DRAFT Information Collection Request

Supporting Statement for the

PM2.5 National Ambient Air Quality Standards 

State Implementation Plan Requirements Rule

EPA ICR Number 2258.03

OMB Control No. 2060-0611

Prepared by:

Office of Air Quality Planning and Standards 

Office of Air and Radiation

U.S. Environmental Protection Agency

Research Triangle Park, North Carolina 27711

March 23, 2015
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EPA Information Collection Request Renewal for the

PM2.5 National Ambient Air Quality Standards

State Implementation Plan Requirements Rule

Table of Contents

1. Identification of the Information Collection Request........................page 3

2. Need for and Use of the Collection..........................................page 4

3. Non-Duplication, Consultation, and other Collection Criteria......... page 6

4. Respondents and the Information Requested..............................page 9

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

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

6. Estimating the Burden and Cost of the Collection........................page 14
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1. Identification of the Information Collection Request

1(a) Title of the Information Collection

The title of the Information Collection Request is PM2.5 National Ambient Air Quality 

Standards (NAAQS) State Implementation Plan Requirements (SIP) Rule, ICR number 2258.03, 

and OMB Control Number 2060-0611, expiration date: May 1, 2018.

1(b) Abstract/Executive Summary

The EPA has established a suite of PM2.5 standards based on evidence and numerous health 

studies demonstrating that serious health effects are associated with exposures to elevated levels 

of PM2.5. Estimates show that attainment of the PM2.5 standards would result in tens of thousands 

fewer premature deaths each year, tens of thousands fewer hospital admissions each year, and 

hundreds of thousands fewer doctor visits, absences from work and school, and respiratory 

illnesses in children annually. EPA initially established annual and 24-hour PM2.5 standards in 

1997. The 24-hour standard was subsequently revised in 2006, and the annual standard was 

revised in 2012.

The EPA is proposing the PM2.5 NAAQS SIP Requirements Rule to describe the CAA 

requirements that must be met by states with nonattainment areas required to develop attainment 

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

Rule is to provide certainty to states regarding their planning obligations such that states may 

begin SIP development. Only states with nonattainment areas are required to submit SIPs that 

meet the requirements of the rule. 

The information collection activities in this proposed rule have been submitted for approval 

to the Office of Management and Budget (OMB) under the Paperwork Reduction Act (PRA).

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

agencies to develop plans to attain the PM2.5 NAAQS, and for EPA to review and take action on 

such plans. 

 The EPA estimates the additional administrative burden for states with nonattainment areas 

for the 2012 PM2.5 NAAQS to be 126,000 hours, and the estimated administrative burden for 

EPA to be 13,860 hours. With respect to ongoing implementation of the 1997 and 2006 PM2.5

standards, the EPA estimates the total additional administrative burden for states to be 145,800

hours, and the estimated administrative burden for EPA to be 16,038 hours. In this analysis, fifty 

percent of the hours are assumed to be expended in the first year, with the remaining hours 

evenly divided between the second and third years of the ICR period. 

For the newly designated nonattainment area burden, the present value of the total additional 

costs for state governments, the respondents, estimated at $7.6 million for the 3 year period. On 

an equivalent annual basis that is $2.5 million per year during the 3 year period of the ICR. For 

the remaining 1997 and 2006 PM25 nonattainment burden, the present value of the total 
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additional costs for state governments, the respondents, estimated at $8.8 million for the 3 year 

period. On an equivalent annual basis that is $2.9 million per year during the 3 year period of the 

ICR. Therefore, the present value of the total additional costs for state governments, the states 

having to respond with SIP revision, estimated at $16.4 million for the 3 year period. On an 

equivalent annual basis that is $5.4 million per year during the 3 year period of the ICR. 

For the newly designated nonattainment area burden, the present value of the Agency 

administrative cost burden is estimated at $0.8 million dollars for the 3 year period. This is 

equivalent to equal annual basis of $0.3 million per year during the three year period. For the 

remaining 1997 and 2006 PM25 nonattainment burden, the present value of the Agency 

administrative cost burden is estimated at $1.0 million dollars for the 3 year period. This is 

equivalent to equal annual basis of $0.3 million per year during the three year period. Therefore, 

the present value of the Agency administrative cost burden is estimated at $1.8 million dollars 

for the 3 year period. This is equivalent to equal annual basis of $0.6 million per year during the 

three year period.

