SUPPORTING STATEMENT PART A: 

INFORMATION COLLECTION REQUEST 

FOR THE 

MANDATORY REPORTING OF GREENHOUSE GASES – 

PROPOSED CORPORATE PARENT REPORTING 

OMB Control No. 2060-NEW

EPA ICR No. 2374.01

March 8, 2010 
ICR for the GHG Reporting Rule 

Corporate Parent Amendment Page 1 March 8, 2010 

SUPPORTING STATEMENT 

FOR MANDATOR REPORTING OF GREENHOUSE GASES - PROPOSED 

CORPORATE PARENT RULE AMENDMENT 

EPA ICR #2374.01

1. IDENTIFICATION OF THE INFORMATION COLLECTION 

 

1(a) Title of the Information Collection 

TITLE: “Mandatory Reporting of Greenhouse Gases (GHG Reporting Rule) –Proposed 

Rule Corporate Parent Reporting”

OMB Control Number: 2060-NEW 

1(b) Short Characterization/Abstract 

The United States (U.S.) Environmental Protection Agency (EPA) is proposing to amend 

the GHG Reporting Rule to require facilities subject to the rule to provide additional information 

items. For Option 1, these items include the following: legal name, physical address, and 

ownership status of a facility’s ultimate US parent company; the facility’s primary North 

American Industry Classification System (NAICS) codes; and whether or not reported emissions 

include those from a cogeneration unit. Option 2 would collect the same information but also 

require facilities owned by more than one parent company to report the address and percent of 

facility ownership for each parent company. EPA is taking comment on both options in the 

preamble. However, for purposes of estimating the burden, the higher burden option is 

presented, which could result in a slight overestimate if a different option is finalized. 

These items would be added to the monitoring, recordkeeping, and reporting burden 

calculated when the GHG Reporting Rule was promulgated on October 30, 2009 (74 FR 56260). 

The ICR for the existing requirements were approved by OMB under OMB Control Number 

2060-0629. The final rule requires reporting of greenhouse gas emissions from all sectors of the 

economy. The rule does not require control of greenhouse gases, rather it requires only that 

sources above certain threshold levels monitor and report emissions. 
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2. NEED FOR AND USE OF THE COLLECTION 

 2(a) Need/Authority for the Collection 

Signed into law on December 26, 2007, the FY2008 Consolidated Appropriations Act 

(henceforth referred to as the “Appropriations Act”) directed EPA to “develop and publish a 

draft rule not later than 9 months after the date of enactment of this Act, and a final rule not later 

than 18 months after the date of enactment of this Act, to require mandatory reporting of 

greenhouse gas emissions above appropriate thresholds in all sectors of the economy of the 

United States.” 

 

The accompanying explanatory statement further directed EPA to “use its existing 

authority under the Clean Air Act” (CAA) to develop a mandatory GHG reporting rule. The 

Agency is further directed to include in its rule reporting of emissions resulting from upstream 

production and downstream sources, to the extent that the Administrator deems it appropriate. 

The Administrator shall determine appropriate thresholds of emissions above which reporting is 

required, and how frequently reports shall be submitted to EPA. The Administrator shall have 

discretion to use existing reporting requirements for electric generating units under §821 of the 

1990 CAA amendments. 

The Final GHG Reporting Rule fulfilled the requirements of the Appropriations Act. 

These amendments simply add additional reporting elements to the list of items in §98.3(c) of the 

final rule. Specifically, the first option under the proposed rule would require all facilities and 

suppliers that meet the applicability criteria in subpart A of 40 CFR Part 98 to list the name and 

address of their ultimate US parent company, the primary North American Industry 

Classification System (NAICS) code, indicate the ownership status of the ultimate parent 

company, report all other applicable NAICS codes, and to specify whether reported emissions 

include those from a cogeneration unit. The second option would collect the same information, 

except for ownership status and would also require facilities and suppliers owned by more than 

one parent company to report the address and percent of facility ownership for each parent 

company. 

