are necessary to protect public 

health. Under EPA’s RTR program, EPA is addressing these two requirements 

concurrently. EPA is updating the information they currently possess and filling 

identified data gaps in that information in order to provide a thorough basis for the RTR 

efforts. The data collection effort will gather additional information to allow 

comprehensive and technically sound analyses that will form the basis for future 

rulemaking decisions. The information is being collected under the authority of section 

114 of the CAA.

2(b) Practical Utility/Users of the Data.

The SPPD of the OAQPS uses the information gathered through the survey form 

to conduct the RTR, on which future rulemaking decisions will be based. 

3. Nonduplication, Consultations and Other Collection Criteria

3(a) Nonduplication.

To the best of EPA’s knowledge, the data to be collected through this survey is 

not available elsewhere. A search of EPA’s ongoing information collections revealed no 

duplication of information gathering efforts, and the information that will be requested is 

not available through other sources. 

In 1994, EPA surveyed aerospace manufacturing and rework facilities to gather 

information to develop MACT standards for the aerospace industry. That survey was 
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sent to a small portion of the industry and did not ask for information about certain 

aerospace manufacturing operations and emission source types. The current survey does 

not duplicate the previous survey. Furthermore, in response to changes in market 

conditions and regulatory requirements (such as the OSHA hexavalent chromium 

exposure limit), EPA expects that many aerospace facilities have changed their coatings, 

enclosed their spray booth operations and reduced HAP content in solvents since 1994. 

To the extent that some of the questions in this survey are similar to those in the previous 

survey, many of the answers that facilities will provide may have changed in the 

intervening years. Because the current survey will collect different and updated 

information as compared to the previous survey, the data collected in 1994 does not 

fulfill EPA’s current needs, and the current survey is not duplicative of the previous 

survey. 

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

Pursuant to the Paperwork Reduction Act (PRA) (44 U.S. C 3501 et seq.), the 

EPA notified the public through a Federal Register notice (see XX FR XXXX, date) of 

the Agency’s intent to submit the Aerospace Industry Survey ICR to OMB. The notice 

included a description of the entities to be affected by the proposed survey, a brief 

explanation of the need for the survey, identification of the statutory authority under 

which the survey will be issued, and an estimate of burden to be incurred by survey

respondents. Through the notice, the Agency requested comments and suggestions 

regarding the survey and the reduction of data collection burden. A summary of the 

comments EPA received and EPA’s responses are included in Attachment 3. 

3(c) Consultations.
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Under 5 CFR 1320.8(d)(1), OMB requires agencies to consult with potential ICR 

respondents and data users about specific aspects of ICRs before submitting an original 

or renewal ICR to OMB for review and approval. EPA sent out a letter providing 

potential respondents with a list of the data elements that will be included in the survey

and requested feedback on these data elements via written communication or by

participation in a conference call with EPA. This teleconference meeting was held 

December 18, 2009, at the EPA facilities in Research Triangle Park, NC. The list of data 

elements is included as Attachment 2 to this supporting statement. The letter was sent to 

relevant trade organizations and to over 1,200 facilities believed to be aerospace 

manufacturing or rework facilities. No feedback, either written or at the meeting, was 

provided by potential respondents directly relating to the data elements of the survey. 

Some facilities did respond to the letter to inform EPA that they were not aerospace 

manufacturing and rework facilities or were area sources.

3(d) Effects of Less Frequent Collection.

This survey is to be administered one time only. If this survey is not conducted, 

the specific data sought in this survey will not be available for EPA’s use in decision 

making about the need for and scope of potential residual risk rules for the aerospace 

industry. 
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3(e) General Guidelines.

This information collection complies with the guidelines in 5 CFR 1320.5(d)(2).

3(f) Confidentiality.

All information submitted to the Agency for which a claim of confidentiality is 

made will be safeguarded according to the Agency policies set forth in Title 40, 

Chapter 1, Part 2, Subpart B—Confidentiality of Business Information (CBI) (See 40 

CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 39999, September 8, 1978; 

43 FR 42251, September 28, 1978; 44 FR 17674, March 23, 1979.)

3(g) Sensitive Questions.

