SUPPORTING STATEMENT PART A: 

INFORMATION COLLECTION REQUEST 

FOR THE 

MANDATORY REPORTING OF GREENHOUSE GASES – 

CORPORATE ID RULE AMENDMENT 

OMB Control No. 2060-NEW 

EPA ICR No. 2374.02

August 2010 
ICR for the GHG Reporting Rule 

Corporate ID Amendment Page 1 August 2010 

SUPPORTING STATEMENT 

FOR MANDATOR REPORTING OF GREENHOUSE GASES - 

CORPORATE ID RULE AMENDMENT 

EPA ICR #2374.02

1. IDENTIFICATION OF THE INFORMATION COLLECTION 

1(a) Title of the Information Collection 

TITLE: “Mandatory Reporting of Greenhouse Gases (GHG Reporting Rule) – Corporate 

ID Rule Amendment.”

OMB Control Number: 2060-NEW 

1(b) Short Characterization/Abstract 

The United States (U.S.) Environmental Protection Agency (EPA) is amending the GHG 

Reporting Rule to require facilities subject to the rule to provide additional information items. 

These items include the following: legal name, physical address, and ownership status of a 

facility’s ultimate US parent company; the facility’s primary North American Industry 

Classification System (NAICS) codes; and whether or not reported emissions include those from 

a cogeneration unit. The amendments also require facilities owned by more than one parent 

company to report the address and percent of facility ownership for each parent company. 

These items will be added to the monitoring, recordkeeping, and reporting burden 

calculated when the GHG Reporting Rule was promulgated on October 30, 2009 (74 FR 56260). 

The final rule requires reporting of greenhouse gas emissions from all sectors of the economy. 

The rule does not require control of greenhouse gases, rather it requires only that sources above 

certain threshold levels monitor and report emissions. 
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Corporate ID Amendment Page 2 August 2010 

2. NEED FOR AND USE OF THE COLLECTION 

2(a) Need/Authority for the Collection 

Signed into law on December 26, 2007, the FY2008 Consolidated Appropriations Act 

(henceforth referred to as the “Appropriations Act”) directed EPA to “develop and publish a 

draft rule not later than 9 months after the date of enactment of this Act, and a final rule not later 

than 18 months after the date of enactment of this Act, to require mandatory reporting of 

greenhouse gas emissions above appropriate thresholds in all sectors of the economy of the 

United States.” 

 

The accompanying explanatory statement further directed EPA to “use its existing 

authority under the Clean Air Act” (CAA) to develop a mandatory GHG reporting rule. The 

Agency is further directed to include in its rule reporting of emissions resulting from upstream 

production and downstream sources, to the extent that the Administrator deems it appropriate. 

The Administrator shall determine appropriate thresholds of emissions above which reporting is 

required, and how frequently reports shall be submitted to EPA. The Administrator shall have 

discretion to use existing reporting requirements for electric generating units under §821 of the 

1990 CAA amendments. 

The Final GHG Reporting Rule fulfilled the requirements of the Appropriations Act. 

These amendments simply add additional reporting elements to the list of items in §98.3(c) of the 

final rule. Specifically, all facilities reporting under the GHG Reporting Rule are required to list 

the name and address of their ultimate US parent company, the primary North American Industry 

Classification System (NAICS) code, and all other applicable NAICS codes and to specify 

whether reported emissions include those from a cogeneration unit. The amendments also 

require facilities owned by more than one parent company to report the address and percent of 

facility ownership for each parent company. 

Given the broad scope of CAA section 114, it is appropriate for EPA to gather the 

information required by this final rule because such information is relevant to EPA’s 

implementation of a wide variety of CAA provisions. 
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Corporate ID Amendment Page 3 August 2010 

2(b) Practical Utility/Users of the Data 

The purpose of collecting the name and physical address of the U.S. parent company(s) in 

the annual reports for 40 CFR part 98 is to assist in aggregating facility-based GHG emissions 

data to the corporate level. This additional data element allows EPA to compile more 

comprehensive information on corporate GHG emissions and conduct a variety of analyses. For 

example, the data collected under this final rule would be immediately available to EPA and 

could inform EPA’s implementation of CAA section 103(g) regarding improvements in sectorbased nonregulatory strategies and technologies for preventing or reducing air pollutants. 