 2(b) Practical Utility/Users of the Data 

 

The purpose of collecting the name and physical address of the U.S. parent company(s) 

on the annual reporting form for the Mandatory GHG Reporting Rule is to assist in aggregating 

facility-based GHG emissions data to the corporate level. This additional data element would 

allow EPA to compile more comprehensive information on corporate GHG emissions and 

conduct a variety of analyses. The data collected under the proposed rule would inform EPA’s 

implementation of section 103(g) of the Clean Air Act regarding improvements in sector-based 

non-regulatory strategies and technologies for preventing or reducing air pollutants. 
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In addition, corporate parent and NAICS code data could assist EPA in developing and 

improving air pollution emission inventories. A more detailed understanding of the sources and 

operational categories of GHG emissions could lead to improvements in air pollution emissions 

information that is relied upon to develop effective control methods. The additional information 

may also inform regulatory strategies being evaluated by EPA. By requiring all facilities subject 

to the Mandatory GHG Reporting Rule to report the operation of cogeneration units at their 

facility, EPA would significantly broaden its knowledge regarding the current implementation of 

cogeneration in all sectors of the economy. By collecting this information annually, EPA would 

also be able to track changes in the use of this technology in individual sectors and across the 

entire U.S. economy. Information on the types and characteristics of facilities that employ 

cogeneration technologies and the performance of cogeneration units could be important to 

future development of greenhouse gas mitigation strategies. 

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA 

 3(a) Nonduplication 

EPA evaluated existing GHG programs and the GHG data currently available to 

determine whether the final GHG Reporting Rule duplicated other information collections. As 

this is simply an amendment for additional reporting requirements, the same analysis applies. 

Documentation of EPA’s review of GHG monitoring protocols for each source category 

used by federal, state, and international voluntary and mandatory GHG programs, and the review 

of state mandatory GHG rules, can be found in the docket at EPA-HQ-OAR-2008-0508-056. 

 3(b) Public Notice Required Prior to Information Collection Request (ICR) 

Submissions to OMB 

The preamble to the proposed rule will give the public notice of and allow the public to 

comment on this ICR. 

 3(c) Consultations 

EPA met with over 4,000 people and 135 groups since proposal signature (March 10, 

2009) of the GHG Reporting Rule. Details of these meetings are available in the docket (EPAHQ-OAR-2008-0508). 

No additional consultations were held during the drafting of these amendments. 
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 3(d) Effects of Less Frequent Collection 

If the information collection were not carried out on this schedule, the Agency would not 

be able to develop an informed tracking system of trends in GHG emissions across the country. 

The year-by-year GHG emissions information from a broad range of industry sectors may 

eventually be used to inform future climate change policy decisions. 

EPA recognizes that highest level US parent company and primary NAICS code(s) may 

change more frequently than annually. However, EPA believes that the burden of requiring 

facilities to update these data elements on a more frequent basis, such as every time a facility’s 

highest level US parent company changes, or primary product(s), activity(s), or service(s), is 

greater than the benefit of obtaining that additional information. Therefore, EPA is only 

proposing to require reporting on these data elements annually, thus lessening the burden as 

much as possible while still gathering the required information. 

 3(e) General Guidelines 

This collection of information is consistent with all OMB guidelines under 5 CFR 

1320.6. However, these amendments, as well as the final GHG Reporting Rule, require that 

facilities retain records for a period of 5 years, which exceeds the 3-year retention period 

specified in the general information collection guidelines in 5 CFR 1320.6(f) of the Office of 

Management and Budget (OMB) regulations implementing the Paperwork Reduction Act. 

Facilities or suppliers that have emissions or products with emission less than 25,000 

metric tons CO2e for five years in a row may cease reporting. Those that cease reporting must 

have records to cover those five years of emissions. EPA selected a 5-year period, instead of a 

shorter time frame, because it allows facilities or suppliers that consistently report less than 

25,000 metric tons CO2e to stop reporting, but avoids the situation where a facility or supplier 

near this level would be constantly moving in and out of the reporting program due to small 

variations from one year to the next. EPA believes 5 years of records for these respondents is 

needed to document that they meet the provisions to cease reporting and so that questions about 

past emission estimates can be resolved, if needed. Thus, the 5-year record retention requirement 

of the rule adds no additional burden. 

 3(f) Confidentiality 

All information submitted to the Agency for which a claim of confidentiality is made will 

be safeguarded according to the Agency policies set forth in Title 40, Chapter 1, Part 2, Subpart 

B -- Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976; 

amended by 43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR

17674, March 23, 1979). 

