### i Table of Contents SUPPORTING STATEMENT for Renewal of Information Collection Requirements under the Paperwork Reduction Act, 44 U.S.C. 3501 et seq.

Final Rule at 40 CFR Part 8 Environmental Impact Assessment of Nongovernmental Activities in Antarcti ca Draft May 20 10 Page 1. Id entification of the I nformation Collection . . . . . . . . . . . . . . . . . . . . . . 1 1(a) Title of the I nformation Collection . . . . . . . . . . . . . . . . . . . . . . . 1 1(b) Abstract . . . . . . . . . . . . . .

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Environmental Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . 2 Coordination of Review of I nformation Received from Other Parties to the Treaty

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2. Need for and Use of the Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2(a) Need/Authority

for the Collection . . . . . . . . . . . . . . . . . . . . . . . . 4 2(b) Practical Utility

/ Users of the Data . . . . . . . . . . . . . . . . . . . . . . . . 4 Role of the I nformation in Regulatory Decisions . . . . . . . . . . . . . 4 Users of the I nformation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 3. Nonduplicat ion, Consultations, and Other Collection Criteria . . . . . . . . . 6 3(a) Nonduplication . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 3(b) Public Notice Required Prior to I CR Submission to OMB . . . . . . 7 3(c) C onsultations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 3(d) Effects of Less Frequent Collection . . . . . . . . . . . . . . . . . . . . . . . . 8 3(e) General Guidelines . . . . . . . . . . . . . . . . . . . .

. . . . . . . . . . . . . . . . 8 3(f) Confidentiality

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 3(g) Sensitive Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 4. The Respo ndents and the I nformation Requested . . . . . . . . . . . . . . . . . . . 9 4(a) Respondents/SI C and NAI CS Codes. . . . . . . . . . . . . . . . . . . . . . . 9 4(b) In formation Requested . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

. . . 9 Data items, including recordkeeping requirements . . . . . . . . . . . . . 9 Respondent Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 5. The I nformation Collected

-- Agency Activities, Collection Methodolog y, and I nformation Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 5(a) Agency

Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 5(b) Collection Methodology and Management . . .

. . . . . . . . . . . . . . . 16 5(c) Small Entity

Flexibility

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 5(d) Collection Schedule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

### ii

6. Estimating the Hours and Cost Burden of the Collection . . . . . . . . . . . . . . 21 6(a) Estimated Annual Respondent Hours and Cost . . . . . . . . . . . . . 21 6(b) Estimated Annual Federal Government Hours and Cost . . . . . . . 30 6(c) Model for Federal Government Review of I EEs . . . . . . . . . . . . . . 37 6(d) Estimated Annual Aggregate Hours and Cost . . . . . . . . . . . . . . . 42 6(e) Reason for Change in Burden . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 6(f) Burden Statement

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 Exhibit 1A: PERMs

- Estimated Respondent Hours and Cost . . . . . . . . . . . . . . 46 Exhibit 1B: I EEs

- Estimated Respondent Hours and Cost . . . . . . . . . . . . . .

. . 47 Table 1. I EEs

- Total Estimated Hours and Cost for the Three I EE Models with 3.5% Escalation Rate . . . . . . . . . . . . . . . . . . . . . . 49 Exhibit 1C: CEEs

- Estimated Respondent Hours and Cost . . . . . . . . . . . . . . . . 51 Ex hibit 1D: Reporting for Emergencies

- Estimated Respondent Hours and Cost Exhibit 2A: PERMs

- Estimated Federal Government Hours and Cost . . . . . . . . 53 Exhibit 2B: I EEs

- Estimated Federal Government Hours and Cost . . . . . . . . . . 55 Ta ble 2. I EEs

- Total Estimated Hours and Cost for the Three I EE Models with 3.5% Escalation Rate . . . . . . .. . . . . . . . . . . . . . . . 58 Exhibit 2C: CEEs

- Estimated Federal Government Hours and Cost . . . . . . . . . 59 Exhibit 2D: Repo rting for Emergencies

- Estimated Federal Government

Hours and Cost . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60 Exhibit 2E: Coordinating Review of I nformation Received from Other Parties

-

Estimated Federal Government Hours and Cost . . . . . . . . . . . . . . 61 Exhibit 3: Summary

- Estimated Respondent/Federal Government

Hours and Cost . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62 Chart 1. Estimated total and annual averag e hours and cost for each ty pe of environmental document that is submitted by a respondent under the Final Rule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62 Chart 2. Estimated total hours and costs for Multi

- Year I EE as t he anticipated level and ty

pe of environmental document most respondents submit under the Final Rule for the 3

- ye ar I CR renewal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62 Chart 3. Estimated hour s and costs for environmental documentation for 3

- ye ar period of this I CR renewal . . . . . . . . . . . . . . . . . . . . . 63 Exhibit 4: Summary

for Respondents and Federal Government

- O&M Costs . . 64 Part B: Statistical Survey

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B

- 1

### 1 SUPPORTING STATEMENT for Renewal of Information Collection Requirements under the Paperwork Reduction Act, 44 U.S.C. 3501 et seq.

Final Rule at 40 CFR Part 8 Environmen tal Impact Assessment of Nongovernmental Activities in Antarctica

___________________________________
1. IDENTIFICATION OF THE INFORMATION COLLECTION 1(a) TITLE OF THE INFORMATION COLLECTION: "Environmental Impact Assessment of Nongovernmental Activi ties in Antarctica (Renewal), EPA ICR Number 1808.05, OMB Control Number 2020
- 0007" 1(b) ABSTRACT: The Environmental Protection Agency = s (EPA = s) regulations at 40 CFR Part 8, Environmental I mpact Assessment of Nongovernmental Activities in Antarctica (Ru le), were promulgated pursuant to the Antarctic Science, Tourism, and Conservation Act of 1996 (Act), 16 U.S.C. 2401 et seq ., as amended, 16 U.S.C. 2403a, which implements the Protocol on Environmental Protection (Protocol) to the Antarctic Treaty of 1959 (Treaty

). The Rule provides for assessment of the environmental impacts of nongovernmental activities in Antarctica, including tourism, for which the United States is required to give advance notice under Paragraph 5 of Article VI I of the Treaty , and for coordination of the review of information regarding environmental impact assessments received from other Parties under the Protocol. The requirements of the Rule apply to operators of nongovernmental expeditions organized in or proceeding from the territ ory of the United States to Antarctica and include commercial and non

commercial expeditions. Expeditions may include ship

- based tours; y acht, skiing or mountaineering expeditions; privately funded research expeditions; and other nongovernmental activiti es. The Rule does not apply to individual U.S. citizens or groups of citizens planning to travel to Antarctica on an expedition for which they are not acting as an operator. (Operators, for example, ty

pically acquire use of vessels or aircraft, hire expe dition staff, plan itineraries, and undertake other organizational responsibilities.) The Rule provides nongovernmental operators with the specific requirements they need to meet in order to comply with the requirements of Article 8 and Annex I

to the Pro tocol. The provisions of the Rule are intended to ensure that potential environmental effects of nongovernmental activities undertaken in Antarctica are appropriately

identified and considered by the operator during the planning process and that to the ex tent practicable, appropriate environmental safeguards which would mitigate or prevent adverse impacts on the Antarctic environment are identified by the operator. Environmental Documentation . Persons subject to the Rule must prepare environmental docum entation to support the operator's determination regarding the level of environmental

### 2

impact of the proposed expedition. Environmental documentation includes a Preliminary Environmental Review Memorandum (PERM), an I nitial Environmental Evaluation (I EE), or a Comprehensive Environmental Evaluation (CEE). The environmental document is submitted to the Office of Federal Activities (OFA). I f the operator determines that an expedition may have: (1) less than a minor or transitory impact, a PERM needs to be submitted no later than 180 day s before the proposed departure to Antarctica; (2) no more than minor or transitory impacts, an IE E needs to be submitted no later than 90 day s before the proposed departure; or (3) more than minor or transitory

impacts, a C EE needs to be submitted. Operators who anticipate such activities are encouraged to consult with EPA as soon as possible regarding the date for submittal of the CEE. 1 

### The Protocol and the Rule also require an operator to employ procedures to assess and provide a regular and verifiable record of the actual impacts of an activity which proceeds on the basis of an I EE or CEE. The record developed through these measures needs to be designed to: (a) enable assessments to be made of the extent to which envir onmental impacts of nongovernmental expeditions are consistent with the Protocol; and (b) provide information useful for minimizing and mitigating those impacts and, where appropriate, on the need for suspension, cancellation, or modification of the activi ty . Moreover, an operator needs to monitor key environmental indicators for an activity proceeding on the basis of a CEE. An operator may also need to carry

out monitoring in order to assess and verify the impact of an activity

for which an I EE would be prepared. For activities that require an I EE, an operator should be able to use procedures currently

being voluntarily

utilized by

operators to provide the required information. 2 

### Should an activity

require a CEE, the operator should consult with EPA to: (a) identify the monitoring regime appropriate to that activity , and (b) determine whether and how the operator might utilize relevant monitoring data collected by the U.S. Antarctic Program. OFA would consult with the National Science Foundation and oth er interested Federal agencies regarding the monitoring regime.

1 Article 3(4), of Annex I of the Pro tocol requires that draft CEEs be distributed to all Parties and the Committee for Environmental Protection 120 days in advance of the next Antarctic Treaty Consultative Meeting (ATCM) at w

hich the CEE may be addressed.
2 For example, such information inclu des, as appropriate and to the best of the operator = s knowledge: identification of the number of tourists put ashore at each site, the number and location of each landing site, the total number of tourists at each site per ship and for the season; the numb er of times the site has been visited in the past; the number of times the site is expected to be visited in the forthcoming season; the times of the year that visits are expected to occur (e.g., before, during, or after the penguin breeding season); the n umber of visitors expected to be put ashore at the site at any one time and over the course of a particular visit; what visitors are expected to do while at the site; verification that guidelines for tourists are followed; description of any tourist except ions to the landing guidelines; and description of any activity requiring mitigation, the mitigative actions undertaken, and the actual or projected outcome of the mitigation.

### 3

In cases of emergency

relating to the safety

of human life or of ships, aircraft, equipment and facilities of high value, or the protection of the environment which would require an activity to be undertaken without completion of the documentation procedures set out in the Rule, the operator would need to notify the Department of State within 15 day s of any activities which would have otherwise required preparation of a CEE, and provide a ful l explanation of the activities carried out within 45 day s of those activities. 3 

### Environmental documents (e.g., PERM, I EE, CEE) are submitted to OFA. Environmental documents are reviewed by OFA, in consultation with the National Science Foundation and ot her interested Federal agencies, and also made available to other Parties and the public as required under the Protocol or otherwise requested. OFA notifies the public of document availability

via the World Wide Web at: http://www.epa.gov/compliance/nepa /international/antarctica/index.html. The ty pes of nongovernmental activities currently being carried out (e.g., ship

- based tours, land

- based tours, flights, and privately

funded research expeditions) are ty pically unlikely to have impacts that are more t han minor or transitory , thus an I EE is the ty pical level of environmental documentation submitted. For the 1997

- 1998 through 200 9

- 20 10 austral summer seasons during the time Rule ha s been in effect, all respondents submitted I EEs with the exception of on e PERM. Paperwork reduction provisions in the Final Rule that are used by the operators include: a) incorporation of material into the environmental document by referring to it in the I EE; b) inclusion of all proposed expeditions by one operator within o ne I EE; c) use of one I EE to address expeditions being carried out by more than one operator; and d) use of multi

- ye ar environmental documentation to address proposed expeditions for a period of up to five consecutive austral summer seasons. Coordinatio n of Review of I nformation Received from Other Parties to the Treaty . The Rule also provides for the coordination of review of information received from other Parties and the public availability

of that information including: (1) a description of nationa l procedures for considering the environmental impacts of proposed activities; (2) an annual list of any I EEs and any decisions taken in consequence thereof; (3) significant information obtained and any action taken in consequence thereof with regard to mo nitoring from I EEs and CEEs; and (4) information in a final CEE. This provision fulfills the United States' obligation to meet the requirements of Article 6 of Annex I to the Protocol. The Department of State is responsible for coordination of these revi ews of drafts with interested Federal agencies, and for public availability

of documents and information. This portion of the Rule does not impose paperwork requirements on any

nongovernmental person subject to U.S. regulation.

3 During the time the Interim Final and Final Rules have been in effect, there we re no emergencies requiring notification by U.S. operators. An Interim Final Rule was in effect from April 30, 1997, until replaced on December 6, 2001, by the Final Rule. The term Rule in this document refers to the period of time the Interim Final and Final Rules have been in place at 40 CFR Part 8 (e.g., for this ICR renew al, the years 1997

- 2010 w hich includes the 1997

- 1998 through 2009

- 2010 austral summer seasons).

### 4

2. NEED FOR AND USE OF TH E COLLECTION 2(a) NEED/AUTHORITY FOR THE COLLECTION: The basis for the Rule is the United States Code as amended: 16 U.S.C. 2401 et seq., as amended, 16 U.S.C. 2403a. The Rule, promulgated pursuant to the Antarctic Science, Tourism, and Conservation Act of 1996, provides nongovernmental operators with the specific requirements they need to meet in order to comply

with the requirements of Article 8 and Annex I to the Protocol on Environmental Protection to the Antarctic Treaty of 1959 and provides for the environmental impact assessment of nongovernmental activities, including tourism, for which the United States is required to give advance notice under paragraph 5 of Article VI I of the Antarctic Treaty of 1959. The Rule also provides for coordination of the review of information regarding environmental impact assessment received by the United States from other Parties under the Protocol. This provision of the Rule includes Federal agency requirements, but does not impose paperwork requirements on any nongovernmental person subject to U.S. regulation. The procedures in the Rule are designed to: ensure that nongovernmental operators identify and assess the potential impacts of their proposed activities, including tourism, on the Antarctic environment; that operators consider these impacts in deciding whether or how to proceed with proposed activities; and that operators provide environmental documentation pursuant to the Act and Annex I of the Protocol. These procedures are consistent with and implemen t the environmental impact assessment provisions of Article 8 and Annex I to the Protocol on Environmental Protection to the Antarctic Treaty

. 2(b) PRACTICAL UTILITY/USERS OF THE DATA: Role of the I nformation in Regulatory Decisions : The Office of Feder al Activities uses environmental impact assessment information and any associated assessment and verification information to ensure that nongovernmental operators identify and assess the potential impacts of their proposed activities, including tourism, on the Antarctic environment; that operators consider these impacts in deciding whether or how to proceed with proposed activities; and that operators provide environmental documentation pursuant to the Act and Annex I of the Protocol. The procedures in the Rule are consistent with and implement the environmental impact assessment provisions of Article 8 and Annex I to the Protocol. The provisions of the Rule are intended to ensure that potential environmental effects of nongovernmental activities undertake n in Antarctica are appropriately identified and considered by the operator during the planning process and that to the extent practicable, appropriate environmental safeguards which would mitigate or prevent adverse impacts on the Antarctic environment ar e identified by the operator. The Rule addresses measures to assess and verify environmental impacts but does not set schedule requirements for submission of assessment and verification reports. Under the Rule, all

### 5

proposed activities for which an I EE o r CEE are prepared need to include procedures designed to provide a regular and verifiable record of the impacts of these activities. For activities requiring an I EE, the Preamble to the Rule states that operators should be able to use the annual procedur es that are voluntarily

utilized by

operators to provide the information. Because measures to assess and verify

environmental impacts for all proposed activities for which an I EE or CEE are prepared are required by

the Rule, and because of the recordkeepi ng requirements of and burden definition in the Paperwork Reduction Act (PRA), EPA has included this information as an element for the operators for which hours and cost were calculated. Because operators voluntarily

provide the information to the governm ent, the hours and cost of review of this information was also included in the government = s burden estimate. I n this case, EPA believes the PRA, Section 3502(13) clearly supports the view that recordkeeping requirements must be considered inclusively

in d eveloping the I CR budget. 4

4 The Paperw ork Reduction Act, 44 U.S.C. Section 3502, states:

A (13) the term A recordk eeping requirement @ means a requirement imposed by or for an agency on persons to maintain specified records, including a requirement to

- (A) retain such records; (B) notify third parties, the Federal Government, or the public of the existence of such rec ords; (C) disclose such records to third parties, the Federal Government, or the public; or (D) report to third parties, the Federal Government, or the public regarding such records; ... @

A Burden @ is defined in the Preamble to the Final Rule, Section VII, Paperw ork Reduction Act, as A ... 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. ... @ 

### The purpose of the Rule is to ensure that the United States has the ability to implement its environmental impact assessment obligations for nongovernmental operators under the Protocol. Section 8.9(b) in the Rule requires tha t operators have A procedures designed to provide a regular and verifiable record of the impacts of these activities. @ The EPA believes that this establishes a requirement that the information be available to EPA. Otherwise, there is no way to know if an operator was in compliance with this requirement in the regulation. As stated in the Preamble to the Rule, it is EPA = s view that, at a minimum, an I EE is the appropriate level of environmental documentation for proposed activities where multiples of the a ctivity over time are likely

and may create a cumulative impact. For activities requiring an I EE, an operator should be able to use procedures that are voluntarily utilized by

operators to provide the required information. The operators currently

provide post
- visit reports to Antarctic Treaty Parties. Currently , the National Science Foundation receives the information voluntarily submitted by

the tour operators and, in cooperation with the I nternational Association of Antarctica Tour Operators (I AATO), u ses the information to prepare annual summary reports. EPA assumes this voluntary process of post

visit reporting will continue. EPA intends to review the information voluntarily submitted, and to maintain files. Because operators are currently voluntar ily

providing the informational reports to the government and because EPA anticipates that this practice will continue, EPA included the hours and cost of review of this information in the government = s burden estimates.

