i

Table of Contents

SUPPORTING STATEMENT

for Renewal of Information Collection Requirements under the

Paperwork Reduction Act, 44 U.S.C. 3501 et seq.

Final Rule at 40 CFR Part 8

Environmental Impact Assessment of Nongovernmental Activities in Antarctica

December 2013

Page

1. Identification of the Information Collection . . . . . . . . . . . . . . . . . . . . . . 1

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

1(b) Short Characterization/Abstract . . . . . . . . . . . . . . . . . . . . . . . . 1

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

2(a) Need/Authority for the Collection . . . . . . . . . . . . . . . . . . . . . . . . 4

2(b) Practical Utility/Users of the Data . . . . . . . . . . . . . . . . . . . . . . . . 4

3. Nonduplication, Consultations, and Other Collection Criteria . . . . . . . . . 6

3(a) Nonduplication . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

3(b) Public Notice Required Prior to ICR Submission to OMB . . . . . . 7

3(c) Consultations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

3(d) Effects of Less Frequent Collection . . . . . . . . . . . . . . . . . . . . . . . . 7

3(e) General Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

3(f) Confidentiality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

3(g) Sensitive Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

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

4(a) Respondents/SIC Codes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

4(b) Information Requested . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

(i) Data items, including recordkeeping requirements. . . . . . . . 9

(ii) Respondent Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

5. The Information Collected--Agency Activities, Collection Methodology,

and Information Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

5(a) Agency Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

5(b) Collection Methodology and Management . . . . . . . . . . . . . . . . . . 16

5(c) Small Entity Flexibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

5(d) Collection Schedule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

6. Estimating the Hours and Cost Burden of the Collection . . . . . . . . . . . . . . 20

6(a) Estimating Respondent Burden . . . . . . . . . . . . . . . . . . . . . . . . . . 20

6(b) Estimating Respondent Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
ii

(i)Estimating Labor Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

(ii)Estimating Capital and Operations and Maintenance Costs. . . 27

(iii) Annualizing Capital Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

6(c) Estimating Agency Burden and Costs. . . . . . . . . . . . . . . . . . 31

6(d) Estimating the Respondent Universe and Total Burden and Costs 43

6(e) Bottom Line Burden Hours and Cost Tables. . . . . . . . . . . . . . . . . 46

(i)Respondent Tally . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46

(ii)The Agency Tally . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46

(iii)Variations in the Annual Bottom Line . . . . . . . . . . . . . . . . . . 46

6(f) Reason for Change in Burden . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46

6(g) Burden Statement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46

Exhibit 1A: PERMs - Estimated Respondent Hours and Cost . . . . . . . . . . . . . . 48

Exhibit 1B: IEEs - Estimated Respondent Hours and Cost . . . . . . . . . . . . . . . . 49

Table 1. IEEs - Total Estimated Hours and Cost for the Three IEE

 Models with 3.5% Escalation Rate . . . . . . . . . . . . . . . . . . . . . . 51

Exhibit 1C: CEEs - Estimated Respondent Hours and Cost . . . . . . . . . . . . . . . . 53

Exhibit 1D: Reporting for Emergencies - Estimated Respondent Hours and Cost 54

Exhibit 2A: PERMs - Estimated Federal Government Hours and Cost . . . . . . . . 55

Exhibit 2B: IEEs - Estimated Federal Government Hours and Cost . . . . . . . . . . 57

Table 2. IEEs - Total Estimated Hours and Cost for the Three IEE

 Models with 3.5% Escalation Rate . . . . . . .. . . . . . . . . . . . . . . . 60

Exhibit 2C: CEEs - Estimated Federal Government Hours and Cost . . . . . . . . . 61

Exhibit 2D: Reporting for Emergencies - Estimated Federal Government

Hours and Cost . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63

Exhibit 2E: Coordinating Review of Information Received from Other Parties -

Estimated Federal Government Hours and Cost . . . . . . . . . . . . . . 64

Exhibit 3: Summary - Estimated Respondent/Federal Government

Hours and Cost . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65

Chart 1. Estimated total and annual average hours and cost for each type

 of environmental document that is submitted by a respondent

 under the Final Rule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65

Chart 2. Estimated total hours and costs for Multi-Year IEE as the

 anticipated level and type of environmental document most

 respondents submit under the Final Rule for the 3-year ICR

 renewal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65

Chart 3. Estimated hours and costs for environmental documentation

 for 3-year period of this ICR renewal . . . . . . . . . . . . . . . . . . . . . 66

Exhibit 4: Summary for Respondents and Federal Government - O&M Costs . . 67

Part B: Statistical Survey . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-1
1

SUPPORTING STATEMENT

for Renewal of Information Collection Requirements under the

Paperwork Reduction Act, 44 U.S.C. 3501 et seq.

Final Rule at 40 CFR Part 8

Environmental Impact Assessment of Nongovernmental Activities in Antarctica

___________________________________

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) TITLE OF THE INFORMATION COLLECTION: "Environmental Impact 

Assessment of Nongovernmental Activities in Antarctica (Renewal)”

EPA ICR Number 1808.07, OMB Control Number 2020-0007"

1(b) SHORT CHARACTERIZATION/ABSTRACT: The Environmental 

Protection Agency=s (EPA=s) regulations at 40 CFR Part 8, Environmental Impact Assessment 

of Nongovernmental Activities in Antarctica (Rule), were promulgated pursuant to the Antarctic 

Science, Tourism, and Conservation Act of 1996 (Act), 16 U.S.C. 2401 et seq., as amended, 16 

U.S.C. 2403a, which implements the Protocol on Environmental Protection (Protocol) to the 

Antarctic Treaty of 1959 (Treaty). The Rule provides for assessment of the environmental 

impacts of nongovernmental activities in Antarctica, including tourism, for which the United 

States is required to give advance notice under Paragraph 5 of Article VII of the Treaty, and for 

coordination of the review of information regarding environmental impact assessments received 

from other Parties under the Protocol. The requirements of the Rule apply to operators of 

nongovernmental expeditions organized in or proceeding from the territory of the United States 

to Antarctica and include commercial and non-commercial expeditions. Expeditions may

include ship-based tours; yacht, skiing or mountaineering expeditions; privately funded research 

expeditions; and other nongovernmental activities. The Rule does not apply to individual U.S. 

citizens or groups of citizens planning to travel to Antarctica on an expedition for which they are 

not acting as an operator. (Operators, for example, typically acquire use of vessels or aircraft, 

hire expedition staff, plan itineraries, and undertake other organizational responsibilities.) The

Rule provides nongovernmental operators with the specific requirements they need to meet in 

order to comply with the requirements of Article 8 and Annex I to the Protocol. The provisions 

of the Rule are intended to ensure that potential environmental effects of nongovernmental 

activities undertaken in Antarctica are appropriately identified and considered by the operator 

during the planning process and that to the extent practicable, appropriate environmental 

safeguards which would mitigate or prevent adverse impacts on the Antarctic environment are 

identified by the operator.

Environmental Documentation. Persons subject to the Rule must prepare environmental 

documentation to support the operator's determination regarding the level of environmental 

impact of the proposed expedition. Environmental documentation includes a Preliminary 
2

Environmental Review Memorandum (PERM), an Initial Environmental Evaluation (IEE), or a 

Comprehensive Environmental Evaluation (CEE). The environmental document is submitted to 

the Office of Federal Activities (OFA). If the operator determines that an expedition may have: 

(1) less than a minor or transitory impact, a PERM needs to be submitted no later than 180 days 

before the proposed departure to Antarctica; (2) no more than minor or transitory impacts, an 

IEE needs to be submitted no later than 90 days before the proposed departure; or (3) more than 

minor or transitory impacts, a CEE needs to be submitted. Operators who anticipate such 

activities are encouraged to consult with EPA as soon as possible regarding the date for submittal 

of the CEE.1

The Protocol and the Rule also require an operator to employ procedures to assess and 

provide a regular and verifiable record of the actual impacts of an activity which proceeds on the 

basis of an IEE or CEE. The record developed through these measures needs to be designed to: 

(a) enable assessments to be made of the extent to which environmental impacts of 

nongovernmental expeditions are consistent with the Protocol; and (b) provide information 

useful for minimizing and mitigating those impacts and, where appropriate, on the need for 

suspension, cancellation, or modification of the activity. Moreover, an operator needs to monitor 

key environmental indicators for an activity proceeding on the basis of a CEE. An operator may

also need to carry out monitoring in order to assess and verify the impact of an activity for which 

an IEE would be prepared. For activities that require an IEE, an operator should be able to use 

procedures currently being voluntarily utilized by operators to provide the required information.2 

Should an activity require a CEE, the operator should consult with EPA to: (a) identify the 

monitoring regime appropriate to that activity, and (b) determine whether and how the operator 

might utilize relevant monitoring data collected by the U.S. Antarctic Program. OFA would 

consult with the National Science Foundation and other interested Federal agencies regarding the 

monitoring regime.

 

1

Article 3(4), of Annex I of the Protocol requires that draft CEEs be distributed to all Parties and the 

Committee for Environmental Protection 120 days in advance of the next Antarctic Treaty Consultative Meeting 

(ATCM) at which the CEE may be addressed.

2

For example, such information includes, as appropriate and to the best of the operator=s knowledge: 

identification of the number of tourists put ashore at each site, the number and location of each landing site, the total 

number of tourists at each site per ship and for the season; the number of times the site has been visited in the past; 

the number of times the site is expected to be visited in the forthcoming season; the times of the year that visits are 

expected to occur (e.g., before, during, or after the penguin breeding season); the number of visitors expected to be 

put ashore at the site at any one time and over the course of a particular visit; what visitors are expected to do while 

at the site; verification that guidelines for tourists are followed; description of any tourist exceptions to the landing 

guidelines; and description of any activity requiring mitigation, the mitigative actions undertaken, and the actual or 

projected outcome of the mitigation.
3

In cases of emergency relating to the safety of human life or of ships, aircraft, equipment 

and facilities of high value, or the protection of the environment which would require an activity

to be undertaken without completion of the documentation procedures set out in the Rule, the 

operator would need to notify the Department of State within 15 days of any activities which 

would have otherwise required preparation of a CEE, and provide a full explanation of the 

activities carried out within 45 days of those activities.3

Environmental documents (e.g., PERM, IEE, CEE) are submitted to OFA. 

Environmental documents are reviewed by OFA, in consultation with the National Science 

Foundation and other interested Federal agencies, and also made available to other Parties and 

the public as required under the Protocol or otherwise requested. OFA notifies the public of 

document availability via the World Wide Web at: 

http://www.epa.gov/compliance/nepa/international/antarctica/index.html. The types of 

nongovernmental activities currently being carried out (e.g., ship-based tours, land-based tours, 

flights, and privately funded research expeditions) are typically unlikely to have impacts that are 

more than minor or transitory, thus an IEE is the typical level of environmental documentation 

submitted. For the 1997-1998 through 2009-2010 austral summer seasons during the time Rule 

has been in effect, all respondents submitted IEEs with the exception of one PERM. Paperwork 

reduction provisions in the Final Rule that are used by the operators include:

a) incorporation of material into the environmental document by referring to it in the IEE;

b) inclusion of all proposed expeditions by one operator within one IEE; 

c) use of one IEE to address expeditions being carried out by more than one operator; and

d) use of multi-year environmental documentation to address proposed expeditions for a 

period of up to five consecutive austral summer seasons. 

Coordination of Review of Information Received from Other Parties to the Treaty. The 

Rule also provides for the coordination of review of information received from other Parties and 

the public availability of that information including: (1) a description of national procedures for 

considering the environmental impacts of proposed activities; (2) an annual list of any IEEs and 

any decisions taken in consequence thereof; (3) significant information obtained and any action 

taken in consequence thereof with regard to monitoring from IEEs and CEEs; and (4) 

information in a final CEE. This provision fulfills the United States' obligation to meet the 

requirements of Article 6 of Annex I to the Protocol. The Department of State is responsible for 

coordination of these reviews of drafts with interested Federal agencies, and for public 

availability of documents and information. This portion of the Rule does not impose paperwork 

requirements on any nongovernmental person subject to U.S. regulation.

 

3

During the time the Interim Final and Final Rules have been in effect, there were no emergencies requiring 

notification by U.S. operators. An Interim Final Rule was in effect from April 30, 1997, until replaced on December 

6, 2001, by the Final Rule. The term Rule in this document refers to the period of time the Interim Final and Final 

Rules have been in place at 40 CFR Part 8 (e.g., for this ICR renewal, the years 1997- 2013 which includes the 

1997-1998 through 2012-2013 austral summer seasons).
4

2. NEED FOR AND USE OF THE COLLECTION

2(a) NEED/AUTHORITY FOR THE COLLECTION: The basis for the Rule is 

the United States Code as amended: 16 U.S.C. 2401 et seq., as amended, 16 U.S.C. 2403a.

The Rule, promulgated pursuant to the Antarctic Science, Tourism, and Conservation Act 

of 1996, provides nongovernmental operators with the specific requirements they need to meet in 

order to comply with the requirements of Article 8 and Annex I to the Protocol on Environmental 

Protection to the Antarctic Treaty of 1959 and provides for the environmental impact assessment 

of nongovernmental activities, including tourism, for which the United States is required to give 

advance notice under paragraph 5 of Article VII of the Antarctic Treaty of 1959.

The Rule also provides for coordination of the review of information regarding 

environmental impact assessment received by the United States from other Parties under the 

Protocol. This provision of the Rule includes Federal agency requirements, but does not impose 

paperwork requirements on any nongovernmental person subject to U.S. regulation.

The procedures in the Rule are designed to: ensure that nongovernmental operators 

identify and assess the potential impacts of their proposed activities, including tourism, on the 

Antarctic environment; that operators consider these impacts in deciding whether or how to 

proceed with proposed activities; and that operators provide environmental documentation 

pursuant to the Act and Annex I of the Protocol. These procedures are consistent with and 

implement the environmental impact assessment provisions of Article 8 and Annex I to the 

Protocol on Environmental Protection to the Antarctic Treaty.

2(b) PRACTICAL UTILITY/USERS OF THE DATA:

Role of the Information in Regulatory Decisions: The Office of Federal Activities uses 

environmental impact assessment information and any associated assessment and verification 

information to ensure that nongovernmental operators identify and assess the potential impacts of 

their proposed activities, including tourism, on the Antarctic environment; that operators 

consider these impacts in deciding whether or how to proceed with proposed activities; and that 

operators provide environmental documentation pursuant to the Act and Annex I of the Protocol. 

The procedures in the Rule are consistent with and implement the environmental impact 

assessment provisions of Article 8 and Annex I to the Protocol. The provisions of the Rule are 

intended to ensure that potential environmental effects of nongovernmental activities undertaken 

in Antarctica are appropriately identified and considered by the operator during the planning 

process and that to the extent practicable, appropriate environmental safeguards which would 

mitigate or prevent adverse impacts on the Antarctic environment are identified by the operator.

The Rule addresses measures to assess and verify environmental impacts but does not set 

schedule requirements for submission of assessment and verification reports. Under the Rule, all 

proposed activities for which an IEE or CEE are prepared need to include procedures designed to 

provide a regular and verifiable record of the impacts of these activities. For activities requiring 

an IEE, the Preamble to the Rule states that operators should be able to use the annual procedures 
5

that are voluntarily utilized by operators to provide the information. Because measures to assess 

and verify environmental impacts for all proposed activities for which an IEE or CEE are 

prepared are required by the Rule, and because of the recordkeeping requirements of and burden 

definition in the Paperwork Reduction Act (PRA), EPA has included this information as an 

element for the operators for which hours and cost were calculated. Because operators 

voluntarily provide the information to the government, the hours and cost of review of this 

information was also included in the government=s burden estimate. In this case, EPA believes 

the PRA, Section 3502(13) clearly supports the view that recordkeeping requirements must be 

considered inclusively in developing the ICR budget.4

 

4

The Paperwork Reduction Act, 44 U.S.C. Section 3502, states:

(13) the term Arecordkeeping requirement@ means a requirement imposed by or for an agency on persons 

to maintain specified records, including a requirement to -

(A) retain such records;

(B) notify third parties, the Federal Government, or the public of the existence of such records;

(C) disclose such records to third parties, the Federal Government, or the public; or

(D) report to third parties, the Federal Government, or the public regarding such records; ...

Burden is defined in the Preamble to the Final Rule, Section VII, Paperwork Reduction Act, as 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. 
6

The purpose of the Rule is to ensure that the United States has the ability to implement its 

environmental impact assessment obligations for nongovernmental operators under the Protocol. 

Section 8.9(b) in the Rule requires that operators have Aprocedures designed to provide a regular 

and verifiable record of the impacts of these activities. The EPA believes that this establishes a 

requirement that the information be available to EPA. Otherwise, there is no way to know if an 

operator was in compliance with this requirement in the regulation. As stated in the Preamble to 

the Rule, it is EPA=s view that, at a minimum, an IEE is the appropriate level of environmental 

documentation for proposed activities where multiples of the activity over time are likely and 

may create a cumulative impact. For activities requiring an IEE, an operator should be able to 

use procedures that are voluntarily utilized by operators to provide the required information. The 

operators currently provide post-visit reports to Antarctic Treaty Parties. Currently, the National 

Science Foundation receives the information voluntarily submitted by the tour operators and, in 

cooperation with the International Association of Antarctica Tour Operators (IAATO), uses the 

information to prepare annual summary reports. EPA assumes this voluntary process of postvisit reporting will continue. EPA intends to review the information voluntarily submitted, and 

to maintain files. Because operators are currently voluntarily providing the informational reports 

to the government and because EPA anticipates that this practice will continue, EPA included the 

hours and cost of review of this information in the government=s burden estimates.

Users of the Information: The procedures in the Rule include procedures for 

environmental documentation, any associated assessment and verification information, and any 

reporting in cases of emergency. This information would be used as follows:

By operators to identify and assess the potential impacts of their proposed activities, 

including tourism, on the Antarctic environment; to consider these impacts in deciding 

whether or how to proceed with proposed activities; and to provide environmental 

documentation pursuant to the Act and Annex I of the Protocol. For a CEE, any decision 

by the operator on whether a proposed activity should proceed in either its original or 

modified form must be based upon the final CEE as well as other relevant considerations, 

and the information provided in an evaluation should allow the operator to make 

decisions based on sound understanding of factors relevant to the likely impact of the 

proposed activity.

By OFA, in consultation with other interested Federal agencies, to ensure that 

nongovernmental operators identify and assess the potential impacts of their proposed 

activities, including tourism, on the Antarctic environment, and that operators consider 

these impacts in deciding whether or how to proceed with proposed activities. OFA also 

makes the environmental documentation and any associated assessment and verification 

information available to other Parties to the Treaty and the public as required under the 

Protocol or as otherwise requested. OFA uses the assessment and verification 

information for such things as tracking Antarctic tourism trends and activities.

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA
7

3(a) NONDUPLICATION: The information that is requested from respondents 

under this ICR is required by statute and is not available from other sources. The Act requires 

these regulations to be consistent with Annex I to the Protocol, and the Rule provides 

nongovernmental operators with the specific requirements they need to meet in order to comply 

with the Protocol. Most Antarctica tour operators currently provide, on an informal basis, 

information to the National Science Foundation prior to each Antarctic season. Operators also 

provide an advance notice to the U.S. Department of State. This information is similar to the 

basic information requirements for preparation of environmental documentation under the Rule. 

