### 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. Id entification of the Information Collection . . . . . . . . . . . . . . . . . . . . . . 1 1(a) Title of the Information Collection . . . . . . . . . . . . . . . . . . . . . . . 1 1(b) Short Characterization/ Abstra ct . . . . . . . . . . .

. . . . . . . . . . . . . 1 2. Need for and Use of the Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2(a) Need/Authorit y 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 I CR 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 I nformation Requested . . . . . . . . . . . . . . . . . . . 9 4(a) Respondents/SI C Codes .

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 4(b) In formation 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

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 6 5(d) Collection Schedule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

6. Estimating the Hours and Cost Burden of the Collection . . . . . . . . . . . . . . 2 0 6(a) Estimating Respondent Burden

. . . . . . . . . . . . . . . . . . . . . . . . . . 2 0 6(b) Estimating Respondent Costs

. . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

### ii (i)Estimating Labor C osts

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

. . . 27 ( iii ) Annualizing Capital Costs

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

. . . . . . . . . . . . . . . . . . 3 1 6(d) Estimating the Respondent Universe and Total Burden and Costs 4 3 6(e) Bottom L ine Burden Hours and Cost Tables

. . . . . . . . . . . . . . . . . 46 (i)Respondent Tall y . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46 (ii)The Agency

Tall y . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46 (iii)Variations in the Annual Bottom L ine

. . . . . . . . . . . . . . . . . . 46 6( f) Reason for Change in Burden . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 6 6( g ) Burden Statement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 6 Exhib it 1A: PERMs

- Estimated Respondent Hours and Cost . . . . . . . . . . . . . . 48 Exhibit 1B: I EEs

- 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: I EEs

- Estimated Federal Government Hours and Cost . . . . . . . . . . 57 Table 2. IEEs

- Total Estimated Hours and Cost for the Three IEE Model s with 3.5% Escalation Rate . . . . . . .. . . . . . . . . . . . . . . . 6 0 Exhibit 2C: CEEs

- Estimated Federal Government Hours and Cost . . . . . . . . . 61 Exhibit 2D: Reporting for Emergencies

- Estimated Federal Government

Hours and Cost . .

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 3 Exhibit 2E: Coordinating Review of Information Received from Other Parties

-

Estimated Federal Government Hours and Cost . . . . . . . . . . . . . . 6 4 Exhibit 3: Summary

- Estimated Respondent/Federal Government

Hours and Cost . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 5 Chart 1. Estimated total and annual average hours and cost for each t ype of environmental document that is subm itted by a respondent under the Final Rule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 5 Chart 2. Estimated total hours and costs for Multi

- Year IEE as the anticipated level and t ype of environmental document most respo ndents submit under the Final Rule for the 3

- ye ar IC R renewal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 5 Chart 3. Estimated hours and costs for environmental documentation for 3

- ye ar period of this I CR renewal . . . . . . . . . . . . . . . . . . . . . 6 6 Exhibit 4: Summary

for Respondents and Federal Government

- O&M Costs . . 6 7 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 Nongove**  **rnmental 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) ”**  **E PA 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 I mpact 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 Treat y of 1959 (Treat y)

. The Rule provides for assessment of the environmental impacts of nongovernmental activities in Antarctica, including tourism, for whi ch 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 requir ements of the Rule appl y 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; y acht, s kiing 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 ar e not acting as an operator. (Operators, for example, ty picall y acquire use of vessels or aircraft, hire expedition staff, plan itineraries, and undertake other organizational responsibilities.) The Rule provides nongovernmental operators with the specif ic requirements they

need to meet in order to compl y with the requirements of Article 8 and Annex Ito the Protocol. The provisions of the Rule are intended to ensure that potential environmental effects of nongovernmental activities undertaken in Antarct ica 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. Environment al 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 day s before the proposed departure to Antarctica; (2) no more than minor or transitory impacts, an IEE n eeds to be submitted no later than 90 day s 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 recor d 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 a nd 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 operat or may also need to carry

out monitoring in order to assess and verify the impact of an activit y for which an IEE would be prepared. For activities that require an IEE, an operator should be able to use procedures currentl y being voluntaril y utilized by o perators 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 releva nt monitoring data collected b y 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: iden tification 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 time s 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 ti me 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 requi ring mitigation, the mitigative actions undertaken, and the actual or projected outcome of the mitigation.

### 3

In cases of emergency

relating to the safet y 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 t he Department of State within 15 day s of any activities which would have otherwise required preparation of a CEE, and provide a full explanation of the activities carried out within 45 day s of those activities. 3 

### Environmental documents (e.g., PERM, I EE, C EE) are submitted to OFA. Environmental documents are reviewed b y 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 ot herwise 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 ty pes of nongovernmental activities currently being carried out (e.g., ship

- based tours, land

- based tours, flights, and privately

funded research expeditions) are t ypicall y unlikel y 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 throug h 200 9

- 20 10 austral summer seasons during the time Rule ha s been in effect, all respondents submitted I EEs with the exception of one PERM. Paperwork reduction provisions in the Final Rule that are used by the operators include: a) incorporation of materi al into the environmental document by referring to it in the I EE; 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

- ye ar envir onmental 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 Treat y . 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 I EEs and any decisio ns taken in consequence thereof; (3) significant information obtained and an y 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 me et 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 th e Rule does not impose paperwork requirements on an y 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 Inter im 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 r enew al, the years 1997

- 2013 w hich 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 compl y w ith 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 b y 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 non governmental 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 o perators 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 Prote ction 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 in formation 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 pro posed 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 b ut 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 voluntaril y utilized by operators to provide the information. Because measures to assess an d verify

environmental impacts for all proposed activities for which an IEE or CEE are prepared are required b y the Rule, and because of the recordkeeping requirements of and burden definition in the Paperwork Reduction Act (PRA), EPA has included this inf ormation 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 estim ate. In this case, EPA believes the PRA, Section 3502(13) clearly supports the view that recordkeeping requirements must be considered inclusivel y in developing the ICR budget. 4

