INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR EPA ICR 

RENEWAL OF THE ICR FOR THE REGIONAL HAZE REGULATIONS

Page 1 of 19

United States Environmental Protection Agency

Office of Air and Radiation

Office of Air Quality Planning and Standards

Air Quality Policy Division

Geographic Strategies Group

INFORMATION COLLECTION REQUEST

SUPPORTING STATEMENT FOR

EPA ICR NUMBER 1813.08,

RENEWAL OF THE ICR FOR THE 

REGIONAL HAZE REGULATIONS

EPA

Draft April 19, 2012

EPA # 1813.08
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR EPA ICR 

RENEWAL OF THE ICR FOR THE REGIONAL HAZE REGULATIONS

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This ICR, EPA Form 1813.08, is an update of the Office of Management 

and Budget (OMB) Control Number 2060-0421; EPA Form 1813.07 which 

expires on October 31, 2012. The current approved collection is for 859 

respondents, 31,841 hours per year, and $2,563,000 per year. This renewal 

requests approval for 35 respondents (34 state agencies, and 1 group of 

Federal Land Managers (FLMs)), 4,080 hours per year, and $198,084 per 

year. Table E.1 summarizes the total annual respondent burden for this 

renewal. No tribes submitted regional haze plans, so there are no burden 

estimates for them.

The change in burden is a program adjustment, reflecting changes in labor 

rates, changes in the activities conducted due to the normal progression of 

the program, and the fact that the aggregate initial regional haze state 

implementation plans (SIPs) and best available retrofit technology (BART)

determinations will have been acted upon by the EPA by November 2012 

and the states will be shifting their focus to development of interim 

progress reports required by the regional haze rule. 

Table E-1 Estimated State, Source, and FLM Respondent Burden to 

Implement Requirements

Task Element

States Source FLMs

Average Annual 

Hours

Average 

Annual 

Cost ($)

Average 

Annual 

Hours

Average 

Annual 

Cost ($)

Average 

Annual 

Hours

Average 

Annual 

Cost ($)

Total Burden by 

Respondent

3,173 154,049 0 0 907 44,035

Total for 

Respondent 

Universe

4,080 hours; $198,084

Executive Summary

Draft 04/17/12
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR EPA ICR 

RENEWAL OF THE ICR FOR THE REGIONAL HAZE REGULATIONS

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This document fulfills the Agency's requirements under the Paperwork 

Reduction Act (PRA) with regards to determining the regulatory burden 

associated with the 

implementation of the 

regional haze program (40 

CFR 51.308) and 

requirements related to the 

Grand Canyon Visibility

Transport Commission (40 

CFR 51.309). It has been 

assigned EPA tracking 

number 1813.08. The title of 

this Information Collection 

Request (ICR) is “Information Collection Request Supporting Statement 

for EPA ICR Number 1813.08, Renewal of The ICR for the Regional Haze 

Regulations.”

Subpart P of 40 CFR 51, Protection of Visibility, also known as the 

regional haze rule, is the subject of this clearance request. In the next 3 

years, activities conducted by the states, Federal Land Managers (FLMs), 

and the EPA will focus on reporting requirements in the rule to address the 

progress of regional haze implementation plans. 40 CFR 51.308 (g)

requires states to develop periodic reports evaluating progress towards the 

reasonable progress goals for improving visibility in Class I areas inside 

the state and in neighboring states. There are similar reporting requirements 

under 40 CFR 51.309, a section of the regional haze rule in which 3 states 

(Utah, Wyoming, and New Mexico) elected to submit their SIPs. Under 

section 309, these states adopted regional haze strategies for the period 

from 2003 to 2018 for sulfur dioxide emissions. These strategies are based 

on recommendations from the Grand Canyon Visibility Transport 

Commission (GCVTC) for protecting the 16 Class I areas on the Colorado 

Plateau area. 

On June 15, 2005, the EPA finalized amendments to the July 1999 regional 

haze rule. These amendments apply to the provisions of the regional haze 

rule that require emission controls known as best available retrofit 

technology, or BART, for industrial facilities emitting air pollutants that 

reduce visibility by causing or contributing to regional haze. The pollutants 

that reduce visibility include fine particulate matter (PM2.5), and 

compounds which contribute to PM2.5 formation, such as nitrogen oxides 

(NOX), sulfur dioxides (SO2), and under certain conditions volatile organic 

compounds (VOC), and ammonia. 