However, the Rule ensures that nongovernmental operators identify and assess the potential 

impacts of their proposed activities, including tourism, on the Antarctic environment, and that 

operators consider these impacts in deciding whether or how to proceed with proposed activities. 

Even the lowest level of environmental documentation, the PERM, directs that the assessment 

process include assessment of the potential direct and reasonably foreseeable indirect impacts on 

the Antarctic environment of the proposed expedition in sufficient detail to assess whether the 

proposed activity has less than a minor or transitory impact, a requirement that leads to 

consistency with Article 8 and Annex I of the Protocol. Operators can, and usually do, include a 

copy of the advance notice as part of their EIA documentation.5 However, simply providing a 

copy of the advance notice submitted to the Department of State as the environmental 

documentation would not meet the requirements of Article 8 and Annex I of the Protocol or the 

provisions of the Rule.

3(b) PUBLIC NOTICE REQUIRED PRIOR TO ICR SUBMISSION TO OMB: 

The Office of Federal Activities published a Notice in the Federal Register requesting 

public comments on the renewal of this ICR and established a public docket for this ICR renewal 

under Docket ID number HQ-OECA-2007-0468. Public comments were requested via the 

Federal Register (78 FR 57847) on September 20, 2013. The proposed information collection did 

not receive any comments. 

3(c) CONSULTATIONS:

The Office of Federal Activities attempted to contact four potential respondents. The 

following is a list of potential respondents contacted:

Ted Cheeseman Ron Naveen

Cheesemans' Ecology Safaris Oceanites, Inc. /Antarctic Site Inventory

408-741-5330 202-237-6262

Bill Davis Bob Simpson

 

5

Alternately, under the paperwork reduction provisions of the Rule, operators could choose to incorporate 

the advance notice by referring to it since it is reasonably available to EPA. Practice has been that the operators 

have included a copy in their environmental assessment documentation.
8

Quark Expeditions Abercrombie & Kent USA, LLC

416-645-8253 630-725-3400 Ext 150

Only Ted Cheeseman of Cheesemans’ Ecology Safaris and Ron Naveen of Oceanites, Inc. 

provided responses. OFA inquired whether or not the respondent burden in the Supporting 

Statement was an accurate portrayal. Ted Cheeseman believed that the majority of burden hours 

were accurate with the exception of the estimate for the multi-year IEE documentation. He 

believes the “multi-year” IEE documentation estimate should be double of what has been 

anticipated. Ron Naveen believed that his burden was half of what EPA estimates to be the 

burden. 

3(d) EFFECTS OF LESS FREQUENT COLLECTION: The Rule requires 

environmental documentation for each operator for each nongovernmental expedition to 

Antarctica. Nongovernmental activities are usually limited to seasonal expeditions during the 

austral summer season and operators report annually on their proposed expeditions. Operators 

with one-time only expeditions report only during the season for which their expedition is 

planned. In order to minimize paperwork and to implement the regulations without undue 

burden on operators, the Rule provides that: (1) material may be incorporated by referring to it 

in the environmental document when it is reasonably available to EPA; (2) more than one 

proposed expedition by an operator may be included within one environmental document; (3) 

one environmental document may also be used to address expeditions being carried out by more 

than one operator; and (4) operators may submit multi-year environmental documentation to 

address proposed expeditions for a period of up to five consecutive austral summer seasons. 

Once environmental documentation has been prepared for a season, an operator can resubmit the 

same document for subsequent seasons provided the level and intensity of the activities are not 

unchanged and that relevant updates are submitted. Updates are likely to include dates of 

expeditions and changes in landing locations. The operator may also revise the document to 

address modifications to the expedition's activities that could have environmental consequences. 

Most operators are likely to employ the multi-year provision thereby further reducing their 

annual reporting burden. Under this paperwork reduction provision, one environmental 

document may be submitted by one or more operators for proposed expeditions for a period of 

up to five consecutive austral summer seasons, provided that the conditions of the multi-year 

environmental document, including the assessment of cumulative impacts, are unchanged. The 

multi-year provision allows operators to update basic information and to provide information on 

additional activities to supplement the multi-year environmental document without having to 

revise and re-submit the entire document.

The Protocol and the Rule also require an operator to employ procedures to assess and 

provide a regular and verifiable record of the actual impacts of any activity which proceeds on 

the basis of an IEE or CEE. For activities requiring an IEE, an operator should be able to use the 

annual procedures currently being voluntarily utilized by operators to provide the information.

3(e) GENERAL GUIDELINES: The information collections associated with the 

Rule follow OMB's guidelines. Section III.F of the Preamble, Submission of Environmental 

Documents, indicates that an operator submits five copies of its environmental documentation, 
9

along with an electronic copy, if available. EPA coordinates review of the document with other 

interested Federal agencies and makes documents received available to the other Parties to the 

Treaty and the public as required under the Protocol or as otherwise requested. EPA believes 

that five copies (total) does not place undue burden on the operator and enables EPA to distribute 

copies to the reviewing agencies in a timely manner, particularly in light of the timing 

requirements for document submission and review prior to departure for the expedition.

3(f) CONFIDENTIALITY: The Rule does not require submission of confidential 

information, nor does EPA anticipate that operators would submit confidential information as 

part of their environmental documentation.

3(g) SENSITIVE QUESTIONS: The Rule does not require response to sensitive 

questions (e.g., questions concerning sexual behavior or attitudes, religious beliefs, or other 

matters usually considered private).

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) RESPONDENTS/SIC CODES: The requirements of the Rule apply to 

operators of nongovernmental expeditions organized in or proceeding from the territory of the 

United States to Antarctica for which the United States is required to give advance notice under

Paragraph 5 of Article VII of the Treaty and includes commercial and non-commercial 

expeditions. Expeditions include ship-based tours; yacht, skiing or mountaineering expeditions; 

flights; privately funded research expeditions; and other nongovernmental or nongovernmentsponsored activities. The Rule does not apply to individual U.S. citizens or groups of citizens 

planning to travel to Antarctica on an expedition for which they are not acting as an operator. 

(Operators, for example, typically acquire use of vessels or aircraft, hire expedition staff, plan 

itineraries, and undertake other organizational responsibilities.) Further, the Act is specific for 

nongovernmental activities, thus governmental jurisdictions are not subject to these regulations.

Most operators are ship-based or land-based tour operators. The SIC Code for Tour 

Operators is 4725 and the NAICS Code is 561520.

4(b) INFORMATION REQUESTED:

 (i) Data items, including recordkeeping requirements: The Rule provides 

nongovernmental operators with the specific environmental documentation requirements they

need to meet in order to comply with relevant portions of the Protocol. Nongovernmental 

operators, including tour operators, conducting expeditions to Antarctica are required to submit 

environmental documentation to EPA that evaluates the potential environmental impact of their 

proposed activities. The type of environmental document required depends upon the nature and 

intensity of the environmental impacts that could result from the activity under consideration. 

Under the Rule, environmental documentation includes a Preliminary Environmental Review 

Memorandum (PERM), an Initial Environmental Evaluation (IEE), or a Comprehensive 

Environmental Evaluation (CEE). If the operator determines that an expedition may have: (1) 
10

less than a minor or transitory impact, a PERM needs to be submitted no later than 180 days 

before the proposed departure to Antarctica; (2) no more than minor or transitory impacts, 

including the cumulative impacts of the proposed activity in light of existing and known 

proposed activities, an IEE needs to be submitted no later than 90 days before the proposed 

departure; or (3) more than minor or transitory impacts, including the cumulative impacts of the 

proposed activity in light of existing and known proposed activities, a CEE needs to be 

submitted.

The Protocol and the Rule also require an operator to employ procedures to assess and 

provide a regular and verifiable record of the actual impacts of an activity which proceeds on the 

basis on an IEE or CEE, including monitoring of key environmental indicators for an activity

proceeding on the basis of a CEE. For activities that require an IEE, an operator should be able 

to use the annual procedures currently being voluntarily utilized by operators to provide the 

information. For activities that require a CEE, OFA would consult with the National Science 

Foundation and other interested Federal agencies regarding the monitoring regime that would be 

appropriate to the activity proposed, and with regard to possible utilization of relevant 

monitoring data collected by the U.S. Antarctic Program.

Environmental documentation is submitted to EPA by an operator prior to an expedition. 

For most respondents, including tour operators, EPA assumes this will be an IEE and, as 

provided in the Rule at Section 8.4, an operator may: (1) include more than one proposed 

expedition within one environmental document, and (2) one environmental document may also 

be used to address expeditions being carried out by more than one operator. An operator can 

also submit multi-year documentation to address proposed expeditions for a period of up to five 

consecutive austral summer seasons thus eliminating the need for annual submission of 

environmental documentation. The multi-year provision also allows operators to update basic 

information and to provide information on additional activities to supplement the multi-year 

environmental document without having to revise and re-submit the entire document. Operators 

are not required to retain the environmental documentation submitted to EPA. There is nothing 

in the Rule, however, that precludes an operator from submitting a previous year's 

documentation, with appropriate updates, for a subsequent year's expedition(s).

In cases of emergency relating to the safety of human life or of ships, aircraft, equipment 

and facilities of high value, or the protection of the environment which requires an activity to be 

undertaken without completion of the documentation procedures set out in the Rule, the operator 

must notify the Department of State within 15 days of any activities which would have otherwise 

required preparation of a CEE, and provide a full explanation of the activities carried out within 

45 days of those activities.

Enforcement action can proceed, pursuant to Section 8.11 of the Rule, against an operator 

who violates any provision of the Rule. Enforcement actions are not, however, subject to the 

requirements of the Paperwork Reduction Act (PRA).

 (ii) Respondent Activities: The EPA considered the definition of "burden" 

developed for the PRA and the Office of Management and Budget=s (OMB's) final rules on 
11

implementing the PRA. For purposes of renewing this ICR, EPA estimated the hours and costs 

to respondents under the Rule. These are the operators (e.g., respondents) for which the United 

States provided advance notice under Paragraph 5 of Article VII of the Treaty for proposed 

nongovernmental expeditions organized in or proceeding from the U.S. to the Antarctic Treaty

area. EPA used a ship-based tour operator as its model respondent since most U.S.-based 

nongovernmental activities covered by the Rule are for operators and activities associated with 

ship-based tourism as summarized in Figure 1.6

Figure 1. Numbers of Operators Submitting Environmental Documentation Under the Rule7and the 

Level of Documentation Submitted

Season Operators Documentation Submitted

1997-1998 9 4 total IEEs submitted including:

 1 IEE submitted on behalf of five IAATO-member operators for expeditions to 

the Peninsula area

 1 IEE submitted by two IAATO-member operators for their expeditions to the 

Ross Sea area

 2 IEEs submitted by two non-IAATO operators

1998-1999 10 4 total IEEs submitted including:

 1 IEE submitted on behalf of seven IAATO-member operators for expeditions 

to the Peninsula area

 1 IEE submitted by one IAATO-member operator for its expeditions to the 

Ross Sea area

 2 IEEs submitted by two non-IAATO operators

1999-2000 13 6 total IEEs submitted including:

 1 IEE submitted on behalf of eight IAATO-member operators for expeditions 

to the Peninsula area

 1 IEE submitted by one IAATO-member operator for its expeditions to the 

Ross Sea area

 4 IEEs submitted by four non-IAATO operators including a one-time only 

filming expedition and a one-time only cruise-only expedition

2000-2001 13 85 total IEEs submitted including:

 1 IEE submitted on behalf of nine IAATO-member operators for expeditions 

 

6

For the 1997-1998 through 2012-2013 austral summer seasons (e.g., during the time the Interim Final and 

Final Rules have been in effect), EPA found that the IEEs for expeditions that were not ship-based (e.g., land-based; 

non-governmental research, and flight expeditions) were usually similar to ship-based IEEs in terms of complexity; 

thus, the IEEs for these expeditions are similar in detail and length.

7

The term Rule in this document refers to the period of time the Interim Final Rule and Final Rule have 

been in place at 40 CFR Part 8 (e.g., for this ICR renewal, the years from 1997-2007 which includes the 1997-1998 

through 2012-2013 austral summer seasons).

8

Nine IAATO-member operators submitted one IEE for their Peninsula area expeditions but one of the 

operators did not proceed with its planned tours during the season; this operator plans to continue its operations in 

the out-years.
12

to the Peninsula area

 1 IEE submitted by one IAATO-member operator for its expeditions to the 

Ross Sea area

 3 IEEs submitted by three non-IAATO operators including a one-time only 

trekking expedition

2001-2002 1297 total IEEs submitted including:

 1 IEE submitted on behalf of seven IAATO-member operators for expeditions 

to the Peninsula area

 1 IEE submitted by one IAATO-member operator for its expeditions to the 

Ross Sea area

 5 IEEs submitted by five non-IAATO operators including a one-time sailor 

training expedition

2002-2003 14 8 total IEEs submitted including:

 1 IEE submitted on behalf of seven IAATO-member operators for expeditions 

to the Peninsula area

 1 IEE submitted by one IAATO-member operator for its expeditions to the 

Ross Sea area

 6 IEEs submitted by six non-IAATO operators 

2003-2004 22 1 PERM submitted for a one-time only flight

13 total IEEs submitted including:

 1 IEE submitted on behalf of nine IAATO-member operators for expeditions 

to the Peninsula area

 1 IEE submitted by one IAATO-member operator for its expeditions to the 

Ross Sea area

 11 IEEs submitted by eleven non-IAATO operators including two one-time 

only flights 

2004-2005 21 16 total IEEs submitted including:

 6 IEE submitted on behalf of 11 IAATO-member operators for expeditions to 

the Peninsula area

 1 IEE submitted by one IAATO-member operator for its expeditions to the 

Ross Sea area

 1 IEE submitted by one IAATO-member operator for its expeditions to the 

Continental area

 8 IEEs submitted by 8 non-IAATO operators 

2005-2006 19 13 total IEEs submitted including:

 5 IEEs submitted on behalf of 11 IAATO-member operators for expeditions to 

the Peninsula area

 1 IEE submitted by one IAATO-member operator for its expeditions to the 

Ross Sea area

 1 IEE submitted by one IAATO-member operator for its expeditions to the 

Continental area

 6 IEEs submitted by 8 non-IAATO operators 

2006-2007 21 13 total IEEs submitted including:

 5 IEEs submitted on behalf of 14 IAATO-member operators for expeditions to 

 

9

Seven IAATO member operators submitted one IEE for their Peninsula area expeditions but one of the 

operators did not proceed with its planned tours during the season.
13

the Peninsula area

 1 IEE submitted by one IAATO-member operator for its expeditions to the 

Ross Sea area

 1 IEE submitted by one IAATO-member operator for its expeditions to the 

Continental area

 6 IEEs submitted by 6 non-IAATO operators 

2007-2008 24 14 total IEEs submitted including:

 6 IEEs submitted on behalf of 14 IAATO-member operators for expeditions to 

the Peninsula area

 1 IEE submitted by one IAATO-member operator for its expeditions to the 

Ross Sea area

 1 IEE submitted by one IAATO-member operator for its expeditions to the 

Continental area

 6 IEEs submitted by 6 non-IAATO operators

2008-2009 17 12 total IEEs submitted including:

 8 IEEs submitted on behalf of 13 IAATO-member operators for expeditions to 

the Peninsula area

 1 IEE submitted by one IAATO-member operator for its expeditions to the 

Ross Sea area

 1 IEE submitted by one IAATO-member operator for its expeditions to the 

Continental area

 2 IEEs submitted by 2 non-IAATO operators

2009-2010 16 11 total IEEs submitted including:

 9 IEEs submitted on behalf of 14 IAATO-member operators for expeditions to 

the Peninsula area

 1 IEE submitted by one IAATO-member operator for its expeditions to the 

Ross Sea area

 1 IEE submitted by one IAATO-member operator for its expeditions to the 

Continental area

 0 IEEs submitted by non-IAATO operators

2010-2011 18 16 total IEEs submitted including:

 12 IEEs submitted on behalf of 14 IAATO-member operators for expeditions 

to the Peninsula area

 0 IEE submitted by one IAATO-member operator for its expeditions to the 

Ross Sea area

 0 IEE submitted by one IAATO-member operator for its expeditions to the 

Continental area

 4 IEEs submitted by non-IAATO operators

2011-2012 15 14 total IEEs submitted including:

 9 IEEs submitted on behalf of 11 IAATO-member operators for expeditions to 

the Peninsula area

 1 IEE submitted by one IAATO-member operator for its expeditions to the 

Ross Sea area

 1 IEE submitted by one IAATO-member operator for its expeditions to the 

Continental area

 3 IEEs submitted by non-IAATO operators

2012-2013 16 1 PERM submitted for a one-time only flight

14 total IEEs submitted including:

 9 IEEs submitted on behalf of 11 IAATO-member operators for expeditions to 

the Peninsula area

 1 IEE submitted by one IAATO-member operator for its expeditions to the 

Ross Sea area

 1 IEE submitted by one IAATO-member operator for its expeditions to the 
14

Continental area

 3 IEEs submitted by non-IAATO operators

The EPA hours and cost estimates are based on the following activities which EPA 

assumes a respondent would carry out to prepare and submit the environmental documentation 

and undertake as assessment and verification procedures.

Assumed Operator Activities Associated With:

1. Preparing and Submitting Environmental Documentation:

1. Read the regulations and evaluate business operations and the expedition(s) activities 

relative to the regulatory provisions of the Rule and determine the level of environmental 

documentation needed;

2. Search reference sources for existing information on environmental conditions at 

proposed expedition site(s) and compile basic information from company records for use in 

preparation of the environmental document for the proposed expedition(s);

3. Prepare the environmental impact assessment (EIA) document (e.g., PERM, IEE or 

CEE), or review a contractor-prepared document, and submit to EPA; and

4. Revise document if necessary, or operator decides to prepare higher level EIA 

document, in response to EPA's comments and submit to EPA.

2. Post-Expedition Assessment and Verification Procedures:

1. Prepare assessment and verification information.

3. Reporting for Cases of Emergency, if necessary:

1. Notify the Department of State of any activities which would have otherwise required 

preparation of a CEE within 15 days.

2. Provide a full report to the Department of State within 45 days.

The Rule does NOT require or contemplate the need for respondents to:

1. Acquire, install, or utilize technology and systems for the purpose of collecting, 

validating, and verifying information;

2. Develop, acquire, install, or utilize technology and systems for the purpose of 

processing and maintaining information;

3. Develop, acquire, install, or utilize technology and systems for the purpose of 

disclosing and providing information; or

4. Adjust the existing ways to comply with any previously applicable instructions and 

requirements.

5. THE INFORMATION COLLECTED--AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT
15

5(a) AGENCY ACTIVITIES: The EPA consults with the Department of State, the 

National Science Foundation, and other interested Federal agencies10 for activities associated 

with the Rule. This enables appropriate government agencies with specific Antarctic interests 

and expertise to be involved with the review of the environmental documentation for proposed 

nongovernmental expeditions including coordination of appropriate information relative to the 

U.S. Antarctic Program. Further, violation of the provisions of the Rule could result in 

enforcement and penalties pursuant to the Antarctic Conservation Act, as amended, as 

undertaken by the National Science Foundation and/or the Department of Justice. Finally, the 

Department of State has specific responsibilities under the Rule, Section 8.12, Coordination of 

reviews from other Parties, and for circulating a CEE that is prepared in accordance with the 

Rule at Section 8.8, along with any decisions by the operator relating thereto, to all Parties. 

