**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 outputd,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 EPAf,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**

aAssumes 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. bEntails 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.

cBurden 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. dIncludes 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.

eBurden 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. dBurden 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. hThere 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

aUnloaded 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> bUnloaded 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

aOne-time cost, incurred in 2020. bRespondents include all 37 EGUs covered under emission guidelines in supplemental proposal.

cRespondents 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 progressa,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 EPAc,d 320 1 320 2 640 506 58 77 $45,298 Report hourly net energy output into ECPMSe 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**

aEntails 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. bBurden 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.

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

eThere 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

aUnloaded 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> bUnloaded 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 suppliesa $500 1 14 $7,000

aRespondents 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 2020a 

# 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**

**Unloaded a**  

## 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 Headquartersa 

## 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**

**Unloaded a**  

## 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