Exhibit 1a. Year 2020: Total Annual Respondent Burden and Cost of Reporting and Recordkeeping Requirements, Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generation Units;

Supplemental Proposal (40 CFR Part 60, Subpart UUUU)

(A)

Hours/ 

Occurrence

(B)

Occurrences/ 

Respondent/Year

(C)

Hours/ 

Respondent/Year

(A x B)

(D) 

Respondents/ 

Year

(E)

Total 

Hours/Year

(C x D)

(F)

Technical 

Hours/Year

(E x 0.79)

(G)

Managerial 

Hours/Year

(E x 0.09)

(H)

Clerical 

Hours/Year

(E x 0.12)

(I)

Cost/Year

1. REPORTING REQUIREMENTS

A. Read and Understand Rule Requirements a 40 1 40 12 480 379 43 58 $39,989

B. Required Activities

Review/disseminate assessment of progress b,c 4,160 1 4,160 2 8,320 6,573 749 998 $588,869

Develop monitoring system for net energy output d,e 516 1 516 12 6,192 6,192 $520,518

C. Create Information Incl. in 1B

D. Gather Information Incl. in 1B

E. Report Preparation

Prepare annual report for EPA f,g 320 1 320 2 640 506 58 77 $45,298

Report hourly net energy output into ECPMS h N/A

TOTAL ANNUAL LABOR BURDEN AND COST 15,632 13,650 850 1,133 $1,194,675

AVERAGE ANNUALIZED COSTS (O&M)

Recordkeeping/reporting supplies $28,790 

a

 Assumes one-time burden of 40 hours to read and understand rule requirements. Respondents include those 12 facilities covered under the emission guidelines in supplemental proposal.

b

 Entails implementation of program, review and assessment of all building blocks utilized by the territory that contribute to territory reduction goal, possible development of contingency measures, plan revisions,

coordination with affected sources, oversight of consumer-based energy efficiency programs, and possible public meeting development on plan revisions.

c

 Burden hours based on 2 FTEs per territory expected to be performed by 4 to 5 territory staff part time, from the energy office and air office (2x8x5x52=4,160 hours). Respondents include those 2 territories with plans.

d

 Includes the one-time development of a monitoring system (including metering hardware and software engineering) to monitor, calculate, and report hourly net energy output into the ECPMS.

e

 Burden hours based on 1 FTE per facility per month for 3 months to develop the monitoring system (1x8x5x4.3*3=516 hours); with a wage rate of $84.06 per hour, the cost is estimated to be about $43,400 per affected

facility. No managerial or clerical labor is involved in this task (assume 100 percent technical labor). Respondents include those 12 facilities covered under the emission guidelines in the supplemental proposal.

f

 Includes compilation of quarterly data downloaded to EPA’s ECPMS system by the affected EGUs and summary of program progress performed above.

d

 Burden hours based on 1 FTE for 1 month to prepare the report and another FTE (managers, attorneys, etc.) for another month to review and comment on the report (2x8x5x4=320 hours). Reporting starts in 2022,

although compilation of information for the first report will start before then; reports will be submitted every year. Respondents include those 2 territories with plans.

h

 There are no reporting costs because the industry is required to report an entire suite of data, of which this data point is a very small percentage, due to the requirements of other rules to which they are subject.

Nationwide Respondent Assumptions

Breakdown of Respondents No. Notes

Total no. affected territories/tribal lands 5 All 5 territories

 No. expected to submit plan 2 2 territories

 No. expected to submit negative declaration 3 3 territories

No. EGUs covered under emission guidelines in supp. prop. 37

No. facilities covered under emission guidelines in supp. prop. 12

Respondent Labor Rates

Unloaded Overhead Multiplier

 (110%) Loaded

Territories a

 Technical $35.26 2.1 $74.05

 Managerial $42.70 2.1 $89.67

 Clerical $16.71 2.1 $35.09

 Composite $95.49

Industry (EGUs) b

 Technical $40.03 2.1 $84.06

 Managerial $59.44 2.1 $124.82

 Clerical $22.49 2.1 $47.23

 Composite $113.75

a Unloaded labor rates from U.S. Department of Labor, Bureau of Labor Statistics, Occupational Employment Statistics, 

May 2013 National Industry-Specific Occupational Employment and Wage Estimates, NAICS 999200 - State Government,

excluding schools and hospitals (OES Designation) <http://www.bls.gov/oes/2013/may/naics4_999200.htm>

b Unloaded labor rates from U.S. Department of Labor, Bureau of Labor Statistics, Occupational Employment Statistics, 