Activities associated with the Rule for the EPA and other Federal agencies consist of the 

following.

EPA and Other Federal Agencies Activities Associated With:

1. Processing and Reviewing Environmental Documentation Received from Operators:

1. Post receipt of environmental documents on OFA's World Wide Website, and provide 

copies to other Federal agencies and the public, if requested.

2. Prepare and publish Federal Register notice of receipt of draft CEEs and notice of 

availability for Final CEEs.

3. Review environmental documents, including any appropriate public comments, and 

provide comments to the operator.

4. Consult with operators on the comments, or any other elements associated with the 

environmental documentation requirements.

5. Circulate to interested Federal agencies and review the revised or final document 

submitted by the operator, and notify the operator, if necessary, if the environmental 

documentation does not meet the requirements of the Protocol and the provisions of the Rule.

6. Notify the Parties and provide copies to the Committee for Environmental Protection 

of the annual list of IEEs, draft CEEs and final CEEs.

7. Maintain files.

 

10EPA routinely consults with the Department of State (DOS) and the National Science Foundation (NSF). 

EPA may consult with other agencies when appropriate for specific activities. These may include: U.S. Coast 

Guard (USCG), Marine Mammal Commission (MMC), National Oceanic and Atmospheric Administration (NOAA, 

including National Marine Fisheries Service), and the Department of Justice (DOJ).
16

2. Processing and Reviewing Post-Expedition Assessment and Verification Information:

1. Review assessment and verification information submitted by operators.

2. Maintain files.

3. Processing and Reviewing Reports for Cases of Emergency, if necessary:

1. Notify Parties to the Protocol when activities taken in cases of emergency are reported 

by operators which required the operator to undertake any activities which would have otherwise 

required preparation of a CEE.

2. Forward the operator's full explanation of the activities carried out to the Parties.

3. Review assessment and verification information submitted by operator.

4. Maintain files.

4. Processing and Reviewing Environmental Documentation Received from Other Parties:

1. Prepare and publish Federal Register notice of receipt of a draft CEE from another 

Party and provide copies to other interested Federal agencies and the public, if requested.

2. Review draft CEE and transmit inter-agency response to the Party that circulated the 

CEE.

3. Provide copies of other environmental documents to interested Federal agencies and 

the public, if requested. Other environmental documents may include:

a) a description of national procedures for considering the environmental impacts 

of proposed activities;

b) an annual list of any IEEs and any decisions taken in consequence thereof;

c) significant information obtained and any action taken in consequence thereof 

with regard to monitoring from IEEs and CEEs; and

d) information on a final CEE.

4. Post receipt of significant monitoring information on OFA's World Wide Website.

5. Maintain files.

5(b) COLLECTION METHODOLOGY AND MANAGEMENT: The 

environmental documentation that is required by the Rule is submitted by operators in 

accordance with the deadlines in the regulations. These documents can be submitted in hard 

copy and can also be submitted electronically. The Rule mandates specific information to be 

included in the document, but does not require a specific format. Since the information 

requirement is the same as that in the Protocol, this allows flexibility for operators who have 

multiple international documentation requirements.11 EPA, in consultation with other interested 

Federal agencies, reviews the environmental documentation relative to the general requirements 

(e.g., Rule, Section 8.4) and the specific requirements for each level of documentation (e.g., 

Rule, Section 8.6 for PERMs; Section 8.7 for IEEs; and Section 8.8 for CEEs). EPA provides its 

comments to the operator, and the operator then prepares revised documentation or responses to 

EPA’s questions or comments. Following the final response from the operator, if appropriate, 

 

11For example, Sweden has a specific form, and the United Kingdom has a permit system. For purposes of 

the Final Rule, an operator could submit environmental documentation prepared for another country as long as all 

the elements required by the regulations are addressed.
17

EPA, with the concurrence of the National Science Foundation, makes a finding that the 

documentation submitted does not meet the requirements of Article 8 and Annex I of the 

Protocol and the provisions of the regulations. EPA provides copies of environmental 

documents to all interested Federal agencies, and the public is informed of receipt of 

environmental documents through notice on OFA’s Homepage on the World Wide Web, and 

through the Federal Register for CEEs.

5(c) SMALL ENTITY FLEXIBILITY: The PRA incorporated the Regulatory 

Flexibility Act into it. The Regulatory Flexibility Act (RFA), as amended by the Small Business 

Regulatory Enforcement Act of 1996 (SBREFA, 5 U.S.C. 601 et seq.), generally requires an 

agency to prepare a regulatory flexibility analysis of any rule subject to notice and comment 

rulemaking requirements under the Administrative Procedure Act or any other statute unless the 

agency certifies that the rule will not have a significant economic impact on a substantial number 

of small entities. Small entities include small businesses, small organizations, and small 

governmental jurisdictions.

The purpose of the RFA/SBREFA is Ato fit regulatory and informational requirements to 

the scale of the business, organizations and governmental jurisdictions subject to the regulation.@ 

To achieve this principle, agencies are required to Asolicit and consider flexible regulatory

proposals and to explain the rationale for their actions to assure that such proposals are given 

serious consideration.@ The RFA/SBREFA does not require an agency to minimize a rule=s 

impact on small entities if there are legal, policy, factual or other reasons for not doing so. The 

RFA/SBREFA requires only that agencies: determine, to the extent feasible, the rule=s 

economic impact on small entities; explore regulatory options for reducing any significant 

economic impact on a substantial number of such entities; and explain the Agency=s ultimate 

choice of regulatory approach.

The RFA/SBREFA requirements to prepare a regulatory flexibility analysis or a 

certification of no significant economic impact on a substantial number of small entities applies 

to proposed rules subject to notice-and-comment rulemaking requirements under the 

Administrative Procedure Act or any other statute, and final rules promulgated under the noticeand-comment rulemaking requirements of the Administrative Procedure Act. Further, the RFA 

requires that an agency identify the types, and estimate the numbers, of small entities Ato which 

the final [or proposed] rule will apply,@ and describe the rule Arequirements@ to which small 

entities Awill be subject@ and any regulatory alternatives, including exemptions and deferrals, 

which would lessen the rule=s burden on small entities. It is EPA=s policy to make an 

assessment of the rule=s impact on any small entities, to engage the potentially regulated entities 

in a dialog regarding the rule, and minimize the impact to the extent feasible. However, in view 

of the requirements of SBREFA, a regulatory flexibility analysis as specified by the RFA is not 

required simply because the rule has some impact on some number of small entities. Instead, 

such analyses is required only in cases where the Agency cannot certify that the rule will not 

have a significant economic impact on a substantial number of small entities.

For purposes of assessing the impacts of the Final Rule on small entities, small entity is 

defined as:
18

(1) a small business as defined by the Small Business Administration with the North 

American Industry Classification System (NAICS) code for ATour Operators,@ code 

561520, with annual maximum receipts of $5.0 million (13 CFR Part 121); and

(2) a small organization that is any not-for-profit enterprise which is independently

owned and operated and is not dominant in its field.

In accordance with section 2403a of the Act, governmental jurisdictions are not subject to this 

rulemaking.12

In determining whether a rule has a significant economic impact on a substantial number 

of small entities, the impact of concern is any significant adverse economic impact on small 

entities, since the primary purpose of the regulatory flexibility analyses is to identify and address 

regulatory alternatives Awhich minimize any significant economic impact of the proposed rule 

on small entities.@ 5 U.S.C. Sections 603 and 604. Thus, an agency may certify that a rule will 

not have a significant economic impact on a substantial number of small entities if the rule 

relieves regulatory burden, or otherwise has a positive economic effect on all of the small entities 

subject to the rule. The EPA believes that because the Rule only requires assessment of 

environmental impacts the effects on any small entities will be limited primarily to the cost of 

preparing such an analysis and that the requirements are no greater than necessary to ensure that 

the United States will be in compliance with its international obligations under the Protocol and 

the Treaty. The costs are minimal because the types of activities currently being carried out 

typically are unlikely to have impacts that are more than minor or transitory assuming that 

activities will be carried out in accordance with the guidelines set forth in the ATCM 

Recommendation XVIII-1, Tourism and Non-Governmental Activities, the relevant provisions 

of other U.S. statutes, and Annexes II-V to the Protocol. Therefore, most activities are likely to 

need only IEE documentation, the cost of which is minimal as shown in Section 6 of this 

Supporting Statement and as presented in the Preamble to the Rule, Section V.D, Paperwork 

Reduction Act. Further, EPA has included provisions in the Rule which are available to all 

respondents, including small entities, which will have a positive effect by minimizing the cost, 

and reducing the paperwork burden, of such an analysis.

 

1216 U.S.C. 2401 et seq., as amended, 16 U.S.C. 2403a.
19

It has been EPA=s experience that respondents used the cost reduction provisions in the 

final regulations. The cost and paperwork reduction provisions in the Rule include: (1) material 

may be incorporated by referring to it in the environmental document with its content briefly

described when the cited material is reasonably available to the EPA; (2) more than one 

proposed expedition by an operator may be included within one environmental document and 

may, if appropriate, include a single discussion of components of the environmental analysis 

which are applicable to some or all of the proposed expeditions; (3) one environmental document 

may also be used to address expeditions being carried out by more than one operator, provided 

that the environmental documentation includes the names of each operator for which the 

environmental documentation is being submitted pursuant to obligations under these regulations; 

and (4) one environmental document may be submitted by one or more operators for proposed 

expeditions for a period of up to five consecutive austral summer seasons, provided that the 

conditions of the multi-year environmental document, including the assessment of cumulative 

impacts, are unchanged. The multi-year provision also allows operators to update basic 

information and to provide information on additional activities to supplement the multi-year 

environmental document without having to revise and re-submit the entire document.13

In consideration of the timing requirements associated with the need to assist new 

operators who are unfamiliar with the regulations and its schedules, or to assist operators who 

have unanticipated amendments to their EIA documentation for a particular year, the Rule at 

Section 8.5(b) provides that EPA may waive or modify the deadlines of the Rule if EPA 

determines that an operator is acting in good faith and that circumstances outside the control of 

the operator created delays, provided that environmental documentation fully meets deadlines 

under the Protocol.

The Rule does not provide an exemption from coverage of the collection of information, 

or any part thereof. This is because the Rule only requires assessment of environmental impacts. 

This assessment is limited to the cost of preparing such an analysis and the requirements would 

be no greater than necessary to ensure that the United States will be in compliance with its 

international obligations under the Protocol and the Treaty.

5(d) COLLECTION SCHEDULE: The schedule for submittal of environmental 

documentation depends on the document to be submitted as described below. An operator could 

submit environmental documentation prior to these deadlines. In all cases, however, documents 

need to be submitted such that the schedule requirements for submitting draft CEEs to the Parties 

can be met by the United States.

Preliminary Environmental Review Memorandum (PERM): In accordance with the Rule 

at Section 8.6, a PERM needs to be submitted to EPA no less than 180 days before the proposed 

departure of the expedition.

 

13For the austral seasons the Rule has been in effect, operators have used all of the available paperwork 

provisions available under the Rule.
20

$ EPA, in consultation with other interested Federal agencies, provides its comments to 

the operator within 15 days of receipt.

$ The operator then has 75 days to revise the PERM or prepare an IEE, if necessary. If 

an IEE is prepared and submitted within the 75 day response period, it is reviewed under the time 

frames for an IEE (see below). If a CEE is prepared, it is reviewed under the time frames for a 

CEE (see below.)

$ Within 30 days, if appropriate, EPA, with the concurrence of the National Science 

Foundation, provides notice to the operator that the environmental documentation does not meet 

the requirements of the Protocol and the provisions of the Rule.

Initial Environmental Evaluation (IEE): In accordance with the Rule at Section 8.7, an 

IEE needs to be submitted no fewer than 90 days before the proposed departure of the 

expedition.

$ EPA, in consultation with other interested Federal agencies, provides its comments to 

the operator within 30 days of receipt.

$ The operator then has 45 days to revise the IEE or prepare a CEE, if necessary. If a 

CEE is prepared, it would be reviewed under the time frames for a CEE (see below).

$ Within 15 days of receiving the final IEE from the operator or, if the operator does not 

provide a final IEE, within 60 days following EPA's comments on the original IEE, if 

appropriate, EPA, with the concurrence of the National Science Foundation, provides notice to 

the operator that the environmental documentation does not meet the requirements of the 

Protocol and the provisions of the Final Rule.

Comprehensive Environmental Evaluation (CEE): In accordance with the Final Rule at 

Section 8.8(b), operators need to submit a CEE.14

$ Within 15 days of receipt, EPA would: (1) send it to the Department of State for 

circulation to the Parties and Committee for Environmental Protection; and (2) publish notice of 

receipt and request for comments in the Federal Register.

$ EPA accepts public comments for 90 days following the published notice.

$ EPA, in consultation with other interested Federal agencies, provides its comments to 

the operator within 120 days following the Federal Register notice.

$ The operator then needs to submit a final CEE 75 days before commencement of the 

proposed activity in the Antarctic Treaty area.

$ Within 15 days of receiving the final CEE from the operator or, if the operator does 

not provide a final CEE, within 60 days prior to departure of the expedition, if appropriate, EPA, 

with the concurrence of the National Science Foundation, provides notice to the operator that the 

environmental documentation does not meet the requirements of the Protocol and the provisions 

of the Final Rule.

 

14See: Final Rule, Preamble, Section III.D.3(c). Article 3(4), of Annex I of the Protocol requires that draft 

CEEs be distributed to all Parties and the Committee for Environmental Protection 120 days in advance of the next 

Antarctic Treaty Consultative Meeting (ATCM) at which the CEE may be addressed. Operators who anticipate such 

activities are encouraged to consult with EPA as soon as possible regarding the date for submitting the CEE. In fact, 

there were no CEEs submitted during the seven austral seasons the Rule has been in effect.
21

$ If EPA does not provide such notice, the operator would have met all requirements 

provided that procedures, which may include appropriate monitoring, are put in place to assess 

and verify the impact of the activity.

$ No later than 60 days before commencement of the proposed activity in the Antarctic 

Treaty area, EPA: (1) transmits the CEE, along with notice of any decisions by the operator, to 

the Department of State for circulation to the Parties, and (2) publishes notice of availability of 

the final CEE in the Federal Register.

Information to Assess and Verify Impacts: There is no set schedule requirements in the 

Final Rule for submitting information on measures to assess and verify environmental impacts. 

Operators provide the information to the National Science Foundation on a voluntary basis. 

Operators often specify this schedule within the environmental document for the expedition.

Reporting for Cases of Emergency: In accordance with the Final Rule at Section 8.10, 

within 15 days in cases of emergency, an operator needs to report notice of any activities which 

would have otherwise required preparation of a CEE to the Department of State, and a full 

explanation of the activities carried out must be provided within 45 days of those activities.

6. ESTIMATING THE HOURS AND COST BURDEN OF THE COLLECTION

6(a) ESTIMATING RESPONDENT BURDEN: 

Exhibits 1A, 1B (including Table 1), and 1C present the estimated respondent (e.g., 

operator) hours and cost for the three possible levels of environmental documentation (e.g., 

PERM, IEE, CEE) and associated post-expedition assessment and verification procedures. 

Exhibit 1D presents the estimated respondent hours and cost for reporting for cases of 

emergency. Respondent burden tables were prepared for each type of environmental 

documentation since the effort should increase as an increasing level of environmental 

documentation is required; e.g., from PERM to IEE to CEE.

The model respondent used in the estimates is a nongovernmental, U.S.-based Antarctic 

tour ship operator.15 The estimated hours and cost for operators is based on the assumption that 

most environmental documentation submitted by operators will be IEEs. As stated in the 

Preamble to the Final Rule (Section III.D.3(b)), at a minimum, an IEE is typically the 

appropriate level of environmental documentation for proposed activities. The types of 

nongovernmental activities that are currently being carried out typically are unlikely to have 

impacts that are more than minor or transitory assuming that activities are carried out in 

accordance with the guidelines set forth in the ATCM, Recommendation XVIII-1, Tourism and 

Non-Governmental Activities, the relevant provisions of other U.S. statutes, and Annexes II-V to 

 

15For the thirteen austral summer seasons the Rule has been in effect, environmental documentation has 

been submitted primarily by ship-based tour operators and one privately funded researcher. Many of the U.S.-based 

tour operators (both ship-based and land-based) are members of IAATO and are experienced for-profit companies 

that organize and/or operate travel programs to the Antarctic.
22

the Protocol. During the austral summer seasons the Rule has been in effect, IEEs have been 

submitted by operators as summarized in Figure 1. The following elements further discuss the 

assumptions factored into the estimated respondent hours and cost.

1. PERM Model for Respondent Submittals: For PERMs, the estimated hours and 

cost is based on the estimated time to comply with the Final Rule at Section 8.4, preparation of 

environmental documents, generally, and Section 8.6, preliminary environmental review. The 

estimate assumes one week at 40 hours per week including revisions in response to any EPA 

comments. Assessment and verification procedures are not required at the PERM level of 

activity and documentation. Although one respondent per year is estimated for purposes of the 

cost calculations in Exhibit 1A, EPA anticipates that the actual number of nongovernmental 

expeditions with activities that will likely proceed with less than minor or transitory impacts may

well be reduced to less than one respondent per year. In fact, during the seven austral summer 

seasons the Rule has been in effect, only one PERM has been submitted as the final document 

for an expedition.

2. IEE Model for Respondent Submittals: EPA has developed three models for IEEs 

that incorporate the estimated time to comply with the Final Rule at Section 8.4, preparation of 

environmental documents, generally, and Section 8.7, initial environmental evaluation. The 

model also considers the experience with IEE documents received during the ten austral summer 

seasons the Rule has been in effect and burden estimates in the previous Supporting Statements 

for the ICRs for the Interim Final and Final Rules. The assumptions for EPA's IEE model 

include the following:

$ Figure 2 lists the potential respondents.

$ The maximum length for an IEE is about 200 pages including supplemental 

information.16

$ IEEs consist of "core" information with supplemental expedition-specific or other 

project-specific information (e.g., dates, landing sites, number of tours, etc.) attached or 

referenced.

$ For initial preparation of the "core" IEE, the estimate assumes four weeks, on average, 

at 40 hours/week, or about 160 hours, including revisions in response to EPA comments. 

 

16For the four IEEs submitted in 1997-1998, the approximate number of pages, including the "core" 

document plus supplemental documentation, was: 215 (5-operator Peninsular Area), 208 (2-operator non-PA), 43 

(non-IAATO member operator), and 20 (privately-funded researcher). The supplemental information submitted by 

the 5 operators for the Peninsular Area IEE, which included tour brochures, averaged about 23 pages per operator. 

