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SUPPORTING STATEMENT

Air Emissions Reporting Requirements (AERR) (Final Rule)

EPA ICR # 2170.04

PART A

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title of the Information Collection

Air Emissions Reporting Requirements (Renewal)

1(b) Short Characterization/Abstract

The United States Environmental Protection Agency (USEPA) promulgated the Air 

Emissions Reporting Requirements (AERR) on December 17, 2008 (FR Vol 73, No. 243, 

76539). The AERR consolidated and streamlined previous requirements of several older rules 

for State, Territorial, and local air pollution control agencies to report air emissions to the 

USEPA annually. The AERR has an approved ICR in place (ICR Number 2170.03). This 

supporting statement and ICR are being submitted to renew USEPA’s authority to collect air 

emissions-related information from State and local agencies for the three-year cycle that will 

include emissions reporting for inventory years 2012, 2013, and 2014, which are due to be 

reported on December 31 of the year following each inventory year.

Under the final AERR ICR, 55 State and Territorial air quality agencies, including the 

District of Columbia (DC), and an estimated 49 local air quality agencies, must annually submit 

emissions data for point sources emitting specified levels of oxides of nitrogen (NOx), carbon 

monoxide (CO), sulfur dioxide (SO2), volatile organic compounds (VOCs), particulate matter 

less than or equal to 10 micrometers in diameter (PM10), particulate matter less than or equal to 

2.5 micrometers in diameter (PM2.5), and ammonia (NH3). 

Every 3 years, States1are required to submit a point source inventory, as well as a statewide 

stationary nonpoint, onroad mobile, and nonroad mobile source inventory for all criteria 

pollutants and their precursors. The emissions data submitted for the annual and 3-year cycle 

inventories are used by EPA’s Office of Air Quality Planning and Standards (OAQPS) to assist 

in developing ambient air quality emission standards, performing regional modeling, and 

preparing national trends assessments and other special analyses and reports.

 

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Except where noted, future reference to “State(s)” in this supporting statement includes 50 States, 4 territories, 49 local 

agencies, and the District of Columbia (DC).
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2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

The purpose of the AERR is to coordinate the various State emission inventory reporting 

requirements, and streamline the activities involved in submitting the emissions data to EPA. 

The AERR has enabled the EPA to achieve uniformity and completeness in a national inventory 

to support national, regional, and local air quality planning and attainment. As EPA moves 

towards a regional focus in addressing air quality issues, there is a greater need for States to 

develop consistent inventories and to share their emissions inventory data with other groups.

While the CAA does not provide a specific authorization for a national emissions database, 

the CAA provides the EPA ample legislative authority for acquiring such data. Emissions data 

are of vital importance to the EPA for fulfilling a host of monitoring, standard-setting, 

rulemaking, reviewing, and reporting duties. Section 110 and 301(a) of the CAA provide a 

primary authority for a national emissions database. Section 110 requires each State to prepare a 

plan which provides for implementation, maintenance, and enforcement of the primary standard 

for each pollutant for which air quality criteria have been issued. This plan must include 

provisions for periodic reports identifying sources and listing amounts of emissions. Section 

301(a) authorizes the Administrator to promulgate necessary regulations.

Congressional support for collecting and reporting emissions data is demonstrated in three 

sections of the CAA. Section 110(a)(2)(F) requires that each State provide for periodic reports 

on the nature and amounts of emissions of criteria pollutants from stationary sources. Sections 

182(a)(3)(A) and 187(a)(5) of the CAA specify periodic inventory requirements for ozone and 

CO nonattainment areas, respectively. Section 182(a)(3)(A) requires States with ozone 

nonattainment areas to submit a current inventory of actual emissions of VOC, NOx, and CO 

every 3 years. Section 187(a)(5) requires a similar inventory of actual CO emissions for CO 

nonattainment areas. Periodic inventories include emission estimates for all point, nonpoint, 

onroad mobile, and nonroad mobile sources. Section 172(c)(3) also provides the Administrator 

with discretionary authority to require other emissions data as deemed necessary for State 

Implementation Plan (SIP) development in nonattainment areas to meet the NAAQS. 