In addition, the data collected through this final rule would be immediately available to 

EPA and could be used for the purposes of providing additional information to support more 

effective research and develop actions to address GHG emissions. For example, corporate parent 

and NAICS data would assist EPA in developing and improving emission inventories, as well as 

characterize emissions data in several different ways. A more detailed understanding of the 

sources and operational categories of GHG emissions could lead to improvements in air 

pollution emissions information that is relied upon to develop effective control strategies. For 

example, EPA could use the NAICS code information gathered by this rule to compare results 

both within industries and across industry sectors. 

Finally, the information gathered through this rule will be immediately available to 

enhance EPA’s implementation of various nonregulatory programs aimed at encouraging 

voluntary reductions of GHG emissions. Under the authority of CAA section 103, EPA has 

launched a variety of nonregulatory programs aimed at reducing emissions of GHGs. The 

additional data will assist EPA by providing more detailed information on possible sources, and 

facility operations within industrial sectors for EPA to work with in the context of these 

programs. 

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA 

3(a) Nonduplication 

EPA evaluated existing GHG programs and the GHG data currently available to 

determine whether the final GHG Reporting Rule duplicated other information collections. As 

this is simply an amendment for additional reporting requirements, the same analysis applies. 

Documentation of EPA’s review of GHG monitoring protocols for each source category 

used by federal, state, and international voluntary and mandatory GHG programs, and the review 

of state mandatory GHG rules, can be found in the docket at EPA-HQ-OAR-2008-0508-056. 
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Corporate ID Amendment Page 4 August 2010 

3(b) Public Notice Required Prior to Information Collection Request (ICR) 

Submissions to OMB 

In response to the request for public comments in the preamble, EPA received two 

written comments that questioned the need for EPA to collect parent company information. One 

commenter submitted that company affiliation should not be used as a factor in policy 

development. The other commenter’s primary objection was that EPA had been vague and nonspecific in justifying collection of parent company information. The commenter stated that 

EPA’s authority to collect information under section 114 is limited by the requirements of the 

Paperwork Reduction Act (5 C.F.R. 1320), under which EPA must demonstrate that the 

requested information has “practical utility.” The commenter felt that EPA had not met the 

definition of “practical utility” in its justification for collecting parent company information. The 

commenter added that as practical utility is necessary for OMB to grant an ICR, EPA should not 

finalize this requirement until it has identified and solicited comment on a practical use. 

EPA responded to these comments in the preamble to the final rule as follows: As 

explained in the section I.C of the preamble, section 114 of the CAA is sufficiently broad for 

EPA to collect this information. Section 114 generally authorizes EPA to gather information 

from any person who owns or operates an emissions source, who is subject to a requirement of 

the CAA, who manufacturers control or process equipment, or who the Administrator believes 

has information necessary for the purposes of section 114(a). EPA may gather information for 

purposes of establishing implementation plans or emissions standards, determining compliance, 

or “carrying out any provision” of the Clean Air Act. For these reasons, the Administrator may 

request that a person, on a one-time, periodic or continuous basis, establish and maintain records, 

make reports, install and operate monitoring equipment and, among other things, provide such 

information the Administrator may reasonably require. This language has been interpreted to 

grant EPA broad authority. See, e.g., Dow Chemical Co. v. U.S., 467 U.S. 227, 233 (1986) 

(“Regulatory and enforcement authority generally carries with it all modes of inquiring and 

investigation traditionally employed or useful to execute the authority granted.”). 

It is reasonable for EPA to request the parent company information. Once EPA has this 

information, EPA will be able to immediately use it to assist in implementation of agency policy 

and program goals including developing and improving emission inventories and enhancing the 

implementation of programs aimed at reducing emissions of GHGs. For more information, refer 

to section I.C of the preamble, where EPA has further explained the immediate usefulness of this 

information under the Clean Air Act, as well as section 2 of this ICR supporting statement. 

