Information Collection Request

Supporting Statement for the

PM2.5 National Ambient Air Quality Standard 

Implementation Rule

EPA ICR Number 2258.02

OMB Control No. 2060-0611

Prepared by:

Office of Air Quality Planning and Standards 

Office of Air and Radiation

U.S. Environmental Protection Agency

Research Triangle Park, North Carolina 27711

May 2011

EPA Information Collection Request Renewal for the

PM2.5 National Ambient Air Quality Standard Implementation Rule
2

Table of Contents

1. Identification of the Information Collection Request........................page 3

2. Need for and Use of the Collection..........................................page 5

3. Non-Duplication, Consultation, and other Collection Criteria......... page 6

4. Respondents and the Information Requested..............................page 10

5. Information Collected—Agency Activities, Collection Methodology and 

Information Management.....................................................page 17

6. Estimating the Burden and Cost of the Collection........................page 19
3

1. Identification of the Information Collection Request

1(a) Title of the Information Collection

The title of the Information Collection Request is PM2.5 National Ambient 

Air Quality Standard Implementation Rule (Renewal), ICR number 2258.02, and OMB 

Control Number 2060-0611

1(b) Abstract/Executive Summary

The Paperwork Reduction Act requires the information found in this Information 

Collection Request (ICR) number 2258.02, to assess the burden (in hours and dollars) 

of the PM2.5 National Ambient Air Quality Standard (NAAQS) Implementation Rule as 

well as the periodic reporting and record keeping necessary to maintain the rule. The 

PM2.5 NAAQS rule applies to particles less than 2.5 micrometers in diameter (PM2.5)

which are also referred to as "fine” particles. The final FRN title is Clean Air Fine 

Particle Implementation Rule.

 The EPA established the PM2.5 standards based on evidence and numerous health 

studies demonstrating that serious health effects are associated with exposures to 

elevated levels of PM2.5. Estimates show that attainment of the PM2.5 standards would 

be likely to result in tens of thousands fewer premature deaths each year, tens of 

thousands fewer hospital admissions each year, and hundreds of thousands fewer doctor 

visits, absences from work and school, and respiratory illnesses in children annually. 

On July 18, 1997, EPA revised the NAAQS for particulate matter to add new 

standards for fine particles, using PM2.5 as the indicator. The EPA established healthbased (primary) annual and 24-hour standards for PM2.5 (62 FR 38652). The annual 

standard was set a level of 15 micrograms per cubic meter, based on the 3-year average 

of annual mean PM2.5 concentrations. The 24-hour standard was set a level of 65 

micrograms per cubic meter, based on the 3-year average of the 98th percentile of 24-

hour concentrations. 

This PM2.5 National Ambient Air Quality Standard Implementation rule was 

proposed November 1, 2005 (70 FR 65983) and was promulgated on April 25, 2007. 

The preamble to the proposed and final regulation addresses the administrative burden 

in general terms. The preamble to the final rule states that an ICR will be prepared.

The first ICR (No. 2258.01) covered a period from April 5, 2008 through April 4, 2011.
4

On October 17, 2006, EPA revised the NAAQS for fine particles. The EPA

established a new primary 24-hour standards for PM2.5 (71 FR 61144) that became 

effective on December 18, 2006. The 24-hour standard was set a level of 35 

micrograms per cubic meter, based on the 3-year average of the 98th percentile of 24-

hour concentrations. The annual standard remained unchanged at a level of 15 

micrograms per cubic meter, based on the 3-year average of annual mean PM2.5

concentrations. The EPA promulgated the initial designations and boundaries for 31 

areas across the country with respect to the 2006 24-hour PM2.5 NAAQS on November 

13, 2009 (74 FR 58688).

The time period covered in this ICR is a three year period from June 1, 2011 

through May 31, 2014. This rule provides the framework for the States to develop SIPs 

to achieve the 1997 PM2.5 NAAQS as well as the 2006 PM2.5 NAAQS. This 

framework reflects the requirements prescribed in CAA sections 110 and part D, 

subpart 1 of title I. A PM2.5 SIP contains rules and other requirements designed to 

achieve the NAAQS by the deadlines established under the CAA, and it also contains a 

demonstration that the State’s requirements will in fact result in attainment. The SIP 

must meet the CAA requirements in subpart 1 to adopt reasonably available control 

measures (RACM) and reasonably available control technology (RACT) and provide 

for reasonable further progress (RFP) toward attainment for the period prior to the 

area’s attainment date. After a State submits a SIP, the CAA requires EPA to approve 

or disapprove the SIP. Tribes are not required to conduct attainment demonstrations or 

submit the RFP, RACT, or RACM requirements. 

In the previous ICR which addressed the 1997 PM2.5 NAAQS, the administrative 

burden for State governments and the Agency were 630,000 hours and 69,300 hours, 

respectively over three years. For the current ICR, the Agency anticipates additional 

administrative burden for State governments and the Agency of 526,200 hours and 

57,882 hours, respectively over three years. Fifty percent of the hours are expended in 

the first year with the remainder evenly divided between the second and third years of 

the ICR period. 

The present value of the total additional costs for State governments, the 

respondents, estimated at $34 million for the 3 year period. On an equivalent annual 

basis that is $11.3 million per year during the 3 year period of the ICR. 

The present value of the Agency administrative cost burden is estimated at $3.5

million dollars for the 3 year period. This is equivalent to equal annual basis of $1.2

million per year during the three year period. 

The incremental administrative burden for the areas and activities covered by this ICR 

is mitigated by certain factors, including:

1. Several promulgated federal rules will reduce future emissions of particulate

matter and its precursors and will help states attain the PM2.5 NAAQS. 

These rules include emission and fuel standards for onroad and nonroad 
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mobile sources, and the Transport Rule, which addresses electric generating 

units.

2. In developing state implementation plans, some States are projected to attain 

based on Regional control programs from EPA analyses conducted as part 

of the Transport Rule, the 2006 PM NAAQS Review, and the PM2.5

NAAQS Implementation Rule. Included in these analyses were emissions 

projections and air quality modeling design value predictions and 

interpolations for 2010, 2014, 2015, 2020, etc. 

3. Experience with meeting the requirements of the PM10, 1997 PM2.5, and 8-

hour Ozone NAAQS. Only 1 of the original 39 PM2.5 nonattainment areas 

required to submit a nonattainment area plan has not submitted the SIP. For 

the thirty-one areas not attaining the 2006 PM2.5 NAAQS, twenty-two of 

those areas have developed SIPs for the 8-hour ozone standard, fifteen 

developed SIPs for the 1997 8-hour PM2.5 standard, and fourteen developed 

SIPs for the PM10 standard. Of the thirty-one nonattainment areas for the 

2006 PM2.5 NAAQS, only one area has never developed a SIP for any 

criteria pollutant. Hence, there is familiarity with SIP activities for 

meeting nonattainment NAAQS requirements. Furthermore, many of these 

areas completed attainment demonstrations and fulfilled RFP and some 

RACT and RACM obligations for the 1997 PM2.5, PM10, or 8-hour Ozone 

NAAQS. 