This section is not applicable because this survey does not involve matters of a 

sensitive nature.

4. The Respondents and the Information Requested

4(a) Respondents/NAICS Codes.

Respondents associated with this information collection are owners or operators 

of existing aerospace manufacturing and rework facilities. The North American 

Industrial Classification Codes (NAICS) associated with this industry are presented in 

Table 1.

Table 1. North American Industrial Classification Codes for the 

Aerospace Manufacturing and Rework Industry

NAICS

Code Description

336411 Aircraft Manufacturing

336412 Aircraft Engine and Engine Parts Manufacturing

336413 Other Aircraft Parts and Auxiliary Equipment Manufacturing

336414 Guided Missile and Space Vehicle Manufacturing
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336415 Guided Missile and Space Vehicle Propulsion Units and 

Propulsion Units Parts Manufacturing

336419 Other Guided Missile and Space Vehicle Parts and Auxiliary

Equipment Manufacturing

481111 Scheduled Passenger Air Transportation

481112 Scheduled Freight Air Transportation

481211 Nonscheduled Chartered Passenger Air Transportation

481212 Nonscheduled Chartered Freight Air Transportation

481219 Other Nonscheduled Air Transportation

Approximately 1,000 aerospace manufacturing and rework facilities have been identified 

to receive this survey. EPA projects a total of about 1,000 responses under this ICR. 

4(b) Information Requested.

4(b)(i) Data items, including recordkeeping requirements. A copy of the survey

and instructions are provided as Attachment 1. There are no recordkeeping requirements 

associated with this request. Information is requested from each respondent on general 

facility information, coating and spray booth information, other processes (e.g., storage 

tanks, metal finishing, etc.), air emissions from these booths and other processes, and 

identification of capture and control devices. 

Part I (Introduction) provides guidance to the respondent and highlights that no 

additional monitoring or testing is required to respond to the request. The introduction

lists an EPA contact for questions and provides the name and address to which the 

completed survey should be mailed. Instructions are also provided for submitting the 

completed form electronically. Finally, an outline of the questionnaire form is provided.

Part II (Instructions) provides instructions on how to complete each form in the 

questionnaire. There are general instructions and instructions specific to each form.
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Form A-1 (Parent Company Information) asks for information about the parent 

company, and size of the parent company, in order for EPA to conduct an appropriate 

economic analysis for this category and evaluate potential small entity impacts. 

Form A-2 (Facility Information) is where the respondent (facility contact 

person), company and facility are identified. EPA will use this information to ensure that 

its facility list is current and accurate, a necessary component of achieving to represent 

the universe of sources in any analyses. Coordinates are requested, along with a typical 

operating schedule for the facility. In addition, questions are asked about the products 

produced at the facility and if the facility is a major source of HAP emissions.

Form B-1 (Spray Booth Information) requests data for each spray booth at the 

facility, including the type of booth, the location coordinates of each booth, and the 

dimensions of each booth. Information is also requested on the type of particulate filter 

system used in the booth. Control device information should also be provided. 

Form C-1 and C-2 (Coatings) are the same form except one requests the 

information in English units and the other requests the information in metric units. 

Respondents do not have to fill out both forms, but can fill out whichever one utilizes the 

data they have easily available. Information is requested on the type of coating, including 

specialty coatings and the HAP contained in each coating. The forms also include a 

section for the respondents to identify the spray booth that each coating was applied in 

and the amount of coating that was applied. 

Form D-1 (Chemical Milling and Metal Finishing Operations) requests HAP 

usage and emissions from chemical milling and metal finishing operations at the facility. 
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Coordinates, dimensions and hours of operation are requested for each tank. Control 

device and work practice information is also requested.

Form E-1 (Blast Depainting/Cleaning Operations) is where the respondent will 

report HAP emissions from blast depainting and cleaning operations that use blasting 

methods. In addition to emissions, coordinates, dimensions and hours of operation are 

also requested. Control device and work practice information should also be recorded on 

this form.