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

mitigated by the fact that many states may be able to attain the standards based on existing 

federal and state emission reduction programs and may not need substantial additional emissions 

reductions from new state regulations. In addition, the fourteen areas designated in December 

2014 as not attaining the 2012 PM2.5 NAAQS are located in 6 states, all of which previously had 

areas designated as nonattainment for the 1997 or 2006 PM2.5 NAAQS. Thus, these states all 

have experience with developing state implementation plans for attaining previously established 

PM2.5 NAAQS. 

2. Need For and Use of the Collection

2(a) Need/Authority for the Collection

The Clean Air Act, which was last amended in 1990, requires the EPA to establish National 

Ambient Air Quality Standards (NAAQS) for air pollutants that may reasonably be anticipated to 

endanger public health or welfare, and which result from numerous or diverse sources. On July 

18, 1997, the EPA revised the NAAQS for particulate matter to add new standards for fine 

particulate matter (particles of solid and liquid material less than 2.5 microns in aerodynamic 

diameter), using PM2.5 as the indicator. The EPA established health-based (primary) annual and 

24-hour standards for PM2.5 (62 FR 38652). The annual standard was set a level of 15 

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

The 24-hour standard was set a level of 65 micrograms per cubic meter, based on the 3-year 

average of the 98th percentile of 24-hour concentrations. The welfare-based secondary standards 

were established identical to the primary standards.

The initial PM2.5 National Ambient Air Quality Standard Implementation rule was proposed 

November 1, 2005 (70 FR 65983) and was promulgated on April 25, 2007 (72 FR 20586). The 

preamble to the proposed and final regulation addresses the administrative burden in general 

terms. The preamble to the final rule stated that an ICR would be prepared. The first ICR (No. 

2258.01) covered a period from April 5, 2008 through April 4, 2011.
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On October 17, 2006, the EPA revised the NAAQS for fine particles. The EPA established a 

new primary 24-hour standards for PM2.5 (71 FR 61144). The 24-hour standard was set a level of 

35 micrograms per cubic meter, based on the 3-year average of the 98th percentile of 24-hour 

concentrations. The annual standard remained unchanged at a level of 15 micrograms per cubic 

meter, based on the 3-year average of annual mean PM2.5 concentrations. The time period 

covered in the second ICR (2258.02) was a three year period from June 1, 2011 through May 31, 

2014.

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

a new primary annual standard PM2.5 (78 FR 3086). The annual standard was set at a level of 12

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

The 24-hour standard remained unchanged at a level of 35 micrograms per cubic meter, based on 

the 3-year average of the 98th percentile of 24-hour concentrations. The time period covered in 

the third ICR (2258.03) is anticipated to be a three year period from May 1, 2015 through May 

31, 2018.

Part D of Title I of the Clean Air Act sets forth the implementation plan requirements for 

areas designated nonattainment for a National Ambient Air Quality Standard. This rule provides 

the framework for states to follow in developing SIPs to attain the 2012 PM2.5 NAAQS and any 

future revisions to the PM2.5 NAAQS. The rule also applies to the remaining nonattainment areas 

for the 1997 PM2.5 NAAQS and the 2006 PM2.5 NAAQS. 

This framework reflects the applicable requirements described in the CAA part D 

nonattainment area provisions found in sections 172 (subpart 1) and sections 188-190 (subpart 

4). A PM2.5 SIP must include rules requiring emission reductions and a demonstration showing 

whether the particular area can attain the standard by its attainment date. A state plan submittal 

for attaining the PM2.5 NAAQS is due to EPA within 18 months after the date the area is 

designated as nonattainment. After a state submits a SIP, the CAA requires the EPA to review 

the plan, and approve or disapprove it.

2(b) User/Users of the Data 

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

nonattainment SIP elements required by the CAA and described in more detail in the PM2.5 SIP 

requirements rule. The PM2.5 SIP must contain state rules and other requirements designed to 

achieve the NAAQS by the deadlines established under the CAA. 

The PM2.5 SIP submitted by the state must include the various requirements in subpart 1 and 

subpart 4, including:

 Baseline emission inventory and projection year inventory for stationary, mobile, and 

area emissions sources in the nonattainment area consistent with section 51.1008 of the 

rule.

 For Moderate areas, an analysis of economic and technological feasibility of potential 

control measures (i.e., reasonably available control measures (RACM) and reasonably 

available control technology (RACT)), and the adoption of state rules requiring emission 
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reductions to ensure attainment of the standard “as expeditiously as practicable,” 

consistent with sections 51.1007 and 51.1009 of the rule.