2. Need For and Use of the Collection

2(a) Need/Authority for the Collection

The Clean Air Act, which was last amended in 1990, requires EPA to set National 

Ambient Air Quality Standards (NAAQS) for wide-spread pollutants from numerous and 

diverse sources considered harmful to public health and the environment. Part D of Title I 

of the Clean Air Act sets forth the plan (implementation) requirements for areas designated 

non-attainment with a promulgated National Ambient Air Quality Standard. The EPA is 

charged under Section 110 of the Clean Air Act (CAA), as amended, to assist each State

with a non-attainment area to develop a plan which provides for implementation, 

maintenance and enforcement of such primary standard. 

As a result of litigation and subsequent court decisions, an implementation framework 

was developed for the PM2.5 NAAQS. The PM2.5 NAAQS Implementation Rule is 

scheduled to be published in April 2007. When the review and comment periods on the 

draft and final federal implementation rules close, the affected parties could begin to assess 

the milestones and begin the planning process.

This ICR is developed in response to the implementation framework to fulfill 

requirements of the Paperwork Reduction Act.
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2(b) User/Users of the Data1

The data collected from the State or local air agency respondents will include the 

required SIP elements prescribed in CAA sections 110 and part D, subpart 1 of title I for 

Implementation plans and the requirements in this Implementation Rule. The PM2.5 SIP 

will contain rules and other requirements designed to achieve the NAAQS by the deadlines 

established under the CAA, and it also contains a demonstration that the State’s 

requirements will in fact result in attainment. The SIP must meet the requirements in 

subpart 1 to adopt RACM, RACT, and provide for RFP toward attainment for the period 

prior to the area’s attainment date. 

The regional and headquarters EPA use the information as part of their review of the 

attainment demonstration, RFP, RACM, and RACT requirements of the PM2.5

implementation plan adequacy. After a State submits a SIP with the technical supporting 

documentation, the CAA requires EPA to approve or disapprove the SIP. The attainment 

demonstration must meet the requirements of 40 CFR 51.112 and Part 51, Appendix W and 

must include inventory data, modeling results, and emission reduction analyses on which 

the State has based its projected attainment date. The attainment date justified by the 

demonstration must be consistent with the requirements of 40 CFR 51.1004(a). The 

modeled strategies must be consistent with requirements in §51.1009 for reasonable further 

progress (RFP) and in §51.1010 for reasonably available control technology (RACT) and 

reasonably available control measures (RACM). The attainment demonstration and 

supporting air quality modeling should be consistent with EPA’s PM2.5 modeling guidance.

The States use the attainment demonstrations, RFP, RACT and RACM determinations

to inform their citizenry, including potentially regulated entities. They also use this 

information and analysis to fulfill federal obligations under Title I, Subpart D of the Clean 

Air Act and the PM2.5 Implementation Rule. 

The potentially regulated entities use this information in assessing future emission 

reduction requirements.

 Emission reducing regulations developed by the States and approved by the EPA are 

federally enforceable. 

3. Non-Duplication, Consultations, and Other Collection 

Criteria

3(a) Non-Duplication

The State respondent will submit a implementation plan for each nonattainment 

area that will need to include a number of elements, including an evaluation of RACT 

 

1 Attainment demonstrations as well as RFP, RACM and RACT are viewed as analytical products to some; 

but are regulations to others. In the context of the Paperwork Reduction Act, the attainment demonstration 

and RFP, RACM and RACT submissions are considered data.
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and RACM, an attainment demonstration showing how the area will attain the 

standards as expeditiously as practicable, and a plan showing that the area will make 

reasonable further progress from the date the area's SIP is due to its attainment date. 

The four parts to the information collection for this ICR can be contained in the 

respondents one PM2.5 SIP submission - the attainment demonstration and the RFP, 

RACT, and RACM requirements.

There are other activities covered by existing ICRs which complement the activities 

required for the attainment demonstration, RFP, RACT, and RACM. One example is 

the Consolidated Emissions Reporting Rule. Salient ICRs and their titles are identified 

below. 

 Requirements for Preparation, Adoption, and Submittal of Implementation 

Plans

o 51.121-51.122 NOx SIP Call...................................2060-0445

o 51.160-51.166 New Source Review................................2060-0003

o 51.321-51.323 Air Quality Data Reporting..................2060-0088

o 51.353-51.354 Inspection/Maintenance......................2060-0252

o 51.365-51.366 Inspection/Maintenance......................2060-0252

 Approval and Promulgation of Implementation Plans

o 52.21 Prevention of Significant Deterioration.................2060-0003

 Ambient Air Monitoring Reference and Equivalent Methods

o 53.4 .................................................................2080-0005

o 53.9(f),(h),(i).......................................................2080-0005

o 53.14................................................................2080-0005

o 53.15 ...............................................................2080-0005

o 53.16(a)-(d),(f).....................................................2080-0005

 Outer Continental Shelf Air Regulations

o 55.4-55.8 ...........................................................2060-0249

o 55.11-55.14 ........................................................2060-0249

 Ambient Air Quality Surveillance

o 58.11-58.14 ........................................................2060-0084

o 58.20-58.23 ........................................................2060-0084

o 58.25-58.28 ........................................................2060-0084

o 58.30-58.31 ........................................................2060-0084

o 58.33 ................................................................2060-0084

o 58.35 ................................................................2060-0084

o 58.40-58.41 .........................................................2060-0084

o 58.43 ................................................................2060-0084

o 58.45 ................................................................2060-0084

o 58.50 ................................................................2060-0084

 8-hour Ozone National Ambient Air Quality Standard Implementation Rule

o 2236.02.............................................................2060 – 0594

Attainment Demonstration. The attainment demonstration requirement appears 

as 40 CFR 51.1007 which implements Clean Air Act subsection 172(c)(1). The 
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attainment demonstration for the PM2.5 NAAQS is unique and does not duplicate other 

implementation plan requirements. However, the States are encouraged to build upon 

related implementation planning processes they used for the 1997 PM2.5 NAAQS, 

Ozone NAAQS, regional haze rule, and/or PM NAAQS. Taking such steps, where 

appropriate, may reduce the incremental administrative burden and enable 

identification of control strategies that achieve requisite multi-pollutant environmental 

progress at a lower cost.

RFP. This unique requirement is described in 40 CFR 51.1009. Although the RFP 

submission does not duplicate other plan requirements, the RFP submission may

complement them. For example, the emission reductions associated with the RFP SIP 

may also demonstrate attainment. 

The States are encouraged to build upon related analyses for federal emission 

reducing rules as well as salient PM-10 and ozone NAAQS and regional haze 

implementation requirements where appropriate. Taking such steps may reduce the 

incremental administrative burden. For example, the temporal and spatial nature of 

emission reductions associated with the federal rules may be sufficient to meet the RFP 

requirements. Hence, the need to identify additional emission reductions to meet RFP 

requirements may be mitigated in some instances. 

In addition, States are encouraged, where appropriate, to take into account similar 

analyses and planning efforts to meet certain PM10 and ozone NAAQS and regional 

haze implementation requirements. Such actions may result in RFP plans which 

achieve requisite multi-pollutant environmental progress at a lower cost. 