3(c) Consultations 

EPA met with over 4,000 people and 135 groups since proposal signature (March 10, 

2009) of the GHG Reporting Rule. Details of these meetings are available in the docket (EPAHQ-OAR-2008-0508). No additional consultations were held during the drafting of these 

amendments. 
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Corporate ID Amendment Page 5 August 2010 

3(d) Effects of Less Frequent Collection 

If the information collection were not carried out on this schedule, the Agency would not 

be able to develop an informed tracking system of trends in GHG emissions across the country. 

The year-by-year GHG emissions information from a broad range of industry sectors may 

eventually be used to inform future climate change policy decisions. 

EPA recognizes that highest level US parent company and primary NAICS code(s) may 

change more frequently than annually. However, EPA believes that the burden of requiring 

facilities to update these data elements on a more frequent basis, such as every time a facility’s 

highest level US parent company changes, or primary product(s), activity(s), or service(s), is 

greater than the benefit of obtaining that additional information. Therefore, EPA is only 

requiring these data elements annually, thus lessening the burden as much as possible while still 

gathering the required information. 

3(e) General Guidelines 

This collection of information is consistent with all OMB guidelines under 5 CFR 

1320.6. However, these amendments, as well as the final GHG Reporting Rule, require that 

facilities retain records for a period of 5 years, which exceeds the 3-year retention period 

specified in the general information collection guidelines in 5 CFR 1320.6(f) of the Office of 

Management and Budget (OMB) regulations implementing the Paperwork Reduction Act. 

Facilities or suppliers that have emissions or products with emission less than 25,000 

metric tons CO2e for five years in a row may cease reporting. Those that cease reporting must 

have records to cover those five years of emissions. EPA selected a 5-year period, instead of a 

shorter time frame, because it allows facilities or suppliers that consistently report less than 

25,000 metric tons CO2e to stop reporting, but avoids the situation where a facility or supplier 

near this level would be constantly moving in and out of the reporting program due to small 

variations from one year to the next. EPA believes 5 years of records for these respondents is 

needed to document that they meet the provisions to cease reporting and so that questions about 

past emission estimates can be resolved, if needed. Thus, the 5-year record retention requirement 

of the rule adds no additional burden. 

3(f) Confidentiality 

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

be safeguarded according to the proposed confidentiality determination published on July 7, 

2010 (75 FR 39094). The determination specified which data reporting elements in part 98 

would be treated as confidential business information (CBI) and which data elements must be 

available to the public under section 114 of the CAA. A final determination will be issued 

before any part 98 data is released. 
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Corporate ID Amendment Page 6 August 2010 

3(g) Sensitive Questions 

This ICR does not involve matters of a sensitive nature. 
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Corporate ID Amendment Page 7 August 2010 

4. THE RESPONDENTS AND THE INFORMATION REQUESTED 

4(a) Respondents/North American Industrial Classification Systems (NAICS) Codes 

The amendments would affect owners and operators of fuel and chemicals suppliers and 

direct emitters of GHGs who are already subject to the rule as well as those who would become 

subject to the rule in the future. However, the burden estimate presented in this statement is 

based on industries subject to the GHG Reporting Rule as of July 2010 and does not account for 

facilities expected to be added to the program through supplemental proposals. The methods and 

assumptions used to estimate the compliance costs for industries currently subject to the rule 

would likewise apply to industries that may be added to the Mandatory Reporting Program in the 

future. The addition of new industries would increase the reporting burden in proportion to the 

increase of the reporting universe. EPA will update and amend this statement as it adds new 

facilities to the Mandatory Reporting Program. 

Industry sectors are listed in Table 4.1 by their corresponding category, the corresponding 

NAICS codes, and examples of affected facilities. 
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Corporate ID Amendment Page 8 August 2010 

Table 4.1. Respondent Industry Sectors 

Category* NAICS Code Examples of regulated entities 

Facilities operating boilers, process heaters, incinerators, 

turbines, and internal combustion engines: 

211 Extractors of crude petroleum and natural gas. 

General Stationary Fuel 

Combustion Sources 

321 Manufacturers of lumber and wood products. 

322 Pulp and paper mills. 

325 Chemical manufacturers. 

324 Petroleum refineries and manufacturers of coal products. 

316, 326, 339 Manufacturers of rubber and miscellaneous plastic 

products. 