The privately-funded researcher incorporated by reference selected information from three previously published 

reports. During the subsequent three years the Interim Final Rule was in effect, the annual submissions averaged 

closer to 50 pages due, in large part, to the use of the paperwork reduction provisions of the Interim Final Rule. This 

Apreparation@ burden is actually less when the fact that tour brochures for the current season prepared for 

commercial purposes and a copy of the advance notice submitted to the Department of State were submitted by the 

tour operators as part of the IEE documentation. However, for purposes of maximum burden estimates, the 1997-

1998 figures are used in the burden calculations. Experience under the Final Rule indicates these assumptions are 

still generally accurate.
23

This estimate assumes a full time effort during the four weeks, and that information will 

be incorporated by reference when appropriate.

$ The estimate assumes 5 hours for an operator to prepare and/or compile supplemental 

information.17

$ If appropriate, EPA anticipates operators will submit the "core" IEE in subsequent 

years with any necessary revisions (discussed below). An estimated one week at 40 

hours/week is estimated to prepare this "revised" IEE for submittal in subsequent years. 

The estimate of 5 hours for preparation and/or compilation of supplemental information 

remains the same.

$ If appropriate, EPA anticipates operators will submit Amulti-year@ IEE 

documentation. In the initial year, this is anticipated to consist of a revised IEE with an 

estimated 40 hours associated preparation time and 5 hours for preparation and/or 

compilation of supplemental information. For the subsequent four consecutive years the 

multi-year@IEE can be submitted by an operator, for purposes of maximum burden 

estimation, 5 hours are estimated for preparation and/or compilation of the supplemental 

information.

$ The IEE level of documentation requires assessment and verification (A/V) 

procedures; 20 hours are estimated for preparation and/or compilation of this 

information.18

$ For an IEE that covers multiple operators, the hours and costs per operator are spread 

among the total number of operators; e.g., the more operators under one document, the 

lower the hours and costs to each individual operator.19

IEE Model 1 - Core IEE: The following estimate is based on EPA’s experience for the 

ten austral summer seasons the Rule has been in effect and considers the paperwork reduction 

options utilized by the operators. EPA anticipates five one-time core IEEs will be prepared for 

the three austral summer seasons this ICR renewal will be in effect. The operator hourly burden 

for preparation of a Core IEE is estimated as follows: 

Prepare "core" IEE: 160 hrs/IEE x 5 IEEs = 800 hours

Prepare supplemental information: 5 hrs/operator x 5 operators = 25 hours

A/V procedures: 20 hrs/operator x 5 operators = 100 hours

TOTAL HOURS = 925 hours

 

17The estimate for preparation of supplemental information excludes any time associated with preparing 

travel brochures and/or major reports referenced in, and submitted along with, an IEE (e.g., researcher reports such 

as those prepared by Oceanites, Inc., and submitted as referenced attachments with the IEE).

18For activities requiring an IEE, an operator should be able to use procedures currently being voluntarily 

utilized by operators to provide the required information.

19For an IEE that covers multiple operators, the cost per operator is further reduced; specific examples are 

listed as a footnote for each model calculation.
24

TOTAL HOURS PER IEE (5 IEEs) = 185 hours

TOTAL HOURS PER OPERATOR (5 operators) = 185 hrs20

IEE Model 2 - Revised IEE: For purposes of maximum burden assessment, EPA 

anticipates that three present ship based tour operators will remain the same, and that these 

operators will continue to submit revised IEEs for the three austral summer seasons this ICR will

be in effect. Updates are likely to include such items as dates of expeditions and changes in 

landing locations. Revisions could address items such as assessment of the potential impacts, 

including cumulative impacts, of modifications to the planned activities and any associated 

mitigation measures, or a reassessment of overall impacts for the expedition. Thus, for 

subsequent seasons, EPA assumes a reduced number of hours would be required for revision of 

the "core" IEE, and the hours for preparation of supplemental information will remain the same. 

The model for estimating respondent hourly burden for a Revised IEE is based on EPA’s 

experience for the ten austral summer seasons the Rule has been in effect and considers the 

paperwork reduction options utilized by the operators. The operator hourly burden for 

preparation of a Revised IEE is estimated as follows:

Prepare "Revised" IEE: 40 hrs/IEE x 3 IEEs = 120hours

Prepare supplemental information: 5 hrs/operator x 3 operators = 15 hours

A/V procedures: 20 hrs/operator x 3 operators = 60 hours

TOTAL HOURS = 195 hours

TOTAL HOURS PER IEE (3 IEEs) = 65 hours

TOTAL HOURS PER OPERATOR (3operators) = 65 hours21

Model 3 - Multi-Year IEE: Under the Final Rule, operators may choose to submit multiyear IEE documentation. Under this model, EPA assumes the operators will submit a Revised 

IEE in the initial year. The multi-year provision then allows operators to supplement the multiyear environmental document without having to revise and re-submit the entire document in 

order to update basic information as necessary, and to provide information on any new activities 

or revisions to the documented activities.

For purposes of demonstrating the full model for a multi-year IEE, EPA assumes nine

multi-year IEEs will be submitted on behalf of 12 operators, and the operator hourly burden for 

preparation of a Multi-Year IEE is estimated as follows:22

 

20If, for example, the Core IEEs cover six operators (e.g., four of the IEEs cover one operator each and one 

of the IEEs covers 2 operators), the cost per operator is reduced from 185 hours to 154 hours.

21If, for example, the three Revised IEEs cover four operators (e.g., two IEEs cover one operator each and 

the other covers two operators), the burden per operator is reduced from 65 hours to 49 hours.

22For purposes of demonstrating the hourly burden for an operator submitting a Multi-Year IEE, EPA 

assumed twelve operators would submit multi-year IEEs during the time covered by this ICR renewal. It is possible 

that two of the operators listed under the Revised IEE model may submit Amulti-year@ rather than revised IEEs. 

However, since the intent of these operators is unknown, EPA assumed these two operators would submit Arevised@

IEEs, an assumption that provides the maximum hours and cost estimates for the three year period of this ICR 
25

Initial Year:

Prepare Revised IEE: 40 hrs/IEE x 9 IEEs = 360 hours

Prepare supplemental information: 5 hrs/operator x 12 ops x 1 year = 60 hours

A/V procedures: 20 hrs/operator x 12 ops x 1 year = 240hours

Four Subsequent Years for a Total of Five Consecutive Years:

Prepare supplemental information: 5 hrs/operator x 12 ops x 4 years = 240 hours

A/V procedures: 20 hrs/operator x 12ops x 4 years = 960 hours

TOTAL HOURS for 5-Year Period of Multi-Year IEE = 1860 hours

TOTAL HOURS PER YEAR (5 Years) PER IEE (9 IEEs) = 42 hours

TOTAL HOURS PER YEAR (5 Years) PER OPERATOR (12 operators) = 31 hours23

3. CEE Model for Respondent Submittals: For CEEs, the estimated hours and cost 

is based on the estimated time to comply with the Final Rule at Section 8.4, preparation of

environmental documents, generally, and Section 8.8, comprehensive environmental evaluation, 

and assumes an increased effort from that required for an IEE. The estimate assumes six (6) 

weeks at 40 hours per week, or 240 hours, including time for revisions in response to EPA's 

comments. The estimate assumes 60 hours to prepare assessment and verification information 

associated with the CEE level of activity and documentation. Further, although one respondent 

per year is estimated for purposes of the cost calculations in Exhibit 1C, EPA anticipates that the 

actual number of nongovernmental expeditions with activities that will likely proceed with more 

than minor or transitory impacts may well be reduced to less than one respondent per year. In 

fact, there were no CEEs submitted during the ten austral summer seasons the Rule has been in 

effect.

4. Emergency Reporting Model: Reporting for Cases of Emergency is based on the 

Final Rule at Section 8.10, Cases of emergency, which requires notice and reporting for activities 

taken in cases of emergency which would have otherwise required the preparation of a CEE. 

The estimate is based on reporting requirements only, not the actual cost of the emergency

response action. The hours and cost estimate assumes one such emergency per 10 years. In fact, 

there were no such incidents during the ten austral summer seasons the Rule has been in effect.

6(b) ESTIMATING RESPONDENT COSTS

(i) ESTIMATING LABOR COSTS

Basis for Cost Estimates: The cost estimates are based on industry labor rates obtained during 

informal consultations with industry representatives and include overhead and fringe benefits. 

The three rates used in the calculations represent the rates provided by the industry 

 

renewal since the hours and costs per operator are more for a Revised IEE than for a Multi-Year IEE.

23 Because the nine Multi-Year IEEs cover twelve operators (e.g., one IEE covers nine operators and the 

other seven cover one operators), the burden per operator is reduced from 36 hours to 34 hours (e.g., the hours for 

the annual supplemental information and A/V procedures) as the initial cost of the Revised IEE is spread among the 

operators.
26

representatives including $65/hour as a low, $75/hour as an intermediate, and $100/hour as a 

high. The $75/hour intermediate rate is used for summary purposes. See Part D for additional 

information on the consultations with affected respondents

Figures 2, 3, 4, 5, and 6 present the estimated Respondent labor cost for drafting the three 

possible levels of environmental documentation (e.g., PERM, IEE, CEE) and associated postexpedition assessment and verification information. 

FIGURE 2. Respondent Labor Costs for PERM Model

Industry 

Representatives Rate Hours Pay Rate/Hour Total Cost

High 40 $100.00 $4.000

Intermediate 40 75.00 3,000

Low 40 65.00 2,600

FIGURE 3. Respondent Labor Costs for IEE “Core” Model

Industry 

Representatives Rate Hours Pay Rate/Hour Total Cost

High 185 $100.00 $18,500

Intermediate 185 75.00 13,875

Low 185 65.00 12,025

FIGURE 4. Respondent Labor Costs for “Revised” IEE Model

Industry 

Representatives Rate Hours Pay Rate/Hour Total Cost

High 65 $100.00 $6,500

Intermediate 65 75.00 4,875

Low 65 65.00 4,225

FIGURE 5. Respondent Labor Costs for “Subsequent Years” IEE Model

Industry 
27

Representatives Rate Hours Pay Rate/Hour Total Cost

High 30 $100.00 $3,000

Intermediate 30 75.00 2,250

Low 30 65.00 1,950

FIGURE 6. Respondent Labor Costs for CEE Model

Industry 

Representatives Rate Hours Pay Rate/Hour Total Cost

High 300 $100.00 $30,000

Intermediate 300 75.00 22,500

Low 300 65.00 19,500

(ii) ESTIMATING CAPITAL AND OPERATIONS AND MAINTENANCE 

COSTS

1. Capital/Start Up Costs: The EPA does not anticipate any capital or start up costs 

on the part of respondents to comply with the provisions of the Final Rule.24

2. O&M Costs: The EPA estimates the following operating and maintenance 

(O&M) costs associated with the paperwork requirements for respondents to comply with 

the provisions of the Final Rule.25 Assumptions and calculations used in EPA's O&M 

estimate for the three levels of environmental documentation are as follows:

 

24One-time capital/start-up costs usually include any produced physical good needed to provide the 

necessary information. Start-up capital must be purchased for the specific purpose of satisfying EPA's reporting or 

recordkeeping requirements. Capital goods include computers, machinery, or equipment. Start-up capital costs are 

usually incurred at the beginning of an information collection period and are usually incurred only once.

25O&M costs are the recurring dollar amount of cost associated with O&M or purchasing services. For 

example, when respondents are required to submit reports or information, O&M costs may include costs for file 

storage, photocopying, and postage.
28

PERMs. The assumptions used for the O&M estimates include:

$ PERMs are estimated to average 25 pages including any supplemental information.

$ One PERM submitted per year by one operator. In fact, during the thirteen austral 

summer seasons the Rule has been in effect, only one PERM has been submitted as the 

final documentation for an expedition.

$ Five copies of each PERM should be submitted.

$ Although not required, the model assumes operators will use express mail to submit 

PERM packages (e.g., original PERM and 5 copies).

$ PERMs do not require assessment/verification procedures.

$ The Final Rule does not require file storage or audits.

The estimated O&M costs for a PERM are calculated as follows:26

(1) Copying: 25 pages/PERM x 5 copies x $0.10/page = $12.50

(2) Mailing: 1 PERM package x $27/package = 27.00

Exhibit 1A incorporates double these estimated O&M costs in the estimated respondent burden 

and costs for PERMs for a three year period27 based on the assumption, for purposes of 

maximum cost calculation, the initial submittal will be revised and resubmitted.

IEEs. The assumptions used for the O&M estimates include:

$ Figure 2 lists the potential respondents.

$ The maximum length for an IEE is 200 pages including supplemental information. 

(See above: IEE Model for Respondent Submittals@)

$ Five copies of each IEE, including supplementary information, should be submitted.

$ Although not required, the model assumes operators will use express mail to submit 

IEE packages (e.g., original IEE and 5 copies).

$ Assessment/verification (A/V) information is estimated as 25 pages per operator.

$ Five copies of each A/V information package may be submitted.

$ Although not required, the model assumes operators will use express mail to submit 

A/V information packages (e.g., original and 5 copies).

$ The Final Rule does not require file storage or audits.

 

26For Exhibits 1 and 2, costs are rounded down to the nearest dollar for $0.01 to $0.49, and rounded up to 

the nearest dollar for $0.50 to $0.99.

27Three years are used in these calculations because that is the period of time the ICR is in effect before it

must be renewed.
29

The estimated O&M costs for the three IEE models are calculated as follows:

Core IEE:

(1) Copying: 200 pages/Core IEE x 5 copies/IEE x $0.10/page = $100.00

 10 pages/Supplemental Info. x 5 copies x $0.10/page = 5.00

 25 pages/ A/V information x 5 copies x $0.10/page = 12.50

(2) Mailing: 1 Core@ IEE package x $27/package = 27.00

 1 Supplemental Information package x $12/package = 12.00

 1 A/V information package x $17/package = 17.00

Revised IEE:

(1) Copying: 200 pages/Revised IEE x 5 copies/IEE x $0.10/page = 100.00

 10 pages/Supplemental Info. x 5 copies x $0.10/page = 5.00

 25 pages/ A/V information x 5 copies x $0.10/page = 12.50

(2) Mailing: 1 Revised@ IEE package x $27/package = 27.00

 1 Supplemental Information package x $12/package = 12.00

 1 A/V information package x $17/package = 17.00

Model Multi-Year IEE:

(1) Copying: 200 pages/Revised IEE x 5 copies/IEE x $0.10/page = $ 100.00

 10 pages/Supplemental Info. x 5 copies x $0.10/page = 5.00

 25 pages/ A/V information x 5 copies x $0.10/page = 12.50

(2) Mailing: 1Revised IEE package x $27/package = 27.00

 1 Supplemental Information package x $12/package = 12.00

 1 A/V information package x $17/package = 17.00

Subsequent Year, Multi-Year IEE:

(1) Copying: 10 pages/Supplemental Info. x 5 copies x $0.10/page = 5.00

 25 pages/ A/V information x 5 copies x $0.10/page = 12.50

(2) Mailing: 1 Supplemental Information package x $12/package = 12.00

 1 A/V information package x $17/package = 17.00

Exhibit 1B, including Table 1B, incorporates the Subsequent Year, Multi-Year IEE estimated 

O&M costs in the estimated respondent hours and costs for IEEs per year. Over the next three 

years, all Multi-Year IEE submissions will follow the Multi-Year Model with a revised 

submission one year and two subsequent years where only supplemental information is filed. To 

calculate the O&M costs over the three year period for the Multi-Year IEEs, the costs of one 

Model Multi-Year and two Subsequent Years Multi-Years are averaged. The costs for the 

Model Multi-Year IEE are listed only to maintain information for purposes of the full Model. 

The O&M costs are doubled for the Core and Revised IEE submittals based on the assumption, 

for purposes of maximum cost calculation, the initial submission will be revised and resubmitted.

Table 3. Summary of the 3-Year Average O&M Costs for a PERM, the Three IEE Models, and a CEE
30

PERM "Core" IEE Revised IEE

Subsequent Year/ 

Multi-Year IEE CEE

Copying: $ 25

Mailing: $ 54

TOTAL $ 79

Copying: $218

Mailing: $ 83

TOTAL $301

Copying: $218

Mailing $83

TOTAL $301

Copying: $ 85

Mailing: $ 47

TOTAL $ 132

Copying: $325

Mailing: $ 81

TOTAL $406

NOTE: The O&M costs for the Multi-Year IEE include the Subsequent Year, Multi-Year IEE costs for 

purposes of this three-year ICR renewal.

CEEs. The assumptions used for the O&M estimates include:

$ CEEs are estimated to average 300 pages including any supplemental information.

$ One CEE submitted per year by one operator. In fact, there were no CEEs submitted during 

the ten austral summer seasons the Rule has been in effect.

$ Five copies of each CEE should be submitted.

$ Although not required, the model assumes operators will use express mail to submit CEE 

packages (e.g., original CEE and 5 copies).

$ Assessment/verification (A/V) information is estimated as 50 pages per operator.

$ Five copies of each A/V information package should be submitted.

$ Although not required, the model assumes operators will use express mail to submit A/V 

information packages (e.g., original and 5 copies).

$ The Final Rule does not require file storage or audits.

$ Mailing charges have been increased to reflect inflation.

The estimated O&M costs for a CEE are calculated as follows:

(1) Copying: 300 pages/CEE x 5 copies x $0.10/page = $150.00

 50 pages/ A/V information x 5 copies x $0.10/page = 25.00

(2) Mailing: 1 CEE package x $32/package = 32.00

 1 A/V information package x $17/package = 17.00

Exhibit 1C incorporates these estimated O&M costs in the estimated respondent hours and cost for CEEs 

for a three year period.28 The O&M costs are doubled for the CEE submission based on the assumption, 

for purposes of maximum cost calculation, the initial submission will be revised and resubmitted.

Reporting for Cases of Emergency. The assumptions used for the O&M estimate include:

$ Emergency Reports are estimated to average 300 pages including supplemental information.

$ The model assumes assessment and verification procedures will be undertaken with 50 pages 

submitted.

$ Five copies of the assessment and verification information should be submitted.

$ Although not required, the model assumes operators will use express mail to submit 

Emergency Reports and assessment and verification information.

 

28Three years are used in these calculations because that is the period of time the ICR is in effect before it 

must be renewed.
31

$ The O&M costs are first calculated to indicate the annual cost assuming one such emergency 

per 10 years. (See: Item 6, above, Emergency Reporting Model)

$ The Final Rule does not require file storage or audits.

$ Mailing charges have been increased to reflect inflation.

(1) Copying:

Emergency Report 300 pages/report x 5 copies x $0.10/page = $150.00

A/V Information 50 pages/package x 5 copies x $0.10/page = 25.00

(2) Mailing:

Emergency Report 1 Emergency Report x $32/report = 32.00

A/V Information 1 A/V package x $17/package = 17.00

O&M for Emergency Reporting in one year = 224.00

Averaged annual Emergency Reporting assuming one emergency per 10 years = 23.00

Exhibit 1D incorporates these estimated O&M costs in the estimated Emergency Response respondent 

hours and costs for years one through three.

(iii) ANNUALIZING CAPITAL COSTS

The EPA does not anticipate any capital or start up costs on the part of respondents to 

comply with the provisions of the Final Rule.29 Therefore, there is no need to annualize capital costs if 

there is not any capital or start up costs.