 For Serious areas, an analysis of economic and technological feasibility of potential 

control measures (i.e., best available control measures (BACM) and best available control 

technology (BACT)), and the adoption of state rules requiring emission reductions to 

ensure attainment of the standard “as expeditiously as practicable,” consistent with 

sections 51.1010 of the rule.

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

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

state emission reduction programs, plus any new emission reduction programs adopted by 

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

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

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

modeling results, and emission reduction analyses on which the state has based its 

projected attainment date. The attainment demonstration and supporting air quality 

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

 A plan showing that future emission reductions will provide for reasonable further 

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

attainment date, consistent with section 51.1012 of the rule; and annual reporting on 

quantitative milestones showing progress in the implementation of the attainment plan 

and associated control measures, consistent with section 51.1013 of the rule. 

The states use this information and analysis to fulfill federal obligations under Title I, 

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

demonstrations, RFP, RACT and RACM determinations to inform their citizenry, including 

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

future emission reduction requirements. 

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

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

SIP with the appropriate technical supporting documentation, the EPA is required under the 

CAA to approve or disapprove the SIP within 12 months. Emission reduction regulations 

developed by the states become federally enforceable when approved by the EPA.

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

3(a) Non-Duplication

As noted in section 2(b) above, the state respondent will submit an implementation plan 

for each nonattainment area that will need to include a number of separate and unique 

elements. For example, each implementation plan will need to include a unique 

RACM/RACT analysis, attainment demonstration, and RFP plan. 

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

elements required in the PM2.5 SIP. For example, the existing fine particle monitoring 
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network, covered under a separate, existing ICR, provides essential data for use by states and 

EPA in identifying key categories of emissions and tracking progress toward attainment.

EPA encourages the states to account for control measures and expected emission 

reductions from existing regulations and implementation planning processes, such as for the 

1997 and 2006 PM2.5 NAAQS, the Ozone NAAQS, the regional haze program, the cross 

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

where appropriate, may enable states to reduce the incremental administrative burden 

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

Relevant ICRs and their titles are identified below. 

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

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

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

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

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

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

 Approval and Promulgation of Implementation Plans

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

 Ambient Air Monitoring Reference and Equivalent Methods

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

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

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

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

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

 Outer Continental Shelf Air Regulations

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

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

 Ambient Air Quality Surveillance

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Management and Budget (OMB)

This is a rule-related ICR. Comments on this ICR will be requested when the rule is 

proposed in the Federal Register in March 2015. 

3(c) Consultations

The EPA is soliciting comment on the proposed PM2.5 SIP requirements rule and also 

intends to have a public hearing during the public comment period. 

3(d) Effects of Less Frequent Collection

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

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

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

3(c) General Guidelines

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

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

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

guidelines reflect the requirements of 5 CFR 1320.6. The proposed PM2.5 NAAQS SIP 

requirements rule does not require:

 reporting more than once a year;

 respondents to participate in a statistical survey; 

 responses to Agency inquiries in less than 30 days;

 respondents to receive remuneration for preparation of reports; 

 records to be kept more than 3 years;

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 manual methods of reporting.

3(f) Confidentiality

 

The information requested from the states to fulfill CAA requirements as described in 

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

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

sources and states should already have information from emission sources, as facilities 

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

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

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

etc.) that is required by this rule. 

 

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

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

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

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

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

3(g) Sensitive Information

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

answers would require sensitive information.

4.0 The Respondents and the Information Requested

4(a) Respondents and Nonattainment areas

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

14 areas designated in December 2014 as not meeting the 2012 PM2.5 NAAQS. These 

nonattainment area designations will be effective in April 2015, and PM2.5 Moderate area 

SIPs will then be due from each relevant state or local air agency in October 2016. Note that 

two of the areas are multi-state nonattainment areas, with part of the nonattainment area 

located in two contiguous states. A total of 6 states will need to submit PM2.5 Moderate area 

SIPs for attaining the 2012 PM2.5 NAAQS. 

Table 1 also includes an estimated 9,000 burden hours for each Moderate area 

nonattainment plan and an estimated total weighted direct and indirect hourly equivalent 

salary cost of $65.10 per hour. (Section 6 provides more details on these estimates.) Table 2 

describes the estimated incremental burden hours for the initial 2012 PM2.5 NAAQS 

nonattainment areas by state and by year.