The BART requirements of the regional haze rule apply to facilities built 

between 1962 and 1977 that have the potential to emit more than 250 tons 

1 Identification of the Information Collection

1.1 Title

OMD1.2

Description

EPA TRACKING NUMBER: 

1813.08

E-TRACKING NUMBER:

OMB-2060-0421

1.2 Description
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR EPA ICR 

RENEWAL OF THE ICR FOR THE REGIONAL HAZE REGULATIONS

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per year of visibility-impairing pollution. Those facilities fall into 26 

categories, including utility and industrial boilers, and large industrial 

plants such as pulp mills, refineries and smelters. Many of these facilities 

have not been previously subject to federal pollution control requirements 

for these pollutants.

Under the 1999 regional haze regulations, states are required to set periodic 

goals for improving visibility in the 156 Federal Class I areas. As states 

work to reach these goals, they must develop regional haze implementation 

plans that contain enforceable measures and strategies for reducing 

visibility-impairing pollution. The 2005 amendments include guidelines, 

known as BART guidelines, for states to use in determining which facilities 

must install controls and the type of controls the facilities must use. States 

had to develop their implementation plans by December, 2007. As part of 

those plans, states were required identify the facilities that will have to 

reduce emissions under BART and then set BART emissions limits for 

those facilities.

The majority of the states did not submit their SIPs on time, and the EPA is 

currently subject to several consent decrees establishing schedules for final 

actions on the SIPs, or promulgation of FIPs, that in the aggregate require 

the agency to complete all remaining unfinished actions on the initial 

regional haze implementation plans by November 2012. Since that date 

aligns closely with the expiration of the currently approved ICR (October 

31, 2012) and the majority of the effort required to complete the actions on 

the initial SIPs will have occurred, the primary focus for estimating burden 

for this 3 year renewal period (October 31, 2012 – October 30, 2015) will 

apply to the next program milestone which is the 5 year periodic progress 

report (see 40 CFR 51.308(g)). The due date for states to submit the 

progress reports is 5 years from their initial regional haze SIP submittals, 

and for an estimated 34 states, that due date falls within the date range of 

this ICR renewal. In the 5 year progress reports, states are required to 

describe the status of the implementation of measures needed to achieve 

reasonable progress goals, report on the emissions reductions achieved, 

assess visibility changes, and evaluate whether the current implementation 

plan is sufficient to meet all established reasonable progress goals.
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR EPA ICR 

RENEWAL OF THE ICR FOR THE REGIONAL HAZE REGULATIONS

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Section 169A of the Clean Air Act (CAA) sets forth a national goal for 

visibility. The goal is the “prevention of any future, and the remedying of 

any existing, impairment in visibility in mandatory Class I Federal areas 

which impairment results from man-made air pollution.” This section of the 

CAA also calls for EPA regulations to assure that states provide for 

reasonable progress toward meeting the national goal. The original 

regulations on protection of visibility in mandatory Class I Federal areas, 

developed in 1980, addressed visibility that is “reasonably attributable” to a 

single source or small group of sources. The regional haze rule, 

promulgated in 1999, added new sections to the code of federal 

environmental regulations. These included sections 40 CFR 51.308 and 40 

CFR 51.309. This ICR renewal request provides for continued 

implementation of the regional raze rule. During this clearance period, we 

anticipate that the reporting requirements under 40 CFR 51.308(g) will be 

the major program focus and the similar reporting requirements (see 40 

CFR 51.309(d)(10)) for 3 states that submitted regional haze SIPs under 40 

CFR 51.309

 

The data collected from respondents include revised state implementation 

plans. These data confirm progress in assessing visibility impairment and 

source contribution, and provide the foundation for the establishment of the 

reasonable progress goals, control strategies, and BART requirements. 

The information in this ICR is based upon the best data available to the 

Agency at this time. However, incomplete data and sampling limitations 

imposed necessitated a certain amount of extrapolation and “best-guess” 

estimations. Consequently, the reader should not consider the conclusions 

to be an exact representation of the level of burden or cost that will occur. 

Instead, this ICR should be considered a directionally correct assessment of 

the impact the programmatic changes included in this rulemaking may have 

over the next 3 years. 

Throughout this ICR, the reader will observe estimated values that show 

accuracy to the single hour or dollar. However, reporting values at the 

single unit level can be misleading. In most situations, the proper way to 

present estimated data would be to determine an appropriate level of 

precision and truncate values accordingly, usually in terms of thousands or 

millions of units. For instance, a spreadsheet generated estimation of 

$5,456,295 could be presented in the text as $5.5 (millions) or $5,456 

(thousands). One problem with such an approach is the loss of data richness 

when the report contains a mixture of very large and very small numbers. 