4 The Paperw ork Reduction Act, 44 U.S.C. Section 3502, states: (13) the term A recordkeeping 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, Paperw ork Reduction A ct, 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 A procedures 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 likel y 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 currentl y provide post

- visit reports to Antarctic Treat y Parties. Currently, the National Science Foundation recei ves 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 post

visit reporting will continue. EPA intends to review the information voluntarily submitted, and to maintain files. Because operators are currentl y voluntarily providing the informational reports to the government and because EPA anticipates that this pr actice 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 a nd verification information, and an y 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 c onsider 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 activit y 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 re levant to the likel y impact of the proposed activit y. 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 th e 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 an y 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 I CR 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 compl y with the Protocol. Most Antarctica tour operators currentl y provide, on an informal basis, information to the National Sci ence 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. Ho wever, 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 reasonabl y foreseeable indirect impacts on the Antarctic environment of the propos ed expedition in sufficient detail to assess whether the proposed activit y 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 I CR 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 an y 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 I nventory 408

- 741

- 5330 202

- 237

- 6262 Bill Davis Bob Simpson

5 Alternately, under the paperwork reduction provisions of the Rule, operators could cho ose 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, LL C 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 portray al. Ted Cheeseman believed that the majority of burden hours were accurate with the exception of the estimate for the multi

- ye ar IEE documentation. He bel ieves the “multi

- year” I EE 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 e nvironmental 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 expedit ions. 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 m ay 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 u sed 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 d ocumentation has been prepared for a season, an operator can resubmit the same document for subsequent seasons provided the level and intensit y of the activities are not unchanged and that relevant updates are submitted. Updates are likel y to include date s 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 likel y to employ the multi

- ye ar provision thereb y 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

- ye ar 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

- ye ar 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 im pacts of an y 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 voluntaril y utilized by operators to provide the information. **3(e) GENER** 

**AL 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 wit h 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 Treat y and the public as required under the Protocol or as otherwise reque sted. 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 timel y manner, particularl y 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 Treat y and includes commercial and non

- commercial expeditions. Expeditions include ship

- based tours; y acht, skiing or mountaineering expeditions; flights; privatel y funded research expeditions; and other nongovernmental or nongovernment

sponsored 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, ty picall y acquire us e 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. Mo st operators are ship

- based or land

- based tour operators. The SI C 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 Antar ctica are required to submit environmental documentation to EPA that evaluates the potential environmental impact of their proposed activities. The ty pe 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 day s before the proposed departure to Antarctica; (2) no more than minor or transitory impacts, includ ing 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 activit y 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 pr ocedures currentl y 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 wou ld 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 respo ndents, 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 b y more than one operator. An operator can also submit multi

- ye ar documentation to address proposed expeditions for a period of up to five consecutive austral summer seasons thus eliminating the need for annu al submission of environmental documentation. The multi

- ye ar 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 r e - 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 updat es, for a subsequent year's expedition(s). In cases of emergency

relating to the safet y 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 c ompletion of the documentation procedures set out in the Rule, the operator must notify

the Department of State within 15 day s of any activities which would have otherwise required preparation of a CEE, and provide a full explanation of the activities carr ied out within 45 day s of those activities. Enforcement action can proceed, pursuant to Section 8.11 of the Rule, against an operator who violates an y provision of the Rule. Enforcement actions are not, however, subject to the requirements of the Paperwo rk 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 b y 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 Rule 7 and 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

- me mber 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 tw o non - IAATO operators 1998

- 1999 10 4 total IEEs submitted including: 1 IEE submitted on behalf of seven IAATO

- member ope rators 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 tw o 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 on e - time only filming expedition and a one

- tim e only cruise

- only expedition 2000

- 2001 13 8 5 total IEEs submitted including: 1 IEE submitted on behalf of nine IAATO

- me mber operators for expeditions

6 For the 1997

- 1998 through 2012

- 2013 austral summe r 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

- bas ed 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 IC R 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 w ith 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 12 9 7 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

- tim e 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

- tim e only flight 13 total IEEs submitted including: 1 IE E submitted on behalf of nine IAATO

- me mber 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

- t ime only flights 2004

- 2005 21 16 total IEEs submitted including: 6 IEE submitted on behalf of 11 IAATO

- me mber 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 IAA TO

- 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 w ith 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 1 3 IAATO

- member operators fo r 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 - I AATO operators 2009

- 2010 

### 16 1 1 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

- IAAT O operators 2011

- 2012 

### 15 1 4 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

- tim e 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 Continen tal 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 compan y records for us e in preparation of the environmental document for the proposed expedition(s); 3. Prepare the environmental impact assessment (EIA) document (e.g., PERM, I EE 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 day s. 2. Provide a full report to the Department of State within 45 day s. The Rule does NOT require or co ntemplate the need for respondents to: 1. Acquire, install, or utilize technology and s ys tems for the purpose of collecting, validating, and verify ing information; 2. Develop, acquire, install, or utilize technology and sy stems for the purpose of proces sing and maintaining information; 3. Develop, acquire, install, or utilize technology and sy stems for the purpose of disclosing and providing information; or 4. Adjust the existing ways to compl y with an y previously applicable instructions and r equirements. **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 agencies 10 

### 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 res ult in enforcement and penalties pursuant to the Antarctic Conservation Act, as amended, as undertaken b y the National Science Foundation and/or the Department of Justice. Finall y, the Department of State has specific responsibilities under the Rule, Sect ion 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 an y 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, includi ng 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 revie w 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.