Table 1. Initial Areas Designated Nonattainment for 2012 PM2.5 NAAQS: Estimated 

Burden for 2012 PM2.5 Moderate SIP Requirements

Initial Nonattainment Area for 

2012 PM2.5 NAAQS State EPA Region 

3-year 

Burden 

Estimate 

(Hours)

3-year

Burden 

Estimate 

(Dollars)

Allegheny PA 3 9,000 $585,900

Allentown PA 3 9,000 $585,900

Canton-Massillon OH 5 9,000 $585,900

 

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

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

solid waste management programs.” See http://www.census.gov/naics.
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Initial Nonattainment Area for 

2012 PM2.5 NAAQS State EPA Region 

3-year 

Burden 

Estimate 

(Hours)

3-year

Burden 

Estimate 

(Dollars)

Cincinnati-Hamilton KY 4 4,500 $292,950

Cincinnati-Hamilton OH 5 4,500 $292,950

Cleveland-Akron-Lorain OH 5 9,000 $585,900

Delaware County PA 3 9,000 $585,900

Imperial county CA 9 9,000 $585,900

Johnstown PA 3 9,000 $585,900

Lebanon County PA 3 9,000 $585,900

Los Angeles-South Coast Air 

Basin CA 99,000 $585,900

Louisville IN 5 4,500 $292,950

Louisville KY 4 4,500 $292,950

Plumas county CA 9 9,000 $585,900

San Joaquin Valley CA 9 9,000 $585,900

West Silver Valley ID 10 9,000 $585,900

TOTAL 126,000 $8,202,600

Table 2 lists the nonattainment areas and states with remaining SIP submittal or 

redesignation requirements for the 1997 PM2.5 NAAQS and the 2006 PM2.5 NAAQS that 

potentially could be required during the ICR period. For purposes of this draft analysis, it has 

been assumed that for the 1997 PM2.5 NAAQS, a Serious area SIP will be required during the 

ICR period for one nonattainment area. It also has been assumed that for the 2006 PM2.5

NAAQS, a Serious area SIP will be required during the ICR period for seven nonattainment 

areas. In addition, it has been assumed that redesignation requests will be submitted for seven 

nonattainment areas for the 2006 PM2.5 NAAQS. (Note that these assumptions have been 

made only for the purposes of this analysis, and a number of factors and future state or EPA 

actions could change the assumptions put forth here.) 

Table 2 also includes an estimated 18,000 burden hours for each Serious area 

nonattainment plan, an estimated 300 hours for state development of a redesignation request, 

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

per hour. Section 6 provides more details on these estimates.
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Table 2. Remaining 1997 PM2.5 and 2006 PM2.5 Nonattainment Areas with Estimated 

Burden for SIP Revision or Redesignation Action 

Area Name State EPA

Reg.

Potential Actions 

during ICR period 

5/2015 to 4/2018

Hours for SIP 

Revision or 

Redesignation 

Action

3-year Burden 

Estimate 

(Dollars)

Chico CA 9 2006 PM25 

Maintenance Plan

300 $19,530

Fairbanks AK 10 2006 PM25 Serious 

Area SIP Revision

18,000 $1,171,800

Imperial County CA 9 2006 PM25 Serious 

Area SIP Revision

18,000 $1,171,800

KnoxvilleSevierville-La 

Follette

TN 4

2006 PM25 

Maintenance Plan

300 $19,530

Liberty-Clairton PA 3 2006 PM25 Serious 

Area SIP Revision

18,000 $1,171,800

Logan ID 10 2006 PM25 Serious 

Area SIP Revision

9,000 $585,900

Logan UT 8 2006 PM25 Serious 

Area SIP Revision

9,000 $585,900

Nogales, AZ AZ 9 2006 PM25 

Maintenance Plan

300 $19,530

Provo UT 8 2006 PM25 Serious 

Area SIP Revision

18,000 $1,171,800

Sacramento CA 9 2006 PM25 

Maintenance Plan

300 $19,530

Salt Lake City UT 8 2006 PM25 Serious 

Area SIP Revision

18,000 $1,171,800

San Francisco

Bay Area

CA 9 2006 PM25 

Maintenance Plan

300 $19,530

San Joaquin 

Valley

CA 9 1997 PM25 Serious 

Area SIP Revision

18,000 $1,171,800

San Joaquin 

Valley

CA 9 2006 PM25 Serious 

Area SIP Revision

18,000 $1,171,800

West Central 

Pinal

AZ 9 2006 PM25 

Maintenance Plan

300 $19,530

TOTAL 145,800 $9,491,580
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 4(b) Information Requested

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

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

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

additional flexibility enables the States to customize, to the extent allowed by the Clean Air Act, 

their approach to attaining and maintaining the PM2.5 NAAQS.

