INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR 

FOR PROPOSED REVISIONS TO THE REGIONAL HAZE REGULATIONS 

Page 1 of 24

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 2540.01, 

ICR FOR PROPOSED REVISIONS TO THE 

REGIONAL HAZE REGULATIONS 

 

 

EPA

EPA # 2540.01 
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR 

FOR PROPOSED REVISIONS TO THE REGIONAL HAZE REGULATIONS 

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This ICR, EPA 2540.01 addresses the reporting and recordkeeping 

requirements under the proposed revisions to the Region Haze Regulations. 

This ICR supplements the ICR for the current regulations, the Office of 

Management and Budget (OMB) Control Number 2060-0421; EPA ICR 

Number 1813.08. Once the revisions are promulgated and this ICR is 

approved, it will be consolidated with the ICR for the existing ICR. 

The burden in this ICR reflects changes in labor rates, changes in the 

activities conducted due to the normal progression of the program, the fact 

that the states will be shifting their primary focus to development of 

periodic comprehensive SIP revisions due in 2021 under revised EPA rule 

requirements. 

Table E-1 Estimated State Respondent Burden to Implement 

Requirements

Task Element 

States

Average Annual 

Hours 

Average Annual 

Cost ($) 

Total Burden by 

Respondent 

9,974 493,996 

 

Executive Summary
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR 

FOR PROPOSED REVISIONS TO 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 2540.01. The title of this Information Collection Request 

(ICR) is “Proposed Revisions to 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 three 

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

and the EPA will focus on submitting SIP revisions and progress reports 

for regional haze. 40 CFR 51.308 (f) requires states to develop regional 

haze implementation plan revisions evaluating and reassessing reasonable 

progress goals, calculations of baseline and natural visibility conditions, the 

long-term strategy, the monitoring strategy and other implementation plan 

requirements. There are similar reporting requirements under 40 CFR 

51.309, a section of the regional haze rule in which three 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 in the Colorado Plateau area. 

During the next three years, fourteen states will also be responsible for 

submitting progress reports. 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, and 40 CFR 51.309(d)(10) requires similar actions on the part of the 

3 states that submitted regional haze SIPs under 40 CFR 51.309. 

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

for improving visibility in the 156 Mandatory Class I Federal 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. States were required to develop 

their initial implementation plans by December, 2007. Periodic 

1 Identification of the Information Collection

1.1 Title

EPA TRACKING NUMBER: 

2540.01 

OMB Control NUMBER: 

2060-NEW 

1.2 Description 
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR 

FOR PROPOSED REVISIONS TO THE REGIONAL HAZE REGULATIONS 

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comprehensive revisions to implementation plans are due July 31, 2018 and 

every 10 years thereafter. 

The primary focus for estimating burden for this 3 year renewal period 

(March 31, 2016 – March 31, 2019) will apply to the next program 

milestone which are the periodic comprehensive SIP revisions due in July 

2018 (see 40 CFR 51.308(f)) for all states, including those covered under 

40 CFR 51.309. In the 5-year progress report required by 11 states during 

this 3 year renewal period, those 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. Similar progress report 

requirements apply to the 3 states covered under 40 CFR 51.309. 

 
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR 

FOR PROPOSED REVISIONS TO 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. Actions under those regulations 

are triggered by a FLM. 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(f) and (g) will be the major program focus along 

with the similar reporting requirements (see 40 CFR 51.309(d)(10)) for the 

three states that submitted regional haze SIPs under 40 CFR 51.309. 

 

The data collected from respondents include revised state implementation 

plans and progress reports. These data confirm progress in assessing 

visibility impairment and source contribution, and provide the foundation 

for the establishment of the reasonable progress goals and control 

strategies. 

 

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” 

estimates. 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 

FOR PROPOSED REVISIONS TO 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 

FOR PROPOSED REVISIONS TO THE REGIONAL HAZE REGULATIONS 

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This information collection renewal request is related to provisions in 40 

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

comprehensive SIP revisions and periodic reports (in the form of 

implementation plan revisions) describing progress towards the reasonable 

progress goals. In addition to the periodic comprehensive SIP revisions due 

July 31, 2018 each state must submit a progress report 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. For most states, these progress 

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

The periodic comprehensive SIP revisions and progress reports required by 

the regional haze rule are unique and do not duplicate other implementation 

plan requirements. 