10 EPA 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), N ational 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 I nformation : 1. Review assessment and verification inf ormation 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 ope rator to undertake an y 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 Part y that circulated the CEE. 3. Provide copies of other environmental documents to interested Federal agencies and the public, if requested. Other environmenta l documents may include: a) a description of national procedures for considering the environmental impacts of proposed activities; b) an annual list of an y IEEs and an y decisions taken in consequence thereof; c) significant information obtained and an y 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 METHODOL**  **OGY AND MANAGEMENT:** The environmental documentation that is required b y t he 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 electronicall y. The R ule 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 document ation 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., R ule , Section 8.6 for PERMs; Section 8.7 for I EEs; 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 th e operator, if appropriate,

11 For example, Sweden has a specific form, and the United Kingdom has a permit system. For purposes of the Final Rule, a n 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 p rovides 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 pre pare a regulatory

flexibility

analy sis of any

rule subject to notice and comment rulemaking requirements under the Administrative Procedure Act or an y 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 A to fit regulatory and informational requirements to the scale of the business, org anizations and governmental jurisdictions subject to the regulation. @ To achieve this principle, agencies are required to A solicit 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 ex tent 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

anal ys is 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 Administrativ e Procedure Act or an y other statute, and final rules promulgated under the notice

and

- comment rulemaking requirements of the Administrative Procedure Act. Further, the RFA requires that an agency

identify the t yp es, and estimate the numbers, of small ent ities A to which the final [or proposed] rule will apply , @ and describe the rule A requirements @ to which small entities A will be subject @ and an y regulatory alternatives, including exemptions and deferrals, which would lessen the rule = s burden on small enti ties. I t 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 o f SBREFA, a regulatory flexibility

anal ys is as specified by

the RFA is not required simply

because the rule has some impact on some number of small entities. I nstead, such anal ys es is required only in cases where the Agency cannot certify

that the rule wi ll 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 Admi nistration with the North American Industry

Classification Sy stem (NAICS) code for A Tour 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 in dependently 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 an y significant adverse economic impact on small entities, since the primary purpose of the regulatory flexibility

analy ses is to identify

and address regulatory

alternatives A which minimize any significa nt 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

burde n, 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 an y small entities will be limited primarily to the co st of preparing such an analy sis 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 Treat y. The costs are minimal because the t yp es o f activities currentl y being carried out ty picall y are unlikel y 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 likel y to need onl y IEE documentation, the cost of which is minimal as shown in Section 6 of this Supporting Stat ement 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 th e cost, and reducing the paperwork burden, of such an analy sis.

12 16 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 reasonabl y available to the EPA; (2) more than one proposed expedition by

an operator may

be included within one en vironmental document and may , if appropriate, include a single discussion of components of the environmental anal ys is which are applicable to some or all of the proposed expeditions; (3) one environmental document may also be used to address expeditions be ing 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 environme ntal 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 im pacts, are unchanged. The multi

- ye ar 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 docu ment. 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 partic ular y ear, 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 delay s, provided that enviro nmental documentation fully meets deadlines under the Protocol. The Rule does not provide an exemption from coverage of the collection of information, or an y part thereof. This is because the Rule onl y requires assessment of environmental impacts. This assessment is limited to the cost of preparing such an anal ys is 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) COLLE**  **CTION 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 b y the United States. Preliminary

Environmental Review Memorandum (PERM) : I n accordance with the Rule at Section 8.6, a PERM needs to be submitted to EP A no less than 180 day s before the proposed departure of the expedition.

13 For the austral seasons the Rule has been in effe ct, operators have used all of the available paperw ork 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 day s 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 day s, 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 R ule. Initial En vironmental Evaluation (IEE) : In accordance with the Rule at Section 8.7, an IEE needs to be submitted no fewer than 90 day s before the proposed departure of the expedition. $ EPA, in consultation with other interested Federal agencies, provides its comm ents to the operator within 30 days of receipt. $ The operator then has 45 day s 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 day s of receiving the f inal IEE from the operator or, if the operator does not provide a final IEE, within 60 day s 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) : I n accordance with the Final Rule at Section 8.8(b), operators need to submit a CEE. 14 

### $ Within 15 day s 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 pu

blic comments for 90 day s following the published notice. $ EPA, in consultation with other interested Federal agencies, provides its comments to the operator within 120 day s following the Federal Register notice. $ The operator then needs to submit a fi nal CEE 75 day s before commencement of the proposed activit y in the Antarctic Treat y area. $ Within 15 day s of receiving the final CEE from the operator or, if the operator does not provide a final CEE, within 60 day s 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.

14 See: 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 f or 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 prov ide 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 day s before commencement of the proposed activity in the Antarctic Treat y area, EPA: (1) transmits the CEE, along with notice of an y 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 Fe deral Register

. In formation to Assess and Verify I mpacts : 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 day s 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 day s of those activities. **6. ESTIMA**  **TING 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 documentatio n (e.g., PERM, I EE, 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 t yp e of envi ronmental documentation since the effort should increase as an increasing level of environmental documentation is required; e.g., from PERM to I EE to CEE. The model respondent used in the estimates is a nongovernmental, U.S.

- based Antarctic tour ship oper ator. 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 I EE is t ypically th e appropriate level of environmental documentation for proposed activities. The ty pes of nongovernmental activities that are currently being carried out ty

pically 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

15 For the thirteen austral summer seasons the Rule has been in effect, environmental documentation has been submitted primarily by s hip

- 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 Antarcti c.

### 22

the Protocol. During the austral summer seasons the Rule has been in effect, I EEs 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, generall y, and Section 8.6, preliminary environmental review. The estimate assumes one week at 4 0 hours per week including revisions in response to an y EPA comments. Assessment and verification procedures are not required at the PERM level of activity and documentation. Although one respondent per y ear is estimated for purposes of the cost calculat ions 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 ye ar. In fact, during the sev en 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, generall y, and Section 8.7, initial environmental evaluation. The model also considers the experience with IEE documents received during the ten austral summer seasons t he 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 maxim um length for an IEE is about 200 pages including supplemental information. 16 

### $ IE Es consist of "core" information with supplemental expedition

- specific or other project

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

16 For the four IEEs submitted in 1997

- 1998, the approximate number of pages, including the "core" document plus supplemental documentation, w as: 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 informatio n 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 A preparation @ 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 w ere 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, an d that information will be incorporated b y 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 subsequen t ye ars 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 y ears. The estimate of 5 hours for preparation and/or compilation of supplemental inform ation remains the same. $ If appropriate, EPA anticipates operators will submit A multi

- ye ar @ IEE documentation. In the initial y ear, this is anticipated to consist of a revised IEE with an estimated 40 hours associated preparation time and 5 hours for pr eparation and/or compilation of supplemental information. For the subsequent four consecutive y ears 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 t hree austral summer seasons this I CR renewal will be in effect. The operator hourl y burden for preparation of a Core IEE is estimated as follows: Prepare "core" IEE: 160 hrs/I EE x 5 I EEs = 800 hours Prepare supplemental information: 5 h rs/operator x 5 operators = 25 hours A/V procedures: 20 hrs/operator x 5 operators = 100 hours TOTAL HOURS = 925 hours

17 The estimate for preparatio n 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).

18 For activities requiring an IEE, an operator should be able to use procedures currently being voluntarily utilized by operators to provide the required information.