 3(g) Sensitive Questions 

This ICR does not involve matters of a sensitive nature. 
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4. THE RESPONDENTS AND THE INFORMATION REQUESTED 

 4(a) Respondents/North American Industrial Classification Systems (NAICS) Codes 

The proposed amendments would affect owners and operators of fuel and chemicals 

suppliers and direct emitters of GHGs who are already subject to 40 CFR Part 98 of the GHG 

Mandatory Reporting Rule as well as those who would become subject to this part of the rule in 

the future. However, the burden estimate presented in this statement is based on facilities and 

suppliers currently subject to the GHG Reporting Rule and does not account for facilities 

expected to be added to the program through upcoming supplemental proposals. The methods 

and assumptions used to estimate the compliance costs for facilities and suppliers currently 

subject to the rule would likewise apply to those that may be added to 40 CFR Part 98 of the 

Mandatory Reporting Rule in the future. The addition of new industries would increase the 

reporting burden in proportion to the increase of the reporting universe. EPA will update and 

amend this statement as it adds new facilities to the Mandatory Reporting Program. 

Industry sectors are listed in Table 4.1 by their corresponding category, the corresponding 

NAICS codes, and examples of affected facilities and suppliers. 
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Table 4.1. Respondent Industry Sectors 

Category* NAICS Code Examples of regulated entities 

 Facilities operating boilers, process heaters, incinerators, 

turbines, and internal combustion engines: 

211 Extractors of crude petroleum and natural gas. 

General Stationary Fuel 

Combustion Sources 

321 Manufacturers of lumber and wood products. 

 322 Pulp and paper mills. 

 325 Chemical manufacturers. 

 324 Petroleum refineries, and manufacturers of coal products. 

 316, 326, 339 Manufacturers of rubber and miscellaneous plastic 

products. 

 331 Steel works, blast furnaces. 

 332 Electroplating, plating, polishing, anodizing, and coloring. 

 336 Manufacturers of motor vehicle parts and accessories. 

 221 Electric, gas, and sanitary services. 

 622 Health services. 

 611 Educational services.

Electricity Generation 221112 Fossil-fuel fired electric generating units, including units 

owned by Federal and municipal governments and units 

located in Indian Country. 

Adipic Acid Production 325199 Adipic acid manufacturing facilities. 

Aluminum Production 331312 Primary Aluminum production facilities. 

Ammonia Manufacturing 325311 Anhydrous and aqueous ammonia manufacturing

facilities. 

Cement Production 327310 Portland Cement manufacturing plants. 

Ferroalloy Production 331112 Ferroalloys manufacturing facilities. 

Glass Production 327211 Flat glass manufacturing facilities. 

 327213 Glass container manufacturing facilities. 

 327212 Other pressed and blown glass and glassware 

manufacturing facilities. 

HCFC-22 Production and 

HFC-23 Destruction 

325120 Chlorodifluoromethane manufacturing facilities. 

Hydrogen Production 325120 Hydrogen manufacturing facilities. 

Iron and Steel Production 331111 Integrated iron and steel mills, steel companies, sinter 

plants, blast furnaces, basic oxygen process furnace 

shops. 

Lead Production 331419 Primary lead smelting and refining facilities. 

 331492 Secondary lead smelting and refining facilities. 

Lime Production 327410 Calcium oxide, calcium hydroxide, dolomitic hydrates 

manufacturing facilities. 

Nitric Acid Production 325311 Nitric acid manufacturing facilities. 

Petrochemical Production 32511 Ethylene dichloride manufacturing facilities. 

325199 Acrylonitrile, ethylene oxide, methanol manufacturing 

facilities. 

325110 Ethylene manufacturing facilities. 

325182 Carbon black manufacturing facilities. 

Petroleum Refineries 324110 Petroleum refineries. 
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Category* NAICS Code Examples of regulated entities 

Phosphoric Acid 

Production 

325312 Phosphoric acid manufacturing facilities. 

Pulp and Paper 322110 Pulp mills. 

Manufacturing 322121 Paper mills. 

 322130 Paperboard mills. 

Silicon Carbide 

Production 

327910 Silicon carbide abrasives manufacturing facilities. 

Soda Ash Manufacturing 325181 Alkalies and chlorine manufacturing facilities. 

212391 Soda ash, natural, mining and/or beneficiation. 

Titanium Dioxide 

Production 

325188 Titanium dioxide manufacturing facilities. 

Zinc Production 331419 Primary zinc refining facilities. 