331 Steel works, blast furnaces. 

332 Electroplating, plating, polishing, anodizing, and coloring. 

336 Manufacturers of motor vehicle parts and accessories. 

221 Electric, gas, and sanitary services. 

622 Health services. 

611 Educational services.

Electricity Generation 221112 Fossil-fuel fired electric generating units, including units 

owned by Federal and municipal governments and units 

located in Indian Country. 

Adipic Acid Production 325199 Adipic acid manufacturing facilities. 

Aluminum Production 331312 Primary Aluminum production facilities. 

Ammonia Manufacturing 325311 Anhydrous and aqueous ammonia manufacturing 

facilities. 

Cement Production 327310 Portland Cement manufacturing plants. 

Ferroalloy Production 331112 Ferroalloys manufacturing facilities. 

Glass Production 327211 Flat glass manufacturing facilities. 

327213 Glass container manufacturing facilities. 

327212 Other pressed and blown glass and glassware 

manufacturing facilities. 

HCFC-22 Production and 

HFC-23 Destruction 

325120 Chlorodifluoromethane manufacturing facilities. 

Hydrogen Production 325120 Hydrogen manufacturing facilities. 

Iron and Steel Production 331111 Integrated iron and steel mills, steel companies, sinter 

plants, blast furnaces, basic oxygen process furnace 

shops. 

Lead Production 331419 Primary lead smelting and refining facilities. 

331492 Secondary lead smelting and refining facilities. 

Lime Production 327410 Calcium oxide, calcium hydroxide, dolomitic hydrates 

manufacturing facilities. 

Nitric Acid Production 325311 Nitric acid manufacturing facilities. 

Petrochemical Production 32511 Ethylene dichloride manufacturing facilities. 

325199 Acrylonitrile, ethylene oxide, methanol manufacturing 

facilities. 

325110 Ethylene manufacturing facilities. 

325182 Carbon black manufacturing facilities. 

Petroleum Refineries 324110 Petroleum refineries. 
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Category* NAICS Code Examples of regulated entities 

Phosphoric Acid 

Production 

325312 Phosphoric acid manufacturing facilities. 

Pulp and Paper 322110 Pulp mills. 

Manufacturing 322121 Paper mills. 

322130 Paperboard mills. 

Silicon Carbide 

Production 

327910 Silicon carbide abrasives manufacturing facilities. 

Soda Ash Manufacturing 325181 Alkalies and chlorine manufacturing facilities. 

212391 Soda ash, natural, mining and/or beneficiation. 

Titanium Dioxide 

Production 

325188 Titanium dioxide manufacturing facilities. 

Zinc Production 331419 Primary zinc refining facilities. 

331492 Zinc dust reclaiming facilities, recovering from scrap 

and/or alloying purchased metals. 

Municipal Solid Waste 

Landfills 

562212 Solid waste landfills. 

221320 Sewage treatment facilities. 

Suppliers of Coal Based 

Liquids Fuels 

211111 Coal liquefaction at mine sites. 

Suppliers of Petroleum 

Products 

324110 Petroleum refineries. 

Suppliers of Natural Gas 221210 Natural gas distribution facilities. 

and NGLs 211112 Natural gas liquid extraction facilities. 

Suppliers of Industrial 

GHGs 

325120 Industrial gas manufacturing facilities. 

Suppliers of Carbon 

Dioxide (CO2) 

325120 Industrial gas manufacturing facilities. 

331419 Primary refiners of nonferrous metals by electrolytic 

methods. 

Magnesium Production 

331492 Secondary magnesium processing plants. 

Underground Coal Mines 212113 Underground anthracite coal mining operations. 