RACT and RACM. These unique requirements are described in 40 CFR 51.1010

which implements CAA subsection 172(c)(1). For each PM2.5 nonattainment area, the 

State shall submit with the attainment demonstration a SIP revision demonstrating that 

it has adopted all reasonably available control measures (including RACT for stationary

sources) necessary to demonstrate attainment as expeditiously as practicable and to 

meet any RFP requirements. The SIP revision shall contain the list of the potential 

measures considered by the State, and information and analysis sufficient to support the 

State’s judgment that it has adopted all RACM, including RACT. 

The States are encouraged to take into account the related analyses and planning 

efforts to meet certain PM10 and ozone NAAQS and regional haze implementation 

requirements where appropriate. Taking such steps can reduce administrative burden 

and foster achievement of multi-pollutant environmental progress at a lower cost.

3(b) Public Notice Required Prior to ICR Submission to the Office of 

Management and Budget (OMB)

A Federdal Register notice soliciting comment on this ICR renewal was published 

on February 2, 2011 (76 FR 5801). 
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3(c) Consultations

The EPA solicited comment on the proposed PM2.5 implementation rules including 

public hearings. The EPA will solicit comment on the final PM2.5 implementation rules 

including public hearing after publication.

3(d) Effects of Less Frequent Collection

The collections under 40 CFR 51.1007, 51.1009, and 51.1010 are necessary to 

provide assurances that identified level of emission reductions are adequate to ensure 

timely attainment and maintenance of the PM2.5 NAAQS while adhering to the 

mandatory measures and requirements for areas whose attainment dates are beyond 5 

years after designation

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR part 1320, section 1320.5.

 The final PM2.5 NAAQS implementation rule does not require:

 reporting more than once a year;

 respondents to participate in a statistical survey; 

 responses to Agency inquiries in less than 30 days;

 respondents to receive remuneration for preparation of reports; 

 records to be kept more than 3 years,

2

and, 

 manual methods of reporting.3

3(f) Confidentiality

The information is requested from the States. To fulfill the attainment 

demonstration, RFP, RACT and RACM requirements, the States will use emissions 

levels and control efficiency data provided by certain facilities in the private and public 

sector. This information is available from a variety of sources. It is the assimilation 

and analysis of that data that is required in the attainment demonstration, RFP, RACT 

and RACM determinations.

There are 37 plan submittals for the 1997 and 2006 PM2.5 nonattainment areas that

States must prepare to meet the attainment demonstration as well as meet the RFP, 

RACT and RACM requirements. States should already have information from 

emission sources, as facilities should have provided this information to meet other 

NAAQS SIP requirements, operating permits, and/or emissions reporting requirements. 

Such information does not generally reveal the details of production processes. But, to 

 

2 However, the states may choose to retain the information for more than 3 years.

3 However, the states must still submit their attainment demonstration, RFP SIP, RACT SIP and RACM SIP.
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the extent it may, the affected facilities are protected. Specifically, the completion of 

the emissions and control efficiency information that is confidential, proprietary, and 

trade secret is protected from disclosure under the requirements of subsections 503(e) 

and 114 (c) of the Clean Air Act.

3(g) Sensitive Information

The requested attainment demonstration, RFP, RACT and RACM submissions do 

not include questions whose answers would require sensitive information.

4.0 The Respondents and the Information Requested

4(a) Respondents and the Non-Attainment areas

Table 1a lists the States affected by the attainment demonstration, RFP, RACT and 

RACM requirements for the 39 non-attainment areas for the 1997 PM2.5 NAAQS. 

Table 1b lists the 31 areas designated nonattainment for the 2006 PM2.5 NAAQS. 

Local, State, and federal agencies are part of the North American Industrial 

Classification System code number 924110.4

There are other entities that may be indirectly affected, as they may comment on the 

draft submissions before they are forwarded to EPA’s Regional Offices. These include 

potentially regulated entities, representatives of special interest groups, and individuals. 

Consideration of the burden on these entities is beyond the scope of the Paperwork 

Reduction Act. 

 

4

http://www.census.gov/naics Code number 924110 includes “administration of air & water resources & 

solid waste management programs
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Table 1a. 1997 Particulate Matter (PM2.5) NAAQS Nonattainment Areas (see 

http://www.epa.gov/air/oaqps/greenbk/qnc.html)

 

Area Action

Atlanta, GA

Baltimore, MD Attainment Demonstration SIP submission

Birmingham, AL Redesignation request submitted

Canton-Massillon, OH Attainment Demonstration SIP submission

Charleston, WV Attainment Demonstration SIP submission

Chattanooga, AL-TN-GA Attainment Demonstration SIP submission

Chicago-Gary-Lake County, IL-IN Clean Data Determination

Cincinnati-Hamilton, OH-KY-IN Attainment Demonstration SIP submission

Cleveland-Akron-Lorain, OH Attainment Demonstration SIP submission

Columbus, OH Attainment Demonstration SIP submission

Dayton-Springfield, OH Attainment Demonstration SIP submission

Detroit-Ann Arbor, MI Attainment Demonstration SIP submission

Evansville, IN Redesignation request submitted

Greensboro-Winston Salem-High Point, NC Clean Data Determination

Harrisburg-Lebanon-Carlisle, PA Clean Data Determination

Hickory, NC Redesignation request submitted

Huntington-Ashland, WV-KY-OH Attainment Demonstration SIP submission

Indianapolis, IN Attainment Demonstration SIP submission

Johnstown, PA Clean Data Determination

Knoxville, TN Attainment Demonstration SIP submission

Lancaster, PA Clean Data Determination

Libby, MT Attainment Demonstration SIP submission

Liberty-Clairton, PA Attainment Demonstration SIP submission

Los Angeles-South Coast Air Basin, CA Attainment Demonstration SIP submission

Louisville, KY-IN Attainment Demonstration SIP submission

Macon, GA Attainment Demonstration SIP submission

Martinsburg, WV-Hagerstown, MD Clean Data Determination

New York-N. New Jersey-Long Island, NY-NJ-CT Attainment Demonstration SIP submission

Parkersburg-Marietta, WV-OH Clean Data Determination

Philadelphia-Wilmington, PA-NJ-DE Attainment Demonstration SIP submission

Pittsburgh-Beaver Valley, PA Attainment Demonstration SIP submission

Reading, PA Clean Data Determination

Rome, GA Attainment Demonstration SIP submission

San Joaquin Valley, CA Attainment Demonstration SIP submission

St. Louis, MO-IL*

Steubenville-Weirton, OH-WV Attainment Demonstration SIP submission

Washington, DC-MD-VA Clean Data Determination

Wheeling, WV-OH Clean Data Determination

York, PA Clean Data Determination

*: For the St. Louis nonattainment area, MO submitted an AD SIP, but IL has not. 