19 For an IEE that covers multiple operators, the cost per opera tor 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 hrs 20


### 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 I EEs for the three austral summer seasons this I CR 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 act ivities 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 hourl y 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 u tilized by the operators. The operator hourl y burden for preparation of a Revised IEE is estimated as follows: Prepare "Revised" IEE: 40 hrs/I EE x 3 IE Es = 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 ( 3 operators) = 65 hours 21


### Model 3

- Multi

- Year IE E : Under the Final Rule, opera tors may choose to submit multi

ye ar IEE documentation. Under this model, EPA assumes the operators will submit a Revised IEE in the initial ye ar. The multi

- ye ar provision then allows operators to supplement the multi

ye ar 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

- ye ar 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

20 If, 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 operato r is reduced from 185 hours to 154 hours.

21 If, for example, the three Revised IEEs cover four operators (e.g., tw o IEEs cover one operator each and the other covers two operators), the burden per operator is reduced from 65 hours to 49 hours.

22 For purposes of demonstrating the hourly burden for an operator submitting a Multi

- Year IEE, EPA assumed twelve operators w ould submit multi

- year IEEs during the time covered by this ICR rene wal. It is possible that two of the operators listed under the Revised IEE m odel may submit A multi

- year @ rather than revised IEEs. How ever, since the intent of these operators is unknown, EPA assumed these tw o operators w ould submit A revised @ IEEs, an assumption that provides the maximum hours and cost estimates for the three yea r period of this ICR

### 25

Initial Year: Prepare Revised IEE: 40 hrs/I EE x 9 IE Es = 360 hours Prepare supplemental information: 5 hrs/operator x 12 ops x 1 y ear = 60 hours A/V procedures: 20 hrs/operator x 12 ops x 1 y ear = 240 hours Four Subsequent Years for a Total of Five Consecutive Years: Prepare supplemental information: 5 hrs/operator x 12 ops x 4 y ears = 240 hours A/V procedures: 20 hrs/operator x 12 ops x 4 y ears = 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 ( 1 2 operators) = 31 hours 23


### 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, generall y, 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 revision s in response to EPA's comments. The estimate assumes 60 hours to prepare assessment and verification information associated with the CEE level of activit y 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 y ear. 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 s uch 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 b y 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 tw elve 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 an d A/V procedures) as the initial cost of the Revised IEE is spread among the operators.

### 26

re presentatives 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 post

expedition assessment and verification information.

FI GURE 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

FI GURE 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

FI GURE 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

FI GURE 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

FI GURE 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 an y 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 env ironmental documentation are as follows:

24 One

- 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 spe cific 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.

25 O&M costs are the recurring dollar amount of cost associated w ith 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 an y supplemental information. $ One PERM submitted per year b y one operator. I n 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 exp ress 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 fol lows: 26 

### (1) Copy ing: 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 ye ar period 27 

### 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 ma ximum 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 op erators 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 req uired, 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.

26 For 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.

27 Three 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) Copy ing: 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 Cor e @ IEE package x $27/package = 27.00

1 Supplemental I nformation package x $12/package = 12.00 1 A/V information package x $17/package = 17.00 Revised IEE : (1) Copy ing: 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 I nformation p ackage x $12/package = 12.00 1 A/V information package x $17/package = 17.00 Model Multi

- Year IEE : (1) Copy ing: 200 pages/Revised IEE x 5 copies/IEE x $0.10/pag e = $ 100.00

10 pages/Supplemental Info. x 5 copi es 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 I nformation package x $12/package = 12.00 1 A/V information package x $17/package = 17.00 Subsequent Year, Multi

- Year IEE : (1) Copy ing: 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 hour s and costs for IEEs per y ear. Over the next three ye ars, all Multi

- Year IEE submissions will follow the Multi

- Year Model with a revised submission one y ear and two subsequent y ears where onl y supplemental information is filed. To calculate the O&M costs over the three ye ar 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 Thre e IEE Models, and a CEE

### 30

PERM "Core" IEE Revised IEE Subsequent Year/ Multi

- Year IEE CEE Copying: $ 25 Mailing: $ 54 TO TAL $ 79 Copying: $218

Mailing: $ 83 TO TAL $301 Copying: $218

Mailing $83 TO TAL $301 Copying: $ 85

Mailing: $ 47 TO TAL $ 132 Copying: $325

Mailing: $ 81 TO TAL $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 pac kages (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 a nd 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 verifi cation information.

28 Three 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 inc orporates 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 Federa l 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 do es 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 Fe deral government is based on the assumption that most environmental documentation submitted by operators will be IEEs.

29 One

- time capital/start

- up costs usually include any produced physical good needed to provide the necessary inf

ormation. 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.

30 There is no respondent burden or cost associated w ith 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 Es timates : The cost estimates are based on consideration of a "m odel" 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 n ature, 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

FI GURE 7 . Federal Model 1 Jo b Estimate of Estimated time Pay Rate Classification Relative Hours Per Hour (Based on GS

- Level) Cost/Hour Manager 2 0.16 $8 4

. 02 for GS 15 $1 3

. 44 Technical 8 0.68 71

. 41 for GS 14 4 8

. 56 Attorney 1 0.08 71

. 41 for GS

- 14 5. 71 Clerical 1 0.08 2 8

. 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:

FI GURE 8

. Federal Model 2

31 See: Exhibits 2A through E, the Federal government estimates for hours and cost. For example, technical activities a ssociated w ith 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 notificatio n of the operator, if necessary. Other activities listed under Environmental Documentation, such as posting document receipt on the WWW, are administrative.