2(b) Practical Utility/Users of the Data

Emissions data and related information on stationary point and nonpoint sources, as well as 

onroad mobile and nonroad mobile sources, are routinely used by OAQPS and the EPA Regional 

Offices in carrying out a variety of activities. These activities support regulatory functions as 

well as functions that are more programmatic in nature such as trends analyses. Such projects 

include:

Evaluation of existing control strategies, such as the NOx SIP Call for States and larger 

areas;

Evaluation of proposed control strategies for States and larger areas, including 

applications of regional scale models;
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Development of national control strategies and preparation of Regulatory Impact 

Analyses (RIA);

Preparation and publication of national summaries of emissions including trend analyses;

As a database to assist in the identification of important source categories for future 

regulation; and

Preparation of the stationary source portion of a report to Congress on SO2 emissions. 

This report is required by Section 406 of the CAA and is due on a 5-year cycle that began 

on January 1, 1995. The report must contain an inventory of national annual SO2

emissions from industrial sources (as defined in Title IV of the CAA).

EPA's Office of Research and Development (ORD) uses emissions source data in 

determining priorities for control technology research and as a key data component in the 

application of regional scale models. EPA's Regional Offices use emissions and other source 

parameters to support source inspections and to analyze the impact of new or modified sources 

within an area. The Emission Inventory and Analysis Group (EIAG) of EPA uses the data to 

assess and analyze trends in criteria pollutant emissions over time.

In addition to supporting projects and initiatives internal to EPA, both OAQPS and the Regional Offices 

respond to numerous requests for reports on emission sources. Typically this is done under the Freedom of 

Information Act. Most requests come from contractors and consultants involved in special studies; a smaller 

number come from the press and universities and others involved in research.

The collection of emissions data specific to nonattainment areas for certain criteria air pollutants is 

necessary to comply with requirements specified in Title I of the CAA. States with nonattainment areas rely 

on current information for point, nonpoint, and mobile sources to revise their SIPs and to plan for emission 

reductions mandated by the CAA. In addition, a statewide inventory compiled at least every 3 years for all 

point, nonpoint, and onroad and nonroad mobile sources is considered to be a key tool to assist States in 

meeting CAA requirements that address emissions tracking, compliance issues, and mid-course adjustments. 

Statewide emission inventories can be used by States affected by pollution transport from upwind areas to 

develop more efficient control strategies to meet the NAAQS. Statewide emission inventories that were 

developed by EPA (the NEI) are being used by the Regional Planning Organizations (RPOs) as the starting 

point for the development of statewide emission inventories used in the regional haze program to define 

control strategies.

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a) Nonduplication

Previous reporting requirements have occasionally forced State agencies into inefficient collecting and 

reporting activities. The AERR was promulgated specifically to simplify previously existing emission 

inventory reporting by States to EPA, offer options for data collection and exchange, and unify reporting 

dates for various categories of inventories to avoid duplication of effort. For example, under the NOx SIP 

Call rule, the EPA required States to submit annual inventories for all NOx sources for which States had 

adopted control measures to meet their NOx budget. In addition, statewide NOx inventories of all controlled 
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and uncontrolled sources were required every 3 years. The CERR rule also required annual and triennial 

emission inventory reporting of many of the same data elements. The AERR aligned the reporting dates and 

combined data from these two previous collection activities to avoid duplication of information collected 

from sources, minimize the burden on industry, and reduce the effort for State and local government agencies 

to compile the data.

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

The Federal Register notice announcing this ICR renewal was published on September 14, 2011. No 

public comments were received. 

3(c) Consultations

EPA participates regularly on monthly conference calls chaired by the National Association of Clean Air 

Agencies (NACAA) to discuss issues raised by State agencies related to emission inventories. EPA has 

developed and is operating a web-accessible database known as the Emission Inventory System (EIS) which

serves as the repository for the state agency data submitted to EPA under the AERR requirements. The EIS 

includes a Support Request area and a QA test environment for State agencies. In addition, EPA provides 

annual training for the State agencies on the development of inventories and the use of the EIS via webinars 

and conferences.