May 2013 National Industry-Specific Occupational Employment and Wage Estimates, NAICS 221100 - Electric Power

Generation, Transmission and Distribution <http://www.bls.gov/oes/2013/may/naics4_221100.htm>

Recordkeeping/Reporting Supplies (Annual O&M Costs)

Supply Item Price per Item Number per Respondent Number of 

Respondents Total

Data acquisition system (upgrade) a,b $500 1 37 $18,500

File cabinet to store hard copy records a,c $235 1 14 $3,290

Miscellaneous annual supplies c

$500 1 14 $7,000

a

 One-time cost, incurred in 2020.

b

 Respondents include all 37 EGUs covered under emission guidelines in supplemental proposal.

c

 Respondents include those 2 territories with plans and those 12 facilities covered under emission guidelines in supplemental proposal.

Burden Item

Respondent Labor Rates (May 2013)

Labor Category

Exhibit 1a 11/3/2014
Exhibit 1b. Years 2025 and 2030: Total Annual Respondent Burden and Cost of Reporting and Recordkeeping Requirements, Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generation Units;

Supplemental Proposal (40 CFR Part 60, Subpart UUUU)

(A)

Hours/ 

Occurrence

(B)

Occurrences/ 

Respondent/Year

(C)

Hours/ 

Respondent/Year

(A x B)

(D) 

Respondents/ 

Year

(E)

Total 

Hours/Year

(C x D)

(F)

Technical 

Hours/Year

(E x 0.79)

(G)

Managerial 

Hours/Year

(E x 0.09)

(H)

Clerical 

Hours/Year

(E x 0.12)

(I)

Cost/Year

1. REPORTING REQUIREMENTS

A. Read and Understand Rule Requirements N/A

B. Required Activities

Review/disseminate assessment of progress a,b 4,160 1 4,160 2 8,320 6,573 749 998 $588,869

Develop monitoring system for net energy output N/A

C. Create Information Incl. in 1B

D. Gather Information Incl. in 1B

E. Report Preparation

Prepare annual report for EPA c,d 320 1 320 2 640 506 58 77 $45,298

Report hourly net energy output into ECPMS e

N/A

TOTAL ANNUAL LABOR BURDEN AND COST 8,960 7,078 806 1,075 $634,167

AVERAGE ANNUALIZED COSTS (O&M)

Recordkeeping/reporting supplies $7,000 

a

 Entails implementation of program, review and assessment of all building blocks utilized by the territory that contribute to territory reduction goal, possible development of contingency measures, plan revisions,

coordination with affected sources, oversight of consumer-based energy efficiency programs, and possible public meeting development on plan revisions.

b

 Burden hours based on 2 FTEs per territory, expected to be performed by 4 to 5 territory staff part time, from the energy office and air office (2x8x5x52=4,160 hours). Respondents include those 2 territories with plans.

c

 Includes compilation of quarterly data downloaded to EPA’s ECPMS system by the affected EGUs and summary of program progress performed above.

d

 Burden hours based on 1 FTE for 1 month to prepare the report and another FTE (managers, attorneys, etc.) for another month to review and comment on the report (2x8x5x4=320 hours). Reporting starts in 2022,

although compilation of information for the first report will start before then; reports will be submitted every year. Respondents include those 2 territories with plans.

e

 There are no reporting costs because the industry is required to report an entire suite of data, of which this data point is a very small percentage, due to the requirements of other rules to which they are subject.

Nationwide Respondent Assumptions

Breakdown of Respondents No. Notes

Total no. affected territories/tribal lands 5 All 5 territories

 No. expected to submit plan 2 2 territories

 No. expected to submit negative declaration 3 3 territories

No. EGUs covered under emission guidelines in supp. prop. 37

No. facilities covered under emission guidelines in supp. prop. 12

Respondent Labor Rates

Unloaded Overhead Multiplier

 (110%) Loaded

Territories a

 Technical $35.26 2.1 $74.05

 Managerial $42.70 2.1 $89.67

 Clerical $16.71 2.1 $35.09

 Composite $95.49

Industry (EGUs) b

 Technical $40.03 2.1 $84.06

 Managerial $59.44 2.1 $124.82

 Clerical $22.49 2.1 $47.23

 Composite $113.75

a Unloaded labor rates from U.S. Department of Labor, Bureau of Labor Statistics, Occupational Employment Statistics, 