### 6

Users of the I nformation : The proc edures in the Rule include procedures for environmental documentation, any associated assessment and verification information, and any reporting in cases of emergency . This information would be used as follows:

$ By operators to identify

and assess the p otential impacts of their proposed activities, including tourism, on the Antarctic environment; to consider these impacts in deciding whether or how to proceed with proposed activities; and to provide environmental documentation pursuant to the Act and Ann ex I of the Protocol. For a CEE, any decision by the operator on whether a proposed activity should proceed in either its original or modified form must be based upon the final CEE as well as other relevant considerations, and the information provided in an evaluation should allow the operator to make decisions based on sound understanding of factors relevant to the likely impact of the proposed activity

.

$ By OFA, in consultation with other interested Federal agencies, to ensure that nongovernmental oper ators identify and assess the potential impacts of their proposed activities, including tourism, on the Antarctic environment, and that operators consider these impacts in deciding whether or how to proceed with proposed activities. OFA also makes the envi ronmental documentation and any associated assessment and verification information available to other Parties to the Treaty and the public as required under the Protocol or as otherwise requested. OFA uses the assessment and verification information for s uch things as tracking Antarctic tourism trends and activities.

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 3(a) NONDUPLICATION: The information that is requested from respondents under this I CR is required by statute and is not available from other sources. The Act requires these regulations to be consistent with Annex I to the Protocol, and the Rule provides nongovernmental operators with the specific requirements they need to meet in order to comply with the Protocol. Most Antarctica tour operators currently provide, on an informal basis, information to the National Science Foundation prior to each Antarctic season. Operators also provide an advance notice to the U.S. Department of State. This information is similar to the basic information requirements for preparation of environmental documentation under the Rule. However, the Rule ensures that nongovernmental operators identify and assess the potential impacts of their proposed activities, including tourism, on the Antar ctic environment, and that operators consider these impacts in deciding whether or how to proceed with proposed activities. Even the lowest level of environmental documentation, the PERM, directs that the assessment

### 7

process include assessment of the poten tial direct and reasonably foreseeable indirect impacts on the Antarctic environment of the proposed expedition in sufficient detail to assess whether the proposed activity

has less than a minor or transitory impact, a requirement that leads to consistency with Article 8 and Annex I of the Protocol. Operators can, and usually do, include a copy of the advance notice as part of their EI A documentation. 5 

### However, simply providing a copy of the advance notice submitted to the Department of State as the envir onmental documentation would not meet the requirements of Article 8 and Annex I of the Protocol or the provisions of the Rule. 3(b) Public Notice Required Prior to ICR Submission to OMB: The Office of Federal Activities published a Notice in the Federal Register requesting public comments on the renewal of this I CR and established a public docket for this I CR renewal under Docket I D number HQ

- OECA

- OECA

- 2007

- 0468. This docket is available for public viewing at the Enforcement and Compliance Docket and I nf ormation Center in the EPA Docket Center (EPA/DC), EPA West, Room B102, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday , excluding legal holiday s. The teleph one number for the Reading Room is (202) 566

- 1744, and the telephone number for the Enforcement and Compliance Docket and I nformation Center is (202) 564

- 1927. An electronic version of the public docket is available through EPA Dockets (EDOCKET) at http:/ /www.epa.gov/edocket. The public may use EDOCKET to obtain a copy of the draft I CR including the Supporting Statement, submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the publ ic docket that are available electronically

. 3(c) Consultations: The Final Rule provides that EPA, in consultation with other interested Federal agencies, will review environmental documents. These other interested Federal agencies have been identified a nd are included in the estimate of burden for the Federal government. These agencies include, primarily , the U.S. Department of State and the National Science Foundation. I n addition, the Department of State agrees with its responsibilities under the Rul e at Section 8.12, Coordination of reviews from other Parties. Part D of the Supporting Statement includes the name, affiliation, contact information, and a summary of the consultations with these two agencies.

5 Alternately, under the paperwork reduction provisions o f the Rule, operators could choose to incorporate the advance notice by referring to it since it is reasonably available to EPA. Practice has been that the operators have included a copy in their environmental assessment documentation. 

### 3(d) Effects of Less Frequent Collection: The Rule requires environmental documentation for each operator for each nongovernmental expedition to Antarctica. Nongovernmental activities are usually limited to seasonal expeditions during the austral summer season and operators report annually on th eir proposed expeditions. Operators with one

- time

### 8

only expeditions report only

during the season for which their expedition is planned. I n order to minimize paperwork and to implement the regulations without undue burden on operators, the Rule provides t hat: (1) material may be incorporated by

referring to it in the environmental document when it is reasonably available to EPA; (2) more than one proposed expedition by an operator may

be included within one environmental document; (3) one environmental do cument may also be used to address expeditions being carried out by more than one operator; and (4) operators may

submit multi

- ye ar environmental documentation to address proposed expeditions for a period of up to five consecutive austral summer seasons. Once environmental documentation has been prepared for a season, an operator can resubmit the same document for subsequent seasons provided the level and intensity of the activities are not unchanged and that relevant updates are submitted. Updates are l ikely to include dates of expeditions and changes in landing locations. The operator may also revise the document to address modifications to the expedition's activities that could have environmental consequences. Most operators are likely to employ the multi

- ye ar provision thereby further reducing their annual reporting burden. Under this paperwork reduction provision, one environmental document may be submitted by

one or more operators for proposed expeditions for a period of up to five consecutive aus tral summer seasons, provided that the conditions of the multi

- ye ar environmental document, including the assessment of cumulative impacts, are unchanged. The multi

- ye ar provision allows operators to update basic information and to provide information on additional activities to supplement the multi

- ye ar environmental document without having to revise and re

- submit the entire document. The Protocol and the Rule also require an operator to employ procedures to assess and provide a regular and verifiable re cord of the actual impacts of any activity which proceeds on the basis of an I EE or CEE. For activities requiring an I EE, an operator should be able to use the annual procedures currently being voluntarily

utilized by

operators to provide the information. 3(e) General Guidelines: The information collections associated with the Rule follow OMB's guidelines. Section I II. F of the Preamble, Submission of Environmental Documents, indicates that an operator submits five copies of its environmental documentat ion, along with an electronic copy , if available. EPA coordinates review of the document with other interested Federal agencies and makes documents received available to the other Parties to the Treaty and the public as required under the Protocol or as o therwise requested. EPA believes that five copies (total) does not place undue burden on the operator and enables EPA to distribute copies to the reviewing agencies in a timely manner, particularly

in light of the timing requirements for document submissi on and review prior to departure for the expedition. 3(f) Confidentiality: The Rule does not require submission of confidential information, nor does EPA anticipate that operators would submit confidential information as part of their environmental docum entation. 3(g) Sensitive Questions: The Rule does not require response to sensitive questions (e.g., questions concerning sexual behavior or attitudes, religious beliefs, or other matters usually considered private).

### 9

4. THE RESPONDENTS AND THE INFORMATI ON REQUESTED 4(a) RESPONDENTS/SIC AND NAICS CODES: The requirements of the Rule apply to operators of nongovernmental expeditions organized in or proceeding from the territory of the United States to Antarctica for which the United States is required to give advance notice under Paragraph 5 of Article VI I of the Treaty and includes commercial and non

- commercial expeditions. Expeditions include ship

- based tours; y acht, skiing or mountaineering expeditions; flights; privately

funded research expeditions; a nd other nongovernmental or nongovernment

sponsored activities. The Rule does not apply to individual U.S. citizens or groups of citizens planning to travel to Antarctica on an expedition for which they are not acting as an operator. (Operators, for exam ple, ty pically acquire use of vessels or aircraft, hire expedition staff, plan itineraries, and undertake other organizational responsibilities.) Further, the Act is specific for nongovernmental activities, thus governmental jurisdictions are not subject to these regulations. Most operators are ship

- based or land

- based tour operators. The SI C Code for Tour Operators is 4725 and the NAI CS Code is 561520. 4(b) INFORMATION REQUESTED: Data items, including recordkeeping requirements : The Rule provides no ngovernmental operators with the specific environmental documentation requirements they need to meet in order to comply with relevant portions of the Protocol. Nongovernmental operators, including tour operators, conducting expeditions to Antarctica are r equired to submit environmental documentation to EPA that evaluates the potential environmental impact of their proposed activities. The ty

pe of environmental document required depends upon the nature and intensity of the environmental impacts that could result from the activity under consideration. Under the Rule, environmental documentation includes a Preliminary Environmental Review Memorandum (PERM), an I nitial Environmental Evaluation (I EE), or a Comprehensive Environmental Evaluation (CEE). I f the operator determines that an expedition may have: (1) less than a minor or transitory

impact, a PERM needs to be submitted no later than 180 day s before the proposed departure to Antarctica; (2) no more than minor or transitory impacts, including the cum ulative impacts of the proposed activity in light of existing and known proposed activities, an I EE needs to be submitted no later than 90 day s before the proposed departure; or (3) more than minor or transitory impacts, including the cumulative impacts of the proposed activity in light of existing and known proposed activities, a CEE needs to be submitted. The Protocol and the Rule also require an operator to employ procedures to assess and provide a regular and verifiable record of the actual impacts of an activity which proceeds on the basis on an I EE or CEE, including monitoring of key environmental indicators for an activity proceeding on the basis of a CEE. For activities that require an I EE, an operator should be able to use the annual procedures cu rrently being voluntarily

utilized by

operators to provide the information. For activities that require a CEE, OFA would consult with the National Science

### 10

Foundation and other interested Federal agencies regarding the monitoring regime that would be appro priate to the activity proposed, and with regard to possible utilization of relevant monitoring data collected by the U.S. Antarctic Program. Environmental documentation is submitted to EPA by an operator prior to an expedition. For most respondents, inc luding tour operators, EPA assumes this will be an I EE and, as provided in the Rule at Section 8.4, an operator may : (1) include more than one proposed expedition within one environmental document, and (2) one environmental document may also be used to ad dress expeditions being carried out by more than one operator. An operator can also submit multi

- ye ar documentation to address proposed expeditions for a period of up to five consecutive austral summer seasons thus eliminating the need for annual submissi on of environmental documentation. The multi

- ye ar provision also allows operators to update basic information and to provide information on additional activities to supplement the multi

- ye ar environmental document without having to revise and re

- submit th e entire document. Operators are not required to retain the environmental documentation submitted to EPA. There is nothing in the Rule, however, that precludes an operator from submitting a previous y ear's documentation, with appropriate updates, for a s ubsequent y ear's expedition(s). In cases of emergency

relating to the safety

of human life or of ships, aircraft, equipment and facilities of high value, or the protection of the environment which requires an activity to be undertaken without completion o f the documentation procedures set out in the Rule, the operator must notify

the Department of State within 15 day s of any activities which would have otherwise required preparation of a CEE, and provide a full explanation of the activities carried out wit hin 45 day s of those activities. Enforcement action can proceed, pursuant to Section 8.11 of the Rule, against an operator who violates any

provision of the Rule. Enforcement actions are not, however, subject to the requirements of the Paperwork Reductio n Act. Respondent Activities : The EPA considered the definition of "burden" developed for the PRA and the Office of Management and Budget = s (OMB's) final rules on implementing the PRA. For purposes of renewing this I CR, EPA estimated the hours and cost s to respondents under the Rule. These are the operators (e.g., respondents) for which the United States provided advance notice under Paragraph 5 of Article VI I of the Treaty for proposed nongovernmental expeditions organized in or proceeding from the U. S. to the Antarctic Treaty area. EPA used a ship

- based tour operator as its model respondent since most U.S.

- based nongovernmental activities covered by the Rule are for operators and activities associated with ship

- based tourism as summarized in Figure 1

. 6

6 For the 1997

- 1998 through 2009

- 2010 austral summer seasons (e.g., during the time the Interim Final and Final Rules have been in effect), EPA found that the IEEs for expeditions that were not ship

- based (e.g., land

- based; non - governmental research, and flight expeditions) w ere usually similar to ship

- based IEEs in terms of complexity; thus, the IEEs for these expeditions are similar in detail and length.

### 11

### 12

Figure 1. Numbers of Operators Submitting Environmental Documentation Under the Rule 7 and the Level

of Documentation Submitted Season Operators Documentation Submitted 1997

- 1998 9 4 total IEEs submitted including:
$ 1 IEE submi tted on behalf of five IAATO

- member operators for expeditions to the Peninsula area
$ 1 IEE submitted by two IAATO

- member operators for their expeditions to the Ross Sea area
$ 2 IEEs submitted by two non

- IAATO operators 1998

- 1999 10 4 total IEEs submitted including:
$ 1 IEE submitted on behalf of seven IAATO

- member operators for expeditions to the Peninsula area
$ 1 IEE submitted by one IAATO

- member operator for its expeditions to the Ross Sea area
$ 2 IEEs submitted by t wo non - IAATO operators 1999

- 2000 13 6 total IEEs submitted including:
$ 1 IEE submitted on behalf of eight IAATO

- member operators for expeditions to the Peninsula area
$ 1 IEE submitted by one IAATO

- member operator for its expeditions to the Ross Sea area
$ 4 IEEs submitted by four non

- IAATO operators including a one

- time only filming expedition and a one

- time only cruise

- only expedition 2000

- 2001 13 8 5 total IEEs submitted including:
$ 1 IEE submitted on behalf of n ine IAATO

- member operators for expeditions to the Peninsula area
$ 1 IEE submitted by one IAATO

- member operator for its expeditions to the Ross Sea area
$ 3 IEEs submitted by three non

- IAATO operators including a one

- time only trekking expedition

7 The term Rule in this document refers to the period of time the Interim Final Rule and Final Rule have been in place at 4 0 CFR Part 8 (e.g., for this ICR renew al, the years from 1997

- 2007 w hich includes the 1997

- 1998 through 2006

- 2007 austral summer seasons).

8 Nine IAATO

- member operators submitted one IEE for their Peninsula area expeditions but one of the operators did not proceed w ith its planned tours during the season; this operator plans to continue its operations in the out

- years.