212112 Underground bituminous coal mining operations. 

562212 Solid waste landfills. 

322110 Pulp mills. 

322122 Newsprint mills. 

322130 Paperboard mills. 

311611 Meat processing facilities. 

311411 Frozen fruit, juice, and vegetable manufacturing facilities. 

311421 Fruit and vegetable canning facilities. 

Industrial wastewater 

treatment 

221320 Sewage treatment facilities. 
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Corporate ID Amendment Page 10 August 2010 

Category* NAICS Code Examples of regulated entities 

322110 Pulp mills. 

322121 Paper mills. 

322122 Newsprint mills. 

322130 Paperboard mills. 

311611 Meat processing facilities. 

311411 Frozen fruit, juice, and vegetable manufacturing facilities. 

311421 Fruit and vegetable canning facilities. 

325193 Ethanol manufacturing facilities. 

Industrial waste landfills 

324110 Petroleum refineries. 

*Manure Management (subpart JJ) is not included. EPA will not implement subpart JJ of the GHG Reporting Rule 

using funds provided in its FY2010 appropriations due to a Congressional restriction prohibiting the expenditure of 

funds for this purpose. 
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Corporate ID Amendment Page 11 August 2010 

4(b) Information Requested 

(i) Data Items 

This final amendment requires facilities to report the following additional data fields: (1) 

the legal names and physical addresses of all parent companies and the percent of ownership 

held by each; (2) all applicable NAICS codes, one of which must be designated, and a second 

that may be designated, as primary; and (3) an indication (by checking yes or no) of whether or 

not the reported emissions include those from one or more cogeneration units. 

EPA defines U.S. parent company(s) as the highest-level United States company(s) with 

an ownership interest in the reporting entity as of December 31 of the year for which data are 

being reported. The U.S. parent company’s physical address is defined as the street, city, state 

and zip code of the U.S. parent company’s physical location. 

For this amendment, EPA defines a North American Industry Classification System 

(NAICS) code as the six-digit code that represents the product(s)/activity(s)/service(s) at the 

facility or supplier as listed in the Federal Register and defined in "North American Industrial 

Classification System Manual 2007," available from the U.S. Department of Commerce, 

National Technical Information Service. The final amendment requires reporters to provide the 

primary NAICS code that most accurately describes the primary product/activity/service at the 

facility, based on revenue. The primary product/activity/service is the principal source of 

revenue for the facility or supplier. If necessary, reporters may provide up to two primary 

NAICS codes. Reporters must also provide all additional NAICS codes that correspond to the 

product(s)/activity(s)/service(s) at the facility that are not related to the principal source of 

revenue for the facility or supplier. 

For the purposes of this amendment, a cogeneration unit is defined as “a unit that 

produces electrical energy and useful thermal energy for industrial, commercial, or heating or 

cooling purposes, through the sequential or simultaneous use of the original fuel energy.”
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(ii) Respondent Activities 

Respondent activities required by the standards are introduced in Section 6(a). To the 

extent practicable, the activities required by respondents were designed to make use of or to be 

consistent with existing reporting and recordkeeping practices. 

In this rulemaking, the following data elements would be reported: 

• Facility NAICS Code(s); 

• Facility Cogeneration 

• U.S. Parent Company Legal Name(s); 

• Parent Company Physical Address(es); and 

• Percent of Facility Ownership by each Parent Company. 
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5. THE INFORMATION COLLECTED – AGENCY ACTIVITIES, COLLECTION 

METHODS, AND INFORMATION MANAGEMENT 

5(a) Agency Activities 

There are not expected to be any EPA Headquarters activities associated with these 

amendments. Contractor burden will include changes to the electronic reporting forms and 

verifying the submitted data. 

5(b) Collection Methodology and Management 

EPA has already established a central repository of inventory data for all respondents. 

Respondents will report data electronically, and EPA will store the data in the database. The 

electronic format, which will reflect the underlying electronic data reporting system, will be 

developed prior to the first reporting date. 

These amendments will require facilities subject to the rule to provide additional 

information items. The methodology for entering these data elements has not changed since the 

GHG Reporting Rule was promulgated on October 30, 2009 (74 FR 56260). 

5(c) Small Entity Flexibility 

EPA took several steps to minimize the impacts on small entities when the GHG 

Reporting Rule was finalized. The Agency met several times with industry trade associations to 

discuss the reporting options considered and their possible impacts on small entities. EPA further 

minimized impacts on small entities by not requiring facilities below a certain emissions 

threshold to report their emissions. Where feasible, EPA also used existing GHG emissions 

estimation and reporting methodologies or provided simplified methodological options to reduce 

reporting burden. 