May 2013 National Industry-Specific Occupational Employment and Wage Estimates, NAICS 999200 - State Government,

excluding schools and hospitals (OES Designation) <http://www.bls.gov/oes/2013/may/naics4_999200.htm>

b Unloaded labor rates from U.S. Department of Labor, Bureau of Labor Statistics, Occupational Employment Statistics, 

May 2013 National Industry-Specific Occupational Employment and Wage Estimates, NAICS 221100 - Electric Power

Generation, Transmission and Distribution <http://www.bls.gov/oes/2013/may/naics4_221100.htm>

Recordkeeping/Reporting Supplies (Annual O&M Costs)

Supply Item Price per Item Number per 

Respondent

Number of 

Respondents Total

Miscellaneous annual supplies a

$500 1 14 $7,000

a

 Respondents include those 2 territories with plans and those 12 facilities covered under emission guidelines in supplemental proposal.

Burden Item

Labor Category

Respondent Labor Rates (May 2013)

Exhibit 1b 11/3/2014
Exhibit 1c. Years 2020, 2025, and 2030: Summary of Respondent Burden and Cost of Reporting and Recordkeeping

Requirements, Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generation Units;

Supplemental Proposal (40 CFR Part 60, Subpart UUUU)

Summary of Annual Respondent Burden and Cost

Total Annual 

Labor Burden 

(Hours)

Total

Annual

Labor Costs

Total Annualized

Capital Costs

Total

Annual

O&M Costs

Year 2020 15,632 $1,194,675 $0 $28,790 

Year 2025 8,960 $634,167 $0 $7,000 

Year 2030 8,960 $634,167 $0 $7,000 

Year 2020 a

5,036 $363,792 $0 $1,235

Year 2025 b

4,480 $317,083 $0 $500

Year 2030 b

4,480 $317,083 $0 $500

a

 Equal to estimate for each burden item in Exhibit 1a divided by the number of respondents in Exhibit 1a for that

burden item, summed for all burden items.

b

 Equal to estimate for each burden item in Exhibit 1b divided by the number of respondents in Exhibit 1b for that

burden item, summed for all burden items.

Summary of Total Annual Responses

Occurrence per 

Respondent

per Year

Respondents

per Year

Total

Responses

Average

Annual report preparation 1 2 2

Total Annual Responses 2

2

1.0

7,816

4,480

4,480

Totals

Nationwide Total

Average per Respondent

Information Collection Activity

 REPORT REQUIREMENTS

Total Number of Responses = 

Responses per Respondent = 

Hours per Response = 

Year 2020

Year 2025

Year 2030

Exhibit 1c 11/3/2014
Exhibit 2a. Year 2020: Total Annual Burden and Cost to the Agency, Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units; Supplemental Proposal

(40 CFR Part 60, Subpart UUUU)

Activity

(A)

Hours/

Occurrence

(B) 

Occurrences/

Facility/Year

(C)

Hours/ 

Facility/Year 

(A x B)

(D)

Facilities/ 

Year

(E)

EPA Total 

Hours/Year

 (C x D)

(F)

EPA Technical 

Hours/Year

 (E x 0.79)

(G)

EPA

Managerial

Hours/Year

 (E x 0.09)

(H)

EPA

Clerical

Hours/Year

 (E x 0.12)

(I)

Cost, $

1. REPORTING SYSTEMS

 Program ECPMS system a

2.0 1 2.0 1 2.0 1.5 0.2 0.2 $120

2. REPORT REVIEW, MODELING, ENERGY EFFIC., ADMIN.

 EPA Headquarters b

170 1 170 1 170 134 15 20 $10,412

 EPA Regions c

4,160 1 4,160 1 4,160 3,286 374 499 $219,247

TOTAL ANNUAL LABOR BURDEN AND COST 4,332 3,422 390 520 $229,778

TOTAL ANNUAL OTHER DIRECT COSTS

 Miscellaneous cost (e.g., telephone, photocopies, postage) $1,000

$230,778

a

 Includes 2.0 hours of EPA Headquarters one-time burden for programming ECPMS system to receive quarterly data from affected facilities, based on Agency burden estimate of 200 hours 

calculated for June 2014 proposal, adjusted for the relative number of facilities, using a ratio of 12 facilities affected by supplemental proposal/1,228 facilities affected by June 2014 proposal.

b

 Includes 170 hours of EPA Headquarters annual burden to oversee the program and help with outreach/territory/enforceability questions and regional assistance, based on Agency burden

estimate of 4,160 hours calculated for June 2014 proposal, adjusted for the relative number of jurisdictions, using a ratio of 2 territories/49 states.

c

 Includes 1 FTE per year for EPA Regions 2 and 9 covering report review, modeling, energy efficiency, and administrative issues (1x8x5x52x2=4,160 hours).