### 13

2001

- 2002 12 9 7 total IEEs submitted including:
$ 1 IEE submitted on behalf of seven IAATO

- member operators for expeditions to the Peninsula area
$ 1 IEE submitted by one IAATO

- member operator for its expeditions to the Ross Sea area
$ 5 IEEs submitted by five non

- IAATO operators including a one

- time sailor training expedition 2002

- 2003 14 8 total IEEs submitted including:
$ 1 IEE submitted on behalf of seven IAATO

- member operators for expeditions to the Peninsula area $ 1 IEE submitted by one IAATO

- member operator for its expeditions to the Ross Sea area
$ 6 IEEs submitted by six non

- IAATO operators 2003

- 2004 22 1 PERM submitted for a one

- time only flight 13 total IEEs submitted including:
$ 1 IEE submitted on behalf of nine IAATO

- member operators for expeditions to the Peninsula area
$ 1 IEE submitted by one IAATO

- member operator for its expeditions to the Ross Sea area
$ 11 IEEs submitted by eleven non

- IAATO operators including two one
- time only flights 2004

- 2005 21 16 total IEEs submitted including:
$ 6 IEE submitted on behalf of 11 IAATO

- member operators for expeditions to the Peninsula area
$ 1 IEE submitted by one IAATO

- member operator for its expeditions to the Ross Sea area
$ 1 IEE submitted by one IAATO

- member operator for its expeditions to the Continental area
$ 8 IEEs submitted by 8 non

- IAATO operators 2005

- 2006 19 13 total IEEs submitted including:
$ 5 IEEs submitted on behalf of 11 IAATO

- member operators for expeditions to the Peninsula area
$ 1 IEE submitted by one IAATO

- member operator for its expeditions to the Ross Sea area
$ 1 IEE submitted by one IAATO

- member operator for its expeditions to the Continental area
$ 6 IEEs submitted by 8 non

- IAATO operators 2006

- 2007 21 13 total IEEs submitted including:
$ 5 IEEs submitted on behalf of 14 IAATO

- member operators for expeditions to the Peninsula area
$ 1 IEE submitted by one IAATO

- member operator for its expeditions to the Ross Sea area
$ 1 IEE submitted by one IAATO

- member operator for its expeditions to the

9 Seven IAATO member operators submitted one IEE for their Peninsula area expeditions but one of the operators did not proceed w ith its planne d tours during the season.

### 14 Continental area
$ 6 IEEs submitted by 6 non

- IAATO operators 2007

- 2008 14 total IEEs submitted including:
$ 6 IEEs submitted on be half of 14 IAATO

- member operators for expeditions to the Peninsula area
$ 1 IEE submitted by one IAATO

- member operator for its expeditions to the Ross Sea area
$ 1 IEE submitted by one IAATO

- member operator for its expeditions to the Continental area $ 6 IEEs submitted by 6 non - IAATO operators 2008

- 2009 12 total IEEs submitted including:
$ 8 IEEs submitted on behalf of 1 3 IAATO

- member operators for expeditions to the Peninsula area
$ 1 IEE submitted by one IAATO

- member operator fo r its expeditions to the Ross Sea area
$ 1 IEE submitted by one IAATO

- member operator for its expeditions to the Continental area
$ 2 IEEs submitted by 2 non - IAATO operators 2009

- 2010 1 1 total IEEs submitted including:
$ 9 IEEs submitted o n behalf of 14 IAATO

- member operators for expeditions to the Peninsula area
$ 1 IEE submitted by one IAATO

- member operator for its expeditions to the Ross Sea area
$ 1 IEE submitted by one IAATO

- member operator for its expeditions to the Continen tal area
$ 0 IEEs submitted by non - IAATO operators 

### The EPA hours and cost estimates are based on the following activities which EPA assumes a respondent would carry out to prepare and submit the environmental documentation and undertake as assessmen t and verification procedures. Assumed Operator Activities Associated With: 1. Preparing and Submitting Environmental Documentation : 1. Read the regulations and evaluate business operations and the expedition(s) activities relative to the regulatory

pr ovisions of the Rule and determine the level of environmental documentation needed; 2. Search reference sources for existing information on environmental conditions at proposed expedition site(s) and compile basic information from company records for use in preparation of the environmental document for the proposed expedition(s); 3. Prepare the environmental impact assessment (EI A) document (e.g., PERM, I EE or CEE), or review a contractor

- prepared document, and submit to EPA; and 4. Revise document if ne cessary , or operator decides to prepare higher level EI A document, in response to EPA's comments and submit to EPA. 2. Post

- Expedition Assessment and Verification Procedures : 1. Prepare assessment and verification information.

### 15

3. Reporting for Cases o f Emergency , if necessary : 1. Notify the Department of State of any activities which would have otherwise required preparation of a CEE within 15 day s. 2. Provide a full report to the Department of State within 45 day s. The Rule does NOT require or cont emplate the need for respondents to: 1. Acquire, install, or utilize technology and sy stems for the purpose of collecting, validating, and verify ing information; 2. Develop, acquire, install, or utilize technology and sy stems for the purpose of processi ng and maintaining information; 3. Develop, acquire, install, or utilize technology and sy stems for the purpose of disclosing and providing information; or 4. Adjust the existing way s to comply with any previously

applicable instructions and requirement s. 5. THE INFORMATION COLLECTED
-- AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT 5(a) AGENCY ACTIVITIES: The EPA consults with the Department of State, the National Science Foundation, and other interested Federal agencies 10 

### for act ivities associated with the Rule. This enables appropriate government agencies with specific Antarctic interests and expertise to be involved with the review of the environmental documentation for proposed nongovernmental expeditions including coordinatio n of appropriate information relative to the U.S. Antarctic Program. Further, violation of the provisions of the Rule could result in enforcement and penalties pursuant to the Antarctic Conservation Act, as amended, as undertaken by

the National Science F oundation and/or the Department of Justice. Finally , the Department of State has specific responsibilities under the Rule, Section 8.12, Coordination of reviews from other Parties, and for circulating a CEE that is prepared in accordance with the Rule at Section 8.8, along with any decisions by

the operator relating thereto, to all Parties. Activities associated with the Rule for the EPA and other Federal agencies consist of the following.

10 EPA routinely consults with the Department of State (DOS) and the National Science Foundation (NSF). EPA may consult with other agencies when appropriate for specific activities. These may include: U.S. Coast Guard (USCG), Ma rine Mammal Commission (MMC), National Oceanic and Atmospheric Administration (NOAA, including National Marine Fisheries Service), and the Department of Justice (DOJ).

### 16

EPA and Other Federal Agencies Activities Associated With: 1

. Processing and Reviewing Environmental Documentation Received from Operators : 1. Post receipt of environmental documents on OFA's World Wide Website, and provide copies to other Federal agencies and the public, if requested. 2. Prepare and publish Fed eral Register notice of receipt of draft CEEs and notice of availability

for Final CEEs. 3. Review environmental documents, including any appropriate public comments, and provide comments to the operator. 4. Consult with operators on the comments, or any other elements associated with the environmental documentation requirements. 5. Circulate to interested Federal agencies and review the revised or final document submitted by

the operator, and notify

the operator, if necessary , if the environmental docum entation does not meet the requirements of the Protocol and the provisions of the Rule. 6. Notify the Parties and provide copies to the Committee for Environmental Protection of the annual list of I EEs, draft CEEs and final CEEs. 7. Maintain files. 2. Processing and Reviewing Post

- Expedition Assessment and Verification I nformation : 1. Review assessment and verification information submitted by operators. 2. Maintain files. 3. Processing and Reviewing Reports for Cases of Emergency , if necessary : 1. Notify Parties to the Protocol when activities taken in cases of emergency are reported by operators which required the operator to undertake any activities which would have otherwise required preparation of a CEE. 2. Forward the operator's full explanat ion of the activities carried out to the Parties. 3. Review assessment and verification information submitted by operator. 4. Maintain files. 4. Processing and Reviewing Environmental Documentation Received from Other Parties : 1. Prepare and publish F

ederal Register notice of receipt of a draft CEE from another Party and provide copies to other interested Federal agencies and the public, if requested. 2. Review draft CEE and transmit inter

- agency response to the Party

that circulated the CEE. 3. Prov ide copies of other environmental documents to interested Federal agencies and the public, if requested. Other environmental documents may include: a) a description of national procedures for considering the environmental impacts of proposed activities; b) an annual list of any

I EEs and any

decisions taken in consequence thereof; c) significant information obtained and any action taken in consequence thereof with regard to monitoring from I EEs and CEEs; and d) information on a final CEE. 4. Post recei pt of significant monitoring information on OFA's World Wide Website. 5. Maintain files.

### 17

5(b) COLLECTION METHODOLOGY AND MANAGEMENT: The environmental documentation that is required by the Rule is submitted by

operators in accordance with the deadlines in the regulations. These documents can be submitted in hard copy and can also be submitted electronically . The Rule mandates specific information to be included in the document, but does not require a specific format. Since the information requirement is the same as that in the Protocol, this allows flexibility for operators who have multiple international documentation requirements. 11 

### EPA, in consultation with other interested Federal agencies, reviews the environmental documentation relative to the g eneral requirements (e.g., Rule, Section 8.4) and the specific requirements for each level of documentation (e.g.,Rule, Section 8.6 for PERMs; Section 8.7 for I EEs; and Section 8.8 for CEEs). EPA provides its comments to the operator, and the operator the n prepares revised documentation or responses to EPA = s questions or comments. Following the final response from the operator, if appropriate, EPA, with the concurrence of the National Science Foundation, makes a finding that the documentation submitted do es not meet the requirements of Article 8 and Annex I of the Protocol and the provisions of the regulations. EPA provides copies of environmental documents to all interested Federal agencies, and the public is informed of receipt of environmental document s through notice on OFA = s Homepage on the World Wide Web, and through the Federal Register for CEEs. 5(c) SMALL ENTITY FLEXIBILITY: The PRA incorporated the Regulatory Flexibility

Act into it. The Regulatory Flexibility

Act (RFA), as amended by the Smal l Business Regulatory

Enforcement Act of 1996 (SBREFA, 5 U.S.C. 601 et seq. ), generally requires an agency to prepare a regulatory

flexibility

analy sis of any

rule subject to notice and comment rulemaking requirements under the Administrative Procedure Act or any other statute unless the agency certifies that the rule will not have a significant economic impact on a substantial number of small entities. Small entities include small businesses, small organizations, and small governmental jurisdictions. The purpose of the RFA/SBREFA is A to fit regulatory and informational requirements to the scale of the business, organizations and governmental jurisdictions subject to the regulation. @ To achieve this principle, agencies are required to A solicit and conside r flexible regulatory proposals and to explain the rationale for their actions to assure that such proposals are given serious consideration. @ The RFA/SBREFA does not require an agency to minimize a rule = s impact on small entities if there are legal, poli cy , factual or other reasons for not doing so. The RFA/SBREFA requires only that agencies: determine, to the extent feasible, the rule = s economic impact on small entities; explore regulatory options for reducing any significant economic impact on a subst antial number of such entities; and explain the Agency = s ultimate choice of regulatory approach.

11 For example, Sweden has a specific form, and the United Kingdom has a permit system. Fo r purposes of the Final Rule, an operator could submit environmental documentation prepared for another country as long as all the elements required by the regulations are addressed.

### 18

The RFA/SBREFA requirements to prepare a regulatory flexibility

analy sis or a certification of no significant economic impact on a substantial number of small entities applies to proposed rules subject to notice

- and

- comment rulemaking requirements under the Administrative Procedure Act or any other statute, and final rules promulgated under the notice

and

- comment rulemaking requirements of the Administrative Pr ocedure Act. Further, the RFA requires that an agency

identify the ty pes, and estimate the numbers, of small entities A to which the final [or proposed] rule will apply , @ and describe the rule A requirements @ to which small entities A will be subject @ and an y regulatory alternatives, including exemptions and deferrals, which would lessen the rule = s burden on small entities. I t is EPA = s policy to make an assessment of the rule = s impact on any small entities, to engage the potentially regulated entities in a d ialog regarding the rule, and minimize the impact to the extent feasible. However, in view of the requirements of SBREFA, a regulatory flexibility

analy sis as specified by

the RFA is not required simply

because the rule has some impact on some number of s mall entities. I nstead, such analy ses is required only in cases where the Agency cannot certify

that the rule will not have a significant economic impact on a substantial number of small entities. For purposes of assessing the impacts of the Final Rule o n small entities, small entity is defined as: (1) a small business as defined by the Small Business Administration with the North American I ndustry

Classification Sy stem (NAI CS) code for A Tour Operators, @ code 561520, with annual maximum receipts of $5.0 million (13 CFR Part 121); and (2) a small organization that is any not
- for

- profit enterprise which is independently owned and operated and is not dominant in its field. In accordance with section 2403a of the Act, governmental jurisdictions are not subje ct to this rulemaking. 12


### In determining whether a rule has a significant economic impact on a substantial number of small entities, the impact of concern is any significant adverse economic impact on small entities, since the primary purpose of the regulat ory flexibility

analy ses is to identify

and address regulatory

alternatives A which minimize any significant economic impact of the proposed rule on small entities. @ 5 U.S.C. Sections 603 and 604. Thus, an agency may certify that a rule will not have a si gnificant economic impact on a substantial number of small entities if the rule relieves regulatory

burden, or otherwise has a positive economic effect on all of the small entities subject to the rule. The EPA believes that because the Rule only requires assessment of environmental impacts the effects on any small entities will be limited primarily to the cost of preparing such an analy sis and that the requirements are no greater than necessary to ensure that the United States will be in compliance with it s international obligations under the Protocol and the Treaty . The costs are minimal because the ty pes of activities currently being carried out ty

pically are unlikely to have impacts that are more than minor or transitory assuming that activities will be carried out

12 16 U.S.C. 2401 et seq ., as amended, 16 U.S.C. 2403a.

### 19

in accordance with the guidelines set forth in the ATCM Recommendation XVI II

- 1, Tourism and Non

- Governmental Activities, the relevant provisions of other U.S. statutes, and Annexes I I

- V to the Protocol. Therefore, most activities are likely t o need only

I EE documentation, the cost of which is minimal as shown in Section 6 of this Supporting Statement and as presented in the Preamble to the Rule, Section V.D, Paperwork Reduction Act. Further, EPA has included provisions in the Rule which are a vailable to all respondents, including small entities, which will have a positive effect by

minimizing the cost, and reducing the paperwork burden, of such an analy sis. It has been EPA = s experience that respondents used the cost reduction provisions in t he final regulations. The cost and paperwork reduction provisions in the Rule include: (1) material may be incorporated by

referring to it in the environmental document with its content briefly described when the cited material is reasonably available to the EPA; (2) more than one proposed expedition by

an operator may

be included within one environmental document and may , if appropriate, include a single discussion of components of the environmental analy sis which are applicable to some or all of the pr oposed expeditions; (3) one environmental document may also be used to address expeditions being carried out by more than one operator, provided that the environmental documentation includes the names of each operator for which the environmental documentat ion is being submitted pursuant to obligations under these regulations; and (4) one environmental document may be submitted by

one or more operators for proposed expeditions for a period of up to five consecutive austral summer seasons, provided that the c onditions of the multi

- ye ar environmental document, including the assessment of cumulative impacts, are unchanged. The multi

- ye ar provision also allows operators to update basic information and to provide information on additional activities to supplement the multi

- ye ar environmental document without having to revise and re

- submit the entire document. 13


### In consideration of the timing requirements associated with the need to assist new operators who are unfamiliar with the regulations and its schedules, or to assist operators who have unanticipated amendments to their EI A documentation for a particular y ear, the Rule at Section 8.5(b) provides that EPA may waive or modify

the deadlines of the Rule if EPA determines that an operator is acting in good faith an d that circumstances outside the control of the operator created delay s, provided that environmental documentation fully meets deadlines under the Protocol. The Rule does not provide an exemption from coverage of the collection of information, or any part thereof. This is because the Rule only requires assessment of environmental impacts. This assessment is limited to the cost of preparing such an analy sis and the requirements would be no greater than necessary to ensure that the United States will be in compliance with its international obligations under the Protocol and the Treaty

.

13 For the austral se asons the Rule has been in effect, operators have used all of the available paperwork provisions available under the Rule.