The same thresholds established by the final GHG Reporting Rule also apply to these 

amendments. 

5(d) Collection Schedule 

Facilities must report all US parent company(s) information and facility primary NAICS 

code(s) annually. EPA is requiring that the US parent company(s) and NAICS code(s) be 

reported as of December 31st of the reporting year, to remain consistent with the other 

requirements of the GHG Reporting Rule. 

 
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Corporate ID Amendment Page 14 August 2010 

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION 

This section presents EPA’s estimates of the burden and costs to respondents associated 

with the activities described in Section 4 as well as the federal burden hours and costs associated 

with the activities described in Section 5(a). 

The average respondent reporting burden is estimated at 9,487 hours per year over the 

three years covered by this information collection. 

Section 6(a) of this ICR provides estimates of burden (hours) for all respondent types. 

Section 6(b) contains estimates of respondent costs for the information collection. Section 6(c) 

summarizes federal burden and costs. Section 6(d) describes the respondent universe and the 

total burden and cost of this collection to respondents. Section 6(e) presents the bottom line 

burden and cost. The burden statement for this information collection is in Section 6(f). 

6(a) Estimating Respondent Burden 

The annual burden estimates for reporting are presented in Table 6.1. 

Table 6.1 Estimated Total Labor Burden and Total Cost 

 

Total Labor Burden 

(hours) Total Cost 

First Reporting Year 

US Parent Company Legal Name, 

Physical Address, and Ownership 

Status 7,142 $430,108 

Facility NAICS Code(s) and 

Cogeneration 7,034 $423,581 

All Data Elements 14,176 $853,689 

Subsequent Reporting Years 

US Parent Company Legal Name, 

Physical Address, and Ownership 

Status 5,384 $324,212 

Facility NAICS Code(s) and 

Cogeneration 1,759 $105,895 

All Data Elements 7,142 $430,107 
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Corporate ID Amendment Page 15 August 2010 

6(b) Estimating Respondent Costs 

Costs to respondents associated with these amendments include labor costs incurred by 

facility staff to report the additional information collection requirements. 

The personnel responsible for reporting the required information are likely to vary by 

industry sector and/or by facility. Table 6.2 provides estimates of the expected personnel titles, 

labor categories, and loaded hourly wage rates. Loaded hourly wage rates represent the total cost 

to the facility per hour of labor, accounting for costs beyond the hourly rate paid to the employee 

such as fringe benefits and overhead. 

To reflect that management, legal and technical staff will be involved in reporting the 

required data elements; a blended management/legal wage rate was created from the average of 

hourly wage rates of management and legal staff. A similar blended technical wage rate was 

calculated from the average of certain technical staff job classifications. An overall weighted 

wage rate was then developed based on estimates from the TRI program for similar data element 

reporting at similar facilities. According to the TRI estimates, management and legal staff are 

estimated to be involved in approximately 0.8% of the reporting effort, while technical staff are 

likely to be needed for the remaining 99.2%. Using these proportions, the weighted loaded wage 

rate, i.e., the blended labor rate, used in this analysis is $60.22 per hour. 

Table 6.2. Labor Rates 

Personnel Type Hourly Wage Rate 

Management Personnel 

 electricity manager $88.79

 refinery manager $101.31

 industrial manager $71.03

 lawyer $101.00

Blended Management and Legal Wage Rate $90.53

Technical 

 electricity engineer/technician $60.84

 refinery engineer/technician $63.89

 industrial engineer/technician $55.20

Blended Technical Wage Rate $59.98

Percent reporting by Management and Legal Personnel 0.8%

Percent reporting by Technical Personnel 99.2%

Blended Labor Rate $60.22
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The time required to report the additional information collection requirements were 

estimated at approximately 80 minutes per facility in the first year (40 minutes per facility in 

subsequent years) to complete the following activities: 

o Identify and record parent company name, 

o Identify and record parent company address, 

o Determine and record percent of company ownership, 

o Identify and record primary NAICS code, 

o Identify and record 2 additional applicable NAICS codes, and 

o Identify and record cogeneration. 

For each additional parent company, these amendments also require approximately 20 

minutes, in all years, to complete the following activities: 

o Identify and record parent company name, and 

o Identify and record parent company address. 