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

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

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

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

such as the Consolidated Emissions Reporting (CERR) Rule (see 

http://www.epa.gov/ttn/chief/cerr/index.html). In developing PM2.5 SIPs, air agencies are 

expected to use a range of other readily available data sources, such as existing federal rules that 

are expected to reduce future emissions of particulate matter precursors, and economic and 

population growth rates.

Respondents’ Activities. The states will compile and reference the data, set forth the 

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

analyses, develop initial drafts, hold hearings, adopt rules, regulations, and programs, have 

discussions with EPA staff as appropriate, refine the draft attainment demonstration as 

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

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

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

answering questions from the states regarding regulatory requirements, potential data sources, 

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

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

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

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

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

promote the development of acceptable demonstrations and SIP submissions.

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

subpart 4 of Part D of the CAA (sections 188-190), and in the PM2.5 Implementation rule.

5.0 The Information Collected—Agency Activities, Collection 

Methodology, and Information Management

 

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

States. The state agencies’ activities include:
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 Develop baseline emissions inventory and projection year inventory.

 Conduct analyses of economic and technological feasibility of potential control 

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

the standard “as expeditiously as practicable.”

 Develop and evaluate emission reduction strategies, and conduct air quality modeling 

showing that existing federal and state emission reduction programs, plus any new 

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

attainment by the attainment date.

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

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

attainment date. 

EPA Regional Offices. The regional office activities include:

 Respond to inquiries from the air agencies and providing guidance on SIP 

development.

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

agencies. 

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

disapproving the SIP submissions.

EPA Headquarters. The EPA headquarters office activities include:

 Answer questions regarding application and interpretation of rule provisions.

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

evaluation of plans from states around the country. 

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

development of acceptable demonstrations and SIP submissions.

5(b) Collection Methodology and Management

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

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

procedures used in its development and implementation. 

 5(c) Small Entity Flexibility

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

 practical steps to develop separate and simplified requirements for small businesses and other 

small entities. See 5 CFR 1320.6(h). The PM2.5 NAAQS implementation regulation does not 

provide a direct administrative burden on small entities. 

 5(d) Collection Schedule 

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

proposed in this rule consistent with CAA requirements. Moderate area SIPs will be due 

within 18 months of the effective date of nonattainment area designation. The proposed rule 
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requests comment on due dates for certain elements of Serious area SIPs; however, under all 

proposed options BACM/BACT requirements would be due within 18 months of the date an 

area is reclassified as Serious. Quantitative milestone reports, as required under the CAA, 

would be due annually. 

6. Estimating the Burden of the Collection

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

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

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

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

the equivalent annual and present value cost estimates.

6(a) Estimating Respondent Burden

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

activities required to develop the relevant PM2.5 SIP or redesignation request and implement 

the plan each year. 

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

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

across areas for a number of reasons, such as the severity of the nonattainment problem and 

whether existing federal and state emission reduction programs are projected to bring the 

area into attainment by the 2021 Moderate area attainment date. 

Burden Estimate for Initial Nonattainment Areas for the 2012 PM2.5 NAAQS 

Table 1 provides the list of 14 areas initially designated as nonattainment for the PM2.5

NAAQS in December 2014 and the states responsible for developing the SIP revisions to 

meet the standard in December 2021. Table 3 below summarizes the number of 

nonattainment SIPs due by state and provides a 3-year breakdown of expected burden hours 

by state.