### 20

5(d) COLLECTION SCHEDULE: The schedule for submittal of environmental documentation depends on the document to be submitted as described below. An operator could submit en vironmental documentation prior to these deadlines. I n all cases, however, documents need to be submitted such that the schedule requirements for submitting draft CEEs to the Parties can be met by

the United States. Preliminary

Environmental Review Memor andum (PERM) : I n accordance with the Rule at Section 8.6, a PERM needs to be submitted to EPA no less than 180 day s before the proposed departure of the expedition.
$ EPA, in consultation with other interested Federal agencies, provides its comments to t he operator within 15 day s of receipt.
$ The operator then has 75 day s to revise the PERM or prepare an I EE, if necessary . I f an I EE is prepared and submitted within the 75 day response period, it is reviewed under the time frames for an I EE (see below). If a CEE is prepared, it is reviewed under the time frames for a CEE (see below.)
$ Within 30 day s, if appropriate, EPA, with the concurrence of the National Science Foundation, provides notice to the operator that the environmental documentation does not meet the requirements of the Protocol and the provisions of the R ule. In itial Environmental Evaluation (I EE) : I n accordance with the Rule at Section 8.7, an IE E needs to be submitted no fewer than 90 day s before the proposed departure of the expediti on. $ EPA, in consultation with other interested Federal agencies, provides its comments to the operator within 30 day s of receipt.
$ The operator then has 45 day s to revise the I EE or prepare a CEE, if necessary . I f a CEE is prepared, it would be revie wed under the time frames for a CEE (see below).
$ Within 15 day s of receiving the final I EE from the operator or, if the operator does not provide a final I EE, within 60 day s following EPA's comments on the original I EE, if appropriate, EPA, with the con currence of the National Science Foundation, provides notice to the operator that the environmental documentation does not meet the requirements of the Protocol and the provisions of the Final Rule. Comprehensive Environmental Evaluation (CEE) : I n accord ance with the Final Rule at Section 8.8(b), operators need to submit a CEE. 14



### $ Within 15 day s of receipt, EPA would: (1) send it to the Department of State for circulation to the Parties and Committee for Environmental Protection; and (2) publish notice of receipt and request for comments in the Federal Register

. $ EPA accepts public comments for 90 day s following the published notice.

14 See: Final Rule, Preamble, Section III.D.3(c). Article 3(4), of Annex I of the Protocol requires that draft CEEs be distributed to all Parties and the Committee for Environmental Protection 120 days in advance of the next Antarctic Treaty Consultative Meeting (ATCM) at which the CEE may be addressed. Operators who anticipate such activities are encouraged to consult with EPA as soon as possible regarding the date for submitting the CEE. In fact, there were no CEEs submitted during the seven austral seasons the Rule has been in effect.

### 21

$ EPA, in consultation with other interested Federal agencies, provides its comments to the operator within 120 day s fo llowing the Federal Register notice.
$ The operator then needs to submit a final CEE 75 day s before commencement of the proposed activity

in the Antarctic Treaty

area. $ Within 15 day s of receiving the final CEE from the operator or, if the operator does not provide a final CEE, within 60 day s prior to departure of the expedition, if appropriate, EPA, with the concurrence of the National Science Foundation, provides notice to the operator that the environmental documentation does not meet the requirements of the Protocol and the provisions of the Final Rule.
$ If EPA does not provide such notice, the operator would have met all requirements provided that procedures, which may include appropriate monitoring, are put in place to assess and verify

the impact of the activity

. $ No later than 60 day s before commencement of the proposed activity in the Antarctic Treaty area, EPA: (1) transmits the CEE, along with notice of any decisions by

the operator, to the Department of State for circulation to the Partie s, and (2) publishes notice of availability of the final CEE in the Federal Register

. In formation to Assess and Verify I mpacts : There is no set schedule requirements in the Final Rule for submitting information on measures to assess and verify environmen tal impacts. Operators provide the information to the National Science Foundation on a voluntary basis. Operators often specify

this schedule within the environmental document for the expedition. Reporting for Cases of Emergency : I n accordance with the Final Rule at Section 8.10, within 15 day s in cases of emergency , an operator needs to report notice of any activities which would have otherwise required preparation of a CEE to the Department of State, and a full explanation of the activities carried out must be provided within 45 day s of those activities. 6. ESTIMATING THE HOURS AND COST BURDEN OF THE COLLECTION 6(a) ESTIMATED ANNUAL RESPONDENT HOURS AND COST Exhibits 1A, 1B (including Table 1), and 1C present the estimated respondent (e.g., operator ) hours and cost for the three possible levels of environmental documentation (e.g., PERM, I EE, CEE) and associated post

- expedition assessment and verification procedures. Exhibit 1D presents the estimated respondent hours and cost for reporting for cases of emergency . Respondent burden tables were prepared for each ty pe of environmental documentation since the effort should increase as an increasing level of environmental documentation is required; e.g., from PERM to I EE to CEE. The model respondent use d in the estimates is a nongovernmental, U.S.

- based Antarctic tour ship operator. 15 

### The estimated hours and cost for operators is based on the assumption that

15 For the ten austral summer seasons the Rule has been in effect, environmental documentation has bee n submitted primarily by ship

- based tour operators and one privately funded researcher. Many of the U.S.

- based tour

### 22

most environmental documentation submitted by operators will be I EEs. As stated in the Preamble to the Final Rule (Section I II. D.3(b)), at a minimum, an I EE is ty pically the appropriate level of environmental documentation for proposed activities. The ty pes of nongovernmental activities that are currently being carried out ty

pically are unlikely

to have impacts that are more than minor or transitory

assuming that activities are carried out in accordance with the guidelines set forth in the ATCM, Recommendation XVI II

- 1, Tourism and Non

- Governmental Activities, the relevant provisions of other U.S. sta tutes, and Annexes I I

- V to the Protocol. During the austral summer seasons the Rule has been in effect, I EEs have been submitted by operators as summarized in Figure 1. The following elements further discuss the assumptions factored into the estimated re spondent hours and cost.

operators (both ship

- based and land

- based) are members of IAATO and are experienced for

- profit companies that organize and/or operate trave l programs to the Antarctic. 

### 1. Number of Respondents : Based on EPA = s experience during the ten austral summer seasons the Rule has been in effect (see Figure 1), for purposes of this I CR renewal, the total number of respondents is estimated as twenty

- three as delineated in Figure 2. This estimate includes 18 repeat operators who are expected to submit new or revised or multi

- ye ar I EE documentation, and five new operators who are expected to submit new I EEs.
FIGURE 2. Estimated Respondents and Anticipated Level of EIA Documentation

Considering EPA = s Experience Under the Rule Operators Number of Operators U.S.

- based I AATO

- member tour operators 1 7 Peninsular Area U.S.

- based I AATO

- member tour operators 1 Ross Sea Area U.S.

- based I AATO

- member to ur operators 1 Continental Area U.S.

- based non

- IA ATO member tour operators 0 Peninsular Area U.S.

- based privately

funded researcher 1 U.S.

- based possible new respondents 5 TOTAL ESTI MATED 2 2
2. Basis for Cost Estimates : The c ost estimates are based on industry labor rates obtained during informal consultations with industry representatives and include overhead and fringe benefits. The three rates used in the calculations represent the rates provided by the industry representa tives including $65/hour as a low, $75/hour as an intermediate, and $100/hour as a high. The $75/hour intermediate rate is used for summary purposes. See Part D for additional information on the consultations with affected respondents. 3. PERM Model for Respondent Submittals : For PERMs, the estimated hours and cost is based on the estimated time to comply with the Final Rule at Section 8.4, preparation of environmental documents, generally , and Section 8.6, preliminary environmental review. The

### 23

estimat e assumes one week at 40 hours per week including revisions in response to any EPA comments. Assessment and verification procedures are not required at the PERM level of activity and documentation. Although one respondent per y ear is estimated for purpos es of the cost calculations in Exhibit 1A, EPA anticipates that the actual number of nongovernmental expeditions with activities that will likely proceed with less than minor or transitory impacts may well be reduced to less than one respondent per y ear. In fact, during the seven austral summer seasons the Rule has been in effect, only one PERM has been submitted as the final document for an expedition. 4. IE E Model for Respondent Submittals : EPA has developed three models for I EEs that incorporate the estimated time to comply with the Final Rule at Section 8.4, preparation of environmental documents, generally , and Section 8.7, initial environmental evaluation. The model also considers the experience with I EE documents received during the ten austral s ummer seasons the Rule has been in effect and burden estimates in the previous Supporting Statements for the I CRs for the I nterim Final and Final Rules. The assumptions for EPA's I EE model include the following:

$ Figure 2 lists the potential respondent s. $ The maximum length for an I EE is about 200 pages including supplemental information. 16



### $ IE Es consist of "core" information with supplemental expedition

- specific or other project

- specific information (e.g., dates, landing sites, number of tours, etc .) attached or referenced.
$ For initial preparation of the "core" I EE, the estimate assumes four weeks, on average, at 40 hours/week, or about 160 hours, including revisions in response to EPA comments. This estimate assumes a full time effort during th e four weeks, and that information will be incorporated by

reference when appropriate.
$ The estimate assumes 5 hours for an operator to prepare and/or compile supplemental information. 17

16 For the four IEEs submitted in 1997

- 1998, the approximate number of pages, including the "core" document plus supplemental documentation, was: 215 (5

- operator Peninsular Area), 208 (2

- operator non
- PA), 43 (non

- IAATO member op erator), and 20 (privately

- funded researcher). The supplemental information submitted by the 5 operators for the Peninsular Area IEE, w hich included tour brochures, averaged about 23 pages per operator. The privately

- funded researcher incorporated by ref erence selected information from three previously published reports. During the subsequent three years the Interim Final Rule was in effect, the annual submissions averaged closer to 50 pages due, in large part, to the use of the paperw ork reduction provi sions of the Interim Final Rule. This
A preparation @ burden is actually less when the fact that tour brochures for the current season prepared for commercial purposes and a copy of the advance notice submitted to the Department of State were submitted by t he tour operators as part of the IEE documentation. How ever, for purposes of maximum burden estimates, the 1997

- 1998 figures are used in the burden calculations. Experience under the Final Rule indicates these assumptions are still generally accurate.
17 T he estimate for preparation of supplemental information excludes any time associated with preparing travel brochures and/or major reports referenced in, and submitted along w ith, an IEE (e.g., researcher reports such as those prepared by Oceanites, Inc., a nd submitted as referenced attachments with the IEE).

### 24

$ If appropriate, EPA anticipates operators will submit the "core" IE E in subsequent ye ars with any

necessary

revisions (discussed below). An estimated one week at 40 hours/week is estimated to prepare this "revised" I EE for submittal in subsequent y ears. The estimate of 5 hours for preparation and/or compilation of sup plemental information remains the same.
$ If appropriate, EPA anticipates operators will submit A multi

- ye ar @ IE E documentation. In the initial y ear, this is anticipated to consist of a A revised @ IE E with an estimated 40 hours associated preparation time and 5 hours for preparation and/or compilation of supplemental information. For the subsequent four consecutive y ears the A multi

- ye ar @ IE E can be submitted by

an operator, for purposes of maximum burden estimation, 5 hours are estimated for preparation an d/or compilation of the supplemental information.

$ The I EE level of documentation requires assessment and verification (A/V) procedures; 20 hours are estimated for preparation and/or compilation of this information. 18



### $ For an I EE that covers multiple o perators, the hours and costs per operator are spread among the total number of operators; e.g., the more operators under one document, the lower the hours and costs to each individual operator. 19


### IE E Model 1

- A Core @ IE E : The following estimate is based on EPA = s experience for the ten austral summer seasons the Rule has been in effect and considers the paperwork reduction options utilized by

the operators. EPA anticipates five one

- time A core @ IE Es will be prepared for the three austral summer seasons thi s I CR renewal will be in effect. The operator hourly burden for preparation of a A Core @ IE E is estimated as follows: Prepare "core" I EE: 160 hrs/I EE x 5 I EEs = 800 hours Prepare supplemental information: 5 hrs/operator x 5 opera tors = 25 hours A/V procedures: 20 hrs/operator x 5 operators = 100 hours TOTAL HOURS = 925 hours TOTAL HOURS PER I EE (5 I EEs) = 185 hours TOTAL HOURS PER OPERATOR (5 operators) = 185 hrs 20


### IE E Model 2

- A Revised @ IE E : F or purposes of maximum burden assessment, EPA anticipates that two present ship based tour operators will remain the same, and that these

18 For activities requiring an IEE, an operator should be able to use procedures currently being voluntarily utilized by operators to provide the required information.

19 For an IEE that covers multiple ope rators, the cost per operator is further reduced; specific examples are listed as a footnote for each model calculation.

20 If, for example, the A Core @ IEEs cover six operators (e.g., four of the IEEs cover one operator each and one of the IEEs covers 2 oper ators), the cost per operator is reduced from 185 hours to 154 hours.

### 25

operators will continue to submit revised I EEs for the three austral summer seasons this I CR will be in effect. Updat es are likely to include such items as dates of expeditions and changes in landing locations. Revisions could address items such as assessment of the potential impacts, including cumulative impacts, of modifications to the planned activities and any assoc iated mitigation measures, or a reassessment of overall impacts for the expedition. Thus, for subsequent seasons, EPA assumes a reduced number of hours would be required for revision of the "core" I EE, and the hours for preparation of supplemental informa tion will remain the same. The model for estimating respondent hourly burden for a A Revised @ IE E is based on EPA = s experience for the ten austral summer seasons the Rule has been in effect and considers the paperwork reduction options utilized by the oper ators. The operator hourly burden for preparation of a A Revised @ IE E is estimated as follows: Prepare "Revised" I EE: 40 hrs/I EE x 3 IE Es = 12 0 hours Prepare supplemental information: 5 hrs/operator x 3 operators = 1 5 hours A/V procedures: 20 hrs/operator x 3 operators = 6 0 hours TOTAL HOURS = 1 95 hours TOTAL HOURS PER I EE (2 I EEs) = 65 hours TOTAL HOURS PER OPERATOR (2 operators) = 65 hours 21 

### Model 3

- A Multi

- Year @ IE E : Under the Final Rule, operators may choo se to submit multi

- ye ar I EE documentation. Under this model, EPA assumes the operators will submit a
A Revised @ IE E in the initial y ear. The multi

- ye ar provision then allows operators to supplement the multi

- ye ar environmental document without having to r evise and re

- submit the entire document in order to update basic information as necessary , and to provide information on any new activities or revisions to the documented activities. For purposes of demonstrating the full model for a A multi

- ye ar @ IE E, EPA assumes eight
A multi

- ye ar @ IE Es will be submitted on behalf of 16 operators, and the operator hourly burden for preparation of a A Multi

- Year @ IE E is estimated as follows: 22


### In itial Year: Prepare A Revised @ IE E: 40 hrs/I EE x 9 IE Es = 3 6 0 hours Prepare supplemental information: 5 hrs/operator x 1 4 ops x 1 y ear = 7 0 hours A/V procedures: 20 hrs/operator x 1 4 ops x 1 y ear = 28 0 hours

21 If, for example, the three A Revised @ IEEs cover four operators (e.g., tw o IEEs cover one operator each and the other covers tw o operators), the burden per operator is reduced from 65 ho urs to 49 hours.

22 For purposes of demonstrating the hourly burden for an operator submitting a A Multi

- Year @ IEE, EPA assumed eight operators would submit multi

- year IEEs during the time covered by this ICR renewal. It is possible that two of the operators listed under the A Revised @ IEE model may submit A multi

- year @ rather than A revised @ IEEs. How ever, since the intent of these operators is unknown, EPA assumed these two operators would submit A revised @ IEEs, an assumption that provides the maximum hours and cost estimates for the three year period of this ICR renewal since the hours and costs per operator are more for a A Revised @ IEE than for a A Multi

- Year @ IEE.

### 26

Four Subsequent Years for a Total of Five Consecutive Years: Prepare supplemental information: 5 hrs/operator x 1 4 op s x 4 y ears = 28 0 hours A/V procedures: 20 hrs/operator x 1 4 ops x 4 y ears = 1 12 0 hours TOTAL HOURS for 5

- Year Period of A Multi

- Year @ IE E = 2 11 0 hours TOTAL HOURS PER YEAR (5 Years) PER I EE ( 9 IE Es) = 47 hours TOTAL HOURS PER YEAR (5 Years) PER OPERATOR (1 4 operators) = 30 hours 23

23 Because the eight A Multi

- Year @ IEEs cover sixteen operators (e.g., one IEE covers nine opera tors and the other seven cover one operators), the burden per operator is reduced from 58 hours to 29 hours (e.g., the hours for the annual supplemental information and A/V procedures) as the initial cost of the A Revised @ IEE is spread among the operators. 