Table 1b. 2006 Particulate Matter (PM2.5) NAAQS Nonattainment Areas (see 

http://www.epa.gov/air/oaqps/greenbk/rnc.html) 
12

Area Action

Allentown, PA

Birmingham, AL Clean Data Determination

Canton-Massillon, OH

Charleston, WV

Chico, CA

Cleveland-Akron-Lorain, OH

Detroit-Ann Arbor, MI

Fairbanks, AK

Harrisburg-Lebanon-Carlisle-York, PA

Imperial Co, CA

Johnstown, PA

Klamath Falls, OR

Knoxville, TN

Lancaster, PA

Liberty-Clairton, PA

Logan, UT-ID

Los Angeles-South Coast Air Basin, CA

Milwaukee-Racine, WI

New York-N. New Jersey-Long Island, NY-NJ-CT

Nogales, AZ

Oakridge, OR

Philadelphia-Wilmington, PA-NJ-DE

Pittsburgh-Beaver Valley, PA

Provo, UT

Sacramento, CA

Salt Lake City, UT

San Francisco Bay Area, CA

San Joaquin Valley, CA

Steubenville-Weirton, OH-WV

Tacoma, WA

Yuba City-Marysville, CA
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As indicated in Tables 1a and 1b, some areas have non-attainment area segments in 

more than one State. Furthermore, some multi-state areas span more than one EPA 

Regional Office. For example, the Philadelphia-Wilmington non-attainment area 

encompasses part of Pennsylvania, New Jersey, and Delaware. Pennsylvania and 

Delaware are in EPA Region 3 jurisdiction, while New Jersey is in EPA Region 2 

jurisdiction. This could increase the administrative burden of the State’s meeting the 

attainment demonstration, RFP, RACT and RACM requirements.

The size of the list of non-attainment areas also suggests greater administrative 

burden. However, the administrative requirements for attainment demonstrations, RFP, 

RACT and RACM are less for the areas that attain the PM2.5 NAAQS within 5 years or 

less of the non-attainment designation date. Furthermore, illustrative air quality

simulations and interpolations done that considered the effects of the Transport Rule

and Regional Haze for geographic areas (excluding AK, AZ, CA, ID, OR, UT, and WA

in the simulations) showed 10 areas with predicted design values above the 2006 PM2.5

NAAQS level in 2014. There are 15 States required to submit the PM2.5 SIPs to meet 

the requirements for the 20 areas needing additional local control measures above the 

Transport Rule predicted results. There are 10 nonattainment areas predicted to meet 

the 2006 PM2.5 design value in 2014 from the Transport Rule simulations. The 8

States for these 11 areas will have less administrative requirement in submitting the 

SIPs requirements

The numbers of non-attainment areas or parts of areas in each State and the 

associated EPA Regional Office are presented in Tables 2a and 2b. These were derived 

from the December 17, 2010 information at: 

http://www.epa.gov/air/oaqps/greenbk/rnca.html. The numbers of areas predicted to be 

in attainment were derived by looking at the Transport Rule and Regional Haze air 

quality model simulation results as illustrated in Table 3a. Table 3b lists the western 

states not included in the Transport Rule modeling for which 2007-2009 monitoring 

data was used as an indicator of attainment.
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Table 2a. The Numbers of Non-Attainment Areas or Parts of Areas in Each State

and EPA Regional Office for the 1997 PM2.5 NAAQS

State or District

No. Areas 

or Parts of 

Areas

EPA 

Region

Alabama 2 4

California 2 9

Connecticut 1 1

District of Columbia 1 3

Delaware 1 3

Georgia 4 4

Illinois 2 5

Indiana 5 5

Kentucky 3 4

Maryland 3 3

Michigan 1 5

Missouri 1 7

Montana 1 8

North Carolina 2 4

New Jersey 2 2

New York 1 2

Ohio 9 5

Pennsylvania 8 3

Tennessee 2 4

Virginia 1 3

West Virginia 6 3

Table 2b. The Numbers of Non-Attainment Areas or Parts of Areas in Each State 

and EPA Regional Office for the 2006 PM2.5 NAAQS

State or District No. Areas or 

Parts of Areas EPA Region

No. of Nonattainment Areas 

Predicted in Attainment by 

2014

Connecticut 1 1 1

New Jersey 2 2 1

New York 1 2 no such area

Delaware 1 3 1

Pennsylvania 7 3 6

West Virginia 2 3 1
15

Alabama 1 4 no such area

Tennessee 1 4 1

Michigan 1 5 no such area

Ohio 3 5 2

Wisconsin 1 5 no such area

Utah 3 8 no such area

Arizona 1 9 1

California 7 9 1

Alaska 1 10 no such area

Idaho 1 10 no such area

Oregon 2 10 no such area

Washington 1 10 no such area

Table 3a. Summary of Results of CAM-X Simulations for Eastern United States 

Base Case Runs and Interpolations Which Include Emission Reductions from 

the Transport Rule (TR1)*

Nonattainment Area Projected Attainment Status in 2014

Allentown, PA Attainment

Birmingham, AL Nonattainment

Canton-Massillon, OH Attainment

Charleston, WV Attainment

Cleveland-Akron-Lorain, OH Nonattainment

Detroit-Ann Arbor, MI Nonattainment

Harrisburg-Lebanon-Carlisle-York, PA Attainment

Johnstown, PA Attainment

Knoxville, TN Attainment

Lancaster, PA Attainment

Liberty-Clairton, PA Nonattainment

Milwaukee-Racine, WI Nonattainment

New York-N. New Jersey-Long Island, NY-NJCT Nonattainment

Philadelphia-Wilmington, PA-NJ-DE Attainment

Pittsburgh-Beaver Valley, PA Attainment

Steubenville-Weirton, OH-WV Nonattainment

* This is an illustrative simulation and is not necessarily a substitute for the work undertaken by the States in response to

requirements for attainment demonstrations, RFP SIP submittals, RACT SIP submittals and RACM SIP submittals.
16

Table 3b. Summary of Western Nonattainment Areas Not Included in 

Transport Rule Simulations

Nonattainment Area Projected Attainment Status in 2014

Chico, CA Nonattainment

Fairbanks, AK Nonattainment

Imperial Co, CA Attainment

Klamath Falls, OR Nonattainment

Logan, UT-ID Nonattainment

Los Angeles-South Coast Air Basin, CA Nonattainment

Nogales, AZ Attainment

Oakridge, OR Nonattainment

Provo, UT Nonattainment

Sacramento, CA Nonattainment

Salt Lake City, UT Nonattainment

San Francisco Bay Area, CA Nonattainment

San Joaquin Valley, CA Nonattainment

Tacoma, WA Nonattainment

Yuba City-Marysville, CA Nonattainment

 4(b) Information Requested

The information requested under this ICR is prescribed by 40 CFR 51.1007 (attainment 

demonstration), 51.1009 (RFP), and 51.1010 (RACT and RACM). The implementation 

framework set forth in the regulation does not adopt a “one-size-fits all” approach to 

meeting the attainment demonstration or RFP, RACT, and RACM requirements. This 

additional flexibility enables the States to customize, to the extent allowed by the Clean Air 

Act, their approach to attaining and maintaining the PM2.5 NAAQS.

Data Items. The emissions and control efficiency data required for the attainment 

demonstration, RFP, RACT, and RACM should have been collected as a result of reporting 

activities required by other OMB approved ICRs. For example, see the ICR associated 

with the Final Consolidated Emissions Reporting Rule (CERR):

http://www.epa.gov/ttn/chief/cerr/index.html. 

There may be other data that the States use. For example, States may identify

economic and population growth rates, federal rules that reduce future emissions of 

particulate matter precursors, and meteorological data. These data are presently available. 

Respondents’ Activities. The States will compile and reference the data, set forth the 

methodology, conduct analyses, develop initial drafts, hold hearings, adopt rules, 

regulations, and programs, have discussions with EPA staff as appropriate, refine the draft 
17

demonstration and RFP, RACT, and RACM requirements as appropriate, adopt the SIP, 

and forward to EPA.