 331492 Zinc dust reclaiming facilities, recovering from scrap 

and/or alloying purchased metals. 

Municipal Solid Waste 

Landfills 

562212 Solid waste landfills. 

 221320 Sewage treatment facilities. 

Suppliers of Coal Based 

Liquids Fuels 

211111 Coal liquefaction at mine sites. 

Suppliers of Petroleum 

Products 

324110 Petroleum refineries. 

Suppliers of Natural Gas 221210 Natural gas distribution facilities. 

and NGLs 211112 Natural gas liquid extraction facilities. 

Suppliers of Industrial 

GHGs 

325120 Industrial gas manufacturing facilities. 

Suppliers of Carbon 

Dioxide (CO2) 

325120 Industrial gas manufacturing facilities. 

*Manure Management (subpart JJ) is not included. EPA will not implement subpart JJ of the GHG Reporting Rule 

due to a Congressional restriction prohibiting the expenditure of funds for this purpose. 
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4(b) Information Requested 

(i) Data Items 

Using Option 1, these amendments would require all facilities and suppliers reporting 

under the GHG Reporting Rule (40 CFR Part 98) to list the name and address of their highest 

level US parent company and the primary North American Industry Classification System 

(NAICS) code for the facility. Each reporting facility and supplier would also be required to 

indicate (by checking yes or no) if reported emissions include those from a cogeneration unit. 

A reporting facility or supplier’s highest level US parent company is the company that 

exercises ultimate financial control over the facility and its GHG emitting operations, either 

directly or indirectly, through one or more intermediaries. The ultimate US parent company is 

the highest level company, located in the United States, and with the largest ownership interest in 

a facility as of December 31 of the reporting year. 

Each reporting facility would also be required to indicate ownership status by selecting 

one of the following descriptions: 

“S”—single ownership (the reporting entity is entirely owned by a single company which 

is not owned by any other company, e.g., it is not a subsidiary or division of another company). 

“W”—wholly owned (the reporting entity is entirely owned by a single company which 

is, itself, owned by another company, e.g., it is a subsidiary or division of another company). 

“M”—multiple owners (the reporting entity is owned by more than one company). 

The primary NAICS code is defined as the six-digit NAICS code that represents the 

primary product(s)/activity(s)/service(s) at the facility as defined in "North American Industrial 

Classification System Manual 2007," available from the U. S. Department of Commerce, 

National Technical Information Service. The primary NAICS code is the principal source of 

revenue. EPA is proposing to define additional NAICS codes as those codes that correspond to 

product(s)/activity(s)/service(s) that provide economic profit, but that are not related to the 

principal source of revenue. 

A cogeneration unit means a unit that produces electric energy and useful thermal energy, 

for industrial, commercial, or heating or cooling purposes through the sequential [or 

simultaneous] use of the original fuel energy. 

Using Option 2, facilities and suppliers would report the preceding information for all 

parent companies except for ownership status (S, W, or M) and would also report the percent of 

ownership for each parent company. 
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(ii) Respondent Activities 

Respondent activities required by the standards are introduced in Section 6(a). To the 

extent practicable, the activities required by respondents were designed to make use of or to be 

consistent with existing reporting and recordkeeping practices. 

In this proposed rulemaking, the following data elements would be reported under 

Option 1: 

• Facility North American Industrial Classification System (NAICS) Code(s); 

• Facility Cogeneration; 

• U.S. Parent Company Legal Name; 

• U.S. Parent Company Physical Address; and 

• Ownership Status (S, W, or M). 

In this proposed rulemaking, the following data elements would be reported under 

Option 2: 

• Facility NAICS Code(s); 

• Facility Cogeneration 

• U.S. Parent Company Legal Name(s); 

• U.S. Parent Company Physical Address(es); and 

• Percent of Facility Ownership by each Parent Company. 
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5. THE INFORMATION COLLECTED – AGENCY ACTIVITIES, COLLECTION 

METHODS, AND INFORMATION MANAGEMENT 

 5(a) Agency Activities 

There are not expected to be any EPA Headquarters activities associated with these 

amendments. Contractor burden will include changes to the electronic reporting forms and 

verifying the submitted data. 

 5(b) Collection Methodology and Management 

EPA has already established a central repository of inventory data for all respondents. 