### 5. CEE Model for Respondent Submittals : For CEEs, the estimated hours and cost is based on the estimated time to comply with the Final Rule at Section 8.4, preparation of environmental documents, generally , and Se ction 8.8, comprehensive environmental evaluation, and assumes an increased effort from that required for an I EE. The estimate assumes six (6) weeks at 40 hours per week, or 240 hours, including time for revisions in response to EPA's comments. The estim ate assumes 60 hours to prepare assessment and verification information associated with the CEE level of activity and documentation. Further, although one respondent per y ear is estimated for purposes of the cost calculations in Exhibit 1C, EPA anticipate s that the actual number of nongovernmental expeditions with activities that will likely proceed with more than minor or transitory

impacts may

well be reduced to less than one respondent per y ear. I n fact, there were no CEEs submitted during the ten aust ral summer seasons the Rule has been in effect. 6. Emergency Reporting Model : Reporting for Cases of Emergency is based on the Final Rule at Section 8.10, Cases of emergency , which requires notice and reporting for activities taken in cases of emergency which would have otherwise required the preparation of a CEE. The estimate is based on reporting requirements only , not the actual cost of the emergency response action. The hours and cost estimate assumes one such emergency per 10 y ears. I n fact, there were no such incidents during the ten austral summer seasons the Rule has been in effect.

### 27

7. Capital/Start Up Costs : The EPA does not anticipate any capital or start up costs on the part of respondents to comply with the provisions of the Final Rule. 24


### 8. O&M Costs : The EPA estimates the following operating and maintenance (O&M) costs associated with the paperwork requirements for respondents to comply with the provisions of the Final Rule. 25 

### Assumptions and calculations used in EPA's O&M estimate for t he three levels of environmental documentation are as follows: PERMs . The assumptions used for the O&M estimates include:

$ PERMs are estimated to average 25 pages including any supplemental information.
$ One PERM submitted per y ear by one operator. In fact, during the thirteen austral summer seasons the Rule has been in effect, only one PERM has been submitted as the final documentation for an expedition.
$ Five copies of each PERM should be submitted.
$ Although not required, the model assumes op erators will use express mail to submit PERM packages (e.g., original PERM and 5 copies).
$ PERMs do not require assessment/verification procedures.

24 One

- time capital/start

- up costs usually include any produced physical good needed to provide the necessary information. Start

- up capital must be purchased for the specific purpose of satisfying EPA's reporting or recordkeeping requirements. Capital goo ds include computers, machinery, or equipment. Start

- up capital costs are usually incurred at the beginning of an information collection period and are usually incurred only once.

25 O&M costs are the recurring dollar amount of cost associated with O&M or p urchasing services. For example, when respondents are required to submit reports or information, O&M costs may include costs for file storage, photocopying, and postage. 

### $ The Final Rule does not require file storage or audits.

### 28

The estimated O&M costs for a PERM are calcul ated as follows: 26 

### (1) Copy ing: 25 pages/PERM x 5 copies x $0.10/page = $12.50 (2) Mailing: 1 PERM package x $27/package = 27.00 Exhibit 1A incorporates double these estimated O&M costs in the estimated respondent burden and costs for P ERMs for a three y ear period 27 

### based on the assumption, for purposes of maximum cost calculation, the initial submittal will be revised and resubmitted. IE Es . The assumptions used for the O&M estimates include:

$ Figure 2 lists the potential respondents

. $ The maximum length for an I EE is 200 pages including supplemental information. (See above: A IE E Model for Respondent Submittals @ )
$ Five copies of each I EE, including supplementary information, should be submitted.
$ Although not required, the mode l assumes operators will use express mail to submit IE E packages (e.g., original I EE and 5 copies).
$ Assessment/verification (A/V) information is estimated as 25 pages per operator.
$ Five copies of each A/V information package may be submitted.
$ Alth ough not required, the model assumes operators will use express mail to submit A/V information packages (e.g., original and 5 copies).
$ The Final Rule does not require file storage or audits.

The estimated O&M costs for the three I EE models are calcula ted as follows:

A Core @ IE E : (1) Copy ing: 200 pages/Core I EE x 5 copies/I EE x $0.10/page = $100.00

10 pages/Supplemental I nfo. x 5 copies x $0.10/page = 5.00 25 pages/ A/V information x 5 copies x $0.10/page = 12.50 (2) Mailing: 1 A Core @ IE E package x $27/package = 27.00

1 Supplemental I nformation package x $12/package = 12.00 1 A/V information package x $17/package = 17.00

A Revised @ IE E : (1) Copy ing: 200 pages/Revised I EE x 5 copies/I EE x $0.1 0/page = 100.00

26 For Exhibits 1 and 2, costs are rounded dow n to the nearest dollar for $0.01 to $0.4 9, and rounded up to the nearest dollar for $0.50 to $0.99.

27 Three years are used in these calculations because that is the period of time the ICR is in effect before it must be renewed. 

### 10 pages/Supplemental I nfo. x 5 copies x $0.10/page = 5.00

### 29 25 pages/ A/V information x 5 copies x $0.10/page = 12.50 (2) Mailing: 1 A Revised @ IE E package x $27/package = 27.00

1 Supplemental I nformati on package x $12/package = 12.00 1 A/V information package x $17/package = 17.00

A Model Multi

- Year @ IE E : (1) Copy ing: 200 pages/Revised I EE x 5 copies/I EE x $0.10/page = $ 100.00

10 pages/Supplemental I nfo. x 5 copies x $0 .10/page = 5.00 25 pages/ A/V information x 5 copies x $0.10/page = 12.50 (2) Mailing: 1 Revised I EE package x $27/package = 27.00

1 Supplemental I nformation package x $12/package = 12.00 1 A/V information package x $17/package = 17.00

A Subsequent Year, Multi

- Year @ IE E : (1) Copy ing: 10 pages/Supplemental I nfo. x 5 copies x $0.10/page = 5.00

25 pages/ A/V information x 5 copies x $0.10/page = 12.50 (2) Mailing: 1 Supplemental I nformati on package x $12/package = 12.00

1 A/V information package x $17/package = 17.00 Exhibit 1B, including Table 1B, incorporates the A Subsequent Year, Multi

- Year @ IE E estimated O&M costs in the estimated respondent hours and costs for I EEs per y ear. Over the next three ye ars, all Multi

- Year I EE submissions will follow the Multi

- Year Model with a revised submission one y ear and two subsequent y ears where only supplemental information is filed. To calculate the O&M costs over the three y ear period for the Multi

- Year I EEs, the costs of one Model Multi

- Year and two Subsequent Years Multi

- Years are averaged. The costs for the
A Model Multi

- Year @ IE E are listed only to maintain information for purposes of the full Model. The O&M costs are double d for the A Core @ and A Revised @ IE E submittals based on the assumption, for purposes of maximum cost calculation, the initial submission will be revised and resubmitted. Table 3. Summary

of the 3

- Year Average O&M Costs for a PERM, the Three IEE Models, a nd a CEE

PERM "Core" IEE A Revised @ IEE A Subsequent Year/ Multi

- Year @ IEE CEE Copy ing: $ 25 Mailing: $ 54 TOTAL $ 79 Copy ing: $218

Mailing: $ 83 TOTAL $301 Copy ing: $218

Mailing $83 TOTAL $301 Copy ing: $ 85

M ailing: $ 47 TOTAL $ 132 Copy ing: $325

Mailing: $ 81 TOTAL $406 NOTE: The O&M costs for the A Multi

- Year @ IEE include the A Subsequent Year, Multi

- Year @ IEE costs for purposes of this three

- ye ar ICR renewal. CEEs . The assumptions used for the O&M estimates include:

### 30 $ CEEs are estimated to average 300 pages including any supplemental information.
$ One CEE submitted per y ear by one operator. In fact, there were no CEEs submitted during the ten austral summer seasons the Rule has been in effect.
$ Five copies of each CEE should be submitted.
$ Although not required, the model assumes operators will use express mail to submit CEE packages (e.g., original CEE and 5 copies).
$ Assessment/verification (A/V) information is estimated as 5 0 pages per operator.
$ Five copies of each A/V information package should be submitted.
$ Although not required, the model assumes operators will use express mail to submit A/V information packages (e.g., original and 5 copies).
$ The Final Rule does n ot require file storage or audits.
$ Mailing charges have been increased to reflect inflation. The estimated O&M costs for a CEE are calculated as follows: (1) Copy ing: 300 pages/CEE x 5 copies x $0.10/page = $150.00 50 pages/ A/V information x 5 copies x $0.10/page = 25.00 (2) Mailing: 1 CEE package x $32/package = 32.00 1 A/V information package x $17/package = 17.00 Exhibit 1C incorporates these estimated O&M costs in the estimated respondent hours and cost for CEEs for a three y ear period. 28 The O&M costs are doubled for the CEE submission based on the assumption, for purposes of maximum cost calculation, the initial submission will be revised and resubmitted. Reporting for Cases of Emergency . The ass umptions used for the O&M estimate include:

$ Emergency

Reports are estimated to average 300 pages including supplemental information.
$ The model assumes assessment and verification procedures will be undertaken with 50 pages submitted.
$ Five copies of the assessment and verification information should be submitted.
$ Although not required, the model assumes operators will use express mail to submit Emergency Reports and assessment and verification information.
$ The O&M costs are first calculated t o indicate the annual cost assuming one such emergency per 10 y ears. (See: Item 6, above, Emergency Reporting Model)
$ The Final Rule does not require file storage or audits.
$ Mailing charges have been increased to reflect inflation. (1) Copy ing: Em ergency

Report 300 pages/report x 5 copies x $0.10/page = $150.00 A/V Information 50 pages/package x 5 copies x $0.10/page = 25.00 (2) Mailing: Emergency

Report 1 Emergency Report x $32/report = 32.00 A/V Information 1 A/V package x $17/package = 17.00

28 Three years are used in these calculations because that is the perio d of time the ICR is in effect before it must be renewed.

### 31

O&M for Emergency

Reporting in one y ear = 224.00 Averaged annual Emergency Reporting assuming one emergency per 10 y ears = 23.00 Exhibit 1D incorporates these estimated O&M costs in the estimated Eme rgency Response respondent hours and costs for y ears one through three. 6(b) ESTIMATED ANNUAL FEDERAL GOVERNMENT HOURS AND COST Exhibits 2A, 2B (including Table 2), and 2C present the estimated Federal government hours and cost for processing and reviewi ng the three possible levels of environmental documentation (e.g., PERM, IEE, CEE) and associated post

- expedition assessment and verification information. Exhibit 2D presents the estimated Federal government hours and cost for activities associated with r eporting for cases of emergency , and Exhibit 2E presents the estimated Federal government hours and cost for coordinating the review of information received from other Parties. 29 The Final Rule does not involve or otherwise impact governmental jurisdiction s including state, local or tribal governments. Federal government burden tables were prepared for each ty pe of environmental documentation since the effort should increase as an increasing level of environmental documentation is required; e.g., from PERM to IEE to CEE. As with the respondents, the model used for the Federal government estimates is a nongovernmental, U.S.

- based ship

- based tour operator, and the estimated hours and cost for the Federal government is based on the assumption that most enviro nmental documentation submitted by operators will be IEEs. The following assumptions were factored into the hourly burden and cost estimates for the Federal government: 1. Number of Respondents : The Federal government estimates are consistent with the r espondent (i.e., operators) estimates with regard to the number of respondents and the projected numbers of environmental documents that may be submitted (see: Section 6(a)). 2. Basis for Cost Estimates : The cost estimates are based on consideration of a "model" government employ ee for activities associated with the Final Rule. Two Federal employ ee "models" were developed: (1) "Federal Model 1" is used for costing activities more technical in nature, and (2) "Federal Model 2" is used for costing activ ities that are more administrative. 30

29 There is no respondent burden or cost associated w ith Section 8.12.
30 See: Exhibits 2A through E, the Federal government estimates for hours and cost. For example, technical activities associated w ith Environmental Documentation include: review of environmental documents, including any public comments, and providing comments to the operator; consultation with operators; and review of the revised/final document submissions and notification of the op erator, if necessary. Other activities listed under Environmental Documentation, such as posting document receipt on the WWW, are administrative.

### 32

"Federal Model 1"

- Technical Activities : The skill mix used for technical activities includes Managers, Technical Staff (such as scientists, environmental protection specialists, and other such technical classifica tions), Attorney s, and Clerical Support. Relative hours are listed in whole hour increments. The development of the cost per hour for "Federal Model 1" is as follows: 31
FIGURE 3. Federal Model 1 Job Estimate of Estimated time Pay Rate Classificat ion Relative Hours Per Hour (Based on GS

- Level) Cost/Hour Manager 2 0.16 $8 4

. 02 for GS 15 $1 3

. 44 Technical 8 0.68 71

. 41 for GS 14 4 8

. 56 Attorney 1 0.08 71

. 41 for GS

- 14 5. 71 Clerical 1 0.08 2 8

. 65 for GS

- 07 2. 29

_________ _________

__________ 12 hours 1.00 hour $ 70

. 00 /hour
"Federal Model 2"

- Administrative Activities : The skill mix used for administrative activities includes Managers, Tec hnical Staff (such as scientists, environmental protection specialists, and other such technical classifications), Attorney s, and Clerical Support. Relative hours are listed in whole hour increments. The development of the cost per hour for "Federal Mode l 2" is as follows:
FIGURE 4. Federal Model 2 Job Estimate of Estimated Pay Rate Classification Relative Hours Time Per Hour (Based on GS

- Level) Cost/Hour Manager 1 0.20 $8 4

. 02 for GS 15 $16. 81 Technical 1 0.20 71

. 41 for GS 14 1 4

. 28 Attorney 0 0.00 71

. 41 for GS

- 14 0.00 Clerical 3 0.60 2 8

. 65 for GS

- 07 1 7

. 19

__________ _________ __________ 5 hours 1.00 hour $4 8

. 28 /hour
Based on EPA = s experience for the t hirteen austral summer seasons the Rule has been in effect, EPA estimates that the administrative costs have been no more than about 

### 2% of the total estimated costs for the Federal government. Because this percentage is so low, the Federal government costs in Exhibit 2A through 2E are all calculated at the $ 70 /hour rate for technical activities. The margin of difference would be as follows:

31 For the "Technical staff," the model uses the GS

- 14 level rates, and assumes that the technical staff may ac tually be composed of GS

- 13 through GS

- 15 level staff. For the "Attorney," the model uses the GS

- 14 level rates, and assumes that the attorneys may actually be composed of GS

- 14 and GS

- 15 level staff. The EPA estimated rates used in the calculations are base rates on the GS scale for the Washington, DC, area with a 25% increase to incorporate overhead and fringe benefits.

### 33 Amount for technical activities Amount for administr ative activities For $ 1,000 $ 980 $ 20 For $ 5,000 $4,900 $100 For $10,000 $9,800 $200 3. PERM Model for Review of Submissions : For PERMs, the respondent needs to comply with the Final Rule at Section 8.4, preparation of environm ental documents, generally , and Section 8.6, preliminary environmental review. The hourly burden for Federal government review of a PERM is estimated to be 25% of the respondent's time to prepare a PERM, or 10 hours, plus an additional 2 hours for adminis trative activities. Assessment and verification procedures are not required at the PERM level of activity and documentation. Although one respondent per y ear is estimated for purposes of the cost calculations in Exhibit 2A, EPA anticipates that the actua l number of nongovernmental expeditions with activities that will likely proceed with less than minor or transitory impacts may

well be reduced to less than one respondent per y ear. I n fact, only one PERM has been submitted as the final documentation for an expedition during the ten austral summer seasons the Rule has been in effect. 4. IE E Model for Review of Submissions : For I EEs, the respondent needs to comply with the Rule at Section 8.4, preparation of environmental documents, generally , and Section 8.7, initial environmental evaluation. Under the Final Rule (see Figure 1), EPA assumes operators would submit I EEs. Operators can choose to submit a A Core @ or A Revised @ or a A Multi

- Year @ IE E as discussed for the respondents in Section 6(a). Under the A Multi

- Year @ IE E model, EPA assumes the operators, as applicable, would submit a A Revised @ IE E in the initial y ear and, for purposes of maximum burden estimation, supplemental information for the subsequent four ye ars. Over the next three y ears, all Multi

- Year I EE submissions will follow the Multi

- Year Model with a revised submission one y ear and two subsequent y ears where only supplemental information is filed. EPA assumes sixteen operators will submit eight A multi

- ye ar @ IE Es. 32 

### EPA has developed a model for Federal government review of the three models for I EEs. A detailed discussion of the "Model for Federal Government Review of I EEs" is presented Section 6(c).