Agency Activities. EPA staff in the regional offices may facilitate timely receipt of the 

attainment demonstration, RFP, RACT, and RACM requirements by reviewing materials 

and answering questions from the States regarding: requirements, potential data sources, 

analysis tools, the draft attainment demonstration and other submissions. The EPA 

Regional Offices will evaluate the SIP submissions and take rulemaking actions to approve 

or disapprove the SIP revisions. 

EPA headquarters staff will facilitate information flow amongst the regions and States 

to foster timely attainment of acceptable demonstrations and SIP submissions.

Reporting Protocols. The dates for the submissions are December 14, 2012 as set forth in 

Part D- Plan Requirements for Nonattainment Areas – Subpart 1- Nonattainment Areas in 

General and the PM2.5 Implementation rule.

5.0 The Information Collected—Agency Activities, Collection 

Methodology, and Information Management

 

 5(a) States, EPA Regional Offices, and EPA Headquarters Offices

States: The States agencies’ activities include5:

 Forecast baseline emissions, develop and evaluate emission reduction strategies 

where warranted, conduct air quality modeling to verify maintenance and 

attainment of the PM2.5 NAAQS

 Calculate the emission reductions necessary to fulfill RFP requirement, 

determine creditable emission reductions, where necessary determine additional 

emission reductions and compliance timing to meet RFP requirement. Draft 

findings, hold State hearings, make revisions as warranted. Submit RFP SIP as 

part of SIP to EPA Regional office. Have discussions with EPA.

 Identify RACT applicable sources and their control measures under baseline 

and attainment conditions; and evaluate alternatives. Draft findings, hold State

hearings, make revisions as warranted. Submit RACT determinations as part of 

SIP to EPA Regional Office. Have discussions with EPA.

 Identify RACM applicable sources and their control measures under baseline 

and attainment conditions; and evaluate alternatives. Draft findings, hold State

hearings, make revisions as warranted. Submit RACM determinations to EPA 

Regional Office. Have discussions with EPA.

 

5

 In some instances, there are local air pollution control districts within the states. These local agencies work 

in partnership with the states to facilitate accomplishment of the activities noted below. 
18

EPA Regional Offices. The regional office activities include:

 Answering inquiries put forth by the States.

 Reviewing data, analysis, and findings of attainment demonstration, RFP, 

RACT and RACM determinations.

 Rulemaking actions approving or disapproving the SIP submissions

EPA Headquarters. The EPA headquarters office activities include:

 Facilitating information flow and problem solving amongst the regions 

regarding demonstrations and submittals from the States

 Answering questions regarding application and interpretation of salient rule 

provisions.

5(b) Collection Methodology and Management

The PM2.5 SIP meeting the attainment demonstration and RFP, RACT and 

RACM requirements will set forth the data sources and analytical methods, as well as 

the emission reduction and air quality improvement verification procedures. 

 5(c) Small Entity Flexibility

For an approved ICR, the Agency must demonstrate that it has taken all 

 practical steps to develop separate and simplified requirements for small businesses and 

other small entities. See 5 CFR 1320.6(h). The PM2.5 NAAQS implementation 

regulation does not provide a direct administrative burden on small entities. 

 5(d) Collection Schedule

During the period from June 1, 2011 through May 31, 2014, the SIP for the 2006 

PM2.5 standardis due on December 14, 2012 that meets the required elements for the

attainment demonstration, RFP, RACT and RACM.

Attainment Demonstration. The demonstration submission date is December 14, 

2012 for Subpart 1 designated non-attainment areas. 

RFP. The RFP SIP submission date is December 14, 2012 for designated nonattainment areas. However, areas that demonstrate attainment as expeditiously as 

practicable but no more than 5 years following designation meet RFP. 

RACT and RACM. For designated non-attainment areas which demonstrate 

attainment as expeditiously as practicable, but no later than 5 years following 

designation, RACT and RACM are met. For areas having an attainment date of more 

than 5 years, the RACT and RACM SIP submission date is December 14, 2012. 
19

6. Estimating the Burden of the Collection

This section provides information on the cost and hours associated with the 

information collection for both the respondents (the affected States) and the Agency

(regional and headquarters offices). Hours and costs are presented for the activities 

associated with each collection item for a non-attainment area (or segment) in a given 

State, as well as the equivalent annual and present value numbers.

6(a) Estimating Respondent Burden

The estimated respondent burden is that associated with the activities which result 

in the States meeting the attainment demonstration, RFP, RACT, and RACM SIP 

requirements. 

The estimated burden is incremental to that required by other EPA environmental 

reporting obligations. The incremental burden for some areas may be less than for 

others. There are several reasons for this disparity. 

 The severity of the non-attainment problem varies among the designated 

areas.

 Certain areas or parts of areas may already have developed and implemented 

RACT and RACM requirements. 

 Some areas may have future predicted PM2.5 design values which 

demonstrate attainment in expeditious and practicable fashion, within 5 

years of designation, under baseline conditions.

 Some areas may fulfill the RFP requirement as a result of creditable 

emission reductions resulting from federal rules that reduce PM2.5 precursor 

emissions.

In the course of conducting the Transport Rule analysis and the economic 

assessment for the PM2.5 NAAQS Implementation Rule, the EPA staff conducted air 

quality simulations. Some of the results are summarized in Table 3. This information, 

together with that in Tables 1 and 2 can serve in estimating the burden hours.

Subpart 1 Non-attainment Areas. 

Of the original 39 nonattainment areas with 58 SIP revisions required for the 1997 

PM2.5 standard, only one area has an outstanding requirements due ( IL part of St. 

Louis, MO-IL nonattainment area). Of the remaining 57 required SIPs, 47 have 

submitted Attainment Demonstration SIPs, 22 have final approved Clean Data 

Determinations, and 5 have submitted Redesignation requests. Thus the bulk of the 

remaining work for these areas consists of developing Maintenance SIPs or mid-course 

corrections for those areas not demonstrating attainment in the 5 years after the area 

was designated nonattainment. The estimated burden for these areas was 300 hours for 

the states to complete their 1997 PM2.5 actions.

EPA designated 31 areas nonattainment for the 2006 PM2.5 NAAQS on January

26, 2011 (http://www.epa.gov/air/oaqps/greenbk/rnc.html). The base case air quality 
20

modeling simulations (see Table 3) were used to develop burden hour estimates for the 

non-attainment areas. The base case modeling was for the Transport Rule (TR1). 

Western states were not included in the TR1 modeling. Hence, monitored readings 

from 2007-2009 were used as indicators for attaining the 2006 PM2.5 standard (see 

Table 4). Some of the 15 nonattainment area in the western states (Alaska, Arizona, 

California, Idaho, Oregon, Utah, and Washington) predominately experience local 

PM2.5 issues as a result of wood-burning stoves in wintertime that would not be 

modeled in the TR1 simulations. Of the 16 nonattainment area for the 2006 PM2.5 

NAAQS, for which TR1 modeling was conducted, it is anticipated that 9 of the 16

nonattainment areas will attain the standard by 2014.