EPA Staff Labor Rates

Unloadeda

Overhead 

Multiplier

 (60%) Loaded

EPA Headquarters

 Technical (Grade 13, Step 5) $38.92 1.6 $62.27

 Managerial (Grade 15, Step 5) $54.10 1.6 $86.56

 Clerical (Grade 9, Step 5) $22.57 1.6 $36.11

EPA Regions

 Technical (Grade 12, Step 5) $32.73 1.6 $52.37

 Managerial (Grade 15, Step 5) $54.10 1.6 $86.56

 Clerical (Grade 7, Step 5) $18.45 1.6 $29.52

a Unloaded labor rates from U.S. Office of Personnel Management < http://www.opm.gov/oca/12tables/pdf/gs_h.pdf>

Other Direct Costs

Expense Item Cost

Miscellaneous cost (e.g., telephone, photocopies, postage) $1,000

TOTAL AVERAGE ANNUAL COST (Average Annual Labor Cost + Average Annual Other Direct Costs)

Labor Category

Labor Rates (2012)

Exhibit 2a 11/3/2014
Exhibit 2b. Years 2025 and 2030: Total Annual Burden and Cost to the Agency, Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units; Supplemental Proposal

(40 CFR Part 60, Subpart UUUU)

Activity

(A)

Hours/

Occurrence

(B) 

Occurrences/

Facility/Year

(C)

Hours/ 

Facility/Year 

(A x B)

(D)

Facilities/ 

Year

(E)

EPA Total 

Hours/Year

 (C x D)

(F)

EPA Technical 

Hours/Year

 (E x 0.79)

(G)

EPA

Managerial

Hours/Year

 (E x 0.09)

(H)

EPA

Clerical

Hours/Year

 (E x 0.12)

(I)

Cost, $

1. REPORTING SYSTEMS

 Program ECPMS system N/A

2. REPORT REVIEW, MODELING, ENERGY EFFIC., ADMIN.

 EPA Headquarters a

170 1 170 1 170 134 15 20 $10,412

 EPA Regions b

4,160 1 4,160 1 4,160 3,286 374 499 $219,247

TOTAL ANNUAL LABOR BURDEN AND COST 4,330 3,421 390 520 $229,658

TOTAL ANNUAL OTHER DIRECT COSTS

 Miscellaneous cost (e.g., telephone, photocopies, postage) $1,000

$230,658

a

 Includes 170 hours of EPA Headquarters annual burden to oversee the program and help with outreach/territory/enforceability questions and regional assistance, based on Agency burden

estimate of 4,160 hours calculated for June 2014 proposal, adjusted for the relative number of jurisdictions, using a ratio of 2 territories/49 states.

b

 Includes 1 FTE per year for EPA Regions 2 and 9 covering report review, modeling, energy efficiency, and administrative issues (1x8x5x52x2=4,160 hours).

EPA Staff Labor Rates

Unloadeda

Overhead 

Multiplier

 (60%) Loaded

EPA Headquarters

 Technical (Grade 13, Step 5) $38.92 1.6 $62.27

 Managerial (Grade 15, Step 5) $54.10 1.6 $86.56

 Clerical (Grade 9, Step 5) $22.57 1.6 $36.11

EPA Regions

 Technical (Grade 12, Step 5) $32.73 1.6 $52.37

 Managerial (Grade 15, Step 5) $54.10 1.6 $86.56

 Clerical (Grade 7, Step 5) $18.45 1.6 $29.52

a Unloaded labor rates from U.S. Office of Personnel Management < http://www.opm.gov/oca/12tables/pdf/gs_h.pdf>

Other Direct Costs

Expense Item Cost

Miscellaneous cost (e.g., telephone, photocopies, postage) $1,000

TOTAL AVERAGE ANNUAL COST (Average Annual Labor Cost + Average Annual Other Direct Costs)

Labor Category

Labor Rates (2012)

Exhibit 2b 11/3/2014
Exhibit 2c. Years 2020, 2025, and 2030: Summary of Agency Burden and Cost,

Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric

Utility Generating Units; Supplemental Proposal (40 CFR Part 60, Subpart UUUU)

Totals Total Annual Labor Burden 

(Hours) Total Annual Costs

Total

 Year 2020 4,332 $230,778 

 Year 2025 4,330 $230,658 

 Year 2030 4,330 $230,658

Average per Response

 Year 2020 2,166 $115,389

 Year 2025 2,165 $115,329

Exhibit 2c 11/3/2014