The ICR for the regional haze rule was revised last in March 2013. 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 September 29, 2015 (80 FR 58473) and provided a 60-day public notice 

and comment period. The EPA received no comments during the comment 

period. 

Additionally, under 5 CFR 1320.8(d)(1), OMB requires agencies to consult 

with potential ICR respondents and data users about aspects of ICRs before 

submitting an ICR to OMB for review and approval. In accordance with 

this regulation, the EPA submitted questions to nine parties via e-mail. The 

individuals contacted were: 

Albert Pearce 

Georgia Department of Natural Resources 

Albert.Pearce@dnr.ga.gov 

Michael Kiss 

Virginia Department of Environmental Quality 

michael.kiss@deq.virginia.gov 

David Healy 

New Hampshire Department of Environmental Services 

david.healy@des.nh.gov 

Preston McLane 

Florida Department of Environmental Protection 

Preston.McLane@dep.state.fl.us 

3 Non-Duplication, Consultation, and Other Collection Criteria

3.2 Public Notice 

Requirements

3.1 NonDuplication

3.3 Consultations
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR 

FOR PROPOSED REVISIONS TO THE REGIONAL HAZE REGULATIONS 

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Jerry Beasley 

Mississippi Department of Environmental Quality 

Jerry_Beasley@deq.state.ms.us 

Maeve Mason 

South Carolina Department of Health and Environmental Control 

masonmr@dhec.sc.gov 

Sushma Masemore 

North Carolina Department of Environmental Quality 

sushma.masemore@ncdenr.gov 

Jim Boylan 

Georgia Department of Natural Resources 

James.Boylan@dnr.ga.gov 

Jimmy Johnston 

Tennessee Department of Environment & Conservation 

James.Johnston@tn.gov 

Mr. David Healy of the New Hampshire Department of Environmental 

Services responded and agreed with the estimates of burden on potential 

respondents, with the caveat that it could take somewhat longer than 500 

hours for a state to prepare periodic comprehensive SIP revisions in some 

circumstances, especially for a state that contains one or more Class I 

Federal areas. The EPA received no other responses to its solicitation for 

consultations. 

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. 

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. 

3.4 Less Frequent 

Collection

3.5 General 

 Guidelines
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR 

FOR PROPOSED REVISIONS TO THE REGIONAL HAZE REGULATIONS 

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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 nationwide and across 

numerous industry classifications, the Agency does not believe there are 

disproportionate environmental justice impacts in implementing in the 

regional haze program. 

3.6 Confidentiality

3.7 Sensitive 

 Questions

3.8 Environmental 

Justice 

Considerations
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR 

FOR PROPOSED REVISIONS TO THE REGIONAL HAZE REGULATIONS 

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The major categories of respondents directly affected during this ICR 

period of March 31, 2016 through March 31, 2019 include the states. The 

states are developing periodic comprehensive SIP revisions and progress 

reports under 40 CFR 51.308(f) and (g) and 40 CFR 51.309(d)(10) which 

require periodic comprehensive SIP revisions and periodic reports (in the 

form of implementation plan revisions) 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 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 mainly focusing on 

revising their SIPs and submitting periodic comprehensive SIP revisions by 

July 31, 2018, which falls within this ICR period. Certain states are also 

working on progress reports to report on progress made towards reaching 

their long term visibility goals. For 14 states, the progress reports will be 

due during the March 31, 2016 to March 31, 2019 ICR period. 