Respondents will report data electronically, and EPA will store the data in the database. The 

electronic format, which will reflect the underlying electronic data reporting system, will be 

developed prior to the first reporting date. 

These amendments will require facilities and suppliers subject to 40 CFR Part 98 (GHG 

Reporting Rule) to provide additional information items. The methodology for entering these 

data elements has not changed since the GHG Reporting Rule was promulgated on October 30, 

2009 (74 FR 56260). 

 5(c) Small Entity Flexibility 

EPA took several steps to minimize the impacts on small entities when the GHG 

Reporting Rule was finalized. The Agency met several times with industry trade associations to 

discuss the reporting options considered and their possible impacts on small entities. EPA further 

minimized impacts on small entities by not requiring facilities below a certain emissions 

threshold to report their emissions. Where feasible, EPA also used existing GHG emissions 

estimation and reporting methodologies or provided simplified methodological options to reduce 

reporting burden. 

The same thresholds established by the final GHG Reporting Rule also apply to these 

amendments. 

 5(d) Collection Schedule 

Facilities must report highest level US parent company information and facility primary 

NAICS code(s) annually. EPA is proposing to require that the highest level US parent company 

and NAICS code(s) be reported as of December 31st of the reporting year, to remain consistent 

with the other requirements of the GHG Reporting Rule. 

 
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6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION 

This section presents EPA’s estimates of the burden and costs to respondents associated 

with the activities described in Section 4 as well as the federal burden hours and costs associated 

with the activities described in Section 5(a). 

The average respondent reporting burden is estimated at 8,772 hours per year over the 

three years covered by this information collection for Option 1 and 8,879 hours for Option 2. 

Section 6(a) of this ICR provides estimates of burden (hours) for all respondent types. 

Section 6(b) contains estimates of respondent costs for the information collection. Section 6(c) 

summarizes federal burden and costs. Section 6(d) describes the respondent universe and the 

total burden and cost of this collection to respondents. Section 6(e) presents the bottom line 

burden and cost. The burden statement for this information collection is in Section 6(f). 

6(a) Estimating Respondent Burden 

 The annual burden estimates for reporting are presented in Table 6.1a and Table 6.1b for 

the first, second, and third year of the rule for Option 1 and Option 2, respectively. 

Table 6.1a Estimated Total Labor Burden and Total Cost for Option 1 

 

Total Labor Burden 

(hours) Total Cost 

First Reporting Year 

US Parent Company Legal Name, 

Physical Address, and Ownership 

Status 

6,579 $396,162 

Facility NAICS Code(s) and 

Cogeneration 

6,579 $396,162 

All Data Elements 13,157 $792,323 

Subsequent Reporting Years 

US Parent Company Legal Name, 

Physical Address, and Ownership 

Status 

4,934 $297,121 

Facility NAICS Code(s) and 

Cogeneration 

1,645 $99,040 

All Data Elements 6,579 $396,162 
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Table 6.1b Estimated Total Labor Burden and Total Cost for Option 2 

 

Total Labor Burden 

(hours) Total Cost 

First Reporting Year 

US Parent Company Legal Name, 

Physical Address, and Percent 

Ownership 6,686 $402,620 

Facility NAICS Code(s) and 

Cogeneration 6,579 $396,162 

All Data Elements 13,265 $798,782 

Subsequent Reporting Years 

US Parent Company Legal Name, 

Physical Address, and Percent 

Ownership 5,041 $303,580 

Facility NAICS Code(s) and 

Cogeneration 1,645 $99,040 

All Data Elements 6,686 $402,620 

6(b) Estimating Respondent Costs 

Costs to respondents associated with these amendments include labor costs incurred by 

facility staff to report the additional information collection requirements. 

The personnel responsible for reporting the required information in the proposed rule are 

likely to vary by industry sector and/or by facility. Table 6.2 provides estimates of the expected 

personnel titles, labor categories, and loaded hourly wage rates. Loaded hourly wage rates 

represent the total cost to the facility per hour of labor, accounting for costs beyond the hourly 

rate paid to the employee such as fringe benefits and overhead. 