3(d) Effects of Less Frequent Collection

The submittal dates required for reporting of emissions data to EPA have been established to minimize 

the burden on State agencies, but also to ensure that State agencies are collecting timely and sufficient 

emission inventory data to support their air pollution control efforts. A statewide inventory compiled at least 

every 3 years for all point, nonpoint, onroad mobile and nonroad mobile sources is considered important to 

assist States in meeting various CAA requirements.

If the information collection were not carried out every 3 years for all sources and annually for major 

point sources, the EPA would not be able to maintain a central, national repository of emissions data from 

which to extract updated information needed to fulfill EPA mandates.

3(e) General Guidelines

This ICR does not violate any of OMB's guidelines for information collections.

3(f) Confidentiality

Any data that is submitted to EPA under this proposed rule will be considered in the public domain and 

cannot be treated as confidential. 

3(g) Sensitive Questions

This information collection does not ask any questions concerning sexual behavior or attitudes, religious 

beliefs, or other matters usually considered private. 
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4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents/North American Industry Classification System (NAICS) Codes

The emissions data required by the AERR is submitted by State, Territorial, and local air pollution 

control agencies. Under the AERR, there are 55 State and Territorial air pollution control agencies and 49 

local air agencies that are subject to the national reporting requirements and are required to compile and 

report emissions information for large stationary point sources on an annual basis, and for smaller point 

sources, stationary nonpoint and onroad and nonroad mobile sources on a 3-year basis. The affected NAICS

code is 924110 – Administration of Air and Water Resources and Solid Waste Management Programs, which 

includes governmental environmental protection and control agencies, and pollution control agencies. 

4(b) Information Requested

The AERR consolidated emission inventory data that were being collected by states and reported to EPA 

under several different provisions of the CAA, including periodic or 3-year cycle inventories, and annual 

point source inventories. Every year, State agencies are required to submit emissions data for large 

stationary point sources emitting one or more of the following pollutants above a specified level: NOx, CO, 

SO2, VOC, PM10, PM2.5, and NH3. The AERR also requires States to report point, nonpoint, onroad 

mobile, and nonroad mobile source emissions data for all criteria pollutants and their precursors every 3 

years on a statewide basis. There are no annual reporting requirements for sources of lead (Pb), however, 

lead emissions must be included in the 3-year cycle inventories. Data elements that must be reported by 

State agencies for point, nonpoint, and onroad and nonroad mobile sources are listed in Appendix A to 

Subpart A of 40 CFR part 51

(ii) Respondent activities

For the point source inventory reporting requirements of the AERR, respondent activities generally 

involve copying emissions and related parameters from an existing State electronic file, resolving any errors 

or anomalies identified through edits or other qualitative reviews, and providing it to EPA electronically 

using eXtensible Markup Language (XML) format. Thus, the activities for generating criteria pollutant point 

source inventories are primarily data processing and typically do not involve the development of new data 

which does not already exist in the State’s files. However, compiling a triennial statewide nonpoint, onroad 

mobile, and nonroad mobile source inventory is expected to involve additional effort by a State. The specific 

respondent activities associated with the AERR are outlined below, and are grouped into annual and triennial 

activities.

Annual State activities include submitting emissions data for Type A point sources emitting 2,500 tons 

per year (tpy) of NOx, CO, or SO2; or 250 tpy of VOC, PM10, PM2.5 or NH3.

Triennial State activities include:

• Submitting emissions data for Type B point sources emitting 100 tpy of NOx, SO2, VOC, PM10, 

PM2.5, or NH3; or 1,000 tpy of CO, as well as emissions data for Type A sources;
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• Developing and reporting statewide inventory emission estimates for stationary nonpoint, onroad 

mobile, and nonroad mobile sources for all criteria pollutants.