The information that is requested under this renewal period under the 

regional haze rule requirements includes: 

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 

• Interstate consultation with states 

The progress report must be in the form of an implementation plan revision 

that complies with procedural requirements of 40 CFR 51.102 and 40 CFR 

51.103. For most states, the report is due five 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 

FOR PROPOSED REVISIONS TO THE REGIONAL HAZE REGULATIONS 

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Requirements for Regional Haze Periodic Comprehensive SIP 

Revision 

• Affirmation of, and revision to, reasonable progress goals, including 

determination of reasonableness of any additional measures that 

could be adopted to achieve the degree of visibility improvement 

projected by the analysis in the original SIP 

• Calculate baseline and natural visibility conditions 

• Address current visibility conditions and actual progress made 

toward natural conditions 

• Conduct 2028 modeling 

• Evaluate effectiveness of, and re-develop, long term strategies 

• Submit monitoring strategy 

The States are working to prepare and submit periodic comprehensive SIP 

revisions by the July 2018 deadline. 
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR 

FOR PROPOSED REVISIONS TO THE REGIONAL HAZE REGULATIONS 

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

the periodic comprehensive SIP revisions and progress reports. For this 

ICR renewal period, the EPA will primarily be reviewing the SIP revisions 

and progress reports required under CFR 51.308(f) and (g) and 

51.309(d)(10). The ten EPA regional offices and 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 SIP revisions.

FLMs. The FLMs will be reviewing the progress reports, the periodic 

comprehensive regional haze SIP revisions, and offering comments to the 

states in fulfillment of the requirement under 40 CFR 51.308(i)(4) for the 

states to coordinate their regional haze efforts with the FLMs. 

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. 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 

FOR PROPOSED REVISIONS TO THE REGIONAL HAZE REGULATIONS 

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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, 

March 31, 2016 through March 31, 2019 mainly involves 

preparation and review of the periodic comprehensive SIP revisions 

and progress reports required under CFR 51.308(f) and (g) and 

51.309(d)(10) of the regional haze rule. Sources, for the most part, 

will not be involved in preparation of these reports. 

The periodic comprehensive SIP revisions prepared by the states are due by 

July 31, 2018. The periodic comprehensive SIP revisions must at a 

minimum include the following elements (similar elements are required for 

the initial SIPs): 

• A summary of affirmation of, and revision to, reasonable progress 

goals, including determination of reasonableness of any additional 

measures that could be adopted to achieve the degree of visibility 

improvement projected by the analysis in the original SIP 

• A description of baseline and natural visibility conditions 

• An assessment of current visibility conditions and actual progress 

made toward natural conditions 

• Details on modeling conducted for the 2028 milestone 

• A summary of the effectiveness of, and re-development of, long 

term strategies 

• A description of the monitoring strategy 

The progress reports prepared by the states are, in most cases, due five 

years after the state submits its comprehensive regional haze SIP. The 

progress reports 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. 
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR 

FOR PROPOSED REVISIONS TO THE REGIONAL HAZE REGULATIONS 

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• 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 I 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. 

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, five years after the initial regional haze plan submission (or 

in the case of 51.309 states, in 2018). 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, before March 31, 2016 or beyond 

March 31, 2019. Accordingly, we have estimated burden only for the 14 

states with due dates that fall within this renewal period. 

 

5.4 Collection 

 Schedule

5.3 Small Entity 

 Flexibility
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FOR PROPOSED REVISIONS TO THE REGIONAL HAZE REGULATIONS 

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Table 5.1 Due Dates for the 5 Year Progress Reports1

State Progress Report Due Date 

Alaska 4/4/2016 

Colorado 6/11/2016 

Illinois 6/24/2016 

Nebraska 6/30/2016 

Wisconsin 7/1/2016 

District of Columbia 10/27/2016 

Massachusetts 12/30/2016 

Maryland 2/13/2017 

Montana 9/18/2017 

Hawaii 10/9/2017 

Virgin Islands 10/22/2017 

Utah 12/31/2018 

Wyoming 12/31/2018 

New Mexico 12/31/2018 

All states (including those subject to a FIP) are required to develop and 

submit periodic comprehensive SIP revisions by July 31, 2018. 

For the purposes of this ICR, we assume that each of these states will in 

fact submit progress reports and/or periodic comprehensive SIP revisions 

on the due dates indicated above. 