32 For purposes of demonstrating the hourly burden for an operator submitting a A Multi

- Year @ IEE, EPA assumed forteen operators will subm it nine multi

- year IEEs during the time covered by this ICR renewal. It is possible that three of the operators listed under the A Revised @ IEE model may submit A multi

- year @ rather than
A revised @ IEEs. How ever, since the intent of these operators is unkno wn, EPA assumed these two operators would submit A revised @ IEEs, an assumption that provides the maximum hours and cost estimates for the three year period of this ICR renewal since the hours and costs per operator are more for a A Revised @ IEE than for a A Multi

- Year @ IEE. 

### 5. CEE Model for Review of Submissions : For CEEs, the respondent needs to comply with the Rule at Section 8.4, preparation of environmental documents, generally , and Section 8.8, comprehensive environmental evaluation. The hourly burden for Federal government review of a CEE is estimated to be 50% of the respondent's time to prepare a CEE, or 120 hours, plus an additional 15 hours for administrative activities. The hourly burden for

### 34

review of assessment and verification information is estimated to be 50% of the respondent's time to prepare the assessment and verification information, or 30 ho urs. Although one respondent per y ear is estimated for purposes of the cost calculations in Exhibit 2C, EPA anticipates that the actual number of nongovernmental expeditions with activities that will likely proceed with more than minor or transitory impac ts may

well be reduced to less than one respondent per y ear. I n fact, there were no CEEs submitted during the ten austral summer seasons the Rule has been in effect. 6. Reviewing Emergency Reports : Reporting for Cases of Emergency is based on the Final Rule at Section 8.10, Cases of Emergency , which would require operator notice and reporting for activities taken in cases of emergency which would have otherwise required the preparation of a CEE. The estimated hourly burden for Federal government review of an Emergency

Report is estimated to be 50% of the respondent's time to prepare a CEE, 33 

### or 120 hours, and 50% of the respondent's time to prepare the assessment and verification information for an emergency , or 30 hours, for review of this information. An additional 15 hours are assumed for notify ing the Parties and for administrative activities. As with the respondents, the Federal government hours and cost estimate assumes one such emergency per 10 y ears. 7. Capital/Start Up Costs : The EPA does not anticipate any capital or start up costs on the part of the Federal government to comply with the provisions of the Final Rule. 8. O&M Costs : The EPA estimates the following operating and maintenance (O&M) costs associated with the paperwork requiremen ts for the Federal government to comply with the provisions of the Final Rule. Assumptions and calculations used in EPA's O&M estimate for the three levels of environmental documentation are as follows: PERMs . The assumptions used for the O&M estimates include:

$ PERMs are estimated to average 25 pages including any supplemental information.
$ One PERM submitted per y ear by one operator. I n fact, during the ten austral summer seasons the Rule has been in effect, only one PERM has been submitted as th e final environmental documentation.
$ Six copies of each PERM are needed for Federal government reviewers.
$ PERMs do not require assessment/verification procedures.
$ File storage and maintenance is estimated at $10 per PERM. The estimated O&M costs for a PERM are calculated as follows:

33 See Final Rule at Section 8.10. Emergency reporting would be required for emergency activities which wo uld have otherwise required the preparation of a CEE. The estimate is based on reporting requirements only, not the actual cost of the emergency response action. The hours and cost estimate assumes one such emergency per 10 years. (See: Respondent Assumption 6.)

### 35

(1) Copy ing: 25 pages/PERM x 6 copies x $0.10/page = $15.00 (2) File Storage: 1 PERM package x $10/package = 10.00 Exhibit 2A incorporates these estimated O&M costs in the estimated Federal governmen t hours and costs for PERMs for a three y ear period. 34 

### The O&M cost for copy ing is doubled based on the assumption, for purposes of maximum cost calculation, that the initial submission will be revised and resubmitted for Federal government review. IE Es

. The assumptions used for the O&M estimates include:

$ Figure 2 lists the potential respondents.
$ The maximum length for an I EE is 200 pages including supplemental information. (See: Section 6(a)).
$ Six copies of each I EE are needed for Federal gover nment reviewers.
$ Assessment/verification (A/V) information packages, are estimated as 25 pages per operator.
$ Six copies of each A/V information package is needed for Federal government reviewers.
$ File storage and maintenance is estimated at $ 10 in cluding storage for an I EE package and the associated A/V information. The estimated O&M cost for the three I EE models are calculated as follows:

A Core @ IE E : (1) Copy ing: 200 pages/Core I EE x 6 copies/I EE x $0.10/page = $120.00

10 pages Supplem ental I nfo. x 6 copies x $0.10/page = 6.00 25 pages/ A/V information x 6 copies x $0.10/page = 15.00 (2) File Storage: 1 I EE package x $10/package = 10.00

A Revised @ IE E : (1) Copy ing: 200 pages/Revised I EE x 6 copies/I EE x $ 0.10/page = $120.00

10 pages Supplemental I nfo. x 6 copies x $0.10/page = 6.00 25 pages/ A/V information x 6 copies x $0.10/page = 15.00 (2) File Storage: 1 I EE package x $10/package = 10.00

A Subsequent Year, Multi

- Year @ IE E : (1) 10 pages Supplemental I nfo. x 6 copies x $0.10/page = 6.00

25 pages/ A/V information x 6 copies x $0.10/page = 15.00 (2) File Storage: 1 I EE package x $10/package = 10.00

34 Three years are used in these calculations because that is the period of time the ICR is in effect before it must be ren ew ed.

### 36

Exhibit 2B, including Table 2B, incorporates t hese estimated O&M costs in the estimated Federal government hours and costs for I EEs per y ear for a following three

- ye ar period based as summarized in Table 4. 35 

### Over the next three y ears, all Multi

- Year I EE submissions will require a revised submission o ne y ear and two subsequent y ears where only supplemental information is filed. To calculate the O&M costs over the three y ear period for the Multi

- Year I EEs, the costs of one Model Multi

- Year and two Subsequent Years Multi

- Years are averaged. The O&M cos ts for copy ing the core and revised I EE submissions are doubled based on the assumption, for purposes of maximum cost calculation, the initial submission will be revised and resubmitted for Federal government review. Table 4. Summary

of the 3

- Year Avera ge O&M Costs for a PERM, the Three IEE Models, and a CEE

PERM A Core @ IEE A Revised @ IEE A Subsequent Year, Multi

- Year @ IEE CEE Copy ing: $ 30 File Storage: $ 10
TOTAL $ 40 Copy ing: $261

File Storage: $ 10
TOTAL $271 Copy ing: $261

File Storage : $ 10
TOTAL $271 Copy ing: $ 101

File Storage: $ 10
TOTAL $ 111 Copy ing: $1740

File Storage: $ 10 FedReg: $ 326 TOTAL $2076


### CEEs . The assumptions used for the O&M estimates include:

$ A Federal Register Notice of Availability must be published for receipt of each draft and final CEE; publication costs are estimated at $163 per column and two columns are assumed to be needed.
$ CEEs are estimated to average 300 pages including any supplemental i nformation.
$ One CEE submitted per y ear by one operator. I n fact, during the ten austral summer seasons the Rule has been in effect, no CEEs were submitted.
$ Six copies of each CEE are needed for Federal government reviewers.
$ Forty

- five copies of e ach CEE are needed for distribution to Parties and the Committee for Environmental Protection.
$ Assessment/verification (A/V) information is estimated as 50 pages per operator.
$ Six copies of each A/V information package is needed for Federal governmen t reviewers.
$ File storage and maintenance is estimated at $10 including storage for a CEE package and associated A/V information.
$ Federal Register publication charges have been increased to reflect inflation.

35 Three years are used in these calculations because that is the period of time the ICR is in effect before it must be renewed.

### 37

The estimated O&M costs for a CEE are ca lculated as follows: (1) Copy ing: 300 pages/CEE x 6 copies x $0.10/page = $ 180.00

300 pages/CEE x 45 copies x $0.10/page = 1,350.00 50 pages/ A/V information x 6 copies x $0.10/page = 30.00 (2) FR Publication: 1 CEE x $16 3/column x 2 columns = 326.00 (3) File Storage: 1 CEE package x $10/package = 10.00 Exhibit 2C incorporates these estimated O&M costs in the estimated Federal government hours and costs for CEEs for a three y ear period. 36 

### The O&M c ost for copy ing is doubled based on the assumption, for purposes of maximum cost calculation, that the initial submittal will be revised and resubmitted for Federal government review and that both the draft and final CEEs will also be provided to the Parti es. Reporting for Cases of Emergency . The assumptions used for the O&M estimates include:

$ Emergency

Reports are estimated to average 300 pages including supplemental information.
$ Six copies of each report are needed for Federal government reviewer s. $ Forty

- five copies of each report are needed for distribution to Parties and the Committee for Environmental Protection.
$ Assessment/verification (A/V) information is estimated as 50 pages per incident.
$ Six copies of each A/V information package needed for Federal government reviewers.
$ The O&M costs are first calculated to indicate the annual cost assuming one such emergency

per 10 y ears. $ File storage and maintenance is estimated at $10 including storage for the emergency report package and associated A/V information. (1) Copy ing: 300 pages/report x 6 copies x $0.10/page = $ 180.00

300 pages/report x 45 copies x $0.10/page = 1,350.00 50 pages/ A/V information x 6 copies x $0.10/page = 30.00 (2) Store File: 1 rep ort package x $10/package = 10.00 Exhibit 2D incorporates these estimated O&M costs in the estimated Federal government hours and costs for emergency

reports for a three y ear period. 37

36 Three years are used in these calculations because that is the period of time the ICR is in effect before it must be renew ed.

37 Three years are used in these calculations because that is the period of time the ICR is in effect before it must be renewed.

### 38

9. Coordinating Review of Other Parties' Doc uments : I n accordance with the Final Rule at Section 8.12, the Department of State would be responsible for the coordination of the review of documents received from other Parties. There is no respondent burden associated with Section 8.12. Exhibit 2E p rovides the Federal government hourly burden and cost estimate based on Employ ee Model 1 and the O&M assumptions and estimates below. I t is not possible to predict what may

be received from another Party in any given y ear, and since there is no respondent burden associated with Section 8.12, hours and costs for a three y ear period are not provided bey ond those estimates listed in Exhibit 2E. 38 

### The assumptions used for the O&M estimates include:

$ A Federal Register Notice of Availability must be publishe d for receipt of each draft CEE; publication costs are estimated at $163 per column and two columns are assumed to be needed.
$ Draft and Final CEEs received from other Parties are estimated to average 300 pages including supplemental information.
$ Othe r documents (e.g., description of national procedures, significant monitoring information) received from other Parties are estimated to average 50 pages.
$ Annual lists of I EEs are estimated to average 10 pages.
$ Six copies of each document are needed f or Federal government reviewers and four copies for the public.
$ File storage and maintenance is estimated at $10 including storage for the sum total of any such documents received. (1) Copy ing: 300 pages/draft CEE x 10 copies x $0.10/page = $30 0.00

300 pages/final CEE x 10 copies x $0.10/page = 300.00 50 pages/other x 10 copies x $0.10/page = 50.00 10 pages/I EE list x 10 copies x $0.10/page = 10.00 (2) FR Pub: 1 CEE x $163 /column x 2 columns = 3 26.00 (3) Store File: 1 set of reports from Parties x $ 10 /set = 10.00 6(c) MODEL FOR FEDERAL GOVERNMENT REVIEW OF IEEs As noted in the assumptions above for both the respondents and the Federal government, EPA assumes that most env ironmental documentation submitted under the Final Rule will be IE Es. Based on experience during the ten austral summer seasons the Rule has been in effect, and the assumption that operators will continue to employ the paperwork reduction provisions in th e Final Rule, including the provision for multi

- ye ar documentation, EPA has developed a model for Federal government review of I EEs based on three ty pes of I EE documentation: (1) "Core" I EE, (2) "Revised" I EE, and (3) "Multi

- Year" IEE.

38 Three years are used in these calculations because that is the period of time the ICR is in effect before it must be renewed

.

### 39

The hourly

estima tes for activities associated with Environmental Documentation in Exhibit 2B are based on experience during the ten austral summer seasons the Rule has been in effect and the anticipated degree of consultation with other interested Federal agencies. The c alculations include the estimated technical review time for the three I EE models, the estimated technical hours per Federal review, and the Federal agencies participating in the review process and their relative level of participation. 1. Estimated Hou rs for Technical Review of an I EE : This estimate includes the following assumptions consistent with those in the respondents' estimated burden (Section 6(a)) and consideration of the experience under the ten austral summer seasons the Rule has been in eff ect:

$ Section 6(a), including Figure 2, lists the potential respondents.
$ The maximum length for an I EE is about 200 pages including supplemental information.
$ An I EE consists of "core" information with supplemental expedition

- specific (e.g., dates, landing sites, number of tours, etc.) or other project

- specific information attached or referenced.
$ The core information requires a "Core I EE" review, and certain of the supplemental information not considered to be part of the "core" document (e.g., s upplemental expedition

- specific information for individual tour operators), requires a "Supplemental In formation" review. A "Core I EE" review is estimated to be 50% of the respondent's time to prepare a "core" I EE, or 80 hours, and a "Supplemental I nform ation" review is estimated to be 25% of the respondent's time to prepare the information, or about 1 hour per supplemental package of information not considered to be part of the "core" document. Review time for supplemental information considered to be p art of the "Core IE E" and included by

reference is included in the review time for the "Core I EE."
$ The time to review a "Revised I EE" is estimated to be 25% of the respondent's time to prepare a "core" I EE, or 40 hours, and a "Supplemental I nformation" review to take 1 hour per supplemental package of information not considered to be part of the "revised" document.
$ Operators may

employ the multi

- ye ar provision whereby multi

- ye ar I EE documentation will be submitted. The multi

- ye ar provision also allow s operators to update basic information and to provide information on additional activities to supplement the multi

- ye ar environmental document without having to revise and re

submit the entire document. Review of the initial multi

- ye ar document is assum ed to be the same as review of a A Revised I EE, @ e.g., 40 hours for the A Revised I EE @ and, for purposes of maximum burden estimation, 1 hour for supplemental information. For the subsequent four y ears, the annual advance notice and confirmation that the c onditions of the multi

- ye ar document are unchanged is estimated to take 10 hours per I EE.
$ The I EE level of documentation requires assessment and verification (A/V) procedures. The hourly

burden for review of A/V information is estimated to be 75% of

### 40

th e respondent's time to prepare the A/V information, or 15 hours per information package.
$ For an I EE that covers multiple operators, the hours and costs per operator for reviews are spread among the total number of operators; e.g., the more operators und er one document, the lower the hours and costs for each review on a per operator basis. 39


### IE E Model 1

- A Core @ IE E : The following estimate is based on EPA = s experience for the ten austral summer seasons the Rule has been in effect and considers the paper work reduction options utilized by

the operators. EPA anticipates five one

- time A core @ IE Es will be prepared for the three austral summer seasons this I CR renewal will be in effect. The Federal government hourly burden for preparation of a A Core @ IE E is estimated as follows: Review "core" I EE 80 hrs/I EE x 5 I EEs = 400 hours Review supplemental information 1 hr/review x 5 operators = 5 hours Review of A/V information 15 hrs/A/V pkg x 5 operators = 75 hours TOTAL HOURS = 480 hours TOTAL HOURS PER I EE (5 I EEs) = 96 hours TOTAL HOURS PER OPERATOR (5 operators) = 96 hrs 40


### IE E Model 2

- A Revised @ IE E : For purposes of maximum burden assessment, EPA assumes that two present ship

- based tour operators wil l remain the same, and that these operators will continue to submit revised I EEs for the three austral summer seasons this I CR will be in effect. Updates are likely to include such items as dates of expeditions and changes in landing locations. Revisions could address items such as assessment of the potential impacts, including cumulative impacts, of modifications to the planned activities and any associated mitigation measures, or a reassessment of overall impacts for the expedition. Thus, for subsequen t seasons, EPA estimates the government review time to be 25% of the respondent's time to prepare a "core" IEE, or 40 hours, and the hours for review of supplemental information will remain the same. 41 

### The model for estimating respondent hourly burden for a A Revised @ IE E is based on EPA = s experience under the Rule and considers the paperwork reduction options employ ed by the operators. The operator hourly burden for preparation of a A Revised @ IE E is estimated as follows: Review "revised" I EE 40 hrs/I EE x 3 IE Es = 12 0 hours Review supplemental information 1 hr/review x 3 operators = 3 hours

39 For an IEE that covers multiple operators, the cost per review per operator is further reduced; specific examples are listed as a footnote for each model calculation.