These simulations and interpolations assumed no additional emission reductions as 

a result of the States developing emission reductions as part of a PM2.5 NAAQS SIP. 

Furthermore, the simulations did not assume any additional emission reductions from 

the Transport Rule. Under these conditions, of the 16 areas included in the analysis, 7 

areas did not have a predicted PM2.5 design value simulated to meet PM2.5 NAAQS by

the end of 2014. If the progress in the simulation is presumed to be as expeditious as 

practicable, the 9 areas meeting the NAAQS should have little problem in developing 

simulations demonstrating attainment and using that information to fulfill the RACT, 

RACM and RFP SIP requirements. The States with these 9 areas may wish to use the 

emission projections, air quality modeling simulations, and design value predictions to 

fulfill most of their attainment demonstration requirement.

As a starting point for developing burden estimates, the Agency looked at the total 

hours expended in related EPA level of effort work assignments for meeting the 1997 

ozone NAAQS, exclusive of the air quality modeling. The total was about 2000 hours 

in level of technical effort.6 The potential scope of that effort was geographically broad 

including all non-attainment areas outside CA. Examples of the specific scope of the 

effort included:

 Design of lower cost control strategies for 16 Subpart 2 moderate and 

certain Subpart 1 areas

 Examination of alternative emission reduction targets and geographic areas 

(e.g., staying in State but going up to 100km for VOC emissions reductions 

and up to 200km for NOx emission reductions for some non-attainment 

areas).

 Assessment of RFP requirements for certain non-attainment areas, 

 Assessment of RACT/RACM

 Differences in cost, emission reductions, economic, and energy impacts 

looking at alternative frameworks for Phases 1 and 2 of the Implementation Rule.

These activities are related to but do not precisely mimic the incremental activities 

undertaken by a State to fulfill the attainment demonstration including the reasonably 

available control measure analysis as well as the RACT SIP, and RFP SIP submissions 

for a given 1 non-attainment area.

 

6 EPA Contract No. 68-D-00-283; Work Assignments 3-53 and 4-66.
21

To avoid understating the State burden, an estimate of 3,000 hours per nonattainment area per State was assumed and applied to the 9 areas that were projected to 

be in attainment by 2014.

7

 

Most of this estimated burden would be incurred in the first year. This is because of 

the overlap of emission reductions associated with the attainment demonstration, RACT 

requirements, and the RFP requirements. For example, emission reductions resulting 

from RACT may be creditable toward attainment and RFP. Furthermore, for Subpart 1 

areas which are projected to meet the standard in an expeditious manner by 2014, that 

demonstration fulfills the RACT, RACM and RFP requirements. Hence, although the 

attainment demonstration is not due until December 12, 2012, it benefits the State and 

potentially regulated entities to make the attainment demonstration and, where 

appropriate, the RACT/RACM/RFP requirements early in the implementation planning 

process. The presumed allocation of total incremental burden across time is 50% in 

year 1, 25% in year 2, and 25% in year 3. 

For the remaining 7 non-attainment area not predicted below the NAAQS in 2014, 

the total incremental burden hour estimate was increased by a factor of 6. Specifically, 

the estimated burden for these areas was 18,000 hours. This estimate may be too high. 

However, directionally, one would expect more burden for the attainment 

demonstration in an area not expected to attain the standard within 5 years of 

designation under base case conditions. The estimated burden was increased for 9

States for the 7 areas because certain areas are multiple State areas. The allocation of 

burden hours across time was the same for the 7 areas as that for the other Subpart 1 

areas. 

The estimated incremental burden for non-attainment areas is presented in Tables

4a and 4b. The State total burden includes some non-attainment areas that include 

multiple States. For example, the Washington PM2.5 non-attainment area requires SIP 

submittals from DC, MD and VA. Tables 4a and 4b present the differences between 

estimated burden for States predicted to meet the PM2.5 NAAQS with Federal Control 

programs on the one hand and other States with areas not predicted to meet the 

NAAQS. 

 

7

For example, if a Subpart 1 area which is projected to attain the standard by 2014 is in two states, the 

assumed burden is 6,000 hours: 3,000 hours for each state. If a similar Subpart 1 area is found in only one 

state, the burden is assumed to be 3,000 hours.
22

Table 4a. Estimated Remaining Incremental Burden for the States Attainment 

Demonstration, RFP SIP Submission, mid-course correction and maintenance 

plans for the Subpart 1 Non-Attainment Areas for the 1997 PM2.5 NAAQS.

State or District EPA Region

No. of 

Areas or 

Parts of 

Areas

Additional Hours 

Year 1

Additional Hours 

Year 2

Additional

Hours Year 3

Alabama 4 2 150 75 75

California 9 2 1,500 750 750

Connecticut 1 1 150 75 75

District of 

Columbia 3 1 150 75 75

Delaware 3 1 150 75 75

Georgia 4 4 9,450 4,725 4,725

Illinois 5 2 9,150 4,575 4,575

Indiana 5 5 450 225 225

Kentucky 4 3 450 225 225

Maryland 3 3 450 225 225

Michigan 5 1 150 75 75

Missouri 7 1 150 75 75

Montana 8 1 150 75 75

North 

Carolina 4 2 150 75 75

New Jersey 2 2 300 150 150

New York 2 1 150 75 75

Ohio 5 9 1,350 675 675

Pennsylvania 3 8 1,800 900 900

Tennessee 4 2 300 150 150

Virginia 3 1 150 75 75

West Virginia 3 6 900 450 450

Total Not 

Applicable

58 27,600 13,800 13,800

Table 4b. Estimated Incremental Burden for the States Attainment 

Demonstration, RACT SIP Submission, and RFP SIP Submission for the 

Subpart 1 Non-Attainment Areas for the 2006 PM2.5 NAAQS.

State or District EPA Region

No. of Areas 

or Parts of 

Areas

Additional Hours 

Year 1

Additional Hours 

Year 2

Additional Hours 

Year 3

Alabama 4 1 9,000 4,500 4,500

Alaska 10 1 9,000 4,500 4,500

Arizona 9 1 1,500 750 750

California 9 7 55,500 27,750 27,750

Connecticut 1 1 9,000 4,500 4,500

Delaware 3 1 1,500 750 750

Idaho 10 1 9,000 4,500 4,500
23

Michigan 5 1 9,000 4,500 4,500

New Jersey 2 2 10,500 5,250 5,250

New York 2 1 9,000 4,500 4,500

Ohio 5 3 19,500 9,750 9,750

Oregon 10 2 18,000 9,000 9,000

Pennsylvania 3 7 18,000 9,000 9,000

Tennessee 4 1 1,500 750 750

Utah 8 3 27,000 13,500 13,500

Washington 10 1 9,000 4,500 4,500

West Virginia 3 2 10,500 5,250 5,250

Alabama 4 1 9,000 4,500 4,500

Total Not 

Applicable 37 235,500 117,750 117,750

6(b) Estimating Respondent Cost

Labor costs are estimated for State governments using the total of projected 

additional hours for the Subpart 1 areas. These estimates do not reflect staff 

experience and economies of scale. The hourly rates are the result of estimated 

directed and indirect cost per employee. The main source of the information is 

http://www.opm.gov/oca/payrates/index.htm

The estimated weighted direct salary cost per employee is $35.88 per hour. 

