### 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, 2010ICR for the GHG Reporting Rule

Corporate Parent Amendment Page 1 March 8, 2010 SUPPORTING STATEMENT FOR MANDATOR REPORTING OF GREENHOUSE GASES - PROPOS ED

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 Ru le) –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 th e rule to provide additional information items. For Option 1, these items include the followin g: legal name, physical address, and ownership status of a facility’s ultimate US parent com pany; 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 col lect 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 taki ng 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 i f a different option is finalized.

These items would be added to the monitoring, recordkeeping, a nd 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 emi ssions from all sectors of the economy. The rule does not require control of greenhouse ga ses, rather it requires only that sources above certain threshold levels monitor and repor t emissions.ICR for the GHG Reporting Rule

Corporate Parent Amendment Page 2 March 8, 2010 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 Appr opriations Act (henceforth referred to as the “Appropriations Act”) dire cted EPA to “develop and publish a draft rule not later than 9 months after the date of en actment 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 t o “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 reportin g 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 elec tric generating units under §821 of the 1990 CAA amendments.

The Final GHG Reporting Rule fulfilled the requirements o f 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 pr oposed 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 own ership status of the ultimate parent company, report all other applicable NAICS codes, and to spec ify whether reported emissions include those from a cogeneration unit. The second opti on would collect the same information, except for ownership status and would also require facilitie s and suppliers owned by more than one parent company to report the address and percent of fac ility ownership for each parent

company.

2(b) Practical Utility/Users of the Data

The purpose of collecting the name and physical address of t he U.S. parent company(s) on the annual reporting form for the Mandatory GHG Report ing 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 r egarding improvements in sector-based non-regulatory strategies and technologies for preventin g or reducing air pollutants.ICR for the GHG Reporting Rule

Corporate Parent Amendment Page 3 March 8, 2010 In addition, corporate parent and NAICS code data could ass ist EPA in developing and improving air pollution emission inventories. A more deta iled understanding of the sources and operational categories of GHG emissions could lead to impro vements in air pollution emissions information that is relied upon to develop effective cont rol methods. The additional information may also inform regulatory strategies being evaluated by EP A. By requiring all facilities subject to the Mandatory GHG Reporting Rule to report the operatio n 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 coll ecting this information annually, EPA would also be able to track changes in the use of this technolo gy in individual sectors and across the entire U.S. economy. Information on the types and char acteristics of facilities that employ cogeneration technologies and the performance of cogener ation units could be important to future development of greenhouse gas mitigation strategies.

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTI ON CRITERIA

3(a) Nonduplication

EPA evaluated existing GHG programs and the GHG data current ly available to determine whether the final GHG Reporting Rule duplicated oth er information collections. As this is simply an amendment for additional reporting requ irements, 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 Coll ection 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 signa ture (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 t hese amendments.ICR for the GHG Reporting Rule

Corporate Parent Amendment Page 4 March 8, 2010 3(d) Effects of Less Frequent Collection

If the information collection were not carried out on t his 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 broa d range of industry sectors may eventually be used to inform future climate change policy decisions.

EPA recognizes that highest level US parent company and pr imary NAICS code(s) may change more frequently than annually. However, EPA bel ieves that the burden of requiring facilities to update these data elements on a more frequen t 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 inform ation. Therefore, EPA is only proposing to require reporting on these data elements annual ly, thus lessening the burden as much as possible while still gathering the required informat ion.

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 G HG 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 guideline s in 5 CFR 1320.6(f) of the Office of Management and Budget (OMB) regulations implementing the Pape rwork Reduction Act.

Facilities or suppliers that have emissions or products with emission less than 25,000 metric tons CO 2 e 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 CO 2 e to stop reporting, but avoids the situation where a fac ility or supplier near this level would be constantly moving in and out of th e 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 clai m of confidentiality is made will be safeguarded according to the Agency policies set forth i n 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.ICR for the GHG Reporting Rule

Corporate Parent Amendment Page 5 March 8, 2010 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 thi s statement is based on facilities and suppliers currently subject to the GHG Reporting Rule and do es not account for facilities expected to be added to the program through upcoming supplemental pr oposals. 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 ne w industries would increase the reporting burden in proportion to the increase of the report ing universe. EPA will update and amend this statement as it adds new facilities to the M andatory Reporting Program.