Consequently, to avoid the loss of information through rounding, this ICR 

2 Need and Use of the Collection

2.1 Need / Authority 

for the Collection

2.2 Practical Utility / 

Users of the Data

2.3 Caveats and 

Considerations
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR EPA ICR 

RENEWAL OF THE ICR FOR THE REGIONAL HAZE REGULATIONS

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reports all values at the single unit level and reminds the reader that there is 

no implied precision inherent in this style of reporting.
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR EPA ICR 

RENEWAL OF THE ICR FOR THE REGIONAL HAZE REGULATIONS

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This information collection renewal request is related to provisions in 40 

CFR 51.308(g) and 40 CFR 51.309(d)(10) which require periodic reports 

describing progress towards the reasonable progress goals. Each state must 

submit an implementation plan revision evaluating whether improvement 

in visibility is made towards the reasonable progress goal for each 

mandatory Class 1 Federal area located within the state and in each 

mandatory Class 1 Federal area located outside the state which may be 

affected by emissions from within the state. These implementation plans 

are due 5 years from the submittal of the initial regional haze plan. The 

reasonable progress implementation plans required by the regional haze 

rule are unique and do not duplicate other implementation plan 

requirements.

In compliance with the PRA, this draft ICR must solicit public comments 

for a 60-day period prior to submission to OMB. 

For any existing rule, § 3507(g) of the PRA limits how long a Director may 

take to approve a collection of information to 3 years. The ICR for the 

regional haze rule was revised last in August 2009. We solicited public 

comments on this ICR prior to submitting it to OMB. We issued a Federal

Register notice requesting comments on the ICR renewal on August 26, 

2009 (74 FR 43118). No significant comments were received.

The EPA consulted with the EPA Region 5 Office for comment, review, 

and suggestions on this ICR renewal. The point of contact for the regional 

office is John Summerhays, regional haze coordinator for EPA Region 5, 

(312)886-6067. Mr. Summerhays had no comments. 

We also contacted the state of Virginia Department of Environmental 

Quality (DEQ), explained the requirements of the ICR renewal, and 

solicited comment. The point of contact is Mr. Michael Kiss, Director, 

Office of Air Quality Assessments, Richmond, VA, (804) 698-4460. Mr. 

Kiss had no comments. 

The information collection requested under this ICR is necessary to ensure 

implementation of the 40 CFR 51.308 and 40 CFR 51.309 requirements. 

OMB's general guidelines for information collections must be adhered to 

by all federal agencies for approval of any rulemaking's collection 

methodology. In accordance with the requirements of 5 CFR 1320.5, the 

Agency believes:

1. The regional haze regulations do not require periodic reporting 

more frequently than every 5 years.

3 Non-Duplication, Consultation, and Other Collection Criteria

3.1 Non-Duplication

3.2 Public Notice 

Requirements

3.3 Consultations

3.4 Less Frequent

Collection

3.5 General

Guidelines
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR EPA ICR 

RENEWAL OF THE ICR FOR THE REGIONAL HAZE REGULATIONS

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2. The regional haze regulations do not require respondents to 

participate in any statistical survey.

3. Written responses to Agency inquiries are not required to be 

submitted in less than 30 days.

4. Respondents do not receive remuneration for the preparation of 

reports required by the Act or part 51.

5. To the greatest extent possible, the Agency has taken advantage of 

automated methods of reporting.

The recordkeeping and reporting requirements contained in the current 

regional haze program and the changes proposed in this rulemaking do not 

exceed any of the Paperwork Reduction Act guidelines contained in 5 CFR 

1320.5, except for the guideline which limits retention of records by 

respondents to 3 years. The Act requires both respondents and state or local 

agencies to retain records for a period of 5 years. The justification for this 

exception is found in 28 U.S.C. 2462, which specifies 5 years as the 

general statute of limitations for federal claims in response to violations by

regulated entities. The decision in U.S. v. Conoco, Inc., No. 83-1916-E 

(W.D. Okla., January 23, 1984) found that the 5-year general statute of 

limitations applied to the CAA.