When the 2012 PM NAAQS were revised in December 2012, EPA released a regulatory 

impact analysis (RIA) at the same time.3 The purpose of the RIA was to provide the public 

with illustrative estimates of the potential costs and health and welfare benefits of attaining 

the revised annual standard. The control strategies presented in the RIA were illustrative and 

represent one set of control strategies states might choose to implement in order to meet the 

final standards. The RIA analysis developed a base case scenario for the year 2020 that 

assessed the projected air quality concentrations in 2020 that would be expected with 

ongoing implementation of a number of national rules, including the following:

 

3

“Regulatory Impact Analysis for the Final Revisions to the National Ambient Air Quality 

Standards for Particulate Matter.” U.S. Environmental Protection Agency, Office of Air Quality 

and Planning Standards, Health and Environmental Impacts Division, February 28, 2013. EPA452/R-12-005. See: http://www.epa.gov/ttn/naaqs/standards/pm/s_pm_2007_ria.html.
15

- Light-Duty Vehicle Tier 2 Rule (1999)

– Heavy Duty Diesel Rule (2000)

– Clean Air Nonroad Diesel Rule (2004)

– Regional Haze Regulations and Guidelines for Best Available Retrofit Technology 

Determinations (2005)

– NOx Emission Standard for New Commercial Aircraft Engines (2005)

– Emissions Standards for Locomotives and Marine Compression-Ignition Engines 

(2008)

– Control of Emissions for Nonroad Spark Ignition Engines and Equipment (2008)

– C3 Oceangoing Vessels (2010)

– Boiler MACT (2011)

– Hospital/Medical/Infectious Waste Incinerators: New Source Performance Standards 

and Emission Guidelines: Final Rule Amendments (2009)

– Reciprocating Internal Combustion Engines (RICE) NESHAPs (2010)

– Mercury and Air Toxics Standards (2011)

– Cross-State Air Pollution Rule (2011)

The RIA analysis projected that all areas expected to be designated as nonattainment for 

the 2012 PM2.5 NAAQS except those areas located in California would be expected to attain 

the standard in 2020, based only on emission reductions from the federal regulations 

identified above. Thus, it could be concluded from this analysis that existing federal emission 

reduction programs will help reduce administrative burden for many air agencies required to 

develop SIPs for newly designated nonattainment areas. 

As a starting point for developing burden estimates for this analysis, the Agency looked 

at the total hours expended in related EPA level of effort work assignments for meeting the 

1997 ozone NAAQS, exclusive of the air quality modeling. The total estimate for ozone 

areas classified as Marginal was about 2,000 hours in level of technical effort.4 The 

estimated burden for a Subpart 4 PM2.5 SIP revision was considered similar to the burden 

for ozone areas classified as Moderate, and estimated at 9,000 hours. The estimated burden 

for a Subpart 4 PM2.5 SIP revision after an area was reclassified to Serious was considered 

similar to ozone areas with higher classifications and estimated at 18,000 hours. 

Most of the estimated burden would be expected to be incurred in the first year because 

the air agency would be expected to be expending resources developing the PM2.5 SIPs that 

would be due 18 months after designation. For the purposes of this analysis, the assumed 

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

and 25% in year 3. 

 

4 EPA Contract No. 68-D-00-283; Work Assignments 3-53 and 4-66.
16

Table 3. Initial Areas Designated Nonattainment for 2012 PM2.5 NAAQS: 

Estimated Incremental Burden Hours by State and Year

State

EPA 

Region

No. of 

Areas or 

Parts of 

Areas

Additional 

hours

Year 1

Additional 

hours 

Year 2

Additional 

hours 

Year 3

California 9 4 18,000 9,000 9,000

Idaho 10 1 4,500 2,250 2,250

Indiana 5 1 2,250 1,125 1,125

Kentucky 4 2 4,500 2,250 2,250

Ohio 5 3 11,250 5,625 5,625

Pennsylvania 3 5 22,500 11,250 11,250

Remaining Subpart 4 Nonattainment Areas for 1997 and 2006 PM2.5 NAAQS

Table 2 provides the list of areas and states still implementing the 1997 and 2006 PM2.5

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

revisions or redesignation requests during the ICR period. For the purpose of this analysis, it 

is assumed that one of the original 39 nonattainment areas for the 1997 PM2.5 standard (San 

Joaquin Valley, CA) will still need to develop a Serious area plan during the ICR period. 

Thus, the bulk of the remaining work for the 1997 nonattainment areas consists of 

developing Maintenance SIPs, and this work was included in the estimates for a prior PM25 

ICR. The estimated burden hours for development of the remaining Serious area SIP is

18,000 hours. 

Of the 32 areas designated as nonattainment for the 2006 PM2.5 standard, Table 2 

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

the ICR period, and that could have a Serious area SIP (or portions thereof) due within 18 

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

burden for development of the SIP revisions to address the Serious area requirements is

18,000 hours. 