For States without nonattainment areas for the criteria air pollutants, the burden associated with 

preparing statewide stationary nonpoint, onroad mobile, and nonroad mobile source inventories was a new 

requirement for the 2002 inventory. However, many States had existing nonattainment areas and had already 

prepared stationary nonpoint, onroad mobile, and nonroad mobile source inventories for their nonattainment 

counties. For States with existing nonattainment areas, the incremental burden associated with preparing 

statewide stationary nonpoint, onroad mobile, and nonroad mobile source inventories every 3 years is 

associated with extending the inventories to cover attainment counties. This incremental burden will vary by 

State depending on the total number of counties as well as the number of nonattainment versus attainment 

counties within each State. Renewal of the ICR will pose no new burden on States for statewide emissions 

reporting since States have reported statewide emissions for the 2002, 2005, and 2008 triennial inventories.

5. THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION METHODS, 

AND INFORMATION MANAGEMENT

5(a) Agency Activities

The EPA activities associated with the AERR include:

Receiving, reviewing, and storing emission inventory data submitted by each State;

Processing and updating data submitted by States, including performing quality assurance of data, 

and coordinating efforts to resolve errors and anomalies; and

Fulfilling information requests.

5(b) Collection Methodology and Management

The EPA has established a central repository of inventory data for all States termed the Emissions

Inventory System (EIS) database. Emissions inventory data reported electronically will be stored in the EIS

database and used by the EPA and by other States for air modeling, tracking progress in meeting CAA 

requirements, setting policy and answering questions from the public. 

The EPA has created and maintains the EIS database as a central repository of inventory data for all 

States, but the data must be supplied by the States in electronic form. The EPA requires that States use a 

defined eXtensible Markup Language (XML) schema for electronic data reporting using EPA’s Central Data 

Exchange (CDX).

5(c) Small Entity Flexibility
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State and Territorial control agencies are not considered to be small entities. According to EPA's ICR 

Handbook, OMB's definition for a small entity includes small governmental jurisdictions with populations of 

less than 50,000. According to 2010 population data from the U.S. Census Bureau, no State or Territory has 

a population below this threshold. In addition, none of the local air agencies that report under the AERR for 

their jurisdictions represent an area of less than 50,000.

5(d) Collection Schedule

States must annually report all required emissions data for Type A point sources of NOx, CO, SO2, 

VOC, PM10, PM2.5, and NH3. States are also required to submit emissions data for all smaller point 

sources (i.e., Type B sources) for the same pollutants as Type A sources, plus lead (Pb), on a 3-year 

schedule. As part of the 3-year cycle reporting requirement, States must also submit statewide stationary 

nonpoint, onroad mobile, and nonroad mobile source emissions for all of the criteria pollutants listed above, 

including lead.

The AERR also contains a provision that allows States the option of estimating one-third of their 3-year 

cycle inventories, including Type B sources, in any given year. This enables States to spread out the effort 

required to prepare a complete 3-year cycle inventory over 3 years. Some conditions apply if a State chooses 

this reporting option (e.g., emission estimates for each year that comprise a complete 3-year cycle inventory 

must be compiled identically), and States subject to the NOx SIP Call may not report triennial NOx 

emissions inventories in this manner.

For all of the above reporting activities, EPA requires that States submit the appropriate emissions data 

within 12 months of the end of the inventory year (e.g., a statewide pollutant emissions inventory for the year 

2011 is required by December 31 of 2012). 

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden

The respondent burden for complying with the reporting requirements of the AERR ICR is estimated 

based on the burden associated with meeting the annual Type A point source inventory reporting 

requirements and the 3-year cycle complete inventory reporting requirements. The State, Territorial, and 

local agencies reporting to EPA under the AERR maintain their own air quality management systems, 

including permitting programs and annual emissions fee programs for their point sources. The efforts they 

expend to collect and manage emissions inventory data for these purposes are not included as part of the 

burden estimates for reporting the data to EPA under the AERR. The efforts expended to support their 

permitting and emissions fee statement programs and other State uses include:

Collecting emissions data and other associated information;

Training staff in coding and submissions techniques;

Quality-assuring emissions data and resolving errors and anomalies; and

Maintaining records associated with data submitted by sources.
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The additional tasks performed in order to submit the point source data to EPA include:

Extracting the necessary data from the State electronic data system;

Converting any new Facility Inventory data into the XML submittal format required by EPA;

Converting the point emissions data into the XML submittal format required by EPA;

Running the automated Quality-assurance checks provided in the EPA data system and resolving any 

critical errors;

Submitting the final file to EPA;

Responding to any follow-up inquiries from EPA.