Confidentiality is not an issue for this rulemaking. In accordance with the 

Clean Air Act Amendments of 1990, any monitoring information to be 

submitted by sources is a matter of public record. To the extent that the 

information required is proprietary, confidential, or of a nature that could 

impair the ability of the source to maintain its market position, that 

information is collected and handled subject to the requirements of §503(e) 

and §114(c) of the Act. Information received and identified by owners or 

operators as confidential business information (CBI) and approved as CBI 

by EPA, in accordance with Title 40, Chapter 1, Part 2, Subpart B, shall be 

maintained appropriately (see 40 CFR 2; 41 FR 36902, September 1, 1976; 

amended by 43 FR 39999, September 8, 1978; 43 FR 42251, September 

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

The consideration of sensitive questions, (i.e., sexual, religious, personal or 

other private matters), is not applicable to this rulemaking. The information 

gathered to develop an implementation plan does not include personal data 

on any owner or operator.

Because the regional haze program operates nation-wide and across 

numerous industry classifications, the Agency does not believe there is a 

disproportionate EJ effect in the regional haze program. 

3.6 Confidentiality

3.7 Sensitive 

Questions

3.8 Environmental 

Justice 

Considerations
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR EPA ICR 

RENEWAL OF THE ICR FOR THE REGIONAL HAZE REGULATIONS

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The major categories of respondents directly affected during this ICR 

period of October 31, 2012 through October 15, 2015 include the states and 

FLMs. The states are developing implementation plans under 40 CFR 

51.308(g) and 40 CFR 51.309(d)(10) evaluating progress towards the 

reasonable progress goal for each mandatory Class I Federal area located 

within the state and in each mandatory Class I Federal area located outside 

the state which may be affected by emissions from within the state. 

The FLMs will evaluate the SIP revisions and provide comments to the 

states. The states are required to consult with the FLMs and explain how 

they address the FLMs comments in their final SIPs.

The information required under this ICR renewal provides for a 

continuation of the process initiated with previous ICRs for the regional 

haze rule. In this stage of the process, the states are revising their SIPs to 

report on progress made towards reaching their long term visibility goals. 

For 34 states, the progress reports will be due during the October 31, 2012 

to October 30, 2015 ICR period.

The information that is requested under this renewal period under the 

regional haze rule requirements includes:

Submittal of Requirements for Periodic Reports Describing Progress 

Towards the Reasonable Progress Goals

 Description of status of control measures

 Summary of emission reductions

 Calculation of visibility conditions and changes

 Calculation of 5 year progress

 Assessment of contributing emissions 

 Assessment of reasonable progress goals 

 Review monitoring strategy and note changes

 Submit 5 year progress report

 Determine degree of visibility improvement

 Consult with FLMs

The first progress reports must be in the form of implementation plan 

revisions that comply with procedural requirements of 40 CFR 51.102 and 

40 CFR 51.103. The reports are due 5 years after the initial regional haze 

plan submission.

4 The Respondents and the Information Requested

4.1 Respondents/

4.2 Information

Requested
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR EPA ICR 

RENEWAL OF THE ICR FOR THE REGIONAL HAZE REGULATIONS

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EPA. Each EPA regional office is responsible for reviewing and approving 

the SIPs and promulgating FIPs when necessary. For this ICR renewal 

period, the EPA will primarily be reviewing the SIP revisions required 

under 308(g) and 309(d)(10), which are the periodic progress reports. The 

10 EPA regional offices as well as the EPA headquarters offices will 

provide direction and facilitate resolution of major issues, and deliver data, 

tools, and training to the states as needed. Each regional office must 

address public comments before approving the SIPs or promulgating FIPs.

FLMs. The FLMs will be reviewing the SIP revisions and offering 

comments as part of the public comment process.

This section discusses the development of burden estimates and their 

conversion into costs, which are separated into burden costs and capital and 

O&M costs. According to the latest guidance for ICRs (EPA 11/05), capital 

and O&M costs display the cost of any new capital equipment the 

respondent may have to purchase solely for information collection, 

assimilation, and storage purposes. For example, if a source had to 

purchase a new mini-computer to store and manipulate data, that computer 

would be a cost of administration subject to reporting in the ICR. In 

addition, the latest guidance instructs the Agency to differentiate the burden 

associated with a source’s labor and that which it hires through outside 

contractors. To the extent a source contracts out for administrative purposes 

(e.g., employing consultants to perform visibility modeling), the burden 

associated with those contracted tasks are not a burden to the source - but 

they still remain a cost. The reader should read this section with the 

following considerations in mind:

 The Agency believes the time necessary to perform a task is 

independent of the origins of its labor. For example, if a source 

would employ 20 hours of burden to fully perform a function, then 

a contractor hired by the source would also take 20 hours to 

perform that same task. Furthermore, the Agency assumes no 

economies or diseconomies of scale. The linear combination of any

amount of contractor and source effort will also sum to 20 hours. 