Form E-2 (Solvent Depainting Operations) is where the respondent will report 

HAP emissions from depainting operations that use solvent materials. The same 

information is requested (e.g., emissions, coordinates, control device) as in Form E-1.

Form E-3 (Solvent Cleaning Operations) requests information on HAP emissions 

from solvent cleaning operations such as hand-wipe cleaning of aerospace components, 

cleaning of spray guns and cleaning of spray booths. In addition to HAP emissions, 

information is requested on location coordinates, building dimensions, control devices 

and work practices. 

Form E-4 (Solvent Cleaning Operations) requests information similar to that 

requested on Form E-3, except that only cleaning operations subject to the Halogenated 

Solvent Cleaning NESHAP (40 CFR 63, subpart T) should be reported. Even though 

halogenated solvent cleaning operations are not subject to the aerospace NESHAP, the 

EPA is concerned that some aerospace facilities may have mistakenly reported emissions 

from these operations as emissions from operations subject to the aerospace NESHAP in 

part reporting to state or local agencies. In order to estimate the residual risk accurately 

from each of these categories, the EPA is attempting to first develop accurate emissions 
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estimates. The respondents’ efforts to properly report halogenated solvent cleaning 

operations on Form E-4 and not on Form E-3 will play an important role in the EPA’s 

development of emissions estimates from these two categories. 

Form F-1 and F-2 (Composite Processing Operations) are the same form except 

one requests the information in English units and the other requests the information in 

metric units. Respondents do not have to fill out both forms, but can fill out whichever 

one utilizes the data they have easily available. Information is requested on the type of 

resins used in composite processing operations, the total volume of resin used and 

information related to the spray booth used to apply the resins. 

Form G-1 (Storage Tanks) is where the respondent will provide HAP emissions 

from storage tanks used to store materials used in aerospace manufacturing and rework 

operations. The type of tank, the coordinates of the tank, the dimensions of the tank, the 

HAP component of the material in the tank and control device information are all 

requested. 

Form H-1 (Wastewater Treatment Operations) requests information on 

wastewater treatment operations as they pertain to aerospace manufacturing and rework 

operations. The coordinates, dimensions, hours of operation, HAP emissions and control 

device information are all requested. 

Form I-1 (Startups and Shutdowns) provides examples of startup and shutdown 

events that would be reported on this form. Information on this form is requested if it is 

readily available. Additional testing or data gathering is not required to complete this 

form for startup and shutdown events.
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Forms J-1 to J-11 (Air Pollution Control Devices) provide a form for each control 

device likely to be in use at aerospace manufacturing and rework facilities. If an air 

pollution control device is not in use at the facility, the relevant form does not need to be 

filled out. The information requested for these forms should be readily available. No 

additional testing or data gathering is required in order to complete these forms.

Form K-1 (Air Pollution Control Device Costs) is where the respondent will enter 

readily available information related to the cost of each air pollution control device for 

which information was provided in Forms J-1 to J-11. 

4(b)(ii)Respondent activities. The survey will be sent to each aerospace 

manufacturing and rework facility, who will be asked to complete and return the survey

instrument. Completion of the survey involves the following steps:

 Reviewing instructions: Respondents will need to read the instructions 

for the survey;

 Search data sources: Respondents may need to consult records and 

review facility information, in addition to gathering available data from 

files, regarding coating usage, booth types, and other requested 

information prior to completing the survey;

 Complete and review the collection of information: Respondents will 

need to complete the survey and review their answers; and

 Transmit or otherwise disclose the information: Respondents will need 

to return the completed survey to EPA.

The request does not require respondents to make measurements of emissions or 

otherwise create information, and it relies on information that should be readily available 
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to the respondent. Consequently, it is consistent and compatible with existing reporting 

and recordkeeping requirements because the survey asks only for this existing 

information. There is no need for respondents to develop or acquire technology or 

systems to collect, process or disclose the information.