 

 

1

 The EPA developed FIPs for Hawaii, Montana, and the Virgin Islands and due dates for 

the progress reports are based on the dates of the FIP promulgation. 
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR 

FOR PROPOSED REVISIONS TO 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 to 50 states the District of Columbia and the 

U.S. Virgin Islands which are working on submitting periodic 

comprehensive SIP revisions, and 11 of which are developing 5-year 

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

section 308(g). All periodic comprehensive SIP revisions are due by July 

31, 2018. Table 5.1 above shows when progress reports are due for each of 

the 11 states. For this renewal period, the burden for industrial sources will 

be negligible as plans and 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); the next due date for progress 

reports for these states is December 31, 2018. Table 6.1 summarizes the 

results for each of the major categories of respondents with details 

discussed in the narrative below. 

Develop and Submit 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 5-year progress 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 

6 Estimating the Burden and Cost of the Collection

6.1 Estimating 

Respondent 

Burden 
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR 

FOR PROPOSED REVISIONS TO THE REGIONAL HAZE REGULATIONS 

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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 

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. 

Develop and Submit Periodic Comprehensive SIP Revisions (or Initial 

SIPs) as required under the Regional Haze Rule. Based on the elements 

that are required for the periodic comprehensive SIP revisions (or initial 

SIPs), which are described in section 5.2 above, and a review of previous 

ICRs, we believe that an estimate of 500 hours per state to complete the 

periodic comprehensive SIP revision (or initial SIP) is reasonable. 

Table 6.1. Estimated Respondent Burden to Implement Requirements 

Task Element Hours/State Hours/Source Year 

Incurred 

Develop and submit 

§308(g) or 309(d)(10) 

Implementation Plan – 5-

year periodic reports 

280 0 2016 - 2019 

Develop and submit 

periodic comprehensive 

SIP revisions 

500 0 2016 - 2018 

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

methods established in the New Source Review (NSR) ICRs2. 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 2015 federal government pay schedule. Managerial 

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

support rates are multiplied by 13%.3

 The hourly rate is $49.53, and the 

calculation is shown in Table 6.3 

 

2 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

3

 Ibid. 

6.2 Estimating 

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

Annual Salary of Technical Staff, GS 11 Step 3 (FY 15 Schedule)* $54,718.00

Annual Cost of Supervisory Staff, GS 13 Step 3 (FY 15 Schedule)* $77,989.00

Factor (1/11) 0.09

 $7,019.01

Annual Cost of Support Staff, GS 6 Step 6 (FY 15 Schedule)* 

Factor (1/8) 

$36,392.00

0.13

 $4,730.96

Annual Applicable Salary of Technical Staff $66,467.97

Benefits (at 16%) $10,634.88

Sick Leave / Vacation (at 10%) $6,646.80

General Overhead (at 29%) $19,275.71

Total Cost Per FTE $103,025.36

Total Hourly Cost (Total Per FTE divided by 2,080 hours per year) $49.53

* https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2015/GS.pdf January 2015 

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 also 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 progress reports and SIPs 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. 

FLMs. The FLMs will review and comment on 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, 

6.2.3 Annualized

Capital Costs 

6.3 Estimating 

Agency Burden 

and Cost 
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR 

FOR PROPOSED REVISIONS TO THE REGIONAL HAZE REGULATIONS 

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particularly related to the time necessary to review progress reports and 

SIPs and prepare federal register notices and respond to public comments. 

For the progress reports, summing the total hours from Table 6.4 (360 

hours) and multiplying by 14 total progress reports yields a total estimate 

of 5,040 hours. Using the calculated labor rate of $49.53/hr. from Table 

6.3, multiplied by the 5,040 hours gives an estimated cost of $249,631, 

which when averaged over the 3 year collection period is about $83,210 per 

year as the Agency’s burden estimate for the progress reports. 

For the periodic comprehensive SIP revisions, summing the total hours 

from Table 6.4 (400 hours) and multiplying by 52 total periodic 

comprehensive SIP revisions yields a total estimate of 20,800 hours. Using 

the calculated labor rate of $49.53/hr, from Table 6.3, multiplied by the 

20,800 hours gives an estimated cost of $1,030,224, which when averaged 

over the 3 year collection period is about $343,408 per year as the 

Agency’s burden estimate for the periodic comprehensive SIP revisions or 

initial SIPs. 