Therefore, the burden estimates in this ICR act as an accurate 

assessment of the total burden to respondents.

 For some burden categories, the Agency believes the hours assigned 

to them will be divided between the source and outside contractors. 

For these categories, the Agency established a composite cost per 

hour by developing a weighted average of the source and contractor 

wages, with the weight defined by the percentage of total effort 

each burden source applied. Consequently, the cost developed in 

this ICR should be interpreted as an upper bound on the actual cost 

5 The Information Collected - Agency Activities, Collection Methodologies, and 

Information Management

5.2 Collection 

Methodology

and

Management

5.1 Agency

Activities
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR EPA ICR 

RENEWAL OF THE ICR FOR THE REGIONAL HAZE REGULATIONS

Page 11 of 19

of administration by the source. The methodology for determining 

cost per hour can be found in greater detail in section 6.2, below.

 While this ICR renewal estimates burden to federal and state 

agencies, it does not include costs estimates to the industrial 

sources. This is because the effort for this ICR renewal period, 

October 31, 2012 through October 31, 2015 mainly involves 

preparation and review of the progress reports required under 

308(g) and 309(d)(10) of the regional haze rule. Sources, for the 

most part, will not be involved in preparation of these reports.

The implementation plans prepared by the states are periodic progress 

reports which are due five years after the state submits its comprehensive 

regional haze SIP. The plans must at a minimum include the following 

elements:

 A description of the status of all measures included in the regional 

haze implementation plan for achieving reasonable progress.

 A summary of the emissions reductions achieved throughout the 

state through implementation of the measures.

 An assessment of the following visibility conditions and changes 

for each mandatory Class 1 Federal area within the state with values 

for most impaired and least impaired days expressed in terms of 5-

year averages of the annual values: current visibility conditions for 

the most impaired and least impaired days; the difference between 

current visibility conditions for the most impaired and least 

impaired days and baseline visibility conditions; and the change in 

visibility impairment for the most impaired and least impaired days 

over the past 5 years.

 An analysis tracking the change over the past 5 years in emissions 

of pollutants contributing to visibility impairment from all sources 

and activities within the state.

 An assessment of any significant changes in anthropogenic 

emissions within or outside the state that have occurred over the 

past 5 years that have limited or impeded progress in reducing 

pollutant emissions and improving visibility.

 An assessment of whether the current regional haze implementation 

plan elements and strategies are sufficient to enable the state, or 

other states with mandatory Class 1 Federal areas affected by

emissions from the state, to meet all established reasonable progress 

goals.

 A review of the state’s visibility monitoring strategy and any

modifications to the strategy as necessary.

 Other elements, including reporting, record keeping, and other 

measures, necessary to assess and report on visibility.
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR EPA ICR 

RENEWAL OF THE ICR FOR THE REGIONAL HAZE REGULATIONS

Page 12 of 19

The Regulatory Flexibility Act (RFA) requires regulatory agencies, upon 

regulatory action, to assess that action’s potential impact on small entities 

(businesses, governments, and small non-governmental organizations) and 

report the results of the assessments in (1) an Initial Regulatory Flexibility

Analysis (IRFA), (2) a Final Regulatory Flexibility Analysis (FRFA), and 

(3) a Certification. For ICR approval, the Agency must demonstrate that it 

"has taken all practicable steps to develop separate and simplified 

requirements for small businesses and other small entities" (5 CFR 

1320.6(h)). In addition, the agencies must assure through various 

mechanisms that small entities are given an opportunity to participate in the 

rulemaking process. 

The EPA determined that it was not necessary to prepare a regulatory

flexibility analysis in connection with the regional haze rule (July 6, 2005, 

70 FR 39104) because the rule did not have a significant economic impact 

on a substantial number of small entities. Similarly, this ICR renewal will 

not impose any direct requirements on small entities and will apply

primarily to states which are developing the SIP revisions.

States are required to submit their periodic progress reports, in the form of 

a SIP revision, 5 years after the initial regional haze plan submission. Table 

5.1 shows when these reports are due for each of the states. Note that some 

states have reports which are due outside of this renewal period, beyond 

October 31, 2012. Accordingly, we have estimated burden only for the 34

states with due dates that fall in 2015 or earlier.