Each facility reporting more than one ultimate parent company requires an additional 

yearly labor burden of 5 minutes to determine and record percent ownership of the additional 

parent companies. 

For purposes of these estimates, it was assumed that 10,406 respondents would have at 

least one parent company and 145 respondents would have multiple parent companies. It was 

estimated that these respondents have an average of 3 parent companies per facility. More 

details are contained in a memorandum entitled, “Total Labor Burden and Cost for Reporting of 

Corporate Parent Name, Address, and Percent Ownership: an Amendment to the GHG Reporting 

Rule.” The memo is located in the docket (EPA-HQ-OAR-2008-0508). 

 

6(c) Estimating Agency Burden and Cost 

There are not expected to be any EPA activities associated with these amendments. 

However, contractor support for modifying the reporting database forms (which will only occur 

in Year 1) and for verifying the information submitted (which will occur in all years) does 

contribute non-labor costs. The costs were estimated as follows: 

o Year 1 = $90,000 

o Subsequent years = $40,000 

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

Every facility regulated under the GHG Reporting Rule will be required to report on the 

additional data elements covered under these amendments. 
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The total number of respondents is estimated at 10,551 per year. 

 

6(e) Bottom Line Burden Hours and Costs 

The bottom line burden hours and costs are shown in Table 6.3a. 

6(f) Reasons for Change in Burden 

Change in burden is the result of Program Change due to Agency Discretion. The 

existing GHG Reporting Rule ICR is being updated to include these amendments to the data 

collection requirements. 
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Table 6.3a Bottom Line Annual Burden and Cost 

First Reporting Year 

Number of Respondents 10,551 

Total Annual Responses 63,740 

Number of Responses per Respondent 6.04 

Total Respondent Labor Hours 14,176 

Respondent Hours per Response 0.22 

Annual Respondent Labor Cost $853,689 

Annual Respondent O&M and Capital Cost $0

Total Respondent Cost (labor + non) $853,689 

Total Agency Labor Hours 900 

Annual Agency Labor Cost $90,000 

Annual Agency non-labor cost $0

Total Hours (Respondents and agency) 15,076 

Total Cost (Respondents plus Agency) $943,689 

Subsequent Reporting Years 

Number of Respondents 10,551 

Total Annual Responses 63,740 

Number of Responses per Respondent 6.04 

Total Respondent Labor Hours 7,142 

Respondent Hours per Response 0.11 

Annual Respondent Labor Cost $430,108 

Annual Respondent O&M and Capital Cost $0

Total Respondent Cost (labor + non) $430,108 

Total Agency Labor Hours 400 

Annual Agency Labor Cost $40,000 

Annual Agency non-labor cost $0

Total Hours (Respondents and agency) 7,542 

Total Cost (Respondents plus Agency) $470,108 
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6(g) Burden Statement 

Approximately 10,600 facilities will incur 14,200 hours and $850,000 in the first year 

and 7,100 hours and $430,000 in subsequent years. Costs are approximately $81 per facility in 

the first year and $41 per facility in subsequent years. 

The average annual burden hours and costs are shown in Table 6.3b. 

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 gather the following information: name, address, and ownership 

status of a facility’s highest level US parent company; and the facility’s primary North American 

Industry Classification System (NAICS) codes and whether or not reported emissions include 

those from a cogeneration unit. If a facility has more than one owner, the facility also must 

report the address and percent of facility ownership for each parent company. 

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. 

 
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Corporate ID Amendment Page 20 August 2010 

Table 6.3b Average Annual Burden and Cost 

Number of Respondents 10,551 

Total Annual Responses 63,740 

Number of Responses per Respondent 6.04 

Total Respondent Labor Hours 9,487 

Respondent Hours per Response 0.15 

Annual Respondent Labor Cost $571,302 

Annual Respondent O&M and Capital Cost $0 

Total Respondent Cost (labor + non) $571,302 

Total Agency Labor Hours 567 

Annual Agency Labor Cost $56,667 

Annual Agency non-labor cost $0 

Total Hours (Respondents and agency) 10,054 

Total Cost (Respondents plus Agency) $627,968