Non-respondents will receive up to two reminder calls encouraging them to 

participate. If EPA decides to issue subpoenas because it does not receive a sufficient 

response rate to accurately characterize the industry, the initial non-respondents will need 

to review the subpoena, as well as following the steps outlined above.

This questionnaire asks for readily obtainable information, e.g., information 

known or easily accessible by technical, managerial or supervisory employees of the 

facility who are responsible for manufacturing, processing, technical services or 

marketing. The facility does not need to generate new information to complete the 

survey. 

The collection will be a one-time event, and there will be no requirement for

respondents to maintain records to support their responses. However, EPA is suggesting 

that respondents keep a copy of the completed questionnaire for their files in case the 

Agency contacts them with any follow-up questions after reviewing their responses. 

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

Information Management

5(a) Agency Activities.

Agency activities associated with the information collection include preparing the 

questionnaire, answering respondent questions about the questionnaire, reviewing data 

submissions, addressing requests for confidentiality and compiling the data into a 

database.
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5(b) Collection Methodology and Management.

Data collection will be accomplished using an electronic survey tool. Recipients 

of the letter announcing the survey’s availability will be directed to an EPA web page to 

download the files. The respondent will be asked to complete and return the survey 

within a three-month timeframe. Respondents will be encouraged to complete an 

electronic copy of the survey and upload it to the EPA web page, which reduces 

transcription errors when EPA processes the responses. Non-respondents will receive up 

to two reminder calls encouraging them to participate. The web page will also have 

instructions on how to submit data that is CBI.

A written survey is being used because some of the information EPA is requesting 

may require the respondent to consult records or other documents at the facility, which 

would be difficult to do during a telephone survey given the type of information 

requested and the number of potential respondents. In addition, the written survey

method will allow the respondent to complete the survey at his or her convenience. 

Electronic transmission of the empty and completed survey forms will lead to more 

efficient data collection, both in terms of reducing mailing costs and paper usage and 

reducing transcription errors. The survey has been designed to be easily compiled into a 

database upon receipt of the completed survey files. 

For this information collection, the submissions will be monitored for 

completeness, and follow-up calls will be made to maximize the response rate. 

Confidential information will be maintained in secure locations as required by procedures 

for handling CBI. Confidential Business Information will not be entered into the 

computer database. Public access to non-CBI information will be provided through the 
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rulemaking docket, which will contain the survey responses and a copy of the resulting 

database.

5(c) Small Entity Flexibility.

EPA has identified a list of roughly 1,000 U.S. facilities with aerospace 

manufacture or rework operations. Some of these manufacturers are small businesses as 

defined by the Small Business Administration’s size standards. EPA considered 

collecting data from only a sample of manufacturers, but determined that a census (a 

survey administered to the entire population of aerospace manufacturing and rework 

facilities, including small businesses) is appropriate. A census will more accurately 

characterize the industry. EPA needs to include small businesses in the survey so that it 

can better estimate potential small business impacts in the event the Agency ultimately 

decides to proceed with a regulatory action. 

In developing the information request, SPPD considered whether a separate 

request or no request for information should be made to small facilities. A major 

consideration was that the burden of responding to the questionnaire is not excessive for 

small facilities. Because they have fewer and simpler processes, smaller facilities will 

require less time to prepare a response than larger facilities. The information requested 

from the smaller facilities should be readily available and no requests are made to 

perform measurements or create information.

Many of the aerospace manufacturing and rework facilities meet the definition of 

small business (e.g., companies with fewer than 1,000 or 1,500 employees total at all 

facilities for facilities in NAICS 2-digit code 33, and companies with less than $7 million 

in annual average receipts for facilities in NAICS 2-digit code 48), and information from 
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small entities is important to this regulatory development. The information collected 

from small entities will improve the analyses that must be performed to assess the 

economic impact of a potential MACT standard on them. A Regulatory Flexibility

Analysis must be performed under the Regulatory Flexibility Act of 1980 if a proposed 

regulation will have a significant economic impact on a substantial number of small 

entities. The information from small entities will also assist in addressing the 

requirements of the Small Business Regulatory Enforcement Fairness Act of 1996.