For the complete 3-year inventories, the efforts required for point sources are similar to the above, 

except a large number of facilities must be extracted from the State data system, formatted into XML, 

checked for critical errors, and submitted. In addition, the States must make estimates for their nonpoint, 

onroad, and nonroad emission sources for the 3-year complete inventories. Most of the State agencies and 

some of the local agencies operate their own systems and capabilities for estimating emissions from such 

source types for their own air quality management planning purposes. For such agencies, the additional tasks 

to submit the emissions data to EPA are similar to the above steps for point sources. For agencies that don’t 

otherwise have a need to estimate nonpoint, onroad, and nonroad emissions, additional estimation steps are 

needed. 

The following sections discuss the assumptions used to develop burden hour estimates for annual and 

triennial activities. Table 6-1 lists the burden items included under these categories, and presents their 

associated burden hours for 1 year. In general, managerial time was estimated to be 5 percent of technical 

staff time. Burden hours and associated costs were estimated for the 3-year period that the affected States 

would have to report emissions data to EPA. In this case, that period corresponds to the years 2012, 2013, 

and 2014 [since they would likely begin collecting data for the emissions year 2012 during 2013, and would 

report the data within 12 months of the end of 2012 (i.e., December 31, 2013)]. Table 6-2 presents the State 

and local respondent annual burden hours and costs by activity.

Annual activities 

For 2 of the 3 years in each triennial cycle, the agencies submit only point source data for Type A 

sources. Based on an analysis of the 2008 NEI, the number of such sources (i.e., facilities) emitting 2,500 

tpy of NOx, CO, or SO2, or 250 tpy of VOC, PM10, PM2.5, or NH3, was 1,498. The number of Type A 

plus Type B sources (those emitting 100 tpy of SO2, NOx, VOC, PM10, PM2.5, or NH3; or 1,000 tpy of 

CO) was found to be 5,3981. A total of 55 State and Territorial agencies and 49 local agencies are required 

to report to the AERR. This equates to an average of 14 large, Type A sources to be reported per agency for 

2 of the 3 years, and an average of 52 facilities to be reported per agency for the triennial inventories. The 

number of sources can be much larger for the large, heavily-industrialized States, and smaller (all the way 

down to zero Type A sources) for some smaller States and local agencies. Because much of the effort 
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needed to report the point source emissions data from the State and local data systems to the EPA involves 

automated data manipulations, there are economies of scale for the States with many sources. The per 

respondent burden estimates shown in Table 6-1 are based on the average number of sources per respondent. 

Use of these averages should provide an overly conservative (larger) estimate of total burden hours, because 

the burden values for the smaller agencies are being overestimated since they will actually have fewer 

sources than average, and the average burden values do not include the economies of scale experienced by 

the larger agencies. 

Triennial activities 

Every 3 years, States are required to submit emissions data for the criteria pollutants for all point, 

nonpoint, onroad mobile, and nonroad mobile sources within the State. The point source threshold definition 

for this triennial inventory year is lowered from the Type A source thresholds used for the annual inventory 

(2500 tpy for NOx, CO, and SO2; 250 tpy for VOC, PM10, PM2.5, and NH3) to 1000 tpy for CO and 100 

tpy for the remaining pollutants. As noted above under Annual Activities, this increases the number of point

sources required to be reported from 1,498 to 5,398. Table 6-1 shows the average hour burden estimates for 

this triennial point source reporting. It is conservatively estimated that the additional hours needed for tasks 

4 and 6, resolving critical QA errors and responding to EPA follow-up questions, will increase by a factor of 

4 compared to the annual Type A reporting. Tasks 2 and 3, converting both the Facility Inventory and point 

emissions data into the XML format, is conservatively estimated to require just twice the effort needed for 

the annual Type A sources, because the task is largely the same regardless of the number of sources. Tasks 1 

and 5, extracting data from State data system and submitting final file to EPA are estimated to require the 

same amount of effort as for a Type A annual reporting year.