Table 6.4. Estimated Agency Burden to Implement Requirements

Task Element Hours/EPA 

Regional 

Office 

Hours/EPA 

Headquarters 

Hours/FLM Year Incurred

Review §308(g) or 

309(d)(10) 

Implementation Plan – 

5-year progress reports 

160 20 40 2016 - 2019 

Respond to Public 

Comments and Prepare 

Federal Register 

Notices 

120 20 0 2016 – 2019 

Review periodic 

comprehensive SIP 

revisions or initial SIPs 

200 20 40 2016 - 2019 

TOTAL (progress 

report) 

280 40 40 2016 - 2019 

TOTAL (periodic 

comprehensive SIP 

revision) 

320 40 40 2016 - 2019 

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

determined as follows. 

States. We assume that 50 states, the District of Columbia, and the U.S. 

Virgin Islands will develop and submit the periodic comprehensive 

regional haze SIP revision required in 2018. We assume that 14 states will 

be affected by the regional haze rule 5-year progress reporting 

requirements. 

6.4 Estimating the 

Respondent 

Universe 
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR 

FOR PROPOSED REVISIONS TO THE REGIONAL HAZE REGULATIONS 

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

plan.

Industry. The sole regional haze requirements for this reporting period are 

for the states to submit periodic progress reports and periodic 

comprehensive SIP revisions, and thus there is no anticipated burden for 

industrial sources. 

Tables 6.5 summarizes the total annual respondent burden to prepare and 

submit the 5-year progress reports and the periodic comprehensive 

revisions to state SIPs (or initial SIPs). The total respondent burden is 

estimated to be 10,307 hours per year and $510,489 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 52 (52 state agencies.)

6.5 Bottom Line 

Burden and Cost 
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR 

FOR PROPOSED REVISIONS TO THE REGIONAL HAZE REGULATIONS 

Page 21 of 24

Table 6.5 Estimated Annual Respondent Burden to Implement 

Requirements

Task Element 

States

Average Annual 

Hours 

Average 

Annual Cost 

($) 

Develop and 

submit §308(g) or 

309(d)(10) 

Implementation 

Plan – 5-year 

periodic reports 

1,307 

Calculation: 

(280 hours per 

plan x 14 plans)/3 

years= 

1,307 hr/yr 

64,719 

Calculation: 

(1,307 hrs per 

yr x labor rate 

of $49.53) 

Develop and 

submit periodic 

comprehensive 

SIP revisions 

9,000 

Calculation: 

(500 hours per 

plan x 54 plans)/3 

years= 

9,000 hr/yr 

445,770 

(9,000 hrs per 

yr x labor rate 

of $49.53) 

Total Burden for 

Respondent

10,307 510,489 

 

The burden estimates for this ICR reflect the requirements of the final 

regional haze rule with respect to the scheduled events and activities in the 

implementation process. The last collection request anticipated the 

program consisting mainly of submission and review of 5-year progress 

reports. The change in burden reflects changes in labor rates, changes in the 

activities conducted due to the normal progression of the program, and the 

fact that the periodic comprehensive regional haze SIP revisions will need 

to be acted on by the EPA beginning in 2018 and the states will be working 

on and submitting those periodic comprehensive SIP revisions. 

The annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 198 hours per respondent. 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 

6.6 Reasons for 

Change in 

Burden 

6.7 Burden 

Statement 
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR 

FOR PROPOSED REVISIONS TO THE REGIONAL HAZE REGULATIONS 

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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. 

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. EPA-HQ-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 3334, 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 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, N.W., Washington D.C. 20503, Attention: Desk Officer 

for EPA. Please include EPA Docket ID No. EPA-HQ-OAR-2003-0162 

and OMB Control Number 2060-0421 in any correspondence. 