To reflect that management, legal and technical staff will be involved in reporting the 

required data elements; a blended management/legal wage rate was created from the average of 

hourly wage rates of management and legal staff. A similar blended technical wage rate was 

calculated from the average of certain technical staff job classifications. An overall weighted 

wage rate was then developed based on estimates from the TRI program for similar data element 

reporting at similar facilities. According to the TRI estimates, management and legal staff are 

estimated to be involved in approximately 0.8% of the reporting effort, while technical staff are 

likely to be needed for the remaining 99.2%. Using these proportions, the weighted loaded wage 

rate, i.e., the blended labor rate, used in this analysis is $60.22 per hour. 
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Table 6.2. Labor Rates 

Personnel Type Hourly Wage Rate 

Management Personnel 

 electricity manager $88.79

 refinery manager $101.31

 industrial manager $71.03

 lawyer $101.00

Blended Management and Legal Wage Rate $90.53

Technical 

 electricity engineer/technician $60.84

 refinery engineer/technician $63.89

 industrial engineer/technician $55.20

Blended Technical Wage Rate $59.98

Percent reporting by Management and Legal Personnel 0.8%

Percent reporting by Technical Personnel 99.2%

Blended Labor Rate $60.22

The time required to report the additional information collection requirements were 

estimated at approximately 80 minutes per facility in the first year (40 minutes per facility in 

subsequent years) to complete the following activities for Option 1 and Option 2, except as 

noted: 

o Identify and record parent company name, 

o Identify and record parent company address, 

o Determine and record type of company ownership1, 

o Determine and record percentage of company ownership2, 

o Identify and record primary NAICS code, 

o Identify and record 2 additional applicable NAICS codes, and 

o Identify and record cogeneration. 

For each additional parent company, Option 2 would also require approximately 20 

minutes, in all years, to complete the following activities: 

o Identify and record parent company name, and 

o Identify and record parent company address. 

Each facility reporting more than one ultimate parent company under Option 2, would 

also require a yearly labor burden of 5 minutes to determine, record, and rank percent ownership 

For purposes of these estimates, it was assumed that 9,868 respondents would have at 

least one parent company and 143 respondents would have multiple parent companies. It was 

estimated that the multiple ownership respondents have an average of 3 parent companies per 

facility. More details are contained in a memorandum entitled, “Total Labor Burden and Cost 

 

1Required under Option 1 but not Option 2. 

2Required under Option 2 but not Option 1. 
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for Reporting of Corporate Parent Name, Address, and Percent Ownership: an Amendment to the 

GHG Reporting Rule.” The memo is located in the docket (EPA-HQ-OAR-2008-0508). 

 

6(c) Estimating Agency Burden and Cost 

There are not expected to be any EPA activities associated with these amendments. 

However, contractor support for modifying the reporting database forms (which will only occur 

in Year 1) and for verifying the information submitted (which will occur in all years) does 

contribute non-labor costs. The costs were estimated as follows: 

o Option 1, year 1 = $85,000 

o Option 1, subsequent years = $40,000 

o Option 2, year 1 = $90,000 

o Option 2, subsequent years = $40,000 

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

Every facility regulated under the GHG Reporting Rule will be required to report on the 

additional data elements covered under these amendments. 

The total number of respondents is estimated at 9,868 per year for Option 1 and Option 

2. These estimates assume that all facilities with multiple parent companies will comply with 

Option 2. 

 

6(e) Bottom Line Burden Hours and Costs 

The bottom line burden hours and costs are shown in Table 6.3a and Table 6.3b for 

Option 1 and Option 2, respectively. 

6(f) Reasons for Change in Burden 

Change in burden is the result of Program Change due to Agency Discretion. The 

existing GHG Reporting Rule ICR is being updated to include these amendments to the data 

collection requirements. 
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Table 6.3a Bottom Line Annual Burden and Cost for Option 1 

First Reporting Year 

Number of Respondents 9,868 

Total Annual Responses 59,208 

Number of Responses per Respondent 6 

Total Respondent Labor Hours 13,157 

Respondent Hours per Response 0.22 

Annual Respondent Labor Cost $792,323 

Annual Respondent O&M and Capital Cost $0 

Total Respondent Cost (labor + non) $792,323 

Total Agency Labor Hours 850 

Annual Agency Labor Cost $85,000 

Annual Agency non-labor cost $0 

Total Hours (Respondents and agency) 14,007 

Total Cost (Respondents plus Agency) $877,323 

Subsequent Reporting Years 

Number of Respondents 9,868 

Total Annual Responses 59,208 

Number of Responses per Respondent 6 

Total Respondent Labor Hours 6,579 

Respondent Hours per Response 0.11 

Annual Respondent Labor Cost $396,162 

Annual Respondent O&M and Capital Cost $0 

Total Respondent Cost (labor + non) $396,162 

Total Agency Labor Hours 400 

Annual Agency Labor Cost $40,000 

Annual Agency non-labor cost $0 

Total Hours (Respondents and agency) 6,979 

Total Cost (Respondents plus Agency) $436,162 
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Table 6.3b Bottom Line Annual Burden and Cost for Option 2 