In addition to the point source reporting, a burden is expected for States to develop the statewide 

stationary nonpoint, onroad mobile, and nonroad mobile source inventories every 3 years. The burden for a 

State agency to develop and report statewide inventories was estimated to entail the use of 1.0 FTE (2080 

hours) every third year. Additional managerial time of 104 hours were added for this activity.

For local agencies responsible for developing and reporting nonpoint and mobile source emissions for 

each county within their jurisdiction, the triennial burden was estimated to be one-half of that estimated for a 

State agency (i.e., 1⁄2 of 2,080 = 1,040 technical hours plus 52 managerial hours). Additional hours were also 

estimated for all local agencies (i.e., 49 agencies) to coordinate and provide some de minimis emissions 

inventory data or supporting information to their corresponding State agency. The time estimated for each 

local agency to perform these activities every 3 years was estimated to be 80 technical hours and 4 

managerial hours.

6(b) Estimating Respondent Costs 

Table 6-2 presents State and local respondent annualized hours and costs for each information collection 

activity. To estimate annualized hours and costs for triennial activities, the burden estimate is divided by 3 to 

estimate the annualized burden spread over a 3-year period. For the annual Type A point source reporting 

activities, annualized hours are the same as shown in Table 6-1. However, in the case of the additional hours 

needed in each triennial reporting year to report the larger number of point sources, the incremental hours 

above the Type A source effort is divided by 3 to estimate the annualized burden.
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(i) Estimating Labor Costs 

For this ICR, the labor rate used for technical staff at State, Territorial, and local agencies is $33.30 per 

hour, and the labor rate for managerial employees at these agencies is $43.89 per hour. These labor rates are 

found in data shown on the U.S. Department of Labor, Bureau of Labor Statistics web site at 

http://www.bls.gov/oes/current/naics4_999200.htm (“National Industry-Specific Occupational Employment 

and Wage Estimates, May 2010”). The technical rate represents the mean hourly wage for Environmental 

Engineers for NAICS 999200 - State Government. The managerial rate represents the mean hourly wage for 

Computer and Information Systems Managers in the same NAICS. An overhead rate of 100% was applied 

to both the technical and managerial mean hourly wage rates to derive the bottom-line rates of $66.60 and 

$87.78 used in the calculations and shown in Table 6-3.

(ii) Estimating Capital and Operations and Maintenance Costs 

The methodology for estimating capital and operations and maintenance costs presented below is based 

on the method used in the ICR for the previous CERR annual inventory (EPA ICR #0916.12, OMB #2060-

0088). Assumptions regarding the number of respondents and work stations are unchanged.

The number of respondents reflects the number of agencies (State, Territorial and local) believed to be 

reporting data directly to EPA. The number of work stations assumed for each respondent reflects the 

number of work stations that would be dedicated to reporting under the AERR. It was assumed that each 

agency would require 5 work stations to comply with the reporting provisions of the AERR (1 for point 

sources, 1 for nonpoint sources, 1 for onroad mobile, 1 for nonroad mobile, and 1 for 

managerial/coordination activities). These costs are accounted for in Table 6-2 under the annual activity 

involving the submittal of Type A point source data by States, although the estimates are anticipated to cover 

the costs involved in developing statewide nonpoint and mobile source inventories as well.

The cost for replacing a work station, when replacement becomes necessary, is assumed to be 

approximately $1,000 per agency. For this ICR, it is assumed that 20 percent of the work stations will be 

replaced each year. Thus, the costs of replacement per agency would be:

5 work stations/agency x 20% replacement/year x $1000/work station = $1000/agency/year

Cost of work station replacement for all agencies equals: $1000/replacement costs/year x 104 

agencies/year = $104,000/year

Maintenance costs are attributed to the normal maintenance of the work stations used to submit the 

required annual and triennial reports to EPA. These costs are estimated to be approximately $120 per 

agency. Thus, total maintenance costs for the respondents are:

$120/agency x 104 agencies = $12,480/year

6(c) Estimating Agency Burden and Cost 

EPA’s costs which relate to this collection can be grouped into three areas:
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1) Emission Inventory System (EIS) annual operation and maintenance costs;

2) Review of data; and

3) Information requests.