Although many of these small businesses are not likely to be major sources of 

HAP emissions, information on emissions and the level of control performance achieved 

is needed from all facilities in the industry to determine with reasonable accuracy the 

“average emission limitation achieved” by the top-performing 12 percent of sources. The 

coverage of small facilities is especially important if any are in this top 12 percent.

In addition, the best controlled sources may include some of the smaller facilities, 

which would affect the determination of MACT for new aerospace facilities. Information 

on smaller facilities will aid in determining if a facility size cutoff is warranted, and if so, 

which of the smaller facilities should be exempt from the MACT standard. The 

information on small facilities will also provide insight into pollution prevention 

measures that might be applicable to larger facilities. Even if the smaller facilities are not 

major sources, the information from their responses to the survey will be useful in 

determining if they are significant area sources that may warrant regulation.
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5(d) Collection Schedule.

The proposed mailing date for the survey is XXXX. The respondents are given

three months to reply, with XXXX being the anticipated date when all data is available 

for analysis by EPA. The data will be used to develop residual risk standards, if 

warranted, with proposal targeted for August 2011 and promulgation in June 2010.

6. Estimating the Burden and Cost of the Collection

6(a) Estimating Respondent Burden.

EPA will request that all U.S. aerospace manufacturing and rework facilities 

complete the questionnaire forms. Each section of the questionnaire is expected to be 

completed by technical and clerical staff and reviewed by managerial staff. Respondent 

activities include reading the cover letter and downloading the forms, reading the 

instructions, gathering data, manipulating data for entry into the forms, entering data into 

the forms and uploading the forms. The exhibit reflects the assumption that technical and 

clerical staff will devote their time to reading instructions, gathering information, 

completing the questionnaire forms and transmitting the information; managerial staff 

will devote their time to reading instructions and reviewing questionnaire responses. 

Table 2 presents the average number of hours required for each task for 

respondents of three sizes: small, medium and large. Due to the wide range in sizes of 

aerospace facilities, it was necessary to estimate the burden for each size of facility. 

Based on the industry’s facility size breakdown contained in the proposal Background 

Information Document for the Aerospace NESHAP, it is assumed that 84 percent of the 

respondents are small facilities, 14 percent are medium facilities and two percent are 
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large facilities. There are approximately 1,000 respondents expected to complete the 

questionnaire. 

A typical small-size facility respondent is estimated to need an average of 30.75 

hours to complete the questionnaire, while a typical medium-size facility respondent is 

estimated to need an average of 86.74 hours to complete the questionnaire and a typical 

large-size facility respondent is estimated to need an average of 142.75 hours to complete 

the questionnaire. These burden estimates include technical, management and clerical 

hours. Table 3 presents the burden estimate for small-size facilities, while Table 4 

presents the burden estimate for medium-size facilities and Table 5 presents the burden 

estimate for large-size facilities. These unit burden estimates are average values. As 

with any average, some respondents will be above the average and others will be below. 

6(b) Estimating Respondent Costs.

The information collection activities and estimated costs for all respondents are 

presented in Tables 3, 4 and 5. The costs are based on hourly rates estimated as follows: 

technical at $49.80/hr, management at $62.08/hr and clerical at $24.79/hr. For a typical 

small-size facility respondent, the costs are estimated as $1,703 (30.75 hours), while for a 

typical medium-size facility respondent the costs are estimated as $4,804 (86.75 hours), 

and for a typical large-size facility the costs are estimated as $7,906 (142.75 hours). 

There are no capital or operation and maintenance costs. A summary of the burden and 

costs for all respondents is presented in Table 6.

6(c) Estimating Agency Burden and Cost.

The costs the federal government would incur would be for preparing the 

questionnaire, answering respondent questions about the questionnaire, reviewing data 
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submissions, addressing requests for confidentiality and compiling the data into a 

database. The burden estimate is presented in Table 7 at the end of this supporting 

statement. Hourly labor rates were taken from the Office of Personnel Management 

Salary Table 2010-GS (effective January 2010) and are as follows: technical (GS-12, 

Step 5) at $32.73/hour, management (GS-15, Step 5) at $54.10/hr, and clerical (GS-5, 

Step 5) at $14.90/hr. The total costs for the Agency are estimated as $47,633. 