Industry sectors are listed in Table 4.1 by their correspond ing category, the corresponding NAICS codes, and examples of affected facilities and supp liers.ICR for the GHG Reporting Rule

Corporate Parent Amendment Page 6 March 8, 2010 Table 4.1. Respondent Industry Sectors Category * NAICS Code Examples of regulated entities

Facilities operating boilers, process heaters, incinerat ors,

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 produ cts. 316, 326, 339 Manufacturers of rubber and miscellaneous plastic products. 331 Steel works, blast furnaces. 332 Electroplating, plating, polishing, anodizing, and colori ng. 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 gene rating units, including units owned by Federal and municipal governments and units located in Indian Country. Adipic Acid Production 325199 Adipic acid manufacturing facilitie s. Aluminum Production 331312 Primary Aluminum production facilitie s. Ammonia Manufacturing 325311 Anhydrous and aqueous ammonia manufacturing facilities. Cement Production 327310 Portland Cement manufacturing plants. Ferroalloy Production 331112 Ferroalloys manufacturing faciliti es. 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 mil ls, steel companies, sinter plants, blast furnaces, basic oxygen process furnace shops. Lead Production 331419 Primary lead smelting and refining faci lities. 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 facil ities. 32511 Ethylene dichloride manufacturing facilities. Petrochemical Production 325199 Acrylonitrile, ethylene oxide, methanol manufacturing facilities. 325110 Ethylene manufacturing facilities. 325182 Carbon black manufacturing facilities. Petroleum Refineries 324110 Petroleum refineries.ICR for the GHG Reporting Rule

Corporate Parent Amendment Page 7 March 8, 2010 Category * NAICS Code Examples of regulated entities Phosphoric Acid Production 325312 Phosphoric acid manufacturing facilities.

322110 Pulp mills. Pulp and Paper Manufacturing 322121 Paper mills. 322130 Paperboard mills. Silicon Carbide Production 327910 Silicon carbide abrasives manufacturing facilities.

325181 Alkalies and chlorine manufacturing facilities. Soda Ash Manufacturing 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.

221210 Natural gas distribution facilities. Suppliers of Natural Gas and NGLs 211112 Natural gas liquid extraction facilities. Suppliers of Industrial GHGs 325120 Industrial gas manufacturing facilities.

Suppliers of Carbon Dioxide ( CO 2 ) 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 e xpenditure of funds for this purpose.ICR for the GHG Reporting Rule

Corporate Parent Amendment Page 8 March 8, 2010 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 n ame and address of their highest level US parent company and the primary North American I ndustry Classification System (NAICS) code for the facility. Each reporting facilit y and supplier would also be required to indicate (by checking yes or no) if reported emissions i nclude those from a cogeneration unit.

A reporting facility or supplier’s highest level US paren t company is the company that exercises ultimate financial control over the facili ty and its GHG emitting operations, either directly or indirectly, through one or more intermedia ries. The ultimate US parent company is the highest level company, located in the United States, a nd with the largest ownership interest in a facility as of December 31 of the reporting year.

Each reporting facility would also be required to indicat e ownership status by selecting one of the following descriptions:

“S”—single ownership (the reporting entity is entirely o wned by a single company which is not owned by any other company, e.g., it is not a subsi diary 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 subsi diary or division of another company). “M”—multiple owners (the reporting entity is owned by mo re 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 NAI CS 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 prof it, but that are not related to the principal source of revenue.

A cogeneration unit means a unit that produces electric ener gy 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 pre ceding 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.ICR for the GHG Reporting Rule

Corporate Parent Amendment Page 9 March 8, 2010 (ii) Respondent Activities

Respondent activities required by the standards are introduce d in Section 6(a). To the extent practicable, the activities required by respondents w ere designed to make use of or to be consistent with existing reporting and recordkeeping practice s.