As of fiscal year 2011, the EIS annual operation and maintenance costs are estimated to be as follows: 

2.0 FTE positions, $300,000 in Working Capital Funds and $750,000 for an Information Technology 

contractor.

The costs of reviewing data submitted by States include costs relating to data review, coordination of 

efforts to resolve any errors or anomalies, and updating of the files after the quality assurance and 

reconciliation assurance efforts have been completed. Within the EPA, the Regional Offices annually use 

about two FTEs in total across the ten Regions to coordinate State efforts in making their submissions, 

perform software edits and other quality reviews, and if required, coordinate updates performed by the 

OAQPS. The OAQPS uses approximately one FTE at a cost of $100,000 to track and process annual data. 

Therefore, approximately 3 FTEs at an annual cost of $300,000 are used by EPA to track and process data.

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

The number of respondents is estimated to be 51 states (including DC), 4 territories and 49 local 

agencies, resulting in 104 total respondents. As detailed in table 6-2, the total annual hourly burden for all 

State, Territorial and local respondents is estimated to be 68,192 hours per year and the total annual cost is 

estimated to be $4,735,411.

6(e) Bottom Line Burden Hours and Cost Tables 

Total Estimated Respondent Burden and Cost Summary

Burden Element/Cost Respondents EPA Total

Number of Respondents 104 104

Total Hours Per year 68,192 10,400 78,592

Annual Capital Cost $104,000 $300,000 $404,000

Annual O&M Cost $12,480 $750,000 $762,480

Total Annual Capital and O&M 

Costs

$116,480 $1,050,000 $1,166,480

Labor Cost Per Year $4,618,931 $500,000 $5,118,931

Total Cost Per Year $4,735,411 $1,550,000 $6,285,411
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6(f) Reasons for Change in Burden 

The net change in emission reporting burden as compared with the existing approved ICRs for the 

AERR (EPA ICR #2170.03) is shown in the table below. The existing approved ICR burden estimates were 

developed and documented only as incremental changes compared to two prior approved ICRs for two rules 

(the CERR and the NOx SIP Call) which the AERR was replacing. The existing approved ICR does not 

contain any bottom-line burden hour estimates for individual activities that would be comparable to those 

shown in Table 6-1 of this ICR. This treatment does not therefore allow for any comparison of which items 

influence the change in burden. However, this ICR renewal does not request any new or additional data 

beyond that which was part of the original ICR for the AERR. In addition, this ICR renewal also uses the 

same per activity burden hour estimates for the major contributing activities from the earlier CERR ICR 

(EPA ICR #0916.13), and derives very similar burden hour estimates as the CERR ICR for the point 

emission sources. The number of respondents has also remained the same. The difference shown in burden 

hours is therefore believed to be due solely to calculational differences either in the incremental change 

estimates from the CERR and NOx SIP Call ICRs to the original AERR ICR approval or to the annualization 

of the burden hours for the 3-year reporting cycle in the original AERR ICR approval. This ICR renewal 

imposes no additional actual burden hours beyond the original AERR ICR approval.

Burden Change

Currently Approved ICR Change Total Requested

Annual Responses 104 0 104

Annual Hour Burden 51,095 17,097 68,192

Annual Cost Burden 4,060,576 674,835 4,735,411

6(g) Burden Statement 

Table 6-2 indicates that the reporting of emissions data required by the AERR is estimated to involve an 

average of 656 hours per year for each State, Territorial and local air pollution control agency required to 

submit. Burden means the total time, effort, or financial resources expended by persons to generate, 

maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed 

to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of 

collecting, validating, and verifying information, processing and maintaining information, and disclosing and 

providing information; adjust the existing ways to comply with any previously applicable instructions and 

requirements; train personnel to be able to respond to a collection of information; search data sources; 

complete and review the collection of information; and transmit or otherwise disclose the information. An 

agency may not conduct or sponsor, and a person is not required to respond to, a collection of information 

unless it displays a currently valid OMB control number. The OMB control numbers for EPA’s regulations 

are listed in 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, 

and any suggested methods for minimizing respondent burden, including the use of automated collection 

techniques, EPA has established a public docket for this ICR under Docket ID Number EPA-HQ-OAR-2004-

0489, which is available for online viewing at www.regulations.gov, or in person viewing at the Air and 
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Radiation Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West Building, Room 

3334, 1301 Constitution Avenue, NW, Washington, D.C. The EPA Docket Center Public Reading Room is 

open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number 

for the Reading Room is (202) 566-1744, and the telephone number for the Air Docket is (202) 566-1742. 