This results from a summation of the professional, managerial, and support staff 

components. 

 Hourly equivalent 2010 Salary of Permanent Professional Staff at GS 11, Step 3 

is $33.34. This is the average of hourly equivalent rates for the San Francisco, 

CA and Washington, D.C. areas.

 To account for permanent managerial staff, 1/11 or 9% of the hourly rate for GS 

13, Step 3 is added to the professional staff hourly rates. The average hourly 

equivalent rate for GS-13 using rates for San Francisco, CA and Washington, 

D.C. is $47.51. Nine percent of that is $4.32.

 To account for permanent support staff at GS-6, Step 6, 1/8 or 16% of the 

hourly rate is added to the professional staff hourly rates. The average hourly

equivalent rate for GS-6, Step 6 using rates for San Francisco, CA and 

Washington, D.C. is $22.17. Sixteen percent of that is $3.55. 

The estimated hourly indirect cost per employee is $23.90. This amount is the sum of the 

following:

 Benefits at 16% of the weighted direct hourly equivalent salary cost per employee 

or $6.59.
24

 Sick and annual leave at 10% of the weighted direct hourly equivalent salary cost 

per employee or $4.12.

 General overhead at 32% of the weighed direct hourly equivalent salary cost per 

employee or $13.18.

The estimated total weighted direct and indirect hourly equivalent salary cost 

per employee is $65.10. For the 1997 NAAQS, the remaining additional cost in 

year 1 for the 21 States to submit the SIP requirements for the 58 areas or parts of 

areas is $1.8 million. The cost estimates for years 2 and 3 are $0.9 million. For the 

2006 NAAQS, the additional cost in year 1 for the 18 States to submit the SIP 

requirements for the 31 areas or parts of areas is $15.3 million. The cost estimates 

for years 2 and 3 are $7.7 million. State costs are detailed in Tables 5a and 5b.

Table 5a. Estimated Incremental Cost for the States Attainment 

Demonstration, RFP SIP Submission, mid-course correction and maintenance 

plans for the Subpart 1 Non-Attainment Areas for the 1997 PM2.5 NAAQS.

State Region Yr 1 cost Yr 2 cost Yr 3 cost

Alabama 4 $9,765 $4,883 $4,883

California 9 $97,650 $48,825 $48,825

Connecticut 1 $9,765 $4,883 $4,883

Delaware 3 $9,765 $4,883 $4,883

District of Columbia 3 $9,765 $4,883 $4,883

Georgia 4 $615,195 $307,598 $307,598

Illinois 5 $595,665 $297,833 $297,833

Indiana 5 $29,295 $14,648 $14,648

Kentucky 4 $29,295 $14,648 $14,648

Maryland 3 $29,295 $14,648 $14,648

Michigan 5 $9,765 $4,883 $4,883

Missouri 7 $9,765 $4,883 $4,883

Montana 8 $9,765 $4,883 $4,883

New Jersey 2 $19,530 $9,765 $9,765

New York 2 $9,765 $4,883 $4,883

North Carolina 4 $9,765 $4,883 $4,883

Ohio 5 $87,885 $43,943 $43,943

Pennsylvania 3 $117,180 $58,590 $58,590

Tennessee 4 $19,530 $9,765 $9,765

Virginia 3 $9,765 $4,883 $4,883

West Virginia 3 $58,590 $29,295 $29,295

SUM $1,796,760 $898,380 $898,380

 
25

Table 5b. Estimated Incremental Cost for the States Attainment 

Demonstration, RFP SIP Submission, mid-course correction and maintenance 

plans for the Subpart 1 Non-Attainment Areas for the 2006 PM2.5 NAAQS.

State Region Yr 1 cost Yr 2 cost Yr 3 cost

Connecticut 1 $585,900 $292,950 $292,950

New Jersey 2 $683,550 $341,775 $341,775

New York 2 $585,900 $292,950 $292,950

Delaware 3 $97,650 $48,825 $48,825

Pennsylvania 3 $1,171,800 $585,900 $585,900

West Virginia 3 $683,550 $341,775 $341,775

Alabama 4 $585,900 $292,950 $292,950

Tennessee 4 $97,650 $48,825 $48,825

Michigan 5 $585,900 $292,950 $292,950

Ohio 5 $1,269,450 $634,725 $634,725

Wisconsin 5 $585,900 $292,950 $292,950

Utah 8 $1,757,700 $878,850 $878,850

Arizona 9 $97,650 $48,825 $48,825

California 9 $3,613,050 $1,806,525 $1,806,525

Alaska 10 $585,900 $292,950 $292,950

Idaho 10 $585,900 $292,950 $292,950

Oregon 10 $1,171,800 $585,900 $585,900

Washington 10 $585,900 $292,950 $292,950

Sum $15,331,050 $7,665,525 $7,665,525

6(c) Estimating Agency Burden and Cost

The estimated agency burden is derived from the estimates for the respondents. 

Draft estimates were developed by the headquarters staff with review by regional 

office staff and subsequent refinement of the Agency burden and cost estimates.

The respondent burden was summed by EPA regional offices and a percentage 

was applied to the yearly burden estimate to reflect the actions taken on the part of 

the regional offices. Once yearly burdens were estimated for the Agency’s 

Regional Offices, a percentage of those amounts are specified to derive estimates 

for the Agency’s Headquarters Office Burdens. Discussions were held with 

Regional Office and Headquarters staff regarding the percentages and resulting 

burden estimates.

Agency Regional Office Burden. Table 6 summarizes total incremental 

respondent burden by Regional Office and provides estimates of total incremental 

Agency Regional Office burden. The summary of total incremental respondent 
26

burden comes from Tables 4a and 4b. The Agency Regional Office burden is 

presumed to be 10% of the estimated total incremental burden for respondent by

EPA Regional Office. The total incremental burden allocation for the Agency 

Regional Offices in Table 5 is 50% in year 1, 25% in year 2, and 25% in year 3.

In discussions with Agency Regional Office staff, they indicated that the total 

incremental burden estimates were ballpark. However, some regional office staff 

felt that a more reasonable allocation of total incremental Agency Regional Office 

burden would be 37.5% in year 1, 37.5% in year 2, and 25% in year 3. If that 

allocation were used, the corresponding Agency Regional Office burden estimates 

in years 1 and 2 would be 2,070 and year 3 would be 1,380. 