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

For small-size facilities, the total burden shown in Table 3 is estimated as 1,291.5

management hours, 25,830 technical hours and 2,583 clerical hours at a cost of 

$1,430,543. The total burden and costs are based on 840 small-size aerospace facilities 

completing the survey.

For medium-size facilities, the total burden shown in Table 4 is estimated as 

607.3 management hours, 12,145 technical hours and 1,214.5 clerical hours at a cost of 

$672,627. The total burden and costs are based on 140 medium-size aerospace facilities 

completing the survey. 

For large-size facilities, the total burden shown in Table 5 is estimated as 142.8

management hours, 2,855 technical hours and 285.5 clerical hours at a cost of $158,118. 

The total burden and costs are based on 20 large-size aerospace facilities completing the 

survey. 

6(e) Bottom Line Burden Hours and Cost Tables.

6(e)(i) Respondent tally. The total respondent burdens are given in Table 6 and 

are estimated as 29,704.5 hours and $1,430,543 for small-size respondents, 

13,966.8 hours and $672,627 for medium-size respondents and 3,283.3 hours and 
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$158,118 for large-size respondents. For all respondents, the total burden is estimated as 

46,954.6 hours and $2,261,288.

6(e)(ii) The Agency tally. The total Agency burden is given in Table 7 and is 

estimated as 1,483.5 hours and $47,633.

6(e)(iii)Variations in the annual bottom line. This section does not apply since 

no significant variation is anticipated.

6(f) Reasons for Change in Burden.

This section does not apply since this is a new collection.

6(g) Burden Statement.

The average respondent burden for each small-size facility is estimated as 30.75

hours and a cost of $1,703. The average respondent burden for each medium-size facility

is estimated as 86.75 hours and a cost of $4,804. The average respondent burden for each 

large-size facility is estimated as 142.75 hours and a cost of 7,906. This includes time to 

read the cover letter and download the forms, read the instructions, gather data, 

manipulate data for entry into forms, enter data into forms and upload forms. No capital 

costs or operation and maintenance costs will be incurred.

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 
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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.

Send comments on the Agency’s need for this information, the accuracy of the 

provided burden estimates, and any suggested methods for minimizing respondent 

burden, including through the use of automated collection techniques to the Director, 

Office of Policy, Planning and Evaluation (OPPE) Regulatory Information Division, U.S. 

Environmental Protection Agency (2137), 401 M St., S.W., Washington, DC 20460; and 

to the Office of Information and Regulatory Affairs, OMB, 725 17th Street, NW, 

Washington, DC 20503, Attention: Desk Officer for EPA. Include the EPA ICR 

number and OMB control number in any correspondence.

PART B OF THE SUPPORTING STATEMENT

This section is not applicable because statistical methods are not used in the data 

collection associated with this information collection.
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TABLE 2. ESTIMATED RESPONDENT BURDEN FOR THE AEROSPACE ICR

Task

Technical Labor Hours by Facility Size

Small Medium Large

Read cover letter/download forms 0.75 0.75 0.75

Read instructions 1.5 1.5 1.5

Gather data 20 60 100

Manipulate data for entry into forms 4 12 20

Enter data into forms 4 12 20

Upload forms 0.5 0.5 0.5

TOTAL TECHNICAL LABOR HOURS 30.75 86.75 142.75
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TABLE 3. ANNUAL RESPONDENT BURDEN AND COST FOR SMALL FACILITIES

Burden Item

(A)

Person hours 

per respondenta

(B)

Number of 

respondents

(C)

Technical 

person hours

(C = A x B)

(D)

Management 

person hours 

(0.05 x C)

(E)

Clerical person 

hours (0.1 x C)

(F)

Costb($)