6(c) ESTIMATING AGENCY BURDEN AND COST: 

Exhibits 2A, 2B (including Table 2), and 2C present the estimated Federal government hours and 

cost for processing and reviewing the three possible levels of environmental documentation (e.g., PERM, 

IEE, CEE) and associated post-expedition assessment and verification information. Exhibit 2D presents 

the estimated Federal government hours and cost for activities associated with reporting for cases of 

emergency, and Exhibit 2E presents the estimated Federal government hours and cost for coordinating the 

review of information received from other Parties.30 The Final Rule does not involve or otherwise impact 

governmental jurisdictions including state, local or tribal governments.

Federal government burden tables were prepared for each type of environmental documentation 

since the effort should increase as an increasing level of environmental documentation is required; e.g., 

from PERM to IEE to CEE. As with the respondents, the model used for the Federal government 

estimates is a nongovernmental, U.S.-based ship-based tour operator, and the estimated hours and cost for 

the Federal government is based on the assumption that most environmental documentation submitted by 

operators will be IEEs.

 

29One-time capital/start-up costs usually include any produced physical good needed to provide the 

necessary information. Start-up capital must be purchased for the specific purpose of satisfying EPA's reporting or 

recordkeeping requirements. Capital goods include computers, machinery, or equipment. Start-up capital costs are 

usually incurred at the beginning of an information collection period and are usually incurred only once.

30There is no respondent burden or cost associated with Section 8.12.
32

The following assumptions were factored into the hourly burden and cost estimates for the 

Federal government:

1. Number of Respondents: The Federal government estimates are consistent with the 

respondent (i.e., operators) estimates with regard to the number of respondents and the projected numbers 

of environmental documents that may be submitted (see: Section 6(a)).

2. Basis for Cost Estimates: The cost estimates are based on consideration of a "model" 

government employee for activities associated with the Final Rule. Two Federal employee "models" 

were developed: (1) “Federal Model 1" is used for costing activities more technical in nature, and (2) 

"Federal Model 2" is used for costing activities that are more administrative.31

"Federal Model 1" - Technical Activities: The skill mix used for technical activities includes 

Managers, Technical Staff (such as scientists, environmental protection specialists, and other such 

technical classifications), Attorneys, and Clerical Support. Relative hours are listed in whole hour 

increments. The development of the cost per hour for "Federal Model 1" is as follows:32

FIGURE 7. Federal Model 1

Job Estimate of Estimated time Pay Rate

Classification Relative Hours Per Hour (Based on GS-Level) Cost/Hour

Manager 2 0.16 $84.02 for GS 15 $13.44

Technical 8 0.68 71.41 for GS 14 48.56

Attorney 1 0.08 71.41 for GS-14 5.71

Clerical 1 0.08 28.65 for GS-07 2.29

 _________ _________ __________

 12 hours 1.00 hour $70.00/hour

"Federal Model 2" - Administrative Activities: The skill mix used for administrative activities 

includes Managers, Technical Staff (such as scientists, environmental protection specialists, and other 

such technical classifications), Attorneys, and Clerical Support. Relative hours are listed in whole hour 

increments. The development of the cost per hour for "Federal Model 2" is as follows:

FIGURE 8. Federal Model 2

 

31See: Exhibits 2A through E, the Federal government estimates for hours and cost. For example, technical 

activities associated with Environmental Documentation include: review of environmental documents, including 

any public comments, and providing comments to the operator; consultation with operators; and review of the 

revised/final document submissions and notification of the operator, if necessary. Other activities listed under 

Environmental Documentation, such as posting document receipt on the WWW, are administrative.

32For the "Technical staff," the model uses the GS-14 level rates, and assumes that the technical staff may 

actually be composed of GS-13 through GS-15 level staff. For the "Attorney," the model uses the GS-14 level rates, 

and assumes that the attorneys may actually be composed of GS-14 and GS-15 level staff. The EPA estimated rates 

used in the calculations are base rates on the GS scale for the Washington, DC, area with a 25% increase to 

incorporate overhead and fringe benefits.
33

Job Estimate of Estimated Pay Rate

Classification Relative Hours Time Per Hour (Based on GS-Level) Cost/Hour

Manager 1 0.20 $84.02 for GS 15 $16.81

Technical 1 0.20 71.41 for GS 14 14.28

Attorney 0 0.00 71.41 for GS-14 0.00

Clerical 3 0.60 28.65 for GS-07 17.19

 __________ _________ __________

 5 hours 1.00 hour $48.28/hour

Based on EPA’s experience for the thirteen austral summer seasons the Rule has been in effect, 

EPA estimates that the administrative costs have been no more than about 2% of the total estimated 

costs for the Federal government. Because this percentage is so low, the Federal government 

costs in Exhibit 2A through 2E are all calculated at the $70/hour rate for technical activities. The 

margin of difference would be as follows:

Amount for technical activities Amount for administrative activities

For $ 1,000 $ 980 $ 20

For $ 5,000 $4,900 $100

For $10,000 $9,800 $200

3. PERM Model for Review of Submissions: For PERMs, the respondent needs to 

comply with the Final Rule at Section 8.4, preparation of environmental documents, generally, 

and Section 8.6, preliminary environmental review. The hourly burden for Federal government 

review of a PERM is estimated to be 25% of the respondent's time to prepare a PERM, or 10 

hours, plus an additional 2 hours for administrative activities. Assessment and verification 

procedures are not required at the PERM level of activity and documentation. Although one 

respondent per year is estimated for purposes of the cost calculations in Exhibit 2A, EPA 

anticipates that the actual number of nongovernmental expeditions with activities that will likely

proceed with less than minor or transitory impacts may well be reduced to less than one 

respondent per year. In fact, only two PERMs has been submitted as the final documentation for 

expeditions during the thirteen austral summer seasons the Rule has been in effect.

4. IEE Model for Review of Submissions: For IEEs, the respondent needs to 

comply with the Rule at Section 8.4, preparation of environmental documents, generally, and 

Section 8.7, initial environmental evaluation. Under the Final Rule (see Figure 1), EPA assumes 

operators would submit IEEs. Operators can choose to submit a Core or Revised or a Multi-Year 

IEE as discussed for the respondents in Section 6(a). Under the Multi-Year IEE model, EPA 

assumes the operators, as applicable, would submit a Revised IEE in the initial year and, for 

purposes of maximum burden estimation, supplemental information for the subsequent four 

years. Over the next three years, all Multi-Year IEE submissions will follow the Multi-Year 

Model with a revised submission one year and two subsequent years where only supplemental 

information is filed. EPA assumes sixteen operators will submit eight multi-year IEEs.33 EPA 

 

33For purposes of demonstrating the hourly burden for an operator submitting a Multi-Year IEE, EPA 
34

has developed a model for Federal government review of the three models for IEEs. A detailed 

discussion of the "Model for Federal Government Review of IEEs" is presented Section 6(c).

5. CEE Model for Review of Submissions: For CEEs, the respondent needs to 

comply with the Rule at Section 8.4, preparation of environmental documents, generally, and 

Section 8.8, comprehensive environmental evaluation. The hourly burden for Federal 

government review of a CEE is estimated to be 50% of the respondent's time to prepare a CEE, 

or 120 hours, plus an additional 15 hours for administrative activities. The hourly burden for 

review of assessment and verification information is estimated to be 50% of the respondent's 

time to prepare the assessment and verification information, or 30 hours. Although one 

respondent per year is estimated for purposes of the cost calculations in Exhibit 2C, EPA 

anticipates that the actual number of nongovernmental expeditions with activities that will likely

proceed with more than minor or transitory impacts may well be reduced to less than one 

respondent per year. In fact, there were no CEEs submitted during the ten austral summer 

seasons the Rule has been in effect.

6. Reviewing Emergency Reports: Reporting for Cases of Emergency is based on 

the Final Rule at Section 8.10, Cases of Emergency, which would require operator notice and 

reporting for activities taken in cases of emergency which would have otherwise required the 

preparation of a CEE. The estimated hourly burden for Federal government review of an 

Emergency Report is estimated to be 50% of the respondent's time to prepare a CEE,34 or 120 

hours, and 50% of the respondent's time to prepare the assessment and verification information 

for an emergency, or 30 hours, for review of this information. An additional 15 hours are 

assumed for notifying the Parties and for administrative activities. As with the respondents, the 

Federal government hours and cost estimate assumes one such emergency per 10 years.

7. Capital/Start Up Costs: The EPA does not anticipate any capital or start up costs 

on the part of the Federal government to comply with the provisions of the Final Rule.

8. O&M Costs: The EPA estimates the following operating and maintenance 

(O&M) costs associated with the paperwork requirements for the Federal government to comply

with the provisions of the Final Rule. Assumptions and calculations used in EPA's O&M 

estimate for the three levels of environmental documentation are as follows:

 

assumed twelve operators will submit nine multi-year IEEs during the time covered by this ICR renewal. It is 

possible that three of the operators listed under the Revised IEE model may submit multi-year rather than revised 

IEEs. However, since the intent of these operators is unknown, EPA assumed these three operators would submit 

revised IEEs, an assumption that provides the maximum hours and cost estimates for the three year period of this 

ICR renewal since the hours and costs per operator are more for a Revised IEE than for a Multi-Year IEE.

34See Final Rule at Section 8.10. Emergency reporting would be required for emergency activities which 

would have otherwise required the preparation of a CEE. The estimate is based on reporting requirements only, not 

the actual cost of the emergency response action. The hours and cost estimate assumes one such emergency per 10 

years. (See: Respondent Assumption 6.)
35

PERMs. The assumptions used for the O&M estimates include:

$ PERMs are estimated to average 25 pages including any supplemental information.

$ One PERM submitted per year by one operator. In fact, during the ten austral summer 

seasons the Rule has been in effect, only one PERM has been submitted as the final 

environmental documentation.

$ Six copies of each PERM are needed for Federal government reviewers.

$ PERMs do not require assessment/verification procedures.

$ File storage and maintenance is estimated at $10 per PERM.

The estimated O&M costs for a PERM are calculated as follows:

(1) Copying: 25 pages/PERM x 6 copies x $0.10/page = $15.00

(2) File Storage: 1 PERM package x $10/package = 10.00

Exhibit 2A incorporates these estimated O&M costs in the estimated Federal government hours 

and costs for PERMs for a three year period.35 The O&M cost for copying is doubled based on 

the assumption, for purposes of maximum cost calculation, that the initial submission will be 

revised and resubmitted for Federal government review.

IEEs. The assumptions used for the O&M estimates include:

$ Figure 2 lists the potential respondents.

$ The maximum length for an IEE is 200 pages including supplemental information. 

(See: Section 6(a)).

$ Six copies of each IEE are needed for Federal government reviewers.

$ Assessment/verification (A/V) information packages are estimated as 25 pages per 

operator.

$ Six copies of each A/V information package are needed for Federal government 

reviewers.

$ File storage and maintenance is estimated at $10 including storage for an IEE package 

and the associated A/V information.

The estimated O&M cost for the three IEE models are calculated as follows:

Core IEE:

(1) Copying: 200 pages/Core IEE x 6 copies/IEE x $0.10/page = $120.00

 10 pages Supplemental Info. x 6 copies x $0.10/page = 6.00

 25 pages/ A/V information x 6 copies x $0.10/page = 15.00

 

35Three years are used in these calculations because that is the period of time the ICR is in effect before it 

must be renewed.
36

(2) File Storage: 1 IEE package x $10/package = 10.00

Revised IEE:

(1) Copying: 200 pages/Revised IEE x 6 copies/IEE x $0.10/page = $120.00

 10 pages Supplemental Info. x 6 copies x $0.10/page = 6.00

 25 pages/ A/V information x 6 copies x $0.10/page = 15.00

(2) File Storage: 1 IEE package x $10/package = 10.00

Subsequent Year, Multi-Year IEE:

(1) 10 pages Supplemental Info. x 6 copies x $0.10/page = 6.00

 25 pages/ A/V information x 6 copies x $0.10/page = 15.00

(2) File Storage: 1 IEE package x $10/package = 10.00

Exhibit 2B, including Table 2B, incorporates these estimated O&M costs in the estimated 

Federal government hours and costs for IEEs per year for a following three-year period based as 

summarized in Table 4.36 Over the next three years, all Multi-Year IEE submissions will require 

a revised submission one year and two subsequent years where only supplemental information is 

filed. To calculate the O&M costs over the three year period for the Multi-Year IEEs, the costs 

of one Model Multi-Year and two Subsequent Years Multi-Years are averaged. The O&M costs 

for copying the core and revised IEE submissions are doubled based on the assumption, for 

purposes of maximum cost calculation, the initial submission will be revised and resubmitted for 

Federal government review.

Table 4. Summary of the 3-Year Average O&M Costs for a PERM, the Three IEE Models, and a CEE

PERM Core IEE Revised IEE

Subsequent Year, 

Multi-Year IEE CEE

Copying: $ 30

File

Storage: $ 10

TOTAL $ 40

Copying: $261

File

Storage: $ 10

TOTAL $271

Copying: $261

File

Storage : $ 10

TOTAL $271

Copying: $ 101

File

Storage: $ 10

TOTAL $ 111

Copying: $1740

File

Storage: $ 10

FedReg: $ 326

TOTAL $2076

CEEs. The assumptions used for the O&M estimates include:

$ A Federal Register Notice of Availability must be published for receipt of each draft 

and final CEE; publication costs are estimated at $163 per column and two columns are 

assumed to be needed.

$ CEEs are estimated to average 300 pages including any supplemental information.

 

36Three years are used in these calculations because that is the period of time the ICR is in effect before it 

must be renewed.
37

$ One CEE submitted per year by one operator. In fact, during the ten austral summer 

seasons the Rule has been in effect, no CEEs were submitted.

$ Six copies of each CEE are needed for Federal government reviewers.

$ Forty-five copies of each CEE are needed for distribution to Parties and the Committee 

for Environmental Protection.

$ Assessment/verification (A/V) information is estimated as 50 pages per operator.

$ Six copies of each A/V information package is needed for Federal government 

reviewers.

$ File storage and maintenance is estimated at $10 including storage for a CEE package 

and associated A/V information.

$ Federal Register publication charges have been increased to reflect inflation.

The estimated O&M costs for a CEE are calculated as follows:

(1) Copying: 300 pages/CEE x 6 copies x $0.10/page = $ 180.00

300 pages/CEE x 45 copies x $0.10/page = 1,350.00

 50 pages/ A/V information x 6 copies x $0.10/page = 30.00

(2) FR Publication: 1 CEE x $163/column x 2 columns = 326.00

(3) File Storage: 1 CEE package x $10/package = 10.00

Exhibit 2C incorporates these estimated O&M costs in the estimated Federal government hours 

and costs for CEEs for a three year period.37 The O&M cost for copying is doubled based on the 

assumption, for purposes of maximum cost calculation, that the initial submittal will be revised 

and resubmitted for Federal government review and that both the draft and final CEEs will also 

be provided to the Parties.

Reporting for Cases of Emergency. The assumptions used for the O&M estimates 

include:

$ Emergency Reports are estimated to average 300 pages including supplemental 

information.

$ Six copies of each report are needed for Federal government reviewers.

$ Forty-five copies of each report are needed for distribution to Parties and the 

Committee for Environmental Protection.

$ Assessment/verification (A/V) information is estimated as 50 pages per incident.

$ Six copies of each A/V information package needed for Federal government 

reviewers.

$ The O&M costs are first calculated to indicate the annual cost assuming one such 

emergency per 10 years.

 

37Three years are used in these calculations because that is the period of time the ICR is in effect before it 

must be renewed.
38

$ File storage and maintenance is estimated at $10 including storage for the emergency

report package and associated A/V information.

(1) Copying: 300 pages/report x 6 copies x $0.10/page = $ 180.00

300 pages/report x 45 copies x $0.10/page = 1,350.00

50 pages/ A/V information x 6 copies x $0.10/page = 30.00

(2) Store File: 1 report package x $10/package = 10.00

Exhibit 2D incorporates these estimated O&M costs in the estimated Federal government hours 

and costs for emergency reports for a three year period.38

9. Coordinating Review of Other Parties' Documents: In accordance with the Final 

Rule at Section 8.12, the Department of State would be responsible for the coordination of the 

review of documents received from other Parties. There is no respondent burden associated with 

Section 8.12. Exhibit 2E provides the Federal government hourly burden and cost estimate 

based on Employee Model 1 and the O&M assumptions and estimates below. It is not possible 

to predict what may be received from another Party in any given year, and since there is no 

respondent burden associated with Section 8.12, hours and costs for a three year period are not 

provided beyond those estimates listed in Exhibit 2E.39

The assumptions used for the O&M estimates include:

$ A Federal Register Notice of Availability must be published for receipt of each draft 

CEE; publication costs are estimated at $163 per column and two columns are assumed to 

be needed.

$ Draft and Final CEEs received from other Parties are estimated to average 300 pages 

including supplemental information.

$ Other documents (e.g., description of national procedures, significant monitoring 

information) received from other Parties are estimated to average 50 pages.

$ Annual lists of IEEs are estimated to average 10 pages.

$ Six copies of each document are needed for Federal government reviewers and four 

copies for the public.

$ File storage and maintenance is estimated at $10 including storage for the sum total of 

any such documents received.

(1) Copying: 300 pages/draft CEE x 10 copies x $0.10/page = $300.00

300 pages/final CEE x 10 copies x $0.10/page = 300.00

 50 pages/other x 10 copies x $0.10/page = 50.00

 

38Three years are used in these calculations because that is the period of time the ICR is in effect before it 

must be renewed.

39Three years are used in these calculations because that is the period of time the ICR is in effect before it 

must be renewed.
39

 10 pages/IEE list x 10 copies x $0.10/page = 10.00

(2) FR Pub: 1 CEE x $163/column x 2 columns = 326.00

(3) Store File: 1 set of reports from Parties x $10/set = 10.00

As noted in the assumptions above for both the respondents and the Federal government, 

EPA assumes that most environmental documentation submitted under the Final Rule will be 

IEEs. Based on experience during the thirteen austral summer seasons the Rule has been in 

effect, and the assumption that operators will continue to employ the paperwork reduction 

provisions in the Final Rule, including the provision for multi-year documentation, EPA has 

developed a model for Federal government review of IEEs based on three types of IEE 

documentation: (1) "Core" IEE, (2) "Revised" IEE, and (3) "Multi-Year" IEE.

The hourly estimates for activities associated with Environmental Documentation in 

Exhibit 2B are based on experience during the thirteen austral summer seasons the Rule has been 

in effect and the anticipated degree of consultation with other interested Federal agencies. The 

calculations include the estimated technical review time for the three IEE models, the estimated 

technical hours per Federal review, and the Federal agencies participating in the review process 

and their relative level of participation.

1. Estimated Hours for Technical Review of an IEE: This estimate includes the 

following assumptions consistent with those in the respondents' estimated burden (Section 6(a)) 

and consideration of the experience under the ten austral summer seasons the Rule has been in 

effect:

$ Section 6(a), including Figure 2, lists the potential respondents.

$ The maximum length for an IEE is about 200 pages including supplemental 

information.

$ An IEE consists of "core" information with supplemental expedition-specific (e.g., 

dates, landing sites, number of tours, etc.) or other project-specific information attached 

or referenced.