32 For the "Technical staff," the model uses the GS

- 14 level rates, and assumes that the technical s taff 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 calcul ations are base rates on the GS scale for the Washington, DC, area with a 25% increase to incorporate overhead and fringe benefits.

### 33

Jo b Estimate of Estimated Pay Rate Classification Relative Hours Time Per Hour (Based on GS

- Level) Cost/Hour Manager 1 0.20 $8 4

. 02 for GS 15 $16. 81 Technical 1 0.20 71

. 41 for GS 14 1 4

. 28 Attorney 0 0.00 71

. 41 for GS

- 14 0.00 Clerical 3 0.60 2 8

. 65 for GS

- 07 1 7

. 19

__________ _________ __________ 5 hours 1.00 hour $4 8

. 28 /hour
Based on EPA ’ s experience for the t hirteen 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, generall y, and Section 8.6, preliminary environmental review. The hourl y burden for Federal government review of a PERM is estimated t o 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 p er y ear 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 PERM s has been submitted as the final documentation for expedition s during the thirteen austral summer seasons the Rule has been in effect. 4. IEE Model for Review of Submissions : For I EEs, 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 subm it 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 y ear and, for purposes of maximum burden estimat ion, supplemental information for the subsequent four ye ars. Over the next three y ears, all Multi

- Year IEE submissions will follow the Multi

- Year Model with a revised submission one y ear and two subsequent y ears where only supplemental information is file d. EPA assumes sixteen operators will submit eight multi

- ye ar IEEs. 33 

### EPA

33 For 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 b e 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 nongovernmenta l 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 ef fect. 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 hourl y 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 assessmen t and verification information for an emergency , or 30 hours, for review of this information. An additional 15 hours are assumed for notify ing the Parties and for administrative activities. As with the respondents, the Federal government hours and cost e stimate assumes one such emergency per 10 y ears. 7. Capital/Start Up Costs : The EPA does not anticipate an y 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 estimat es 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 e nvironmental documentation are as follows:

assumed twelve operators w ill submit nine multi

- year IEEs during the time covered by this ICR rene wal. It is possible that three of the operators listed under the Revised IEE model may submit multi

- year rather than revised IEEs. How ever, since the intent of these operators is unk nown, EPA assumed these three operators w ould 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 M ulti

- Year IEE.

34 See Final Rule at Section 8.10. Emergency reporting would be required for emergency activities which wo uld have otherwise required the preparation of a CEE. The estimate is based on reporting requirements only, not the actual cost of the em ergency 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 an y supplemental information. $ One PERM submitted per year b y one operator. I n 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 governm ent 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) Copy ing: 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 ye ar period. 35 

### The O&M cost for cop yi ng is do ubled 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 I EE package and the associated A/V information. The estimated O&M cost for the three IEE models are calculated as follows: Core IEE : (1) Copy ing: 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

35 Three years are used in these calculations because that is the period of time the ICR is in effect before it must be renewe d.

### 36

(2) File Storage: 1 I EE package x $10/package = 10.00 Revised IEE : (1) Copy ing: 200 pages/Revised IEE x 6 copies/I EE 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 I EE 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 I EE package x $10/package = 10.00 Exhibit 2B, including Table 2B, incorporates these estimated O&M costs in the estimated Fede ral government hours and costs for IEEs per year for a following three

- ye ar period based as summarized in Table 4. 36 

### Over the next three ye ars, all Multi

- Year IEE submissions will require a revised submission one y ear and two subsequent y ears where onl y su pplemental 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 cop yi ng the core and revised IEE submis sions 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

TO TAL $ 40 Copying: $261

File Storage: $ 10

TO TAL $271 Copying: $261

File Storage : $ 10

TO TAL $271 Copying: $ 101

File Storage: $ 10

TO TAL $ 111 Copying: $1740

File Storage: $ 10 FedReg: $ 326 TO TAL $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 an y supplemental informatio n.

36 Three 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 b y 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. $ Fort y - five copies of each CEE a re 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 reviewe rs. $ 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) Copy ing: 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 ye ar period. 37 

### The O& M cost for copy ing 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 Pa rties. 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 revie wers. $ Fort y - 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 ye ars.

37 Three 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) Copy ing: 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 $0.1 0/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 y ear period. 38


### 9. Coordinating Review of Other Parties' Documents : I n 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 hourl y burden and cost estimate based on Employ ee Model 1 and the O&M assumptions and estimates below. I t is not possible to predict what may

be received from another Party i n an y given ye ar, and since there is no respondent burden associated with Section 8.12, hours and costs for a three y ear period are not provided bey ond those estimates listed in Exhibit 2E. 39 

### The assumptions used for the O&M estimates include: $ A Federa l 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 I EEs 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) Copy ing: 300 pa ges/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

38 Three years are used in these calculations because that is the period of time the ICR is in effect before it must be renewed.

39 Three 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 en vironmental 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

- ye ar documentation, EPA has developed a model for Federal government review of IEEs based on three ty pes of IEE documentation: (1) "Core" IEE, (2) "Revised" IE E, and (3) "Multi

- Year" IEE.