Read cover letter/download 

forms 0.75 840 630.0 31.5 63.0 34,891

Read instructions 1.5 840 1,260.0 63.0 126.0 69,783

Gather data 20 840 16,800.0 840.0 1,680.0 930,434

Manipulate data for entry 

into forms 4 840 3,360.0 168.0 336.0 186,087

Enter data into forms 4 840 3,360.0 168.0 336.0 186,087

Upload forms 0.5 840 420.0 21.0 42.0 23,260.86

TOTAL LABOR 

BURDEN AND COST 30.75 n/a 25,830.0 1,291.5 2,583.0 1,430,543

a

See values in Table 1.

b Costs were taken from the Bureau of Labor Statistics, National Compensation Survey, Employer Costs for Employee Compensation Supplementary Tables December 2007. Supplementary Table 2 –

Employer costs per hour worked for employee compensation and costs as a percent of total compensation: Private industry workers in manufacturing industries, by occupational group, establishment 

size and bargaining status. December 2007. Available on-line at http://www.bls.gov/ect. The cost for technical person hours is $49.80/hour, taken from the total compensation value for the 

“professional and related” occupational group. The cost for management person hours is $62.08/hr, taken from the total compensation value for the “management, business and financial” occupational 

group. The cost for clerical person hours is $24.79/hr, taken from the total compensation value for the “office and administrative support” occupational group.
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TABLE 4. ANNUAL RESPONDENT BURDEN AND COST FOR MEDIUM FACILITIES

Burden Item

(A)

Person hours 

per respondenta

(B)

Number of 

respondents

(C)

Technical 

person hours

(C = A x B)

(D)

Management 

person hours 

(0.05 x C)

(E)

Clerical person 

hours (0.1 x C)

(F)

Costb($)

Read cover letter/download 

forms 0.75 140 105.0 5.3 10.5 5,815

Read instructions 1.5 140 210.0 10.5 21.0 11,630

Gather data 60 140 8,400.0 420.0 840.0 465,217

Manipulate data for entry 

into forms 12 140 1,680.0 84.0 168.0 93,043

Enter data into forms 12 140 1,680.0 84.0 168.0 93,043

Upload forms 0.5 140 70.0 3.5 7.0 3,877

TOTAL LABOR 

BURDEN AND COST 86.75 n/a 12,145.0 607.3 1,214.5 672,627

a

See values in Table 1.

b Costs were taken from the Bureau of Labor Statistics, National Compensation Survey, Employer Costs for Employee Compensation Supplementary Tables December 2007. Supplementary Table 2 –

Employer costs per hour worked for employee compensation and costs as a percent of total compensation: Private industry workers in manufacturing industries, by occupational group, establishment 

size and bargaining status. December 2007. Available on-line at http://www.bls.gov/ect. The cost for technical person hours is $49.80/hour, taken from the total compensation value for the 

“professional and related” occupational group. The cost for management person hours is $62.08/hr, taken from the total compensation value for the “management, business and financial” occupational 

group. The cost for clerical person hours is $24.79/hr, taken from the total compensation value for the “office and administrative support” occupational group. 
24

TABLE 5. ANNUAL RESPONDENT BURDEN AND COST FOR LARGE FACILITIES

Burden Item

(A)

Person hours 

per respondenta

(B)

Number of 

respondents

(C)

Technical 

person hours

(C = A x B)

(D)

Management 

person hours 

(0.05 x C)

(E)

Clerical person 

hours (0.1 x C)

(F)

Costb($)

Read cover letter/download 

forms 0.75 20 15.0 0.8 1.5 831

Read instructions 1.5 20 30.0 1.5 3.0 1,661

Gather data 100 20 2,000.0 100.0 200.0 110,766

Manipulate data for entry 

into forms 20 20 400.0 20.0 40.0 22,153

Enter data into forms 20 20 400.0 20.0 40.0 22,153

Upload forms 0.5 20 10.0 0.5 1.0 554

TOTAL LABOR 

BURDEN AND COST 142.75 n/a 2,855.0 142.8 285.5 158,118

a

See values in Table 1.