$ The core information requires a "Core IEE" review, and certain of the supplemental 

information not considered to be part of the "core" document (e.g., supplemental 

expedition-specific information for individual tour operators), requires a "Supplemental 

Information" review. A "Core IEE" review is estimated to be 50% of the respondent's 

time to prepare a "core" IEE, or 80 hours, and a "Supplemental Information" review is 

estimated to be 25% of the respondent's time to prepare the information, or about 1 hour 

per supplemental package of information not considered to be part of the "core" 

document. Review time for supplemental information considered to be part of the "Core 

IEE" and included by reference is included in the review time for the "Core IEE."
40

$ The time to review a "Revised IEE" is estimated to be 25% of the respondent's time to 

prepare a "core" IEE, or 40 hours, and a "Supplemental Information" review to take 1 

hour per supplemental package of information not considered to be part of the "revised" 

document.

$ Operators may employ the multi-year provision whereby multi-year IEE 

documentation will be submitted. The multi-year provision also allows operators to 

update basic information and to provide information on additional activities to 

supplement the multi-year environmental document without having to revise and resubmit the entire document. Review of the initial multi-year document is assumed to be 

the same as review of a Revised IEE, e.g., 40 hours for the Revised IEE and, for purposes 

of maximum burden estimation, 1 hour for supplemental information. For the subsequent 

four years, the annual advance notice and confirmation that the conditions of the multiyear document are unchanged is estimated to take 10 hours per IEE.

$ The IEE level of documentation requires assessment and verification (A/V) 

procedures. The hourly burden for review of A/V information is estimated to be 75% of 

the respondent's time to prepare the A/V information, or 15 hours per information 

package.

$ For an IEE that covers multiple operators, the hours and costs per operator for reviews 

are spread among the total number of operators; e.g., the more operators under one 

document, the lower the hours and costs for each review on a per operator basis.40

IEE Model 1 - Core IEE: The following estimate is based on EPA’s experience for the 

thirteen austral summer seasons the Rule has been in effect and considers the paperwork 

reduction options utilized by the operators. EPA anticipates three one-time core IEEs will be 

prepared for the three austral summer seasons this ICR renewal will be in effect. The Federal 

government hourly burden for preparation of a Core IEE is estimated as follows:

Review "core" IEE 80 hrs/IEE x 3IEEs = 240 hours

Review supplemental information 1 hr/review x 3 operators = 3hours

Review of A/V information 15 hrs/A/V pkg x 3 operators = 45 hours

TOTAL HOURS = 288 hours

TOTAL HOURS PER IEE (5 IEEs) = 96 hours

TOTAL HOURS PER OPERATOR (5 operators) = 96 hrs41

IEE Model 2 - Revised IEE: For purposes of maximum burden assessment, EPA 

assumes that three present ship-based tour operators will remain the same, and that these 

operators will continue to submit revised IEEs for the three austral summer seasons this ICR will 

be in effect. Updates are likely to include such items as dates of expeditions and changes in 

 

40For an IEE that covers multiple operators, the cost per review per operator is further reduced; specific 

examples are listed as a footnote for each model calculation.

41If, for example, the ACore@ IEEs cover six operators (e.g., four of the IEEs cover one operator each and 

one of the IEEs covers 2 operators), the cost per operator is reduced from 96 hours to 80 hours.
41

landing locations. Revisions could address items such as assessment of the potential impacts, 

including cumulative impacts, of modifications to the planned activities and any associated 

mitigation measures, or a reassessment of overall impacts for the expedition. Thus, for 

subsequent seasons, EPA estimates the government review time to be 25% of the respondent's 

time to prepare a "core" IEE, or 40 hours, and the hours for review of supplemental information 

will remain the same.42 The model for estimating respondent hourly burden for a ARevised@

IEE is based on EPA=s experience under the Rule and considers the paperwork reduction 

options employed by the operators. The operator hourly burden for preparation of a ARevised@

IEE is estimated as follows:

Review "revised" IEE 40 hrs/IEE x 3 IEEs = 120 hours

Review supplemental information 1 hr/review x 3 operators = 3 hours

Review of A/V information 15 hrs/A/V pkg x 3 operators = 45 hours

TOTAL HOURS = 168 hours

TOTAL HOURS PER IEE (3 IEEs) = 56 hours

TOTAL HOURS PER OPERATOR (3 operators) = 56 hrs43

Model 3 - Multi-Year IEE: Under the Final Rule, operators may also choose to submit 

multi-year IEE documentation. Under this model, EPA assumes the operators will submit a 

Revised IEE in the initial year. The multi-year provision then allows operators to supplement the 

multi-year environmental document without having to revise and re-submit the entire document 

in order to update basis information as necessary, and to provide information on any new 

activities or revisions to the documented activities.

EPA assumes twelve operators may submit "multi-year" IEEs, and the Federal 

government hourly burden for review of the "Multi-Year" IEE will require review at the Revised 

IEE level of review (e.g., 40 hours) and 1 hour for supplemental information. Review also 

includes 15 hours for A/V information. In subsequent years, for purposes of maximum burden 

estimation, 2 hours per IEE is estimated for review of supplemental information and 15 hours for 

A/V information. The Federal government hourly burden is estimated as follows for review of 

"Multi-Year" IEEs:44

 

42If a new IEE is submitted by another U.S.-based operator, the hourly burden estimate for this IEE is the 

same as for an initially prepared "core" IEE.

43If, for example, the Revised IEEs cover four operators (e.g., two of the IEEs cover one operator each and 

one of the IEEs covers 2 operators), the cost per operator is reduced from 56 hours to 42 hours per review per 

operator.

44For purposes of demonstrating the hourly burden for an operator submitting a Multi-Year IEE, EPA 

assumed twelve operators would submit nine multi-year IEEs during the time covered by this ICR renewal. It is 

possible that the three operators listed under the Revised IEE model may submit multi-year rather than revised IEEs. 

However, since the intent of these operators is unknown, EPA assumed these three operators would submit revised 

IEEs, an assumption that provides the maximum hours and cost estimates for the three year period of this ICR 

renewal since the hours and costs per operator are more for a Revised IEE than for a Multi-Year IEE.
42

Initial Year:

Review Revised IEE: 40 hrs/IEE x 9 IEEs x 1 yr = 360 hours

Review supplemental information: 1 hr/operator x 12 ops x 1 year = 12 hours

Review A/V information: 15 hrs/operator x 12 ops x 1 year = 180 hours

Four Subsequent Years for a Total of Five Consecutive Years:

Review supplemental information: 1 hr/operator x 12 ops x 4 years = 48 hours

Review A/V information: 15 hrs/operator x 12 ops x 4 years = 720 hours

TOTAL HOURS for 5-Year Period of Multi-Year IEE = 1320 hours

TOTAL HOURS PER YEAR (5 Years) PER IEE 9 IEEs) = 29 hours

TOTAL HOURS PER YEAR (5 Years) PER OPERATOR (12 operators) = 22 hours45

2. Estimated Technical Hours by Federal Agency for Review of an IEE: EPA has used 

and would continue to use a "Principal Reviewer/Associate Reviewer" process to review 

environmental documentation submitted by operators. OFA would serve as the Principal 

Reviewer. Associate Reviewers may include representatives from program offices within EPA 

and other Federal agencies with an interest in Antarctica. The interested Federal agencies are 

listed in Section 5(a). Based on experience during the ten austral summer seasons the Rule has 

been in effect and the anticipated consultation needs under the Final Rule, the following 

calculations spread amongst the Federal agencies the 96 total hours per ACore@ IEE review, the 

56 total hours per ARevised@ IEE review, and the 16 total hours per ASubsequent Year, MultiYear IEE.

Core IEEs Revised IEEs Subseq.Yrs, Multi-Year IEEs

Federal

Agency

Relative

Time/Hr

x 96

Hrs Hrs

Relative 

Time/Hr

x 56

Hrs Hrs

Relative

Time/Hr

x 40

Hrs Hrs

EPA

NSF

DOS

Others

0.49

0.35

0.15

0.01

x 96 

x 96 

x 96 

x 96

47

34

14

 1

0.50

0.35

0.15

0.00

x 56

x 56

x 56

x 56

28

20

8

0

 0.50

 0.40

 0.10

 0.00

x 40

x 40

x 40

x 40

20

16

4

0

Totals 1.00 96 1.00 56 1.00 40

Others may include: USCG, NOAA, MMC and DOJ

The model further assumes that 2/3 of the time for review of each document applies to the draft 

IEE, and 1/3 of the time to the final IEE:

"Subsequent Years,

 

45Because the nine Multi-Year IEEs cover twelve operators (e.g., one IEE covers one operator and the 

other covers two operators), the hours per operator is reduced from 24 hours to 20 hours (e.g., the hours for review 

of the annual supplemental information and A/V information) as the initial review cost of the Revised IEE is spread 

among the operators.
43

 Core IEEs Revised IEE Multi-Year IEE

Review Hours per Draft 64 37 27

Review Hours per Final 32 19 13

Total Hours 96 56 40

The hours are then spread amongst the Federal agencies as follows:

 Core IEE Revised IEE Subseq.Yrs, Multi-Year IEE

 Draft Final Draft Final Draft Final

EPA

NSF

DOS

Others

.49

.35

.15

.01

31

22

10

 1

16

11

 5

 0

.50

.35

.15

.00

18

13

 6

 0

10

 7

 2

 0

.50

.35

.15

.00

13

11

3

0

6

6

1

0

Totals 64 32 37 19 27 13

In Exhibits 2A through 2E for the "Estimated Federal Government Hours and Cost," the 

total hours listed for the Government hours/year are assumed to include the spread of hours 

across the Federal agencies as calculated above. The costs in Exhibits 2A through 2E are 

calculated at the $65/hour rate for technical activities as discussed in Section 6(b), item 2.

6(d) ESTIMATING RESPONDENT UNIVERSE AND TOTAL BURDEN AND 

COSTS:

Number of Respondents: Based on EPA=s experience during the thirteen austral summer 

seasons the Rule has been in effect (see Figure 1), for purposes of this ICR renewal, the total 

number of respondents is estimated as eighteen as delineated in Figure 9. This estimate includes 

15 repeat operators who are expected to submit new or revised or multi-year IEE documentation, 

and three new operators who are expected to submit new IEEs.

FIGURE 9. Estimated Respondents and Anticipated Level of EIA Documentation 

Considering EPA=s Experience Under the Rule

Operators Number of Operators

U.S.-based IAATO-member tour operators 11 Peninsular Area

U.S.-based IAATO-member tour operators 1 Ross Sea Area

U.S.-based IAATO-member tour operators 1 Continental Area

U.S.-based non-IAATO member tour operators 0 Peninsular Area

U.S.-based privately funded researcher 2

U.S.-based possible new respondents 3

TOTAL ESTIMATED 18
44

Exhibit 3 is the summary of the estimated hours and costs for respondents and the Federal 

government. This summary compiles the totals for the respondents (Exhibits 1A, 1B including 

Table 1, 1C, and 1D) and Federal government (Exhibits 2A, 2B including Table 2, 2C, and 2D) 

for each level of environmental documentation.46 Chart 2 in Exhibit 3 further summarizes for 

respondents and the Federal government the hours and costs for the most likely documentation 

scenario for the 3-year life of this ICR renewal, namely, a "Multi-Year" IEE which includes for 

the initial year a "Revised" IEE and "Subsequent Year, Multi-Year" IEE documentation for the 

two subsequent years. Exhibit 3 is annualized over a three year period by assuming a 3.5% 

escalation rate per year, the assumed Consumer Price Index (CPI) escalation rate.47

Based on the reporting by operators for the thirteen austral summer seasons during the 

time the Rule has been in effect under an OMB-approved ICR and EPA's understanding of the 

types of nongovernmental activities likely to continue to be undertaken by U.S.-based operators 

in Antarctica, EPA anticipates that the most likely scenario during the three-year renewal period 

this information collection will be in effect consists of the following:

$ Eighteen operators will likely plan expeditions to Antarctica and will submit 

environmental documentation including assessment and verification information. 

Thirteen will likely be repeat operators with annual expeditions, and five operators may

submit new documentation. These three may include new operators planning annual 

expeditions and operators of one-time only expeditions.

$ Three of the 15 repeat operators with annual expeditions will submit revised IEEs.

$ It was assumed that 12 of the 15 repeat operators would submit new Multi-Year IEEs, 

including a "Revised" IEE in the initial year and "Subsequent Year, Multi-Year" IEE 

documentation for the two subsequent years.

$ No CEEs have been submitted as the final documentation during the past thirteen 

austral seasons and only two PERMs has been submitted during this time-frame. No 

CEEs or PERMs are anticipated during the effective period for this ICR renewal.

$ There were no emergencies requiring emergency reporting during the ten austral 

summer seasons the Rule has been in effect, and none are expected to occur during the 

effective period for this ICR renewal.

$ Other than receipt of the annual list of IEEs, there is no way to anticipate receipt of 

environmental documents from the Parties on an annual basis or during the effective 

period for this ICR renewal. There is no burden to the respondents associated with 

receipt of documents from the Parties. Therefore, there are no burden estimates 

associated with coordinating review of information received from other Parties included 

in the burden summary.

 

46Exhibit 2E summarizes the Federal government hours and cost for coordinating review of information 

received from other Parties and is not further summarized since it is not possible to predict what may be received 

from another Party in any given year, and there is no associated respondent hours or costs.

47Three years are used in these calculations because that is the period of time the ICR is in effect before it 

must be renewed.
45

$ The Consumer Price Index (CPI) is estimated to be 3.5% for the subsequent years and 

is incorporated into the cost calculations for these years.

Based on the above assumptions, Chart 3 in Exhibit 3 summarizes the estimated hours 

and costs for the respondents and the Federal government for the 3-year period of this ICR 

renewal. This summary assumes 18 operators per year with 3 new operators and 15 repeat 

operators each year. For the 15 repeat operators, the assumptions are that three will prepare 

"Revised" IEEs and 12 will prepare "Multi-Year" IEEs.

As summarized in Chart 3, for the estimated 18 operators submitting environmental 

documentation under the Final Rule during this ICR renewal period, the annual total hours for 

the 18 operators is estimated to be 1,254 hours, and the annual total hourly burden per operator is 

estimated to be 70 hours. These annual totals reflect submission of different levels of 

documentation by the 18 operators. The estimated annual average time per respondent ranges 

from 42 to 185 hours depending on the level of environmental documentation and the paperwork 

reduction provisions employed by the respondent. 

As summarized in Chart 3, for the estimated 18 operators submitting environmental 

documentation under the Final Rule during this ICR renewal period, the annual total cost for the 

18 operators is estimated to be $100,575, and the annual total cost burden per operator is 

estimated to be $5,588. These annual totals reflect submission of different levels of 

documentation by the 18 operators. The estimated annual average per respondent ranges from 

$3,372 to $14,678 depending on the level of environmental documentation and the paperwork 

reduction provisions employed by the respondent.

As summarized in Chart 3, for the estimated 18 operators submitting environmental 

documentation under the Final Rule during this ICR renewal period, the annual total hours and 

cost for the Federal government is estimated as 804 hours and $61,515. The annual total hours 

and cost per operator for the Federal government is estimated as 45 hours and $3,418. These 

annual totals reflect submission of different levels of documentation by the 18 operators. The 

estimated annual average hours and cost per respondent ranges from 29 hours and $2,224 to 96 

hours and $7,254 depending on the level of environmental documentation and the paperwork 

reduction provisions employed by the respondent.

Exhibit 4 summarizes the Respondent and Agency estimated O&M costs as well as an 

O&M breakout within the total cost burden. 

6(e) BOTTOM LINE BURDEN HOURS AND COST TABLES: 

(i) RESPONDENT TALLY

 TOTAL ESTIMATED RESPONDENT BURDEN AND COST SUMMARY

Number of Total Hours Per Total Labor Cost Total Annual 
46

Respondents Year Per Year O&M Costs

“Core” 3 555 $43,131 $903

“Revised” 3 195 $15,174 $903

“Multi-Year” 12 504 $38,880 $1,584

Total 18 1,254 $97,185 $3,390

(ii) THE AGENCY TALLY

TOTAL ESTIMATED AGENCY BURDEN AND COST SUMMARY

Number of 

Respondents

Total Hours Per 

Year

Total Labor Cost 

Per Year

Total Annual 

O&M Costs

“Core” 3 288 $20,949 $813

“Revised” 3 168 $12,252 $813

“Multi-Year” 12 348 $25,356 $1,332

Total 18 804 $58,557 $2,958

(iii) VARIATIONS IN THE BOTTOM LINE

There is no anticipation of significant variation (>25%) in the annual respondent 

reporting/recordkeeping burden or cost over the course of the clearance period request. 

6(f) REASONS FOR CHANGE IN BURDEN

The current inventory approved by the Office of Management and Budget (OMB) for the 

annual reporting and recordkeeping hourly burden is 1,708 hours. The total 3-year estimated 

hourly burden of 3,762 hours for the anticipated 18 operators represents an annual reporting and 

recordkeeping hourly burden of 1,254 hours, or 70 hours per operator for this 3-year renewal 

period. This decreased adjustment to the annual reporting and recordkeeping hourly burden is 

454 hours. This decreased adjustment is the result of a change to the level of environmental 

documentation EPA anticipates the operators will submit.

 6(g) BURDEN STATEMENT

Burden Statement: The annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 1,254 hours annually, or 70 hours per response. This hourly 

burden reflects annual submission of different levels of environmental documentation by an 

anticipated 18 respondents (e.g., U.S.-based nongovernmental operators). 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 

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 
47

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. 

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-OECA-2007-0468, which is available for online viewing at 

www.regulations.gov, or in person viewing at the Enforcement and Compliance Docket and 

Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 

Constitution Avenue, NW, Washington, D.C. The EPA Docket Center 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 Reading Room is (202) 566-1744, and the telephone number for the 

Enforcement and Compliance Docket and Information Center is (202) 564-1752. An electronic 

version of the public docket is available at www.regulations.gov. This site can be used to submit 

or view public comments, access the index listing of the contents of the public docket, and to 

access those documents in the public docket that are available electronically. When in the 

system, select “search,” then key in the Docket ID Number identified above. Also, you can send 

comments to the Office of Information and Regulatory Affairs, Office of Management and 

Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please 

include the EPA Docket ID Number EPA-HQ-OECA-2007-0468 and OMB Control Number 

2020-0007 in any correspondence.
48

Exhibit 1A: PERMs - ESTIMATED RESPONDENT HOURS AND COST

 Respondent Respondent Rate Range Capital/ O & M No. of Totals for Respondent Rate Range

ICR Activity: PERMs Hrs/Yr $65/hour $75/hour $100/hour Startup Cost Cost Respondents $65/hour $75/hour $100/hour

Environmental Documentation

1. Study the regulations

2. Search reference sources for existing 

information and compile information from 

company records

3. Prepare PERM and submit

4. Revise PERM in response to EPA's 

comments and submit

Post-Expedition Assessment & Verification

1. Prepare A/V information and submit - 

NOT REQUIRED FOR PERMs

40 $ 2,600 $ 3,000 $ 4,000 Env. Doc.

None

Post-Exp. A/V

None

Env. Doc.