In this proposed rulemaking, the following data elements would be reported under Option 1:

• Facility North American Industrial Classification Sys tem (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.ICR for the GHG Reporting Rule

Corporate Parent Amendment Page 10 March 8, 2010 5. THE INFORMATION COLLECTED – AGENCY ACTIVITIES, COL LECTION 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 invent ory 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 elec tronic 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. T he methodology for entering these data elements has not changed since the GHG Reporting Ru le 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 time s 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 faci lities below a certain emissions threshold to report their emissions. Where feasible, EPA also used existing GHG emissions estimation and reporting methodologies or provided simplifi ed methodological options to reduce reporting burden.

The same thresholds established by the final GHG Reportin g Rule also apply to these amendments.

5(d) Collection Schedule

Facilities must report highest level US parent company inf ormation and facility primary NAICS code(s) annually. EPA is proposing to require tha t 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.ICR for the GHG Reporting Rule

Corporate Parent Amendment Page 11 March 8, 2010 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 t he federal burden hours and costs associated with the activities described in Section 5(a).

The average respondent reporting burden is estimated at 8,772 h ours 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 (ho urs) 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. Se ction 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 Op tion 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 $396,162ICR for the GHG Reporting Rule

Corporate Parent Amendment Page 12 March 8, 2010 Table 6.1b Estimated Total Labor Burden and Total Cost for O ption 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 colle ction requirements.

The personnel responsible for reporting the required inform ation 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 lab or, accounting for costs beyond the hourly rate paid to the employee such as fringe benefits and ove rhead.

To reflect that management, legal and technical staff wil l 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 simil ar 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 es timates, management and legal staff are estimated to be involved in approximately 0.8% of the reporti ng effort, while technical staff are likely to be needed for the remaining 99.2%. Using these prop ortions, the weighted loaded wage rate, i.e., the blended labor rate, used in this analysis is $60.22 per hour.ICR for the GHG Reporting Rule

Corporate Parent Amendment Page 13 March 8, 2010 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 co llection requirements were estimated at approximately 80 minutes per facility in the f irst 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 ownership 1

,

o Determine and record percentage of company ownership 2

,

o Identify and record primary NAICS code,

o Identify and record 2 additional applicable NAICS codes, an d

o Identify and record cogeneration.

For each additional parent company, Option 2 would also r equire approximately 20 minutes, in all years, to complete the following activit ies:

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 multipl e parent companies. It was estimated that the multiple ownership respondents have a n average of 3 parent companies per facility. More details are contained in a memorandum entitled, “Total Labor Burden and Cost

1 Required under Option 1 but not Option 2.

2 Required under Option 2 but not Option 1.ICR for the GHG Reporting Rule

Corporate Parent Amendment Page 14 March 8, 2010 for Reporting of Corporate Parent Name, Address, and Per cent 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 associate d with these amendments. However, contractor support for modifying the reporting databa se forms (which will only occur in Year 1) and for verifying the information submitted (whi ch will occur in all years) does contribute non-labor costs. The costs were estimate d 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 the se amendments to the data collection requirements.ICR for the GHG Reporting Rule

Corporate Parent Amendment Page 15 March 8, 2010 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) $436,162ICR for the GHG Reporting Rule

Corporate Parent Amendment Page 16 March 8, 2010 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) $442,620ICR for the GHG Reporting Rule

Corporate Parent Amendment Page 17 March 8, 2010 6(g) Burden Statement

For Option 1, approximately 9,900 facilities will incur 13,200 h ours and $790,000 in the first year and 6,600 hours and $400,000 in subsequent years. Cost s are approximately $80 per facility in the first year and $40 per facility in subsequen t 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 h ours 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 subsequen t 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 resourc es expended by persons to generate, maintain, retain, or disclose or provide infor mation to or for a federal agency. This includes the time needed to review instructions; develop, acqu ire, install, and utilize technology and systems for the purposes of collecting, validating, an d verifying information, processing and maintaining information, and disclosing and providing informat ion; adjust the existing ways to comply with any previously applicable instructions and requi rements; train personnel to be able to respond to a collection of information; search data s ources; 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 currentl y 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, th e accuracy of the provided burden estimates, and any suggested methods for minimizing res pondent 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 Cons titution Avenue, NW, Washington, D.C. The EPA Docket Center Public Reading Room i s open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The t elephone 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, acc ess the index listing of the contents of the public docket, and to access those documents in the publ ic 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 I nformation 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 Numb er 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