b Costs were taken from the Bureau of Labor Statistics, National Compensation Survey, Employer Costs for Employee Compensation Supplementary Tables December 2007. Supplementary Table 2 –

Employer costs per hour worked for employee compensation and costs as a percent of total compensation: Private industry workers in manufacturing industries, by occupational group, establishment 

size and bargaining status. December 2007. Available on-line at http://www.bls.gov/ect. The cost for technical person hours is $49.80/hour, taken from the total compensation value for the 

“professional and related” occupational group. The cost for management person hours is $62.08/hr, taken from the total compensation value for the “management, business and financial” occupational 

group. The cost for clerical person hours is $24.79/hr, taken from the total compensation value for the “office and administrative support” occupational group.
25

TABLE 6. SUMMARY OF ESTIMATED RESPONDENT BURDEN FOR THE 

AEROSPACE ICR

Value by Facility Size

Small Medium Large

Total Number of Respondents 840 140 20

Total Labor Hours 29,704.5 13,966.8 3,283.3

Labor Hours Per Respondent 30.75 86.75 142.75

Total Labor Cost ($) 1,430,543 672,627 158,118

Labor Cost Per Respondent ($) 1,703 4,804 7,906
26

TABLE 7. ANNUAL BURDEN AND COST FOR THE FEDERAL GOVERNMENT

Burden Item

(A)

EPA 

Hrs/Occurrence

(B)

Contractor 

Hrs/Occurrence

(C)

Number of 

Occurrences

(D)

Total EPA Hrs 

(AxC)

(E)

Total 

Contractor Hrs 

(BxC)

(F)

Total Hrs 

(D+E)c

Develop survey and 

industry mailing list 50.0 350.0 1 50.0 350.0 400.0

Distribute survey 40.0 0.0 1 40.0 0.0 40.0

Answer questionsa0.1 0.25 200 20.0 50.0 70.0

Audit/review submissions 0.25 0.1 1000 250.0 100.0 350.0

Enter into database/QA 

check 0.0 0.3 1000 0.0 300.0 300.0

Analyze submissions and 

summarize results 0.0 80.0 1 0.0 80.0 80.0

Respond to requests for 

confidentialityb0.3 0.2 100 30.0 20.0 50.0

TOTAL LABOR 

BURDEN AND COST n/a n/a n/a 390.0 900.0 1,290.0

a

It is assumed that questions will need to be answered for 20 percent of the respondents.

b

It is assumed that responses to requests for confidentiality will be needed for 10 percent of the respondents.

c

For the purposes of the cost calculations in this table, it is assumed that EPA and Contractor hours for technical, management, and clerical positions cost the same amount.
27

TABLE 7. ANNUAL BURDEN AND COST FOR THE FEDERAL GOVERNMENT (cont.)

Burden Item

(G)

Technical person hours 

(=F) (GS12)

(H)

Management person 

hours (G x 0.05)

(GS15)

(I)

Clerical person hours 

(G x 0.1) (GS5)

(J)

Costd($)

Develop survey and 

industry mailing list 400.0 20.0 40.0 14,770.00

Distribute survey 40.0 2.0 4.0 1,477.00

Answer questionsa70.0 3.5 7.0 2,584.75

Audit/review submissions 350.0 17.5 35.0 12,923.75

Enter into database/QA 

check 300.0 15.0 30.0 11,077.50

Analyze submissions and 

summarize results 80.0 4.0 8.0 2,954.00

Respond to requests for 

confidentialityb50.0 2.5 5.0 1,846.25

TOTAL LABOR 

BURDEN AND COST 1,290.0 64.5 129.0 47,633.25

d Costs were taken from the U.S. Office of Personnel Management, Salary Table 2010-GS, effective January 2010, available on-line at http://www.opm.gov/oca/10tables/html/gs_h.asp. All hourly rates 

are baseline values. It was assumed that the technical person is a GS-12, Step 5 employee with a rate of $32.73 per hour, that the management person is a GS-15, Step 5 employee with a rate of $54.10 

per hour, and that the clerical person is a GS-5, Step 5 employee with a rate of $14.90 per hour.