Copying $ 25

Mailing 54

__________

 $ 79

Post-Exp. A/V

Copying $ 0

Mailing 0

____________

 $ 0

 $ 79

 1 $ 2,679 $ 3,079 $ 4,079

Totals for Respondent Rate Range Hours $65/hour $75/hour $100/hour

YEAR ONE 40 $ 2,679 $ 3,079 $ 4,079

YEAR TWO (3.5% estimated CPI escalation rate) 40 2,773 3,187 4,222

YEAR THREE (3.5% estimated CPI escalation rate) 40 2,870 3,298 4,370

TOTAL ESTIMATED POTENTIAL HOURS and COST: 120 $ 8,322 $ 9,564 $12,671

AVERAGE EST. HOURS and COST PER YEAR PER OPERATOR: 40 $ 2,774 $ 3,188 $ 4,224

Assumptions:

1. Exhibit 1A represents the estimated hours and cost for PERMs. In fact, during the thirteen austral summer seasons the Rule has been in effect, only two PERMs were submitted as the final documentation for an 

expedition. For purposes of estimating the potential maximum hours and cost associated with PERMs over the three-year life of the ICR, the three-year projection assumes submission of one PERM per year for each of the 

next three years. Although one respondent per year is estimated for purposes of the burden calculations, EPA anticipates that the actual number of nongovernmental expeditions with activities that will likely proceed with less 

than minor or transitory impacts may well be reduced to less than one respondent per year.

2. Estimates for preparation of a PERM are based on estimated time that would be needed to comply with the Rule at Section 8.4, preparation of environmental documents, generally, and Section 8.6, preliminary 

environmental review.

3. The cost estimates are based on industry labor rates obtained during informal consultations with industry representatives and include overhead and fringe benefits. The three rates used in the calculations represent the rates 

provided by the industry representatives. The $75/hour intermediate rate is used for summary purposes. See Part D for additional information on the consultations with affected respondents.

4. Hours and cost associated with preparation of higher level EIA documentation, if necessary, is addressed in Exhibits 1B (IEEs) and 1C (CEEs).
49

Exhibit 1B: IEEs - ESTIMATED RESPONDENT HOURS AND COST

 Respondent Respondent Rate Range Capitol/ O & M No. of Totals for Respondent Rate Range

ICR Activity: IEEs Hrs/Yr $65/hour $75/hour $100/hour Startup Cost Cost Respondents $65/hour $75/hour $100/hour

MODEL 1: "Core" IEE

Environmental Documentation

1. Study the regulations

2. Search reference sources 

for existing information and 

compile information from 

company records

3. Prepare Core IEE and 

submit

4. Revise in response to 

EPA's comments and submit

Supplemental Information

1. Prepare and submit 

supplemental information

Post-Expedition Assessment 

& Verification

1. Prepare A/V information 

and submit 

185 $ 12,025 $ 13,875 $ 18,500 Env.Doc.

None

Supp.Info.

None

Post-Exp. A/V

None

Env.Doc.

Copying $ 200

Mailing 54

___________

 $ 254

Supp.Info.

Copying $ 5

Mailing 12

___________

 $ 17

Post-Exp. A/V

Copying $ 13

Mailing 17

___________

 $ 30

$ 301

See Table 1 $ 12,326 $ 14,176 $ 18,801

Assumptions for IEEs:

1. IEEs would need to comply with the Rule at Section 8.4, preparation of environmental documents, generally, and Section 8.7, initial environmental evaluation.

2. A "Core" IEE and associated supplemental information comprises the IEE package for the initial preparation of an IEE by an operator.

3. A "Revised" IEE and associated supplemental information comprises the IEE package for a current year's submission developed through revision of a previous year's submission.

4. A Multi-Year IEE consists of a ARevised@ IEE and the associated supplemental information in the initial year and, for each of the subsequent four years, an annual submission of the advance notice and confirmation that 

the information provided in the Multi-Year IEE is unchanged.

5. Supplemental information for purposes of the costs estimated in Exhibit 1B and Table 1 refers to supplemental information submitted regarding the specifics of the tours/expedition (e.g., dates, number of tours, etc.) rather 

than supplemental information of a more technical nature that is incorporated into the "Core" or "Revised" IEE by reference.

6. The cost estimates are based on industry labor rates obtained during informal consultations with industry representatives and include overhead and fringe benefits. The three rates used in the calculations represent the rates 

provided by the industry representatives. The $75/hour intermediate rate is used for summary purposes. See Part D for additional information on the consultations with affected respondents.
50

 Respondent Respondent Rate Range Capitol/ O & M No. of Totals for Respondent Rate Range

ICR Activity: IEEs Hrs/Yr $65/hour $75/hour $100/hour Startup Cost Cost Respondents $65/hour $75/hour $100/hour

MODEL 2: "Revised" IEE

Environmental Documentation

1. Study the regulations

2. Search reference sources for 

existing information and 

compile information from 

company records

3. Prepare Revised IEE and 

submit

4. Revise in response to EPA's 

comments and submit

Supplemental Information

1. Prepare and submit 

supplemental information

Post-Expedition Assessment & 

Verification

1. Prepare A/V information 

and submit 

 65 $ 4,225 $ 4,875 $ 6,500 Env.Doc.

None

Supp.Info.

None

Post-Exp. A/V

None

Env.Doc.

Copying $ 200

Mailing 54

___________

 $ 254

Supp.Info.

Copying $ 5

Mailing 12

____________

 $ 17

Post-Exp. A/V

Copying $ 13

Mailing 17

____________

 $ 30

$ 301

See Table 1 $ 4,526 $ 5,176 $ 6,801

 Respondent Respondent Rate Range Capitol/ O & M No. of Totals for Respondent Rate Range

ICR Activity: IEEs Hrs/Yr $65/hour $75/hour $100/hour Startup Cost Cost Respondents $65/hour $75/hour $100/hour

"Subsequent Years" for Multi-Year 

IEE under MODEL 3

Supplemental Information

1. Prepare and submit supplemental 

information

Post-Expedition Assessment & 

Verification

 30 $ 1,950 $ 2,250 $ 3,000 Supp.Info.

None

Post-Exp. A/V

None

Supp.Info.

Copying $ 5

Mailing 12

____________

 $ 17

Post-Exp. A/V

Copying $ 13

Mailing 17

$30

See Table 1 $ 1,987 $ 2,297 $ 3,047
51

1. Prepare A/V information and 

submit 

$ 47

TABLE 1. IEEs - TOTAL ESTIMATED HOURS AND COST FOR THE THREE IEE MODELS WITH 3.5% ESCALATION RATE

Core IEE for One Operator and One IEE

 Totals for Respondent Rate Range

Hours $65/hour $75/hour $100/hour

YEAR ONE 185 $ 12,326 $ 14,176 $ 18,801

YEAR TWO (3.5% estimated CPI escalation rate) 185 12,757 14,672 19,459

YEAR THREE (3.5% estimated CPI escalation rate) 185 13,203 15,186 20,140

TOTAL ESTIMATED POTENTIAL HOURS and COST: 555 $ 38,286 $ 44,034 $ 58,400

AVERAGE EST. HOURS and COST PER YEAR PER OPERATOR: 185 $ 12,762 $ 14,678 $ 19,467

Revised IEE for One Operator and One IEE

 Totals for Respondent Rate Range

Hours $65/hour $75/hour $100/hour

YEAR ONE 65 $ 4,526 $ 5,176 $ 6,801

YEAR TWO (3.5% estimated CPI escalation rate) 65 4,684 5,357 7,039

YEAR THREE (3.5% estimated CPI escalation rate) 65 4,848 5,544 7,285

TOTAL ESTIMATED POTENTIAL HOURS and COST: 195 $ 14,058 $16,077 $ 21,125

AVERAGE EST. HOURS and COST PER YEAR PER OPERATOR: 65 $ 4,686 $ 5,359 $ 7,042

"Multi-Year" IEE for One Operator and One IEE - A Multi-Year IEE consists of a Revised IEE and, for each of the subsequent four years, an annual submission of the advance 

notice and confirmation that the information provided in the Multi-Year IEE is unchanged. See above for the hours and cost per operator for the "Revised" IEE for the initial year. 

The hours and cost per operator for the subsequent years follows for which hours and cost are calculated for "Subsequent Year Multi-Year" IEE submissions.

“Subsequent Year Multi-Year” IEE for One Operator

 Totals for Respondent Rate Range

Hours $65/hour $75/hour $100/hour

YEAR ONE 30 $ 1,987 $ 2,297 $ 3,047

YEAR TWO (3.5% estimated CPI escalation rate) 30 2,057 2,377 3,154

YEAR THREE (3.5% estimated CPI escalation rate) 30 2,129 2,460 3,264

TOTAL ESTIMATED POTENTIAL HOURS and COST: 90 $ 5,192 $ 7,134 $ 9,465

AVERAGE EST. HOURS and COST PER YEAR PER OPERATOR: 30 $ 1,731 $ 2,378 $ 3,155
52

Average Estimated Hours and Cost for One Operator Initiating and Continuing with a Multi-Year IEE During This ICR Renewal Period

"Revised" IEE based on $75/hour rate and average cost 65 $ 5,359

"Subsequent Year Multi-Year" IEE based on $75/hour rate and average cost for two subsequent years 30hrs x 2 = 60 $2,378 x 2 = $ 4,756

TOTAL ESTIMATED POTENTIAL HOURS and COST: 125 $ 10,115

(over 3-year life of this ICR Renewal)

AVERAGE EST. HOURS and COST PER YEAR PER OPERATOR: 42 $ 3,372

(over 3-year life of this ICR Renewal)
53

Exhibit 1C: CEEs - ESTIMATED RESPONDENT HOURS AND COST

 Respondent Respondent Rate Range Capitol/ O & M No. of Totals for Respondent Rate Range

ICR Activity: CEEs Hrs/Yr $65/hour $75/hour $100/hour Startup Cost Cost Respondents $65/hour $75/hour $100/hour

Environmental Documentation

1. Study the regulations

2. Search reference sources for 

existing information and 

compile information from 

company records

3. Prepare CEE and submit

4. Revise in response to EPA's 

comments and submit

Post-Expedition Assessment & 

Verification

1. Prepare A/V information 

and submit

300 $ 19,500 $ 22,500 $ 30,000

Env. Doc.

None

Post-Exp. A/V

None

Env. Doc.

Copying $ 300

Mailing 64

___________

 $ 364

Post-Exp. A/V

Copying $ 25

Mailing 17

____________

 $ 42

 $ 406 1 $ 19,906 $ 22,906 $ 30,406

Totals for Respondent Rate Range

Hours $65/hour $75/hour $100/hour

YEAR ONE 300 $ 19,906 $ 22,906 $ 30,406

YEAR TWO (3.5% estimated CPI escalation rate) 300 20,603 23,708 31,470

YEAR THREE (3.5% estimated CPI escalation rate) 300 21,324 24,538 32,571

TOTAL ESTIMATED POTENTIAL HOURS and COST: 900 $ 61,833 71,152 94,447

AVERAGE EST. HOURS and COST PER YEAR PER OPERATOR: 300 $ 20,611 23,717 31,482

Assumptions:

1. Exhibit 1C represents the estimated hours and cost for CEEs. In fact, no CEEs were submitted during the thirteen austral summer seasons the Rule has been in effect. For purposes of estimating the potential maximum 

hours and cost associated with CEEs over the three-year life of the ICR, the three-year projection assumes submission of one CEE per year for each of the next three years. Although one respondent per year is estimated for 

purposes of the cost calculations, EPA anticipates that the actual number of nongovernmental expeditions with activities that will likely proceed with less than minor or transitory impacts may well be reduced to less than one 

respondent per year.

2. Estimates for preparation of a CEE are based on estimated time that would be needed to comply with the Final Rule at Section 8.4, preparation of environmental documents, generally, and Section 8.8, comprehensive 

environmental evaluation.

3. The cost estimates are based on industry labor rates obtained during informal consultations with industry representatives and include overhead and fringe benefits. The three rates used in the calculations represent the rates 

provided by the industry representatives. The $75/hour intermediate rate is used for summary purposes. See Part D for additional information on the consultations with affected respondents.
54

1D. REPORTING FOR EMERGENCIES - ESTIMATED RESPONDENT HOURS AND COST

Respondent Respondent Rate Range Capitol/ O & M No. of Totals for Respondent Rate Range

ICR Activity: CEEs Hrs/Yr $65/hour $75/hour $100/hour Startup Cost Cost Respondents $65/hour $75/hour $100/hour

Reporting for Cases of 

Emergency

1. Initial Report

2. Full Report

Post-Emergency Assessment 

& Verification

1. Prepare A/V information 

and submit

300 $ 19,500 $ 22,500 $ 30,000

Reporting

None

Post A/V

None

Reporting

Copying $ 150

Mailing 32

__________

 $ 182

Post A/V

Copying $ 25

Mailing 17

__________

 $ 42

 $ 224

 1 $ 19,724 $ 22,724 $ 30,224

There were no emergencies that required reporting during the seven austral summer seasons the Rule has been in effect. An incident requiring emergency reporting could occur 

in the subsequent years. The following cost estimates are not additive, however, since only one such emergency in 10 years is estimated.

Totals for Respondent Rate Range

Hours $65/hour $75/hour $100/hour

YEAR ONE 300 $ 19,724 $ 22,724 $ 30,224

YEAR TWO (3.5% estimated CPI escalation rate) 300 20,414 23,519 31,282

YEAR THREE (3.5% estimated CPI escalation rate) 300 21,128 24,342 32,377

Assumptions:

1. Reporting for Cases of Emergency is based on the Final Rule at Section 8.10, Cases of emergency, which requires notice and reporting for activities taken in cases of emergency which would have otherwise required the 

preparation of a CEE. The estimate is based on reporting requirements only, not the actual cost of the emergency response action. The hours and cost estimate assumes one such emergency per 10 years.

2. Only one incident requiring emergency reporting is estimated to occur over a 10-year period. In fact, there was no emergency reporting during the ten austral summer seasons the Rule has been in effect.

3. The cost estimates are based on industry labor rates obtained during informal consultations with industry representatives and include overhead and fringe benefits. The three rates used in the calculations represent the 

rates provided by the industry representatives. The $75/hour intermediate rate is used for summary purposes. See Part D for additional information on the consultations with affected respondents.
55

Exhibit 2A: PERMs - ESTIMATED FEDERAL GOVERNMENT HOURS AND COST

 Federal Gov't. Federal Gov't. Capitol/ O & M No. of Total

ICR Activity: PERM hours/year $70/hour Startup Cost Cost Respondents Cost/Year

PERMs from U.S.-Based Operators:

1. Post PERM receipt on WWW, provide copies to interested 

Federal agencies and public, if requested

2. Review PERM and any public comments, provide 

comments to and consult with operator

3. Provide copies of revised/final PERM to interested Federal 

agencies, review, and notify operator, if necessary

4. Maintain file

Post-Expedition Assessment & Verification

1. Review A/V information - NOT REQUIRED FOR PERMs

 12 $ 840

PERM 

 None

Post-Exp A/V

 None

PERM

Copying $ 30

FR Pub. 0

Store Files 10

_____________

 $ 40

Post-Exp A/V

None

$ 40

 1 $ 880

Hours Cost

YEAR ONE 12 $ 880

YEAR TWO (3.5% estimated CPI escalation rate on $794) 12 911

YEAR THREE (3.5% estimated CPI escalation rate on $822) 12 943

TOTAL ESTIMATED POTENTIAL BURDEN and COST: 36 $ 2,734

AVERAGE EST. BURDEN and COST PER YEAR PER OPERATOR: 12 $ 911

Assumptions:

1. Exhibit 2A represents the estimated hours and cost for PERMs. In fact, during the thirteen austral summer seasons the Rule has been in effect, only one PERM was submitted as the final documentation for an expedition. 

For purposes of estimating the potential maximum hours and cost associated with PERMs over the three-year life of the ICR, the three-year projection assumes submission of one PERM per year for each of the next three 

years. Although one respondent per year is estimated for purposes of the cost calculations, EPA anticipates that the actual number of nongovernmental expeditions with activities that will likely proceed with less than minor 

or transitory impacts may well be reduced to less than one respondent per year.

2. Estimates for review of a PERM is estimated as 25% of the respondent's time, or 10 hours, to prepare a PERM that would be in compliance with the Final Rule at Section 8.4, preparation of environmental documents, 

generally, and Section 8.6, preliminary environmental review, and two hours for administrative activities.

3. Hours and cost associated with preparation of higher level EIA documentation, if necessary, is addressed in Exhibits 2B (IEEs) and 2C (CEEs).

4. Based on EPA=s experience for the thirteen austral summer seasons the Rule has been in effect, EPA estimates that the administrative costs have been no more than about 2% of the total estimated costs for the Federal 

government. Because this percentage is so low, the Federal government costs in Exhibit 2A through 2E are all calculated at the $70/hour rate for technical activities. 
56

Exhibit 2B: IEEs - ESTIMATED FEDERAL GOVERNMENT HOURS AND COST

Federal Gov't. Federal Gov't. Capitol/ O & M No. of Total

ICR Activity: IEEs hours/year $70/hour Startup Cost Cost Respondents Cost/Year

Environmental Documentation

MODEL 1: "Core" IEE

1. Post IEE receipt on WWW, provide copies to 

interested Federal agencies and public, if 

requested

2. Review IEE and any public comments, 

provide comments to and consult with operator

3. Provide copies of revised/final IEE to 

interested Federal agencies, review , and notify 

operator, if necessary

4. Maintain file

Supplemental Information

1. Review supplemental information

Post-Expedition Assessment & Verification

1. Review A/V information -

Core IEE

 80

 1

 15

 96

$ 5,600

$ 70

$ 1050

$ 6,720

Core IEE

 None

Supp. Info.

 None

Post-Exp A/V

 None

Core IEE

Copying $ 261

Store Files 10*

___________

 $ 271

*File storage includes Supp. and 

A/V Information

Supp. Info.

Included above

Post-Exp A/V

Copying $ 15

File Storage *

_________

$ 15

*Included above

$ 286

See Table 2 $ 7,006
57

Federal Gov't. Federal Gov't. Capitol/ O & M No. of Total

ICR Activity: IEEs hours/year $70/hour Startup Cost Cost Respondents Cost/Year

Environmental Documentation

MODEL 2: "Revised" IEE

1. Post IEE receipt on WWW, provide copies to 

interested Federal agencies and public, if 

requested

2. Review IEE and any public comments, provide 

comments to and consult with operator

3. Provide copies of revised/final IEE to 

interested Federal agencies, review, and notify 

operator, if necessary

4. Maintain file

Supplemental Information

1. Review supplemental information

Post-Expedition Assessment & Verification

1. Review A/V information -

Revised IEE

 40

 1

 15

 56

$ 2,800

$ 70

$ 1050

$ 3,920

Revised IEE

 None

Supp. Info.

 None

Post-Exp A/V

 None

Revised IEE

Copying $ 261

Store Files 10*

___________

 $ 271

*File storage includes Supp. and 

A/V Information

Supp. Info.