Table 5.1 Due Dates for the 5 Year Progress Reports1

Initial Regional Haze 

Submittal Year

5 Year Progress Report 

Due Date

State

2007 2012 NC, SC

2008 2013 AL, AR, DE, KY, LA, 

MS, MO, TN, UT, 

Albuquerque/Bernalillo 

County NM2

2009 2014 CA, CT, KS, MN, NV, 

NJ, RI, TX, VT

2010 2015 District of Columbia, 

 

1 The EPA is developing FIPs for Hawaii, Montana, and the Virgin Islands and due dates 

for the progress reports will be based on the dates of the FIP promulgation

2

 Albuquerque/Bernalillo County in New Mexico must also submit a regional haze SIP to 

completely satisfy the requirements of section 110(a)(2)(D)(i)(II) of the CAA for the 

entire State of New Mexico under the New Mexico Air Quality Control Act (section 74-2-

4).

5.4 Collection

Schedule

5.3 Small Entity

Flexibility
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR EPA ICR 

RENEWAL OF THE ICR FOR THE REGIONAL HAZE REGULATIONS

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FL, GA, ID, ME, MI, 

NH, NY, ND, OK, OR, 

PA, VA

2011 2016 AK, AZ, CO, IN, NE, 

NM, OH, SD, WA, 

WY

2012 2017 MA, MD
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR EPA ICR 

RENEWAL OF THE ICR FOR THE REGIONAL HAZE REGULATIONS

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

persons to generate, maintain, retain, or disclose or provide information to 

or for a federal agency. This includes the time needed to review 

instructions; develop, acquire, install, and utilize technology and systems 

for the purposes of collecting, validating, and verifying information, 

processing and maintaining information, and disclosing and providing 

information; adjust the ways to comply with any previously applicable 

instructions and requirements; train personnel to be able to respond to a 

collection of information; and transmit or otherwise disclose the 

information. The burden estimate should be composed of (1) the total 

capital and start-up cost component annualized over its useful life; (2) the 

total operation, maintenance and purchases of services component. Each 

component should be divided into burden borne directly by the respondent 

and any services that are contracted out.

This ICR renewal will apply primarily to 34 states which are developing 5-

year progress reports in the form of SIP revisions to satisfy the 

requirements of the regional haze rule. Table 5.1 above shows when these 

reports are due for each of the states and the estimated due date for the 

SIPs. The FLMs will review and comment on those plans. For this renewal 

period, the burden for industrial sources will be negligible as the reports are 

required from the states.

For three states (Utah, Wyoming, and New Mexico) which submitted their 

regional haze SIPs under section 309 of the regional haze rule, there are 

also 5-year periodic reporting requirements that are essentially the same as 

the requirements under section 308(g). Table 6.1 summarizes the results for 

each of the major categories of respondents with details discussed in the 

narrative below.

Develop and Submit 5-Year Progress Reports as required under the 

Regional Haze Rule. Based on the elements that are required for the 

report, which are described in section 5.2 above, we believe that an 

estimate of 280 hours per state to complete the report is reasonable. Much 

of the analysis for the report will entail the states assessing changes in their 

emission inventories for the reporting period and reporting on changes in 

visibility based on available monitoring data. This burden estimate does not 

include any hours for preparation and finalization of the emission 

inventories because it is assumed that the EPA will provide an approved 

inventory, with appropriate forward projections of future visibility

conditions, which the states may use for their analyses. For each individual 

state, we believe that approximately 160 hours on average is needed to 

analyze, evaluate, and summarize changes in the inventory and monitoring 

data over the reporting period, and another 80 hours is sufficient to prepare 

the report in the form of a SIP revision. These estimates are based on 

6 Estimating the Burden and Cost of the Collection

6.1 Estimating 

Respondent 

Burden

5.4 Collection

Schedule
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR EPA ICR 

RENEWAL OF THE ICR FOR THE REGIONAL HAZE REGULATIONS

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informal conversations with state and the EPA’s technical staff. Finally, we 

assumed that states would need approximately 40 additional hours to 

address and respond to any public comments received on its SIP revision.

We assumed the FLMs would spend 80 hours, on average, reviewing and 

formally commenting on each of the SIP revisions.

Table 6.1. Estimated Respondent Burden to Implement Requirements

Task Element Hours/State Hours/Source FLM –

hours/state 

SIP

Year 

Incurred

Develop and submit 

§308(g) or 309(d)(10) 

Implementation Plan – 5-

year periodic reports

240 0 80 2012 - 2015

This ICR uses the most recently available wage values with the wage rate 

methods established in the New Source Review (NSR) ICRs3. For this 

renewal period, the burden for industrial sources will be negligible as the 

reports are required from the states with review being done by the EPA and 

the FLMs. 