The hourl y 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 IE E : 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 Rul e 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

- speci fic (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 In formation" 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 "Sup plemental 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 co nsidered to be part of the "Core IEE" and included b y 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 "Supplement al I nformation" 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 whereb y multi

- ye ar IEE documentation will be submitted. The multi

- year prov ision 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. Review of the initial multi

- year do cument 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 multi

ye ar 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 oper ators 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 conside rs 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 hourl y burden for preparation of a Cor e IEE is estimated as follows: Review "core" IEE 80 hrs/I EE x 3 IEEs = 240 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 = 288 hours TOTAL HOURS PER IEE (5 IEEs) = 96 hours TOTAL HOURS PER OPERATOR (5 operators) = 96 hrs 41


### 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 I EEs for the three austral summer seasons this I CR will be in effect. Updates are likely to include such items as dates of expeditions and changes in

40 For 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.

41 If, for example, the A Core @ IEEs cover six operators (e.g., four of the IEEs cover one o perator 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 ite ms 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 est imates 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 A Revised @ IEE is based on EPA = s experience under the Rule and considers the paperwork reduction options employ ed b y the operators. The operator hourly burden for preparation of a A Revised @ IEE is estimated as follows:

Review "revised" IEE 40 hrs/I EE x 3 IE Es = 12 0 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 = 1 68 hours TOTAL HOURS PER IEE ( 3 IEEs) = 56 hours TOTAL HOURS PER OPERATOR ( 3 operators) = 56 hrs 43


### Model 3

- Multi

- Year IE E : 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 y ear. The multi

- ye ar 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 act ivities or revisions to the documented activities. EPA assumes twelve operators may submit "multi

- ye ar" IEEs, and the Federal government hourl y burden for review of the "Multi

- Year" IEE will require review at the Revised IEE level of review (e.g., 40 hour s) and 1 hour for supplemental information. Review also includes 15 hours for A/V information. In subsequent y ears, for purposes of maximum burden estimation, 2 hours per IEE is estimated for review of supplemental information and 15 hours for A/V inform ation. The Federal government hourly burden is estimated as follows for review of "Multi

- Year" IEEs: 44

42 If 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 "c ore" IEE.

43 If, for example, the Revised IEEs cover four operators (e.g., tw o 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.
44 For purposes of d emo nstrating the hourly burden for an operator submitting a Multi

- Year IEE, EPA assumed twelve operators w ould submit nine multi

- year IEEs during the time covered by this ICR rene wal. It is possible that the three operators listed under the Revised IEE mo del m ay submit multi

- ye ar rather than revised IEEs. How ever, since the intent of these operators is unknown, EPA assumed these three operators w ould submit revised IEEs, an assumption that provides the maximum hours and cost estimates for the three year p eriod 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/I EE x 9 IE Es x 1 y r = 3 6 0 hours Review supplemental information: 1 hr/operator x 12 ops x 1 y ear = 12 hours Review A/V information: 15 hrs/operator x 12 ops x 1 y ear = 180 hours Four Subsequent Years for a Total of Five Consecutive Years: Review supplemental information: 1 hr/operator x 12 ops x 4 y ears = 48 hours Review A/V information: 15 hrs/ operator x 12 ops x 4 y ears = 720 hours TOTAL HOURS for 5

- Year Period of Multi

- Year IEE = 1320 hours TOTAL HOURS PER YEAR (5 Years) PER IEE 9 IE Es) = 29 hours TOTAL HOURS PER YEAR (5 Years) PER OPERATOR ( 12 operators) = 22 hours 45


### 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. As sociate 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 A Core @ IEE review, the 56 total hours per A Revised @ IEE review, and the 16 total hours per A Subsequent Year, Multi

Year IEE. Core IEEs Revised IEEs Subseq.Yrs, Multi

- Year IEE 

### s Federal Agency Relative

Tim e/Hr x 96

Hrs Hrs Relative

Tim e/Hr x 56

Hrs Hrs Relative

Tim e/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,

45 Because the nine Multi

- Year IEEs cover tw elve operators (e.g., one IEE covers one operator and the other covers tw o operators), the hour s 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 revie w cost of the Revised IEE is spread am ong 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/ ye ar 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 1 5 repeat operators who are expected to submit new or revised or multi

- ye ar IEE documentation, and three new operators who are expected to submit new I EEs.
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 1 1 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

- IA ATO memb er 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 f urther summarizes for respondents and the Federal government the hours and costs for the most likely documentation scenario for the 3

- ye ar life of this I CR renewal, namely , a "Multi

- Year" IEE which includes for the initial y ear a "Revised" IEE and "Subsequ ent Year, Multi

- Year" IEE documentation for the two subsequent y ears. Exhibit 3 is annualized over a three y ear period by assuming a 3.5% escalation rate per ye ar, the assumed Consumer Price Index (CPI) escalation rate. 47 

### Based on the reporting by operat ors 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 ty pes of nongovernmental activities likely to continue to be undertaken b y U.S.

- based operators in Antarctica, EPA anticipates that the most likely scenario during the three

- ye ar 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 docum entation 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 I EEs. $ It was assumed that 12 of the 15 repeat operators would submit new Multi

- Year IEEs, including a "Revised" IEE in the initial y ear and "Sub sequent Year, Multi

- Year" IEE documentation for the two subsequent y ears. $ 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

.
46 Exhibit 2E summarizes the Federal gove rnment 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 hour s or costs.

47 Three 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 y ears 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

- ye ar period of this I CR renewal. This summary

assumes 18 operators per y ear with 3 new operators and 15 repeat operators each ye ar. 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 I CR renewal period, the annual total hours for the 18 operators is estimated to be 1,254 hours , and the annual total hourl y 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 envir onmental documentation and the paperwork reduction provisions employ ed b y the respondent. As summarized in Chart 3, for the estimated 18 operators submitting environmental documentation under the Final Rule during this I CR renewal period, the annual total cost for the 18 operators is estimated to be $ 100 , 5 75 , 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 a verage per respondent ranges from $3,372 to $14,678 depending on the level of environmental documentation and the paperwork reduction provisions employ ed b y the respondent. As summarized in Chart 3, for the estimated 18 operators submitting envir onmental documentation under the Final Rule during this I CR 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 estima ted as 4 5 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 th e level of environmental documentation and the paperwork reduction provisions employ ed b y 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 BURD**  **EN HOURS AND COST TABLES: (i)**  **RESPONDENT TALLY**
TO TA L 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 “M ulti

- Year” 12 504 $38,880 $1,584 **Total 18**  **1,254 $**  **97,185 $3,390**  

### (ii) **THE AGENCY TALLY**
TO TA L 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 “M ulti

- 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 responden t reporting/recordkeeping burden or cost over the course of the clearance period request.
**6( f**  **) REASONS FOR CHANGE IN BURDEN**  The current inventory

approved b y the Office of Management and Budget (OMB) for the annual reporting and recordkeeping hourl y burden is 1,708 hours . The total 3