Table 2 also includes 6 nonattainment areas that have attained the 2006 PM25 NAAQS

and have a final Clean Data Determination. (See 

http://www.epa.gov/oar/oaqps/greenbk/rfr2rpt5.html). The estimated burden hours for 

development of a redesignation request and maintenance plan is 300 hours. The presumed 

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

and 25% in year 3. 

Using the information in table 2, table 4 below provides a 3-year breakdown of expected 

burden hours by state and by year.
17

Table 4. Nonattainment Areas for 1997 and 2006 PM2.5 NAAQS: 

Estimated Incremental Burden Hours by State and Year

State

EPA 

Region

Additional 

hours Year 1

Additional 

hours Year 2

Additional 

hours Year 3

AK 10 9,000 4,500 4,500

AZ 9 300 150 150

CA 9 27,450 13,725 13,725

ID 10 4,500 2,250 2,250

PA 3 9,000 4,500 4,500

TN 4 150 75 75

UT 8 22,500 11,250 11,250

6(b) Estimating Respondent Cost

Labor costs are estimated for State governments using the total of projected 

additional hours for the areas. These estimates do not reflect staff experience and 

economies of scale. The hourly rates are the result of estimated directed and indirect cost 

per employee. The main source of the information is 

http://www.opm.gov/oca/payrates/index.htm

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

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

 Hourly equivalent 2010 Salary of Permanent Professional Staff at GS 11, Step 3 is 

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

Washington, D.C. areas.

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

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

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

Nine percent of that is $4.32.

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

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

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

Sixteen percent of that is $3.55. 

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

following:

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

$6.59.

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

employee or $4.12.
18

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

employee or $13.18.

. 

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

employee is $65.10. The estimated total incremental respondent burden for the state 

respondents to meet the new 2012 PM25 SIP requirements and complete the remaining 

1997 and 2006 SIP requirements is provided in Table 5.

Table 5. Estimated Total Incremental Cost and Hour Burden for the States (Respondents) to Fulfill 

the new 2012 PM25 SIP requirements and complete the remaining 1997 and 2006 SIP Submittal 

Requirements.

NAAQS Additional Cost 

for Year 1

Additional Cost 

for Year 2

Additional Cost 

for Year 3

Burden for the 3-year 

ICR period (hrs)

2012 $4.1 million $1.8 million $1.7 million 126,000

1997/2006 $4.7 million $2.0 million $1.9 million 145,800

Total $8.83 million $3.8 million $3.6 million 271,800

 

6(c) Estimating Agency Burden and Cost

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

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

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

cost estimates.

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

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

regional offices. Once yearly burdens were estimated for the Agency’s Regional Offices, 

a percentage of those amounts are specified to derive estimates for the Agency’s 

Headquarters Office Burdens. Discussions were held with Regional Office and 

Headquarters staff regarding the percentages and resulting burden estimates.

Agency Regional Office Burden. Table 6 summarizes total incremental respondent 

burden by Regional Office and provides estimates of total incremental Agency Regional 

Office burden. The summary of total incremental respondent burden comes from Tables 

1 and 2. The Agency Regional Office burden is presumed to be 10% of the estimated 

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

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

year 2, and 25% in year 3.

Agency Headquarters Burden. Table 6 also summarizes total incremental respondent 

burden Agency headquarter burden. The Regional Office burden estimates for years 1, 2, 
19

and 3 are multiplied by 10% to arrive at an estimate for Headquarters burden for the same 

3 years. 

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

burden estimate for year 1 for the 2012 NAAQS is 6,930 hours. The estimates for years 

2 and 3 are 3,460 hours each year. The regional and headquarters office burden estimate 

for year 1 for the 1997 and 2006 NAAQS is 8,000 hours. The estimates for years 2 and 3 

are 4,000 hours each year.

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

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

The result is the total cost estimate for the Agency provided in Table 6.

Table 6. Estimated Total Incremental Cost and Hour Burden for the EPA Regions and Headquarter 

to Fulfill the new 2012 PM25 SIP requirements and complete the remaining 1997 and 2006 SIP 

Submittal Requirements.