Consistent with methodologies for previous NSR ICRs, the labor rate used 

to calculate federal, state, and local respondents’ labor costs is 

approximated from the 2012 federal government pay schedule. Managerial 

rates are accounted for by multiplying the hourly rate by 9%; the clerical 

support rates are multiplied by 13%.4The hourly rate is $48.55, and the 

calculation is shown in Table 6.3

Table 6.3 Determination of Federal, State, and Local Wage Rates

Annual Salary of Technical Staff, GS 11 Step 3 (FY 12 Schedule)* $53,639.00

Annual Cost of Supervisory Staff, GS 13 Step 3 (FY 12 Schedule)* $76,452.00

Factor (1/11) 0.09

$6,880.68

Annual Cost of Support Staff, GS 6 Step 6 (FY 12 Schedule)*

Factor (1/8)

$35,672.00

0.13

$4,637.36

Annual Applicable Salary of Technical Staff $65,157.04

 

3

U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, 

INFORMATION COLLECTION REQUEST FOR CHANGES TO PREVENTION OF 

SIGNIFICANT DETERIORATION AND NONATTAINMENT NEW SOURCE REVIEW: 

EMISSIONS TEST FOR ELECTRIC GENERATING UNITS, August 2006, p. 20

4

Ibid.

6.2 Estimating 

Respondent Costs
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR EPA ICR 

RENEWAL OF THE ICR FOR THE REGIONAL HAZE REGULATIONS

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Benefits (at 16%) $10,425.13

Sick Leave / Vacation (at 10%) $6,515.70

General Overhead (at 29%) $18,895.54

Total Cost Per FTE $100,993.41

Total Hourly Cost (Total Per FTE divided by 2,080 hours per year) $48.55

* http://www.opm.gov/oca/12tables/html/gs.asp February 2012

Since the purchase of capital equipment is believed to be an insignificant 

factor in meeting the requirements associated with this ICR renewal, the 

EPA assumes the operation, maintenance, or services are negligible Most 

of the data and other guidance for estimating emissions and visibility

impacts are available in electronic form and any equipment needed to 

respond to requests will be part of the respondent’s operating inventory.

Typically annualized capital cost would be derived from a discounted net 

present value of the stream of costs that would occur over the life of the 

activity, or the ICR, whichever is shorter. However we do not anticipate 

these types of expenses will be incurred during this clearance period. 

For this ICR, we have assumed the following number of offices will be 

involved in implementing the Regional Haze requirements.

EPA Regional Offices. We assume that all 10 EPA Regional Offices will 

be responsible for reviewing implementation plans from the states in their

jurisdiction, responding to public comments, and preparing federal register

notices in taking final action on the SIPs. 

EPA Headquarters. The EPA Headquarters staff will provide oversight 

and review of the submittals.

Table 6.4 presents our estimate of the Agency burden in the ICR clearance 

period which is the average to review one state plan. In developing these 

estimates, we considered previous estimates for similar activities, 

particularly related to the time necessary to review SIPs and prepare federal 

register notices and respond to public comments. The SIP revisions for this 

renewal period are anticipated to be much abbreviated compared to the 

comprehensive regional haze SIP submittals which are required to be 

submitted every 10 years. This results in a reduced burden relative to the 

previous ICR renewals as there are no modeling, emission inventory, or 

control strategy analyses due during the 2012 – 2015 collection period.

Summing the total hours from Table 6.4 (400 hours) and multiplying by 34 

total plans yields a total estimate of 13,600 hours. Using the calculated

labor rate of $48.55/hr, from Table 6.3, multiplied by the 13,600 hours 

6.2.3 Annualized

Capital Costs

6.3 Estimating 

Agency Burden 

and Cost
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR EPA ICR 

RENEWAL OF THE ICR FOR THE REGIONAL HAZE REGULATIONS

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gives an estimated cost of $660,280, which when averaged over the 3 year 

collection period is $220,093 per year as the Agency’s burden estimate.

Table 6.4. Estimated Agency Burden to Implement Requirements

Task Element Hours/EPA

Regional Office

Hours/EPA

Headquarters

Year Incurred

Review Periodic 

Progress Reports 

from States

160 80 2012 - 2015

Respond to Public 

Comments and 

Prepare Federal 

Register Notices

120 40 2012 – 2015

TOTAL 280 120

For the purpose of estimating burden in this ICR, the respondent universe is 

determined as follows.