- ye ar estimated hourly burden of 3,762 hours for the anticipated 18 operators represents an ann ual reporting and recordkeeping hourl y burden of 1, 254 hours, or 7 0 hours per operator for this 3

- ye ar renewal period. This decreased adjustment to the annual reporting and recordkeeping hourl y burden is 4 54 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 hourl y 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 to tal 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 technol ogy and s ystems for the purposes of collecting, validating, and verify ing information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y with any previously applicable instructions and requ irements; 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 display s 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 t his 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 I CR 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 In formation Center in the EPA Docket Center (EPA/DC), EPA West, Roo m 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 holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the te lephone 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 l isting of the contents of the public docket, and to access those documents in the public docket that are available electronically . When in the sy stem, select “search,” then key in the Docket ID Number identified above. Also, y ou 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 an y correspondence

.

### 48 **Exhibit 1A: PERMs**
**- ESTIMATED RESPONDENT HOURS AND COST** 

Respondent Respondent Rate Range Capit a l/ 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 E nv. 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. I n fact, during the t hirteen austral summer seasons the Rule has been in effect, only two PERM s w ere submitted as the final documentation for an expedition. For purposes of estimating the potential maximum hours and cost associa te d with PERMs over the three

- year life of the I CR, 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 estimat ed time that would be needed to comply with the Rule at Section 8.4, preparation of environmental documents, generally, and S ection 8.6, preliminary environmental review. 3. The cost estimates are based on industry labor rates obtained during informal cons ultations with industry representatives and include overhead and fringe benefits. The three rates used in the calculations r epresent the rates provided by the industry representatives. The $75/hour intermediate rate is used for summary purposes. See Par t 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 ( IE Es) 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 S tartup 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. Pre pare 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 $ 13,87 5 $ 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 I EEs: 1. I EEs 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 I EE package for the initial preparation of an I EE by a n operator. 3. A "Revised" I EE and associated supplemental information comprises the I EE package for a c urrent year's submission developed through revision of a previous year's submission. 4. A Multi

- Year I EE consists of a A Revised @ IE E and the associated supplemental information in the initial year and, for each of the subsequent four years, an annual sub m ission of the advance notice and confirmation that the information provided in the Multi

- Year I EE is unchanged. 5. Supplemental information for purposes of the costs estimated in Exhibit 1B and Table 1 refers to supplemental information submitted regardin g 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" I EE by reference. 6. The cost estimates are based on industry la bor 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 Resp ondent Rate Range ICR Activity: I EEs Hrs/Yr $65/hour $75/hour $100/hour Startup Cost Cost Respondents $65/hour $75/hour $100/hour MODEL 2: "Revised" I EE Environmental Documentation 1. Study the regulations 2. Search reference sources for existing information and compile information from company records 3. Prepare Revised I EE and submit 4. Revise in response to EPA's comments and submit Supplemental I

nformation 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.I nfo. 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/hou r $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 , 0 00 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 $ 1,9 87 $ 2,2 97 $ 3 , 0 47

### 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 TO TA L ESTIMATED POTENT IAL 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 TO TA L 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 IE E 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 follow s for which hours and cost are calculated for "Subsequent Year Multi

- Year" IEE submis sions. “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% estimate d CPI esca lation rate) 30 2,057 2,377 3,154 YEAR THREE (3.5% estimate d CPI escalation rate) 30 2,129 2,460 3,264 TO TA L ESTIMATED PO TENTIAL HOURS and COST: 90 $ 5,192 $ 7,134 $ 9,465 AVERAGE EST. HOURS and COS T 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 tw o subsequent years 30 hrs x 2 = 60 $2,3 78 x 2 = $ 4, 756 TO TA L ESTIMATED POTENTIAL HOURS and COST: 1 25 $ 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/hou r $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 TO TA L 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. I n fact, no CEEs were submitted during the t hirteen 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 I CR, 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 min or 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 obtai ned during informal consultations with industry representatives and include overhead and fringe benefits. The three rates us ed in the calculations represent the rates provided by the industry representatives. The $75/hour intermediate rate is used for su mmary 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 w ere no emergencies that required reporting during the seven austral summer seasons the Rule has been in effect. An incident requiring emergency repo rting could occur in the subsequent years. The follow ing cost estimates are not additive, however, since only one such emergency i n 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 an d reporting f or 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 ac tion. The hours and cost estimate assumes one su ch emergency per 10 years. 2. Only one incident requiring emergency reporting is estimated to occur over a 10

- year period. I n 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 a nd 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 affe cted respondents.

### 55 **Exhibit 2A: PERMs**
**- ESTIMATED FEDERAL GOVERNMENT HOURS AND COST** 

Federal Gov't. Federa l 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 $ 8 8 0

Hours Cost YEAR ONE 12 $ 8 8 0 YEAR TWO (3.5% estimated CPI escalation rate on $794) 12 911 YEAR THREE (3.5% estimated CPI escalation rate on $822) 12 943 TO TA L 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. I n fact, during the t hirteen 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 t he I CR, 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 expe ditions 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 prepa ration of higher level EIA documentation, if necessary, is addressed in Exhibits 2B (I EEs) and 2C (CEEs). 4. Based on EPA = s experience for the t hirteen 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 Ex hibit 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, 6 00

$ 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 & Verificatio n

1. Review A/V information
- Revised IEE 40

1

15 56 $ 2, 8 00

$ 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, 8 00

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. I EEs 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" I EE and associated supplemental information comprises the I EE package for the initial submittal of an I EE by an operator. 3. "Revised" I EE and associated supplemental information comprises the IEE package for a current year's submittal developed through revision of a previous year's su bmittal. 4. A Multi

- Year I EE consists of a Revised I EE and the associated supplemental information in the initial year and, for each of the subse quent four years, an annual submission of the advance notice and confirmation that the information provided in the Multi