40 If, for example, the A Core @ IEEs cover six operators (e.g., four of the IEEs cover on e operator each and one of the IEEs covers 2 operators), the cost per operator is reduced from 96 hours to 80 hours.

41 If a new IEE is submitted by another U.S.

- based operator, the hourly burden estimate for this IEE is the same as for an initially prepared "core" IEE.

### 41

Review of A/V information 15 hrs/A/V pkg x 3 operators = 45 hours TOTAL HOURS = 1 68 hours TOTAL HOURS PER I EE ( 3 IE Es ) = 56 hours TOTAL HOURS PER OPERATOR ( 3 operators) = 56 hrs 42 

### Model 3

- A Multi

- Year @ IE E : Under the Final Rule, operators may also choose to submit multi

- ye ar I EE documentation. Under this model, EPA assumes the operators will submit a A Revised @ IE E in the initial y ear. The multi

- ye ar provision then allows operators to supplement the multi

- ye ar environmental document without having to revise and re

- submit the entire document in order to update basis information as necessary , and to p rovide information on any new activities or revisions to the documented activities. EPA assumes eight operators may submit "multi

- ye ar" IEEs, and the Federal government hourly burden for review of the "Multi

- Year" IEE will require review at the A Revised I EE @ level of review (e.g., 40 hours) and 1 hour for supplemental information. Review also includes 15 hours for A/V information. I n subsequent y ears, for purposes of maximum burden estimation, 2 hours per I EE is estimated for review of supplemental infor mation and 15 hours for A/V information. The Federal government hourly burden is estimated as follows for review of "Multi

- Year" IEEs: 43


### In itial Year: Review A Revised @ IE E: 40 hrs/I EE x 9 IE Es x 1 y r = 3 6 0 hours Review supplemental information: 1 hr/ operator x 1 4 ops x 1 y ear = 1 4 hours Review A/V information: 15 hrs/operator x 1 4 ops x 1 y ear = 2 1 0 hours Four Subsequent Years for a Total of Five Consecutive Years: Review supplemental information: 1 hr/operator x 1 4 ops x 4 y ears = 56 hou rs Review A/V information: 15 hrs/operator x 1 4 ops x 4 y ears = 84 0 hours TOTAL HOURS for 5

- Year Period of A Multi

- Year @ IE E = 1 480 hours TOTAL HOURS PER YEAR (5 Years) PER I EE 9 8 I EEs) = 33 hours TOTAL HOURS PER YEAR (5 Years) PER OPERATOR (1 4 operators) = 2 1 hours 44

42 If, for example, the A Revised @ IEEs cover four operators (e.g., tw o of the IEEs cover one operator each and one of the IEEs covers 2 operators), the cost per operator is reduced from 56 hours to 42 hours per review per operator.
43 For purposes of demonstrating the hourly burden for an operator submitting a A Multi

- Year @ IEE, EPA assumed forteen operators would submit nine multi

- year IEEs during the time covered by this ICR renewal. It is possible that the three operators listed under the A Revis ed @ IEE model may submit A multi

- year @ rather than A revised @ IEEs. How ever, since the intent of these operators is unknown, EPA assumed these three operators would submit
A revised @ IEEs, an assumption that provides the maximum hours and cost estimates for the three year period of this ICR renewal since the hours and costs per operator are more for a A Revised @ IEE than for a A Multi

- Year @ IEE.

44 Because the eight A Multi

- Year @ IEEs cover forteen operators (e.g., one IEE covers one operator and the other covers two operators), the hours per operator is reduced from 24 hours to 20 hours (e.g., the hours for review of the annual supplemental information and A/V information) as the initial review cost of the A Revised @ IEE is spread

### 42

2. Estimated Technical Hours by Federal Agency

for Review of an I EE : EPA has used and would continue to use a "Principal Reviewer/Associate Reviewer" process to review environmental documentation submitted by operators. OF A would serve as the Principal Reviewer. Associate Reviewers may include representatives from program offices within EPA and other Federal agencies with an interest in Antarctica. The interested Federal agencies are listed in Section 5(a). Based on expe rience during the ten austral summer seasons the Rule has been in effect and the anticipated consultation needs under the Final Rule, the following calculations spread amongst the Federal agencies the 96 total hours per A Core @ IE E review, the 56 total hour s per A Revised @ IE E review, and the 16 total hours per A Subsequent Year, Multi

- Year @ IE E.

A Core @ IE Es A Revised @ IE Es A Subseq.Yrs, Multi

- Year @ IEE 

### s Federal Agency Relative

Tim e/Hr x 96

Hrs Hrs Relative

Tim e/Hr x 56

Hrs Hrs Relative

Tim e/ Hr x 40

Hrs Hrs EPA NSF DOS Others 0.49

0.35 0.15 0.01 x 96

x 96 x 96 x 96 47 34 14 1 0.50 0.35 0.15 0.00 x 56

x 56 x 56 x 56 28 20 8 0 0.50

0.40 0.10 0.00 x 40

x 40 x 40 x 40 20

16 4 0 Totals 1.00 96 1.00 56 1.00 30

A Others @ may include: USCG, NOAA, MMC and DOJ 

### The model further assumes that 2/3 of the time for review of each document applies to the draft IE E, and 1/3 of the time to the final I EE:

A Core @ IE Es A Revised @ IE E " Subsequent Years, Multi

- Year @ IE E Review Hours per Draft 64 37 27 Review Hours per Final 32 19 13 Total Hours 96 56 40 The hours are then spread amongst the Federal agencies as follows:

among the operators.

### 43 A Core @ IEE A Revised @ I EE A Subseq.Yrs, Multi

- Year @ IEE Draft Final Draft Final Draft Final EPA NSF DOS Others .49

.35 .15 .01 31 22 10 1 16 11 5 0 .50 .35 .15 .00 18 13 6 0 10 7 2 0 .50 .35 .15 .00 13 1 1 3 0 6 6 1 0 Totals 64 32 37 19 27 13


### In Exhibits 2A through 2E for the "Estimated Federal Government Hours and Cost," the total hours listed for the Government hours/y ear are assumed to include the spread of hours across the Federal agencies as calculated above. The costs in Exhibits 2A through 2E are calculated at the $65/hour rate for technical activities as discussed in Section 6(b), item 2. 6(d) ESTIMATED ANNUAL AGGREGATE HOURS AND COST Exhibit 3 is the summary of the estimated hours and costs for respondents and the Federal government. This summary compiles the totals for the respondents (Exhibits 1A, 1B including Table 1, 1C, and 1D) and Federal government (Exhibits 2A, 2B including Table 2, 2C, and 2D) for each lev el of environmental documentation. 45 

### Chart 2 in Exhibit 3 further summarizes for respondents and the Federal government the hours and costs for the most likely documentation scenario for the 3

- ye ar life of this I CR renewal, namely , a "Multi

- Year" IEE which includes for the initial y ear a "Revised" I EE and "Subsequent Year, Multi

B Year" IEE documentation for the two subsequent y ears. Exhibit 3 is annualized over a three y ear period by assuming a 3.5% escalation rate per y ear, the assumed Consumer Price I nde x (CPI ) escalation rate. 46 

### Based on the reporting by operators for the thirteen austral summer seasons during the time the Rule has been in effect under an OMB

- approved I CR and EPA's understanding of the ty pes of nongovernmental activities likely to contin ue to be undertaken by U.S.

- based operators in Antarctica, EPA anticipates that the most likely scenario during the three

- ye ar renewal period this information collection will be in effect consists of the following:

$ Twenty

- t wo operators will likely plan expeditions to Antarctica and will submit environmental documentation including assessment and verification information. Seventeen will likely

be repeat operators with annual expeditions, and five operators may submit new documentation. These five may in clude new operators planning annual expeditions and operators of one

- time only expeditions.

45 Exhibit 2E summarizes the Federal government hours and cost for coordinating review of information received from other Parties and is not further summarized since it is not possible to predict what may be received from another Party in any given year, and there is no associated respondent hours or costs.

46 Three years are used in these calculations because that is the period of time the ICR is in effect before it must be renewed.

### 44

$ T hree of the 18 repeat operators with annual expeditions will submit revised I EEs.
$ It was assumed that 9 of the 1 7 repeat operators would submit new Multi

- Year IE Es, including a "Revised" I EE in the initial y ear and "Subsequent Year, Multi

- Year" IEE documentation for the two subsequent y ears. $ No CEEs have been submitted as the final documentation during the past t hirteen austral seasons and only

one PERM has been submitted during this time

- frame. No CEEs or PERMs are anticipated during the effective period for this I CR renewal.
$ There were no emergencies requiring emergency reporting during the ten austral summer seasons the Rule has been in effect, and non e are expected to occur during the effective period for this I CR renewal.
$ Other than receipt of the annual list of I EEs, there is no way to anticipate receipt of environmental documents from the Parties on an annual basis or during the effective period for this I CR renewal. There is no burden to the respondents associated with receipt of documents from the Parties. Therefore, there are no burden estimates associated with coordinating review of information received from other Parties included in the bur den summary

. $ The Consumer Price I ndex (CPI ) is estimated to be 3.5% for the subsequent y ears and is incorporated into the cost calculations for these y ears. Based on the above assumptions, Chart 3 in Exhibit 3 summarizes the estimated hours and costs f

or the respondents and the Federal government for the 3

- ye ar period of this I CR renewal. This summary

assumes 2 2 operators per y ear with 5 new operators and 1 7 repeat operators each y ear. For the 1 7 repeat operators, the assumptions are that t hree will p repare "Revised" I EEs and 1 4 will prepare "Multi

- Year" IEEs. As summarized in Chart 3, for the estimated 2 2 operators submitting environmental documentation under the Final Rule during this I CR renewal period, the annual total hours for the 2 2 operators i s estimated to be 1, 708 hours , and the annual total hourly burden per operator is estimated to be 7 8 hours . These annual totals reflect submission of different levels of documentation by

the 23 operators. The estimated annual average time per respondent ranges from 42 to 185 hours depending on the level of environmental documentation and the paperwork reduction provisions employ ed by the respondent. As summarized in Chart 3, for the estimated 2 2 operators submitting environmental documentation under the Final Rule during this I CR renewal period, the annual total cost for the 2 2 operators is estimated to be $13 6 , 675 , and the annual total cost burden per operator is estimated to be $ 6 , 213 . These annual totals reflect submission of different levels of docum entation by

the 2 2 operators. The estimated annual average per respondent ranges from $3, 372 to $14,678 depending on the level of environmental documentation and the paperwork reduction provisions employ ed by the respondent. As summarized in Chart 3, fo r the estimated 2 2 operators submitting environmental documentation under the Final Rule during this I CR renewal period, the annual total hours and

### 45

cost for the Federal government is estimated as 105 4 hours and $ 80 , 471 . The annual total hours and cost per operator for the Federal government is estimated as 4 8 hours and $3, 658 . These annual totals reflect submission of different levels of documentation by the 2 2 operators. The estimated annual average hours and cost per respondent ranges from 29 hours and $2, 224 to 96 hours and $ 7 , 254 depending on the level of environmental documentation and the paperwork reduction provisions employ ed by the respondent. 6(e) REASONS FOR CHANGE IN BURDEN The current inventory

approved by

the Office of Management and Budge t (OMB) for the annual reporting and recordkeeping hourly burden is 1, 663 hours . The total 3

- ye ar estimated hourly burden of 5 , 124 hours for the anticipated 2 2 operators represents an annual reporting and recordkeeping hourly

burden of 1, 708 hours, or 7 8 hours per operator for this 3

- ye ar renewal period. This increased adjustment to the annual reporting and recordkeeping hourly burden is 45 hours . This increased adjustment is the result of a change to the level of environmental documentation EPA anticipa tes the operators will submit.
6(f) BURDEN STATEMENT Burden Statement : The annual public reporting and recordkeeping burden for this collection of information is estimated to average 1, 708 hours annually , or 7 8 hours per response. This hourly burden reflects annual submission of different levels of environmental documentation by an anticipated 2 2 respondents (e.g., U.S.

- based nongovernmental operators). Burden means the total time, effort, or financial resources expended by persons to generate, maint ain, 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 sy stems for the purposes of collecting, validating, and verify ing infor mation, processing and maintaining information, and disclosing and providing information; adjust the existing way s 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 display s a currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15. To comment on the Agency 's need for this information, the accuracy of the provided burden estimates, and any sugges ted methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this I CR under [EPA

- HQ

- OECA

- 2007

- 0468], which is available for online viewing at www.regulations.gov, or in person v iewing at the Enforcement and Compliance Docket and I nformation Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30

### 46

p.m., Mond ay

through Friday , excluding legal holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the Enforcement and Compliance Docket and I nformation Center is (202) 564

- 1752. An electronic version of the public doc ket 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 sy stem, select A search, @ then key in the docket I D number identified above.

### 47 Exhibit 1A: PERMs
- ESTIMATED RESPONDENT HOURS AND COST
Respondent Respondent Rate Range Capitol/ O & M No. of Totals for R espondent Rate Range ICR Activity: PERMs Hrs/Y r $65/hour $75/hour $100/hour Startup Cost Cost Respondents $65/hour $75/hour $100/hour Environmental Documentation 1. Study the regulations 2. Search reference s ources for existing information and compile information from company

records 3. Prepare PERM and submit 4. Revise PERM in response to EPA's comments and submit Post

- Expedition Assessment & Verification 1. Prepare A/V information and submit

- NOT REQUIRE D FOR PERMs 40 $ 2,600 $ 3,000 $ 4,000 Env. Doc. None

Post

- Exp. A/V None Env. Doc.

Copy ing $ 25 Mailing 54

____________

_ $ 79

Post

- Exp . A/V Copy ing $ 0 Mailing 0

____________ $ 0 $ 79 1 $ 2,679 $ 3,079 $ 4,079



### Totals for Respondent Rate Range Hours $65/ hour $75/hour $100/hour YEAR ONE 40 $ 2,679 $ 3,079 $ 4,079 YEAR TWO (3.5% estimated CPI escalation rate) 40 2,773 3,187 4,222 YEAR THREE (3.5% estimated CPI escalation rate) 40 2,870 3,298 4,370 TOTAL ESTI M ATED POTENTI AL HOURS and COST: 120 $ 8,322 $ 9,564 $12,671 AVERAGE EST. HOURS and COST PER YEAR PER OPERATOR: 40 $ 2,774 $ 3,188 $ 4,224
Assumptions: 1. Exhibit 1A represents the estimated hours and cost for PERMs. In fact, during the t hirteen austral summer seasons the Rule has been in effect, only one PERM was submitted as the final documentation for an expedition. For purposes of estimating the potential maximum hours and cost associated with PERMs over the three

- year life of the ICR, the t hree

- year projection assumes submission of one PERM per year for each of the next three years. Although one respondent per year is estimated for purposes of the burden calculations, EPA anticipates that the actual number of nongovernmental expeditions wit h activities that will likely proceed with less than minor or transitory impacts may well be reduced to less than one respondent per year. 2. Estimates for preparation of a PERM are based on estimated time that would be needed to comply with the Rule at S ection 8.4, preparation of environmental documents, generally, and Section 8.6, preliminary environmental review. 3. The cost estimates are based on industry labor rates obtained during informal consultations with industry representatives and include overh ead and fringe benefits. The three rates used in the calculations represent the rates provided by the industry representatives. The $75/hour intermediate rate is used for summary purposes. See Part D for addit ional information on the consultations with affected respondents. 4. Hours and cost associated with preparation of higher level EIA documentation, if necessary, is addressed in Exhibits 1B ( IEEs) and 1C (CEEs).