States. We assume that 34 states, including Bernalillo County in New 

Mexico, will be affected by the regional haze rule reporting requirements. 

Tribes. No tribes have elected to develop and implement the regional haze 

plan.

Industry. The sole regional haze requirement for this reporting period is 

for the states to submit periodic progress reports, and thus there is no 

anticipated burden for industrial sources.

FLMs. The burden hours for FLMs are estimated for the group as a whole, 

and are estimated to be 80 hours for each SIP revision. For 34 total SIPs, 

the total hours would be 2,720. Multiplying by the labor rate of $48.55/hr 

equates to a cost of $132,056, or $44,019 per year for each of the 3 years.

Tables 6.6 summarizes the total annual respondent burden which is 4,080

hours per year and $198,000 per year. As described in section 6.2.2 and 

6.2.3, there are no operation and maintenance costs or capital costs 

associated with activities to be conducted during this 3-year clearance 

period. The total number of respondents is 35 (34 state agencies and 1 

group of FLMs.)

6.5 Bottom Line 

Burden and Cost

6.4 Estimating the 

Respondent 

Universe
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR EPA ICR 

RENEWAL OF THE ICR FOR THE REGIONAL HAZE REGULATIONS

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Table 6.6 Estimated Annual Respondent Burden to Implement 

Requirements

Task Element

States FLMs

Average Annual 

Hours

Average 

Annual Cost 

($)

Average 

Annual Hours

Average 

Annual Cost 

($)

Develop and 

submit §308(g) or 

309(d)(10) 

Implementation 

Plan – 5-year 

periodic reports

3,173

Calculation:

(280 hours per 

plan x 34 plans)/3

years=

3,173 hr/yr

154,049

Calculation:

(3,173 hrs per 

yr x labor rate 

of $48.55)

0 0

Review and 

Comment on 

Reports

0 0 907

Calculation:

(80 hours per 

plan x 34 

plans)/3 years=

907 hr/yr

44,035

Calculation:

(907 hrs per yr 

x labor rate of 

$48.55)

Total Burden by

Respondent

3,173 154,049 907 44,035

Total for 

Respondent 

Universe

4,080 hours; $198,084

The burden estimates for this ICR renewal period cover different task 

elements than those for the previous renewal (1813.07). These differences 

reflect the requirements of the final regional haze rule with respect to the 

scheduled events and activities in the implementation process.

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

persons to generate, maintain, retain, or disclose or provide information to 

or for a federal agency. This includes the time needed to review 

instructions; develop, acquire, install, and utilize technology and systems 

for the purposes of collecting, validating, and verifying information, 

processing and maintaining information, and disclosing and providing 

information; adjusting the existing ways to comply with any previously

applicable instructions and requirements; training personnel to be able to 

respond to a collection of information; searching data sources; completing

and reviewing the collection of information; and transmitting or otherwise 

disclosing the information. The Agency may not conduct or sponsor, and a 

person is not required to respond to, a collection of information unless it 

displays a currently valid OMB control number. The OMB control numbers 

for the EPA’s regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 

15.

6.6 Reasons for 

Change in 

Burden

6.7 Burden 

Statement
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR EPA ICR 

RENEWAL OF THE ICR FOR THE REGIONAL HAZE REGULATIONS

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To comment on the Agency’s need for this information, the accuracy of the 

provided burden estimates, and any suggested methods for minimizing 

respondent burden, including through the use of automated collection 

techniques, the EPA has established a public docket for this ICR under 

Docket ID No. OAR-2003-0162, that is available for public viewing at the 

Air and Radiation Docket and Information Center, in the EPA Docket 

Center (EPA/DC), EPA West, Room B102, 1301 Constitution Ave., NW, 

Washington, DC. The EPA Docket Center Public Reading Room is open 

from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 

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

and the telephone number for the Air Docket is (202) 566-1742. An 

electronic version of the public docket is available through EPA Dockets 

(EDOCKET) at http://www.epa.gov/edocket. Use EDOCKET to submit or 

view public comments, access the index listing of the contents of the public 

docket, and to access those documents in the public docket that are 

available electronically. Once in the system, select “search,” then key in the 

docket ID number identified above. Also, you can send comments to the 

Office of Information and Regulatory Affairs, Office of Management and 

Budget, 725 17th Street, N.W., Washington D.C. 20503, Attention: Desk 

Officer for EPA. Please include the EPA Docket ID No. (OAR-2003-0162) 

in any correspondence.