- Year I EE 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.) r ather than supplemental information of a more technical nature that is incorporated into the "Core" or "Revised" I EE 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 $ 2 1 , 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 C PI escalation rate) 56 4, 353 YEAR THREE (3.5% estimated CPA escalation rate) 56 4, 5 05 TOTAL ESTIMATED POTENTIAL HOURS and COST: 168 $ 1 3 , 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 cos t 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 TO TA L 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, 1 59 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

$ 1 1 , 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 $ 1 3 , 626

YEAR ONE 165 $1 3 , 626 YEAR TWO (3.5% estimated CPI escalation rate on $12,590) 165 $1 4 , 103 YEAR THREE (35% estimated CPI escalation rate on $13,031) 165 $1 4 , 597 TOTAL ESTI MATED POTENTIAL BURDEN and COST: 495 $ 42 , 326 AVERAGE EST. BURDEN and COST PER YEAR PER OPERATOR: 165 $1 4 , 109 Assumptions: 1. Exhibit 2C represents the estimated hours and cost for CE Es. I n fact, no CEEs were submitted during the ten austral summer seasons the Rule has been in effect. For purposes of esti mating the potential maximum hours and cost associated with CEEs over the three

- year life of the I CR, the three

- year projection ass umes submittal of one CEE per year for each of the next three years. Although one respondent per year is estimated for purpo ses of the cost calculations, EPA anticipates that the actual number of nongovernmental expeditions with activities that will lik el y 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 t he 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 verificatio n 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 Regist er notice and circulate copies of CEEs to all Parties and others that may request copie s.

### 63 **Exhibit 2D: Reporting for Emergencies**
**- Esti**  **ma ted 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 $ 1 1 , 550 None Copying $1740 FR Pub. 0 Store Files 10

___________ $1750 1 $ 10,660 1,750

______ $1 3 , 300

YEAR ONE 165 $1 3 , 300 YEAR TWO (3.5% estimated CPI escalation rate of $12,410) 165 1 3 , 766 YEAR THREE (3.5% estimated CPI escalation rate for $12,845) 165 1 4 , 248

Assumptions: 1. Reporting for Cases of Emergency is based on the Final Rule at Section 8.10, Cases of emergency, which would require noti ce 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 respons e 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. I n fact, there was no emergency reporting during the seven austral summer seasons the Rule has been in effect. An incident requiring emergency reporti ng could occur in the subsequent years. The cost estimates for reporting for cases of emergency are not additive because onl y 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 1 5 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 Inform**  **ation 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 sign ificant 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 fr om 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 P arties during the ten austral summer seasons the Rule has been in effect other than the annual list of IEEs. The re is no way to anticipate receipt of environmental documents from the Parties, other than the annual list of IEEs, on an ann ual basis. There is no burden or cost to the respondents associated with receipt of documents from the Parties, therefore, the cos ts are not further defined.

### 65 **Exhibit 3: SUMMARY**
**- ESTIMATED RESPONDENT/FEDERAL GOVERNMENT HOURS AND COST**  CHART 1: Summary for Respondents and Federal Government

- Estim ated 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 Em ergency Reporting Hours Cost Hours Cost Hours Cost Hours Cost Hours Cost Hours Cost Respondent Year 1 Year 2 Year 3 TO TA L 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 TO TA L Annual Average 12 $ 8 80 12 $ 911 12 $ 943 36 $ 2, 734 12 $ 911 96 $ 7 , 006

96 $ 7 , 251 96 $ 7 , 504 288 $2 1 , 761 96 $ 7 , 254 56 $ 4 , 206

56 $ 4, 353 56 $ 4, 505 168 $1 3 , 064 56 $ 4, 355 16 $ 1, 120

16 $ 1, 159 16 $ 1, 200 48 $ 3, 479 16 $ 1, 159 165 $ 1 3 , 626

165 $ 1 4 , 103 165 $ 1 4 , 597 495 $ 42 , 326 165 $ 1 4 , 109 165 $1 3 , 300

165 $1 3 , 766 165 $1 4 , 248

TO TA L Annual Average 156 $12, 298

52 $ 4,0 99 843 $6 5 , 795

281 $21, 931 363 $2 9 , 141

121 $ 9, 714 1 38 $ 10 , 613

4 6 $ 3, 538 1395 $11 3 , 478

465 $ 3 7 , 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 mo st 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) 1 25 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 TO TA LS

- For one operator 2 1 3 hours 71 hrs per op per yr $ 1 6 , 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 l evel and type of environmental document a respondent would likely submit under the Final Rule. The $75/hour intermediate rate is u sed 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 28 8 x 3 = 8 64 $ 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 = 1 95 $ 5,359 x 3 = $ 1 6 , 077 1 95 x 3 = 585 $ 16,077 x 3 = $ 48 , 231 56 x 3 = 168 $ 4, 355 x 3 = $ 13 , 065 1 68 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 = $ 4 0,464 504 x 3 = 1,512 $ 40,464 x 3 = $ 121 , 392 29 x 1 2 = 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 TO TA L 3

- YEAR BURDEN for 18 operators TO TA L 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 13 4 $ 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 = $ 2,4 3 9 $ 2,4 3 9 + 62,8 4 7 = $65,2 8 6 3 of 15 repeat operators submit "Revised" IEEs each year Burden per year Total 3

- year burden $ 301 x 3 = $ 903 $ 903 + 1 5 , 174 = $ 1 6 , 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 ,7 56 = $ 39 , 195 12 of 15 repeat operators submit new "Multi

- Year" IEEs 48 Burden per year Total 3

- year burden $ 132 x 1 2 = $ 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 TO TA L 3

- YEAR BURDEN for 18 operators TO TA L 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 C o st $ 2 , 95 8 + 58 , 5 57 = $ 6 1 , 515 $ 1 64 + 3, 2 5 3 = $ 3, 417 $ 8 , 874 + 1 75 , 6 7 1 = $ 184,545 $ 49 3 + 9 , 75 9 = $ 10 , 25 3

48 New "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: Respon dent $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

.