Included above

Post-Exp A/V

Copying $ 15

File Storage *

____________

 $ 15

*Included above

$ 286

 See Table 2 $ 4,206
58

Federal Gov't. Federal Gov't. Capitol/O & M No. of Total

ICR Activity: IEEs hours/year $70/hour Startup Cost Cost Respondents Cost/Year

Environmental Documentation

MODEL 3: "Multi-Year" IEE

Year 1: "Revised" IEE

Years 2 and 3: "Subsequent 

Years Multi-Year" IEE

1. Review supplemental 

information

2. Review A/V information -

 

 40

 1

 15

$ 2,800

Years 2 and 3

$ 70

$ 1050

________

$ 1,120

 None

 None

Year 1

Copying $ 261

Store Files 10*

___________

 $ 271

*File storage includes Supp. and A/V Information

Years 2 and 3

Copying $ 15

File Storage *

____________

 $ 15

See Table 2 See Table 2

Assumptions:

1. IEEs would need to comply with the Rule at Section 8.4, preparation of environmental documents, generally, and Section 8.7, initial environmental evaluation.

2. "Core" IEE and associated supplemental information comprises the IEE package for the initial submittal of an IEE by an operator.

3. "Revised" IEE and associated supplemental information comprises the IEE package for a current year's submittal developed through revision of a previous year's submittal.

4. A Multi-Year IEE consists of a Revised IEE and the associated supplemental information in the initial year and, for each of the subsequent four years, an annual submission of the advance notice and confirmation that the 

information provided in the Multi-Year IEE is unchanged.

5. Supplemental information for purposes of the costs estimated in Exhibit 2B and Table 2 refers to supplemental information submitted regarding the specifics of the tours/expedition (e.g., dates, number of tours, etc.) rather 

than supplemental information of a more technical nature that is incorporated into the "Core" or "Revised" IEE by reference. The one hour for review of the supplemental information is assigned to EPA to simplify the model 

and calculations.
59

______________________________________________________________________________________________________

TABLE 2. IEEs - TOTAL ESTIMATED HOURS AND COST FOR THE THREE IEE MODELS, 3.5% ESCALATION RATE

Core IEE for One Operator and One IEE - (Core IEE + Supplemental Information + A/V Information)

HOURS COST

YEAR ONE 96 $ 7,006

YEAR TWO (3.5% estimated CPI escalation rate) 96 7,251

YEAR THREE (3.5% estimated CPA escalation rate) 96 7,504

TOTAL ESTIMATED POTENTIAL HOURS and COST: 288 $ 21,761

AVERAGE EST. HOURS and COST PER YEAR PER OPERATOR 96 $ 7,254

Revised IEE for One Operator and One IEE - (Revised IEE + Supplemental Information + A/V Information)

HOURS COST

YEAR ONE 56 $ 4,206

YEAR TWO (3.5% estimated CPI escalation rate) 56 4,353

YEAR THREE (3.5% estimated CPA escalation rate) 56 4,505

TOTAL ESTIMATED POTENTIAL HOURS and COST: 168 $ 13,064

AVERAGE EST. HOURS and COST PER YEAR PER OPERATOR 56 $ 4,355

"Multi-Year" IEE for One Operator and One IEE - A "Multi-Year" IEE consists of a "Revised" IEE and, for each of the subsequent four years, an annual submission 

of the advance notice and confirmation that the information provided in the Multi-Year IEE is unchanged. See above for the hours and cost per operator for the 

"Revised" IEE for the initial year. The hours and cost per operator for the subsequent years follows for which hours and cost are calculated for "Subsequent Year 

Multi-Year" IEE submissions.

“Subsequent Year Multi-Year” IEE for One Operator - (Supplemental Information + A/V Information)

HOURS COST

YEAR ONE 16 $ 1,120

YEAR TWO (3.5% estimated CPI escalation rate) 16 1,159

YEAR THREE (3.5% estimated CPA escalation rate) 16 1,200
60

TOTAL ESTIMATED POTENTIAL HOURS and COST: 48 $ 3,479

AVERAGE EST. HOURS and COST PER YEAR PER OPERATOR 16 $ 1,159

Average Estimated Hours and Cost for One Operator Initiating and Continuing with a Multi-Year IEE During This ICR Renewal Period

Revised IEE for One Operator and One IEE HOURS COST

"Revised" IEE 56 $ 4,355

"Subsequent Year Multi-Year" IEE - cost for 2 years 16 hrs x 2 = 32 $1,159 x 2 = 2,318

TOTAL ESTIMATED POTENTIAL HOURS AND COST: 88 $ 6,673

(over 3-year life of this ICR Renewal)

AVERAGE EST. HOURS and COST PER YEAR PER OPERATOR: 29 $ 2,224

(over 3-year life of this ICR Renewal)
61

Exhibit 2C: CEEs - ESTIMATED FEDERAL GOVERNMENT HOURS AND COST

Federal Gov't. Federal Gov't. Capitol/ O & M No. of Total

ICR Activity: CEE hours/year $70/hour Startup Cost Cost Respondents Cost/Year

CEEs from U.S.-Based Operators:

1. Post CEE receipt on WWW, provide copies to 

interested Federal agencies and public, if 

requested

2. Prepare/publish FR notices for receipt of 

draft CEE and NOA for final CEE; copy and 

transmit final CEE to Parties

3. Review draft CEE and any public comments, 

provide comments to and consult with operator

4. Provide copies of revised/final CEE to 

interested Federal agencies and public, if 

requested, and to Parties, review, and notify 

operator, if necessary

5. Maintain file

Post-Expedition Assessment & Verification

1. Review A/V information -

CEE

135

Post-Exp A/V

30

 165

CEE

$ 9,450

Post-Exp A/V

$ 2,100

$ 11,550

CEE

None

Post-Exp 

A/V

 None

CEE

Copying $1710 FR Pub. 326

Store Files 10*

_____________

 $2046*

*Includes CEE and A/V 

Information

Post-Exp A/V Copying $ 30

FR Pub. 0

Store Files *

_____________

 $ 30

* Included above $2,076

1

$ 13,626

YEAR ONE 165 $13,626

YEAR TWO (3.5% estimated CPI escalation rate on $12,590) 165 $14,103

YEAR THREE (35% estimated CPI escalation rate on $13,031) 165 $14,597

TOTAL ESTIMATED POTENTIAL BURDEN and COST: 495 $42,326

AVERAGE EST. BURDEN and COST PER YEAR PER OPERATOR: 165 $14,109

Assumptions:

1. Exhibit 2C represents the estimated hours and cost for CEEs. In fact, no CEEs were submitted during the ten austral summer seasons the Rule has been in effect. For purposes of estimating the potential maximum hours 

and cost associated with CEEs over the three-year life of the ICR, the three-year projection assumes submittal of one CEE per year for each of the next three years. Although one respondent per year is estimated for purposes 

of the cost calculations, EPA anticipates that the actual number of nongovernmental expeditions with activities that will likely proceed with less than minor or transitory impacts may well be reduced to less than one 

respondent per year.
62

2. Estimates for review of a CEE is estimated as 50% of the respondent's time, or 120 hours, to prepare a CEE that would be in compliance with the Final Rule at Section 8.4, preparation of environmental documents, 

generally, and Section 8.8, comprehensive environmental evaluation, with an additional 15 hours for administrative activities, and 50% of respondent's time for assessment and verification procedures for review of the 

information.

3. EPA would publish Federal Register notices for domestic CEEs, and the Department of State would publish the Federal Register notice and circulate copies of CEEs to all Parties and others that may request copies.
63

Exhibit 2D: Reporting for Emergencies - Estimated Federal Government Hours and Cost

Federal Gov't. Federal Gov't. Capitol/ O & M No. of Total

ICR Activity: CEE hours/year $70/hour Startup Cost Cost Respondents Cost/Year

Reporting for Cases of Emergency

1. Notify Parties

2. Provide initial and full report to interested 

Federal agencies and review

3. Provide full report to Parties

4. Review A/V information

5. Maintain files

165 $ 11,550 None Copying 

$1740

FR Pub. 0

Store Files 10

___________

 

$1750 

 1 $ 10,660

 1,750

______

$13,300

YEAR ONE 165 $13,300

YEAR TWO (3.5% estimated CPI escalation rate of $12,410) 165 13,766

YEAR THREE (3.5% estimated CPI escalation rate for $12,845) 165 14,248

Assumptions:

1. Reporting for Cases of Emergency is based on the Final Rule at Section 8.10, Cases of emergency, which would require notice and reporting for activities taken in cases of emergency which would have otherwise required 

the preparation of a CEE. The estimate is based on reporting requirements only, not the actual cost of the emergency response action. The hours and cost estimate assumes one such emergency per 10 years.

2. Only one incident requiring emergency reporting is estimated to occur over a 10-year period. In fact, there was no emergency reporting during the seven austral summer seasons the Rule has been in effect. An incident 

requiring emergency reporting could occur in the subsequent years. The cost estimates for reporting for cases of emergency are not additive because only one such emergency in 10 years is estimated.

3. Estimates for review of an Emergency Report is estimated as 50% of the respondent's time to prepare the Emergency Report that would be in compliance with the Final Rule at Section 8.10, or 120 hours, and 50% of 

respondent's time for assessment and verification procedures for review of the information, or 30 hours, with an additional 15 hours for administrative activities.

3. The Department of State is responsible for notification of Parties and follow-up coordination with the Parties; hours have been allocated to the DOS accordingly.
64

Exhibit 2E: Coordinating Review of Information Received from Other Parties - Estimated Federal Government Hours and Cost

Federal Gov't. Federal Gov't. Capitol/ O & M No. of Total

ICR Activity: Other Party Docs. hours/year $70/hour Startup Cost Cost Respondents Cost/Year

Coordinate Review of Information Received from 

Other Parties

1. Prepare and publish FR notice of receipt of 

draft CEE, provide copies to interested Federal 

agencies and public, if requested

2. Review draft CEE and provide inter-agency 

response to Party

3. Provide copies of other documents (including 

final CEEs, annual list of IEEs, national 

procedures, significant monitoring information) to 

interested Federal agencies and public, if 

requested

4. Post receipt of significant monitoring 

information on WWW and provide copies to 

interested Federal agencies and public, if 

requested

5. Maintain files

110 $7,700

None Copying $ *

FR Pub 326

Store Files 10

____________

 $ 336

* Copying per document:

Draft CEE $360

Final CEE 180

Other doc. 50

IEE list 10

See: Assum. 2, below See: Assum. 2, below

Assumptions:

1. The Department of State would be responsible for compliance with the Final Rule at Section 8.12, Coordination of reviews from other Parties.

2. The calculations in Exhibit 2E are based on receipt of a CEE from another Party. One Draft CEE was received from other Parties during the ten austral summer seasons the Rule has been in effect other 

than the annual list of IEEs. There is no way to anticipate receipt of environmental documents from the Parties, other than the annual list of IEEs, on an annual basis. There is no burden or cost to the 

respondents associated with receipt of documents from the Parties, therefore, the costs are not further defined.
65

Exhibit 3: SUMMARY - ESTIMATED RESPONDENT/FEDERAL GOVERNMENT HOURS AND COST

CHART 1: Summary for Respondents and Federal Government - Estimated Total and Annual Average hours and cost for each type of environmental document that is submitted 

by a Respondent under the Final Rule

PERM Core IEE Revised IEE Subsequent Year 

Multi-Year IEE

CEE Emergency

Reporting

Hours Cost Hours Cost Hours Cost Hours Cost Hours Cost Hours Cost

Respondent

 Year 1

 Year 2

 Year 3

TOTAL

Annual Average

 40 $ 3,079

 40 $ 3,187

 40 $ 3,298

120 $ 9,564

 40 $ 3,188

 185 $14,176

 185 $14,672

 185 $15,186

 555 $44,034

 185 $14,678

 65 $ 5,176

 65 $ 5,357

 65 $ 5,544

 195 $16,077

 65 $ 5,359

 30 $ 2,297

 30 $ 2,377

 30 $ 2,460

 

 90 $ 7,134

 30 $ 2,378

 300 $ 22,906

 300 $ 23,708

 300 $ 24,538

 900 $ 71,152

 300 $ 23,717

300 $22,724

300 $23,519

300 $24,342

Federal 

Government

 Year 1

 Year 2

 Year 3

TOTAL

Annual Average

 12 $ 880

 12 $ 911

 12 $ 943

 36 $ 2,734

 12 $ 911

 96 $ 7,006

 96 $ 7,251

 96 $ 7,504

288 $21,761

 96 $ 7,254

 56 $ 4,206

 56 $ 4,353

 56 $ 4,505

168 $13,064

 56 $ 4,355

 16 $ 1,120

 16 $ 1,159

 16 $ 1,200

 48 $ 3,479

 16 $ 1,159

 165 $ 13,626

 165 $ 14,103

 165 $ 14,597

 495 $ 42,326

 165 $ 14,109

165 $13,300

165 $13,766

165 $14,248

TOTAL

Annual Average

156 $12,298

 52 $ 4,099

843 $65,795

281 $21,931

363 $29,141

121 $ 9,714

138 $ 10,613

 46 $ 3,538

1395 $113, 478

 465 $ 37,826

CHART 2: Summary for Respondents and Federal Government - Estimated total hours and costs for Multi-Year IEE as the anticipated level and type of environmental document 

most respondents submit under the Final Rule for the 3-year ICR renewal (Year 1 = "Revised" IEE, Years 2 and 3 = "Subsequent Year Multi-Year" IEE)

Multi-Year IEE

 Total Hours

3-Year Total Annual 3-Yr Average

 Total Cost

3-Year Total Annual 3-Yr Average

Respondent (for one operator) 125 hours 42 hrs per op per yr $ 10,115 $ 3,372 per operator per year

Federal Government (for one op.) 88 hours 29 hrs per op per year $ 6,673 $ 2,224 per op per year

TOTALS - For one operator 213 hours 71 hrs per op per yr $ 16,366 $ 5,456 per op per year

NOTES: Annual Average is the average per respondent per year. Chart 1 presents the maximum hours and cost for a respondent. Chart 2 presents the maximum hours and cost based on the anticipated level and type of 

environmental document a respondent would likely submit under the Final Rule. The $75/hour intermediate rate is used for summary purposes. The hours and cost estimates for Emergency Reporting assume one such 

emergency per 10 years.
66

CHART 3: Summary for Respondents and Federal Government - Estimated hours and costs for environmental documentation for 3-year period of this ICR renewal.

Summary assumes 18 operators per year with 3 new operators and 15 repeat operators each year. For the 15 repeat operators, the assumptions are that 3 will prepare "Revised" 

IEEs and 12 will prepare "Multi-Year" IEEs. For Chart 3, the calculations use the "Annual Average" from Chart 1for "Core," "Revised," and "Subsequent Year, Multi-Year" IEEs 

and the hours and cost in Chart 2 for the "Multi-Year" IEE.

Operators: 18 operators each year for the 3-year ICR 

renewal period

Respondent Burden 

Hours Cost

Federal Government Burden

Hours Cost

3 new operators submit "Core" IEEs each year

Burden per year

Total 3-year burden

185 x 3 = 555 $14,678 x 3 = $ 44,034 

555 x 3 = 1,665 $44,034 x 3 = $132,102

 96 x 3 = 288 $7,254 x 3 = $ 21,762

288 x 3 = 864 $21,762 x 3 = $65,286

3 of 15 repeat operators submit "Revised" IEEs each year

Burden per year

Total 3-year burden

65 x 3 = 195 $ 5,359 x 3 = $ 16,077

195 x 3 = 585 $16,077 x 3 = $ 48,231

 

56 x 3 = 168 $ 4,355 x 3 = $ 13,065

168 x 3 = 504 $13,065 x 3 = $ 39,195

12 of 15 repeat operators submit new "Multi-Year" IEEs

Burden per year

Total 3-year burden

 42 x 12 = 504 $ 3,372 x 12 = $ 40,464

504 x 3 = 1,512 $40,464 x 3 = $ 121,392

 29 x 12 = 348 $ 2,224 x 12 = $26,688

348 x 3 = 1044 $26,688 x 3 = $80,064

ANNUAL TOTAL BURDEN for 18 operators

ANNUAL TOTAL BURDEN per operator

TOTAL 3-YEAR BURDEN for 18 operators

TOTAL 3-YEAR BURDEN per operator

 1,254 $100,575

 70 $ 5,588

 3,762 $301,725

 209 $ 16,763

 804 $ 61,515

 45 $ 3,418

 2,412 $ 184,545

 134 $ 10,253
67

EXHIBIT 4: SUMMARY FOR RESPONDENTS AND FEDERAL GOVERNMENT - O&M COSTS

Estimated O&M costs for Respondents and the Federal Government and O&M breakout within the total cost burden.

Operators: 18 operators each year for the 3-year ICR 

renewal period

Respondent Burden 

O&M Cost O&M + Labor = Total Cost

Federal Government Burden

O&M Cost O&M + Labor = Total Cost

3 new operators submit "Core" IEEs each year

Burden per year

Total 3-year burden

$ 301 x 3 = $ 903 $903 + 43,131 = $ 44,034 

$903 x 3 = $ 2,709 $2,709 + 129,393 = $132,102

$ 271 x 3 = $813 $ 813 + 20,949 = $ 21,762

$813 x 3 = $2,439 $ 2,439 + 62,847 = $65,286

3 of 15 repeat operators submit "Revised" IEEs each year

Burden per year

Total 3-year burden

$ 301 x 3 = $ 903 $ 903 + 15,174 = $ 16,077

$ 903 x 3 = $ 2,709 $2,709 + 45,522 = $ 48,231

$ 271 x 3 = $ 813 $ 813 + 12,252 = $ 13,065

$ 813 x 3 = $2,439 $ 2,439 + 36,756 = $ 39,195

12 of 15 repeat operators submit new "Multi-Year" 

IEEs48

Burden per year

Total 3-year burden

$ 132 x 12 = $ 1,584 $ 1,584 + 38,880 = $ 40,464

$ 1,584 x 3 = $ 4,752 $4,752 + 116,640 = $ 121,392

$ 111 x 12 = $ 1,332 $ 1,332 + 25,356 = $26,688

$ 1,332 x 3 = $3,996 $ 3,996 + 76,068 = $80,064

ANNUAL TOTAL BURDEN for 18 operators

ANNUAL TOTAL BURDEN per operator

TOTAL 3-YEAR BURDEN for 18 operators

TOTAL 3-YEAR BURDEN per operator

 O&M Labor Total Cost

 $ 3,390 + 97,185 = $100,575

 $ 188 + 5,399 = $ 5,587

 $10,170 + 291,555 = $301,725

 $ 565 + 16,198 = $ 16,763

 O&M Labor Total Cost

 $2,958 + 58,557 = $ 61,515

 $ 164 + 3,253 = $ 3,417

 $8,874 + 175,671 = $184,545

 $ 493 + 9,759 = $ 10,253

 

48New "Multi-Year" IEE includes "Revised" IEE in the first year and "Subsequent Year, Multi-Year" IEE in years 2 and 3. The average cost for the 

three year period of the ICR renewal is used in the calculations in Exhibit 4.

For the total three years: 

Respondent $301 + (2 x $47)= $395

Federal Government $271 + (2 x $31) = $333

Average for the three years: 

Respondent $395/ 3 years = $132/year

Federal Government $333/ 3 years = $111/year
68
B-1

PART B OF THE SUPPORTING STATEMENT

STATISTICAL SURVEY

This collection of information does not use or is otherwise based on a statistical survey.