First Reporting Year 

Number of Respondents 9,868 

Total Annual Responses 59,637 

Number of Responses per Respondent 6.04 

Total Respondent Labor Hours 13,265 

Respondent Hours per Response 0.22 

Annual Respondent Labor Cost $798,782 

Annual Respondent O&M and Capital Cost $0 

Total Respondent Cost (labor + non) $798,782 

Total Agency Labor Hours 900 

Annual Agency Labor Cost $90,000 

Annual Agency non-labor cost $0 

Total Hours (Respondents and agency) 14,165 

Total Cost (Respondents plus Agency) $888,782 

Subsequent Reporting Years 

Number of Respondents 9,868 

Total Annual Responses 59,637 

Number of Responses per Respondent 6.04 

Total Respondent Labor Hours 6,686 

Respondent Hours per Response 0.11 

Annual Respondent Labor Cost $402,620 

Annual Respondent O&M and Capital Cost $0 

Total Respondent Cost (labor + non) $402,620 

Total Agency Labor Hours 400 

Annual Agency Labor Cost $40,000 

Annual Agency non-labor cost $0 

Total Hours (Respondents and agency) 7,086 

Total Cost (Respondents plus Agency) $442,620 
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6(g) Burden Statement 

For Option 1, approximately 9,900 facilities will incur 13,200 hours and $790,000 in the 

first year and 6,600 hours and $400,000 in subsequent years. Costs are approximately $80 per 

facility in the first year and $40 per facility in subsequent years. The annual public reporting and 

recordkeeping burden for this option is estimated to average 0.15 hours per response. 

For Option 2, approximately 9,900 facilities will incur 13,300 hours and $800,000 in the 

first year and 6,700 hours and $400,000 in subsequent years. Costs are approximately $81 per 

facility in the first year and $41 per facility in subsequent years. The annual public reporting and 

recordkeeping burden for this option is estimated to average 0.15 hours per response. 

The average annual burden hours and costs are shown in Table 6.3c and Table 6.3d for 

Option 1 and Option 2, respectively. 

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. 

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-2008-0508, which is available for online viewing at 

http://www.regulations.gov, or in person viewing at the Air and Radiation docket 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 and Radiation docket is (202) 

566-1742. An electronic version of the public docket is available at http://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-OAR-2008-0508 and 

OMB Control Number 2060-NEW on any correspondence. 
ICR for the GHG Reporting Rule 

Corporate Parent Amendment Page 18 March 8, 2010 

Table 6.3c Average Annual Burden and Cost for Option 1 

Number of Respondents 9,868 

Total Annual Responses 59,208 

Number of Responses per Respondent 6.00 

Total Respondent Labor Hours 8,772 

Respondent Hours per Response 0.15 

Annual Respondent Labor Cost $528,216 

Annual Respondent O&M and Capital Cost $0 

Total Respondent Cost (labor + non) $528,216 

Total Agency Labor Hours 550 

Annual Agency Labor Cost $55,000 

Annual Agency non-labor cost $0 

Total Hours (Respondents and agency) 9,322 

Total Cost (Respondents plus Agency) $583,216 

Table 6.3d Average Annual Burden and Cost for Option 2 

Number of Respondents 9,868 

Total Annual Responses 59,637 

Number of Responses per Respondent 6.04 

Total Respondent Labor Hours 8,879 

Respondent Hours per Response 0.15 

Annual Respondent Labor Cost $534,674 

Annual Respondent O&M and Capital Cost $0 

Total Respondent Cost (labor + non) $534,674 

Total Agency Labor Hours 567 

Annual Agency Labor Cost $56,667 

Annual Agency non-labor cost $0 

Total Hours (Respondents and agency) 9,445 

Total Cost (Respondents plus Agency) $591,341