Proposed changes to the regional haze rule include: a 3-year extension of 

the deadline for state submittal of periodic comprehensive SIP revisions 

(from July 31, 2018 to July 31, 2021); a change in submission deadlines for 

progress reports and removal of the requirement that progress reports be 

submitted as SIP revisions; discontinuance of the 1980s-era requirement for 

36 states and territories with Class I areas to submit SIP revisions every 10 

years that assess whether reasonably attributable visibility impairment 

(RAVI) is occurring and removal of the obligation for the EPA to 

periodically assess RAVI for the 20 states that never committed to meet 

this requirement; extension to the remaining 16 states the ability of a FLM 

to certify to a state that RAVI is occurring and thereby trigger a 

requirement for a responsive SIP revision; and clarification of several terms 

in the current rule text and updating of cross references. 

7 Changes Anticipated as a Result of Proposed Rule Revisions

7.1 Summary of 

Proposed Rule 

Changes 
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR 

FOR PROPOSED REVISIONS TO THE REGIONAL HAZE REGULATIONS 

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Under the proposed rule, the SIPs revisions for all states due by July 31, 

2018 would instead be due by July 31, 2021. As a result, activities 

conducted by the states, Federal Land Managers (FLMs), and the EPA 

would shift from focusing on actual submittal of SIP revisions to focusing 

on early analysis to support SIP revision development, although some 

states (particularly eastern states) may still elect to submit on or near the 

current 2018 deadline. Under the existing and proposed rules, 40 CFR 

51.308(g) also 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. The timing of these 

progress reports due during the period 2016-2019 would not change under 

the proposed rule. There are similar reporting requirements under 40 CFR 

51.309, a section of the regional haze rule in which three states (Utah, 

Wyoming, and New Mexico) elected to submit their SIPs, and none of its 

requirements for the period 2016-2019 would be altered by the proposed 

rule. 

Other sections of 40 CFR 51 relate to reasonably attributable visibility 

impairment (RAVI). Under the proposed rule, all states would be subject to 

FLM certifications of RAVI, as opposed to the current 36. The historical 

rarity of a RAVI certification implies that no additional RAVI certifications 

would occur during the 3-year period at issue and likely no RAVI 

certifications even if the current rule were to remain in place. 

With all of these proposed changes considered, the overall burden on states 

would represent a reduction compared to what would otherwise occur if the 

provisions of the current rule were to stay in place. See Table 7.1 for an 

estimate of these reductions. 

Table 7.1 Estimated Annual Respondent Burden to Implement 

Requirements: Current Rule vs. Proposed Rule Revisions

7.2 Estimating 

Change in 

Respondent 

Burden 
INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR 

FOR PROPOSED REVISIONS TO THE REGIONAL HAZE REGULATIONS 

Page 24 of 24

Task Element 

States

Average Annual 

Hours: Current Rule 

Average Annual Cost ($): 

Current Rule

Average Annual Hours: 

Proposed Rule Revisions 

Average Annual Cost ($): 

Proposed Rule Revisions 

Develop and submit 

§308(g) or 

309(d)(10) 

Implementation Plan 

– 5-year periodic 

reports 

1,307 

Calculation: 

(280 hours per plan x 14 

plans)/3 years= 

1,307 hr/yr 

64,719 

Calculation: 

(1,307 hrs per yr x labor rate 

of $49.53)

1,307 

(No change) 

64,719 

Calculation: 

(1,307 hrs per yr x labor rate 

of $49.53) 

Develop and submit 

periodic 

comprehensive SIP 

revisions 

9,000 

Calculation: 

(500 hours per plan x 54 

plans)/3 years= 

9,000 hr/yr 

445,770 

Calculation: 

(9,000 hrs per yr x labor rate 

of $49.53)

2,000 

Calculation: 

(500 hours per plan x 12 

early plans)/3 years= 

2,000 hr/yr 

99,060 

Calculation: 

(2,000 hrs per yr x labor rate 

of $49.53) 

Early analysis to 

support SIP revision 

development 

0 0 2,667 

Calculation: 

(200 hours per plan x 40 

remaining on-time plans)/3 

years= 

2,667 hr/yr 

132,097 

(2,667 hrs per yr x labor rate 

of $49.53) 

Total Burden by 

Respondent

10,307 510,489 5,974 295,876