Table 6a. Estimated Agency Regional Office Burden Derived by Taking 10% 

of Regional Respondent Burden Total for Years 1, 2, and 3 for the 1997 PM2.5

NAAQS

EPA Regional 

Office

Total Regional

Respondents' burden (hrs)

Yr 1 EPA Region 

burden (hrs)

Yr 2 EPA Region burden 

(hrs)

Yr 3 EPA Region 

burden (hrs)

1 300 15 8 8

2 900 45 23 23

3 7,200 360 180 180

4 21,000 1,050 525 525

5 22,200 1,110 555 555

6

No PM2.5 Nonattainment 

areas

0 0 0

7 300 15 8 8

8 300 15 8 8

9 3,000 150 75 75

10 No PM2.5 Nonattainment 

areas

0 0 0

Sum 55,200 2,760 1,380 1,380

Table 6b. Estimated Agency Regional Office Burden Derived by Taking 10% 

of Regional Respondent Burden Total for Years 1, 2, and 3 for the 2006 PM2.5

NAAQS

EPA Regional 

Office

Total Regional Respondents' 

burden (hrs)

Yr 1 EPA Region 

burden (hrs)

Yr 2 EPA Region 

burden (hrs)

Yr 3 EPA Region 

burden (hrs)

1 18,000 900 450 450

2 39,000 1,950 975 975

3 60,000 3,000 1,500 1,500

4 21,000 1,050 525 525

5 75,000 3,750 1,875 1,875

6 No PM2.5 Nonattainment areas 0 0 0

7 No PM2.5 Nonattainment areas 0 0 0

8 54,000 2,700 1,350 1,350

9 114,000 5,700 2,850 2,850

10 90,000 4,500 2,250 2,250

Sum 471,000 23,550 11,775 11,775
27

Agency Headquarters Burden. The Regional Office burden estimates for years 1, 

2, and 3 are multiplied by 10% to arrive at an estimate for Headquarters burden for 

the same 3 years. 50% of this number is assigned to year 1, and 25% of that 

number is assigned to years 2 and 3. Resulting hours for year 1 for the 1997 

NAAQS are 276. The estimates for years 2 and 3 are 138. Resulting hours for 

year 1 for the 2006 NAAQS are 2,355. The estimates for years 2 and 3 are 1,178. 

Total Incremental Burden for the Agency. The regional and headquarters office 

burden estimate for year 1 for the 1997 NAAQS is 3,036 hours. The estimates for 

years 2 and 3 are 1,518 hours each year. The regional and headquarters office 

burden estimate for year 1 for the 2006 NAAQS is 25,905 hours. The estimates for 

years 2 and 3 are 12,953 hours each year.

Total Cost for the Agency. Using the weighted direct and indirect salary

equivalent hour rate derived in section 6(b), the total incremental burden hours are 

multiplied by that rate. The result is the total cost estimate for the Agency; see 

Table 7.

Table 7a. 1997 NAAQS Total Cost Estimate for the Agency

Entity Year 1 Year 2 Year 3

Regional Offices $0.2 million $0.09 million $0.09 million

Headquarters 

Office $0.02 million $0.009 million $0.009 million

Total Agency 

Cost $0.2 million $0.1 million $0.1 million

Table 7b. 2006 NAAQS Total Cost Estimate for the Agency

Entity Year 1 Year 2 Year 3

Regional Offices $1.5 million $0.8 million $0.8 million

Headquarters 

Office $0.2 million $0.08 million $0.08 million

Total Agency 

Cost $1.7 million $0.8 million $0.8 million

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

Part D of Title I of the Clean Air Act of 1990 provided plan requirements 

for Subpart 1 non-attainment areas along with prescribed requirements and 

schedules for those areas. The major set of respondents is the States, as they have 

over 90% of the estimated additional burden to meet these requirements on the 

specified schedule. There is also burden imposed on the Regional and Headquarters 

Offices of the Agency. Because of the overlap in work for the attainment 

demonstration, RACM SIP submittal, RACT SIP submittal, and RFP SIP submittal, 

most of the cost will be incurred in year 1 of the 3 year period covered by this ICR. 
28

In the Agency’s roles as facilitator, compiler, reviewer, and preparer, the estimated 

burden for the Agency is also expected to be greater in the 1st year than in the 2nd or 

3

rd years. 

The total incremental respondent universe burden and cost estimates are 

presented in Tables 8a and 8b. 

Table 8a. 1997 PM2.5 NAAQS Total Incremental Respondent & Agency 

Universe Burden and Cost Estimates 

Entity

Average Yearly 

Burden (hours)

3-Year 

Burden (hrs)

Present Value of Costs 

for 3-Year Burden

States 18,400 55,200 $3,593,520

Agency 2,024 6,072 $364,626

Total 20,424 61,272 $3,958,146

Table 8b. 2006 PM2.5 NAAQS Total Incremental Respondent & Agency 

Universe Burden and Cost Estimates 

Entity

Average Yearly 

Burden (hours)

3-Year 

Burden (hrs)

Present Value of 

Costs for 3-Year 

Burden

States 157,000 471,000 $30,662,100

Agency 17,270 51,810 $3,111,215

Total 174,270 522,810 $33,773,315

*The estimates are in current year (2010) dollars. Costs for years 2 and 3 are calculated using the equation Present Value = 

Future Value/ (1 + interest rate)t ,where “t” is the number of years hence (i.e., 0 for year 1, 1 for year 2, 2 for year 3). The 

adjusted values for years 1, 2, and 3 are then summed.

6(e) Reason for Change in Burden

In the previous ICR for implementing the 1997 PM2.5 NAAQS, we estimated a total of 

210,000 burden annual hours for states. In this ICR revision, we are requesting a decrease 

in burden to states of 34,600 annual hours due to the following factors:

 The number of non-attainment areas has decreased as areas have come into compliance 

with the 1997 PM2.5 standards

 The burden associated with the remaining 1997 PM2.5 non-attainment areas is less 

because of the work they have done previously to comply with the standards.

 The burden associated with the nonattainment areas for the 2006 PM2.5 standard is less 

than the original burden of the 1997 standard due to fewer nonattainment areas.

 The burden associated with the nonattainment areas for the 2006 PM2.5 standard is less 

because some areas are projected to attain the standard before the area’s attainment date 

based on Transport Rule modeling projections.
29

The estimates have been calculated using 2010 dollars and some assumptions 

regarding overhead, O&M costs, and capital costs have been adjusted to meet current 

guidelines and common procedures for preparing ICRs.

6(f) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information

for the 1997 NAAQS is estimated to average 317 hours per response. Similarly, the annual 

public reporting and recordkeeping burden for this collection of information for the 2006 

NAAQS is estimated to average 4,243 hours per response. Burden means the total time, 

effort, or financial resources expended by persons to generate, maintain, retain, or disclose 

or provide information to or for a Federal agency. This includes the time needed to review 

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

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

information, and disclosing and providing information; adjust the existing ways to comply

with any previously applicable instructions and requirements; train personnel to be able to 

respond to a collection of information; search data sources; complete and review the 

collection of information; and transmit or otherwise disclose the information. 

An Agency may not conduct or sponsor, and a person is not required to respond to a 

collection of information unless it displays a currently valid OMB control number. The 

OMB control numbers for EPA’s regulations are listed in 40 CFR part 9 and 48 CFR 

chapter 15. However, as was stated in the April 2007 Federal Register Notice for the 

PM2.5 Implementation Rule, “... the failure to have an approved ICR for this rule does not 

affect the statutory obligation for the States to submit SIPs as required under part D of the 

CAA.”

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-2007-0265, which is available for online 

viewing at www.regulations.gov, or in person viewing at the Air and Radiation Docket in 

the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, 

NW, Washington, D.C. The EPA Docket Center Public Reading Room is open from 8:30 

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

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

Docket is (202) 566-1742. An electronic version of the public docket is available at 

www.regulations.gov. This site can be used to submit or view public comments, access the 

index listing of the contents of the public docket, and to access those documents in the 

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

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

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

NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA 
30

Docket ID Number EPA-HQ-OAR-2007-0265 and OMB Control Number 2060-0611 in 

any correspondence.