NAAQS

Total State 

Respondents' 

burden (hrs)

Additional 

Cost for Year 1

Additional 

Cost for Year 2

Additional 

Cost for Year 3

Regions and HQ 

Burden for the 3-

year ICR period

2012 126,000 $0.4 million $0.2 million $0.2 million 13,900

1997/2006 145,800 $0.5 million $0.2 million $0.2 million 16,000

Total 271,800 $0.9 million $0.4 million $0.4 million 29,900

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

The total incremental respondent universe burden and cost estimates are presented 

in Tables 7 and 8. 

Table 7. 2012 PM2.5 NAAQS Total Incremental Respondent & Agency Universe Burden and Cost 

Estimates 

Entity

Average Yearly 

Burden (hours)

3-Year 

Burden (hrs)

Present Value of Costs 

for 3-Year Burden

States 42,000 126,000 $7.6 million

Agency 4,620 13,860 $0.8 million

Total 46,620 139,860 $8.4 million
20

Table 8. 1997 PM2.5 and 2006 PM2.5 NAAQS Total Incremental Respondent & Agency Universe 

Burden and Cost Estimates 

Entity

Average Yearly 

Burden (hours)

3-Year 

Burden (hrs)

Present Value of 

Costs for 3-Year 

Burden

States 48,600 145,800 $8.8 million

Agency 5,346 16,038 $0.96 million

Total 53,946 161,838 $9.7 million

*The estimates are in current year (2012) dollars. Costs for years 2 and 3 are calculated using the equation Present Value = Future 

Value/ (1 + interest rate)t ,where “t” is the number of years hence (i.e., 0 for year 1, 1 for year 2, 2 for year 3). The adjusted values for 

years 1, 2, and 3 are then summed.

6(e) Reason for Change in Burden

We are requesting an increase in burden of 302,000 hours due to implementation of this new 

regulation and the implementation of the remaining requirements for the 1997 PM25 and 2006 

PM25 NAAQS. This burden estimate is lower than the estimate for the previous PM2.5 

Implementation ICR renewal primarily because the number of designated nonattainment areas 

covered by this ICR is lower. The estimates have been calculated using 2012 dollars and some 

assumptions regarding overhead, O&M costs, and capital costs have been adjusted to meet 

current guidelines and common procedures for preparing ICRs.

6(f) Burden Statement

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

for the 2012 PM25 NAAQS is estimated to average 2,625 hours per state respondent for this 

reporting period. This estimate is derived by taking 42,000 hours, the average yearly burden for 

the states identified in Table 1, and dividing by 16, the number of affected state responses. 

Similarly, the annual public reporting and recordkeeping burden for this collection of 

information for the 1997 and 2006 NAAQS is estimated to average 3,240 hours, which is the 

48,600 hours average yearly burden for the states identified in Table 1, and dividing by 15, the 

number of affected state responses.

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

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

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

each state submitting the PM2.5 SIP required for each PM2.5 nonattainment area. The PM2.5 SIPs 

due during this ICR reporting period will need to include several elements, including the

attainment demonstration, RFP plan, RACT and RACM. In meeting these milestones, such 

incremental efforts may include reviewing instructions as well as verifying, processing, 

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

acquisition, installation, and/or utilization of technological systems for several purposes. These 
21

purposes include collecting, verifying, validating, processing, maintaining and disclosing 

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

adjusting the ways to comply with the previously applicable instructions associated with other

National Ambient Air Quality Standards such as 8-hr ozone and PM10. Consequently, in meeting 

the milestones, there could be some incremental burden associated with learning/training, 

searching data sources, and transmitting the deliverables.

An Agency may not conduct or sponsor, and a person is not required to respond to a 

collection of information unless it displays a currently valid OMB control number. The OMB 

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

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

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

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

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

approved ICR for this rule does not affect the statutory obligation for the states to submit SIPs as 

required under part D of the CAA.”

The Agency established a docket for the PM2.5 National Ambient Air Quality Standards State 

Implementation Requirements Rule under Docket ID No.OAR-2013-0691. All documents in the 

docket are listed in the EDOCKET index at http://www.epa.gov/epahome/dockets.htm or 

http://www.regulations.gov. Although listed in the index, some information such as Confidential 

Business Information is not publicly available. Other information such as copyrighted materials 

are not placed on the internet, but are available in hard copy form at the EPA Docket Center (Air 

Docket), EPA/DC, EPA West, Room B102, 1301 Constitution Ave., NW., Washington, DC. The 

Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding 

legal holidays. The telephone number for the Public Reading Room is (202) 566-1744. The 

telephone number for the Office of Air and Radiation Docket and Information Center is (202) 

566-1742.