An electronic version of the public docket is available at www.regulations.gov. This site can be used to 

submit or view public comments, access the index listing of the contents of the public docket, and to access 

those documents in the public docket that are available electronically. When in the system, select “search,” 

then key in the Docket ID Number identified above. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, 

D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OAR2004-0489 and OMB Control Number 2060-0580 in any correspondence.
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Table 6-1. State Respondent Burden Hours by Activity 

 Information Collection Activity

Hours Per Respondent

Managerial 

Hours

Technical 

Hours Total

 Annual

 1. Extract data from the State data system 4 4

 2. Convert data into the XML format – Facility info 8 8

 3. Convert data into the XML format – Emissions info 4 4

 4. Run quality-assurance checks and resolve critical errors 2 24 26

 5. Submit final file to EPA via CDX 2 2

 6. Respond to follow-up inquiries from EPA 2 4 6

 Subtotal for Annual Point Source Reporting – Type A sources 4 46 50

Triennial

 1. Extract data from the State data system 4 4

 2. Convert data into the XML format – Facility info 16 16

 3. Convert data into the XML format – Emissions info 8 8

 4. Run quality-assurance checks and resolve critical errors 8 96 104

 5. Submit final file to EPA via CDX 2 2

 6. Respond to follow-up inquiries from EPA 8 16 24

 Subtotal for Triennial Point Source Reporting – all point sources 16 142 158

 Subtotal for Triennial Point Source Reporting – increment 3rd year 12 96 108

 7. For State agencies, develop and report statewide inventory for 

stationary nonpoint, nonroad mobile, and onroad mobile sources for all 

pollutants 

104 2,080 2,184

 8. For local agencies, develop and report county-level inventories for 

stationary nonpoint, nonroad mobile, and onroad mobile sources for all 

pollutants 

52 1,040 1,092

 9. For local agencies, coordinate with State agencies to complete 

stationary nonpoint, nonroad mobile, and onroad mobile sources for all 

pollutants 

4 80 84
Table 6-2. Annualized Respondent Burden and Cost by Activity

Information Collection Activity

Hours and Costs Per Respondent Total Hours and Costs

Mgr. 

Hrs/yr @

$87.78/Hr

Tech. 

Hrs/yr @

$66.60/Hr

Respondent

Hours/Year

Labor

Cost/Year

Capital Cost O & M

Cost

Number of

Respondents

Total

Hours/Year1

Total

Cost/Year2

Annual

Submit Type A point sources 4.00 46.00 50.00 3,415 104,000312,4803104 5,200 471,640

Triennial (triennial hours from Table 6-1 divided by 3 to annualize)

Submit Type B point sources (increment above Type A) 4.00 32.00 36.00 2,482 104 3,744 258,128

For state agencies, develop and report statewide inventory for 

stationary nonpoint, onroad mobile, and nonroad mobile 

sources

34.67 693.33 728.0 49,219 55 40,040 2,707,045

For local agencies, develop and report county-level 

inventories for stationary nonpoint, onroad mobile, and 

nonroad mobile sources

17.33 346.67 364.0 24,609 49 17,836 1,205,841

For local agencies, coordinate with State agencies to 

complete stationary nonpoint, onroad mobile, and nonroad 

mobile sources

1.33 26.67 28.0 1,893 49 1,372 92,757

Total 61.33 1144.67 1206 81,619 104,000 12,480 varies 68,192 4,735,411

1 Hours per year are rounded to the nearest hour.

2 Costs per year are rounded to the nearest dollar.

3

These costs represent the total annual cost for all agencies, not the cost per agency. Ta

ble 

6-

3. 

An

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al 

St

ate 

Re

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on

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B

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