### 48 Exhibit 1B: IEEs
- ESTIMATED RESPONDENT HOURS AND COST
Respondent Res pondent Rate Range Capitol/ O & M No. of Totals for Respondent Rate Range ICR Activity: IEEs Hrs/Y r $65/hour $75/hour $100/hour Startup Cost Cost Respondents $65/hour $75/hour $100/hour MODEL 1: "Core" IEE Environmental Documentation 1. Study the regulations 2. Search reference sources for existing information and compile information from company

records 3. Prepare Core IEE and submit 4. Revise in response to EPA's comments an d submit Supplemental Information 1. Prepare and submit supplemental information

Post

- Expedition Assessment & Verification 1. Prepare A/V information and submit 185 $ 12,025 $ 13,875 $ 18,500 Env.Doc. None

Supp.Info. None

Post

- Exp. A/V None Env.Doc.

Copy ing $ 200 Mailing 54

____________

_ $ 254

Supp.Info. Copy ing $ 5 Mailing 12

_________

___ $ 17 Post

- Exp. A/V Copy ing $ 13 Mailing 17

____________

$ 30
$ 301 See Table

1 $ 12,326 $ 14,176 $ 18,801

Assumptions for IEEs: 1. I EEs would need to comply with the Rule at Section 8.4, preparation of environmental documents, generally, and Section 8 .7, initial environmental evaluation. 2. A "Core" I EE and associated supplemental in formation comprises the IEE package for the initial preparation of an IEE by an operator. 3. A "Revised" IEE and associated supplemental information comprises the IEE package for a current year's submission develop ed through revision of a previous year's submission. 4. A A Multi

- Year @ IEE consists of a A Revised @ IEE and the associated supplemental information in the initial year and, for each of the subsequent four years, an annual sub mission of the advance notice and confirmation that the information prov ided in the Multi

- Year I EE is unchanged. 5. Supplemental information for purposes of the costs estimated in Exhibit 1B and Table 1 refers to supplemental information submitted regarding the specifics of the tours/expedition (e.g., dates, number of tours, etc.) rather than supplemental information of a more technical nature that is incorporated into the "Core" or "Revised" IEE by reference. 6. The cost estimates are based on industry labor rates obtained during informal consultations with industry represen tatives and include overhead and fringe benefits. The three rates used in the calculations represent the rates provided by the industry representatives. The $75/hour intermediate rate is used for summary purposes. See Part D for addit ional information o n the consultations with affected respondents.

### 49 Respondent Respondent Rate Range Capitol/ O & M No. of Totals for Respondent Rate Range ICR Activity: IEEs Hrs/Yr $65/hour $75/hour $100/hour Startup Cost Cost Respondents $65/hour $75/hour $100/hour MODEL 2: "Revised" IEE Environmental Documentation 1. Study the regulations 2. Search reference sources for existing information and compile information from company records 3. Prepare Revised IEE and submit 4. Revise in response to EPA's comments and submit Supplemental Information 1. Prepare and submit supplemental information

Post

- Expedition Assessment & Verification 1. Prepare A/V information and submit

65 $ 4,225 $ 4,875 $ 6,500 Env.Doc. None

Supp.I nfo. None

Post

- Exp. A/V None Env.Doc.

Copy ing $ 200 Mailing 54

_______ _____

_ $ 254

Supp.Info. Copy ing $ 5 Mailing 12

____________

$ 17 Post

- Exp. A/V Copy ing $ 13 Mailing 17

____________

$ 30
$ 301 See Table

1 $ 4,526 $ 5,176 $ 6,801

### 50 Respondent Respondent Rate Range Capitol/ O & M No. of Totals for Respondent Rate Rang e ICR Activity: IEEs Hrs/Y r $65/hour $75/hour $100/hour Startup Cost Cost Respondents $65/hour $75/hour $100/hour "Subsequent Y ears" for Multi

- Ye ar IEE under MODEL 3 Supplemental Information 1. Prepare and submit supplemental information

Post

- Expedition Assessment & Verification 1. Prepare A/V information and submit 30 $ 1, 950 $ 2, 250 $ 3 , 0 00 Supp.Info. None

Post

- Exp. A/V No ne Supp.Info.

Copy ing $ 5 Mailing 12

____________

$ 17 Post

- Exp. A/V Copy ing $ 13 Mailing 17

____________

$ 30 $ 47 See Table

1 $ 1,9 87 $ 2,2 97 $ 3 , 0 47

TABLE 1. IEEs
- TOTAL ESTIMATED HOURS AND COST FOR THE THREE IEE MODELS WITH 3.5% ESCALATION RATE

A Core @ IEE for One Operator and One IEE Totals for Respondent Rate Range Hours $65/hour $75/hour $100/hour YEA R ONE 185 $ 12,326 $ 14,176 $ 18,801 YEAR TWO (3.5% estimated CPI escalation rate) 185 12,757 14,672 19,459 YEAR THREE (3.5% estimated CPI escalation rate) 185 13,203 15,186 20,140 TOTAL ESTIMATED POTENTIAL HOURS and COST: 555 $ 38,286 $ 44,034 $ 58,400 AVERAGE EST. HOURS and COST PER YEAR PER OPERATOR: 185 $ 12,762 $ 14,678 $ 19,467

A Revised @ IEE for One Operator and One IEE Totals for Respondent Rate Range Hours $65/hour $75/hour $100/hour YEAR ONE 65 $ 4,526 $ 5,176 $ 6,801 YEAR TWO (3.5% estimated CPI escalation rate) 65 4,684 5,357 7,039 YEAR THREE (3.5% estimated CPI escalation rate) 65 4,848 5,544 7,285 TOTAL ESTIMATED POTENTIAL HOURS and COST: 195 $ 14,058 $16,077 $ 21,125 AVERAGE EST. HOURS and COST PER YEAR PER OPERATOR: 65 $ 4,6 86 $ 5,359 $ 7,042

### 51 "Multi

- Year" IEE for One Operator and One IEE

- A A Multi

- Year @ IEE consists of a A Revised @ IEE and, for each of the subsequent four years, an annual submission of the advance notice and confirmation that the inform ation provided in the Multi

- Year IEE is unchanged. See above for the hours and cost per operator for the "Revised" IEE for the initial year. The hours and cost per operator for the subsequent years follow s for w hich hours and cost are calculated for "Sub sequent Year Multi

- Year" IEE submissions. “Subsequent Year Multi

- Year” IEE for One Operator Totals for Respondent Rate Range Hours $65/hour $75/hour $100/hour YEAR ONE 30 $ 1, 987 $ 2,297 $ 3,047 YEAR TWO (3.5% estimate d CPI escalation rate) 30 2,057 2,377 3,154 YEAR THREE (3.5% estimate d CPI escalation rate) 30 2,129 2,460 3,264 TOTAL ESTIMATED PO T ENTIAL HOURS and COST: 90 $ 5,192 $ 7,134 $ 9,465 AVERAGE EST. HOURS and COS T PER YEAR PER OPERATOR: 30 $ 1,731 $ 2,378 $ 3,155
Average Estimated Hours and Cost for One Operator Initiating and Continuing with a Multi

- Year IEE Duri ng This ICR Renewal Period "Revised" IEE based on $75/hour rate and average cost 65 $ 5,359 "Subsequent Year Multi

- Year" IEE based on $75/hour rate and average cost for tw o subsequent years 30 hrs x 2 = 60 $2,3 78 x 2 = $ 4, 756 TOTAL ES TIMATED POTENTIAL HOURS and COST: 1 25 $ 10 , 115 (over 3

- year life of this ICR Renewal) AVERAGE EST. HOURS and COST PER YEAR PER OPERATOR: 42 $ 3, 372 (over 3

- year life of this ICR Renewal)

### 52 Exhibit 1C: CEEs
- ESTIMATED RESPONDENT HOURS AND COST Respondent Respondent Rate Range Capitol/ O & M No. of Totals for Respondent Rate Range ICR Activity: CEEs Hrs/Y r $65/hour $75/hour $100/hour Startup Cost Cost Respo ndents $65/hour $75/hour $100/hour Environmental Documentation 1. Study the regulations 2. Search reference sources for existing information and compile information from company records 3. Prepare CEE and submit 4. Revise in response to EPA's comments and submit Post

- Expedition Assessment & Verification 1. Prepare A/V information and submit 300 $ 19,500 $ 22,500 $ 30,000 Env. Doc. None

Post

- Exp. A/V None Env. Doc.

Copying $ 300 Mailing 64

___________ $ 364

Post

- Exp. A/V Copying $ 25 Mailing 17

____________

$ 42 $ 406 1 $ 19,906 $ 22,906 $ 30,406



### Totals for Respondent Rate Range Hours $65/hour $75/hour $100/hour YEAR ONE 300 $ 19,906 $ 22,906 $ 30,406 YEAR TWO (3.5% estimated CPI escalation rate) 300 20,603 23,708 31,470 YEAR THREE (3.5% estimated CPI escalation rate) 300 21,324 24,538 32,571 TOTAL ESTIMATED POTENTIAL HOURS and COST: 900 $ 61,833 71,152 94,447 AVERAGE EST. HOURS and COST PER YEAR PER OPERATO R: 300 $ 20,611 23,717 31,482 Assumptions: 1. Exhibit 1C represents the estimated hours and cost for CEEs. In fact, no CEEs were submitted during the ten austral summ er seasons the Rule has been in effect. For purposes of esti mating the potential maximum hours and cost associated with CEEs over the three

- year life of the ICR, the three

- year projection assumes submission of one CEE per year for each of the next three years. Although one respondent per year is estimated for purp oses of the cost calculations, EPA anticipates that the actual number of nongovernmental expeditions with activities that will likely pro ceed with less than minor or transitory impacts may well be reduced to less than one respondent per year. 2. Estimates for preparation of a CEE are based on estimated time that would be needed to comply with the Final Rule at Section 8.4, prepa ration of environmental documents, generally, and Section 8.8, comprehensive environmental evaluation. 3. The cost estimates are based on industry labor rates obtained during informal consultations with industry representatives and include overhead and f ringe benefits. The three rates used in the calculations represent the rates provided by the industry representatives. The $75/ho ur intermediate rate is used for summary purposes. See Part D for additional information on the consultations with affected respondents.

### 53 1D. REPORTING FOR EMERGENCIES
- ESTIMATED RESPONDENT HOURS AND COST Respondent Respondent Rate Rang e Capitol/ O & M No. of Totals for Respondent Rate Range ICR Activity: CEEs Hrs/Y r $65/hour $75/hour $100/hour Startup Cost Cost Respondents $65/hour $75/hour $100/hour Repor ting for Cases of Emergency 1. Initial Report 2. Full Report

Post

- Emergency Assessment & Verification 1. Prepare A/V information and submit

300 $ 19,500 $ 22,500 $ 30,000 Reporting None

Pos t A/V None Reporting

Copy ing $ 150 Mailing 32

____________

_ $ 182 Post A/V Copy ing $ 25 Mailing 17

____________

_ $ 42 $ 224 1 $ 19,724 $ 22,724 $ 30,224

There w ere no emergencies that required reporting during the seven austral summer seasons the Rule has been in effect. An in cident requiring emergency reporting could occur in the subsequent years. The follo wing cost estimates are not additive, however, since only one such emergency in 10 years is estimated. 

### Totals for Respondent Rate Range Hours $65/hour $75/hour $100/hour YEAR ONE 300 $ 19,724 $ 22,724 $ 30,224 YEAR TWO (3.5% estima ted CPI escalation rate) 300 20,414 23,519 31,282 YEAR THREE (3.5% estimated CPI escalation rate) 300 21,128 24,342 32,377 Assumptions: 1. Reporting for Cases of Emergency is based on the Final Rule at Section 8.10, Cases of emergency, which requires notice and reporting for activities taken in cases of emergency whic h would have otherwise required the preparation of a CEE. The estimate is based on reporting requirements only, not the actual co st of the emergency response action. The hours and cost estimate assumes one such emergency per 10 years. 2. Only one incident requiring emergency reporting is estimated to occur over a 10

- year period. In fact, there was no emergency reporting during th e ten austral summer seasons the Rule has been in effect. 3. The cost estimates are based on industry labor rates obtained during informal consultations with industry representatives and include overhead and fringe benefits. The three rates used in the c alculations represent the rates provided by the industry representatives. The $75/hour intermediate rate is used for summary purposes. See Part D for addit ional information on the consultations with affected respondents.

### 54 Exhibit 2A: PERMs
- ESTIMATED F EDERAL GOVERNMENT HOURS AND COST
Federal Gov't. Federal Gov't. Capitol/ O & M No. of Total ICR Activity: PERM hours/year $ 70 /hour Startup Cost Cost Respondents Cost/Year PERMs from U.S.

- Based Ope rators : 1. Post PERM receipt on WWW, provide copies to interested Federal agencies and public, if requested 2. Review PERM and any public comments, provide comments to and consult with operator 3. Provide copies of revised/final PERM to interested Federal agencies, review, and notify

operator, if necessary 4. Maintain file

Post

- Expedition Assessment & Verification 1. Review A/V information

- NOT REQUIRED FOR PERMs 12 $ 840 PERM

No ne

Post

- Exp A/V

None PERM

Copy ing $ 30 FR Pub. 0 Store Files 10

____________

_ $ 40

Post

- Exp A/V

None

$ 40 1 $ 8 8 0

Hours Cost YEAR ONE 12 $ 8 8 0 YEAR TWO (3.5% estimated CPI escalation rate on $794) 12 911 YEAR THREE (3.5% estimated CPI escalation rate on $822) 12 943 TOTAL ESTIMATED POTENTIAL BURDEN and COST: 36 $ 2, 734 AVERAGE EST. B URDEN and COST PER YEAR PER OPERATOR: 12 $ 911 Assumptions: 1. Exhibit 2A represents the estimated hours and cost for PERMs. In fact, during the t hirteen austral summer seasons the Rule has been in effect, only one PERM was submitted as the final doc umentation for an expedition. For purposes of estimating the potential maximum hours and cost associated with PERMs over the three

- year life of the ICR, the three

- year projection assumes submission of one PERM per year for each of the next three years. A lthough one respondent per year is estimated for purposes of the cost calculations, EPA anticipates that the actual number of nongovernmental expeditions with activities that will likely proceed with less than minor or transitory impacts may

well be reduce d to less than one respondent per year. 2. Estimates for review of a PERM is estimated as 25% of the respondent's time, or 10 hours, to prepare a PERM that would be in compliance with the Final Rule at Section 8.4, preparation of environmental documents, generally, and Section 8.6, preliminary environmental review, and two hours for administrative activities.

### 55

3. Hours and cost associated with preparation of higher level EIA documentation, if necessary, is addressed in Exhibits 2B (I EEs) and 2C (CEEs). 4. Based on EPA = s experience for the t hirteen austral summer seasons the Rule has been in effect, EPA estimates that the administrative costs have been no more than about 2% of the total estimated costs for the Federal government. Because this percentage is so low, the Federal government costs in Exhibit 2A through 2E are all calculated at the $ 70 /hour rate for technical activities.

### 56 Exhibit 2B: IEEs
- ESTIMATED FEDERAL GOVERNMENT HOURS AND COST

Federal Gov't. Federal Gov't. Capitol/ O & M No. of Total ICR Activity: IEEs hours/y ear $ 70 /hour Startup Cost Cost Respondents Cost/Y ear Environmental Documentation MODEL 1: "Core" IEE 1. Post IEE receipt on W WW, provide copies to interested Federal ag encies and public, if requested 2. Review IEE and any public comments, provide comments to and consult with operator 3. Provide copies of revised/final IEE to interested Federal agencies, review , and notify operator, if necessary 4. Maintain file Supplem ental Information 1. Review supplemental information Post

- Expedition Assessment & Verification 1. Review A/V information

- Core IEE

80

1

15

96 $ 5, 6 00

$ 70

$ 105 0

$ 6, 720 Core IEE

None

Supp. Info. None

Post

- Exp A/V

None Core IEE

Copy ing $ 261 Store Files 10*

___________ $ 271 *File storage includes Supp. and A/V Information

Supp. Info. Include d above

Post

- Exp A/V Copy ing $ 15 File Storage *

___________

_ $ 15 *Included above $ 286 See

Table 2 $ 7 , 006

### 57 Federal Gov't. Federal Gov't. Capi tol/ O & M No. of Total ICR Activity: IEEs hours/y ear $ 70 /hour Startup Cost Cost Respondents Cost/Y ear Environmental Documentation MODEL 2: "Revised" IEE 1. Post IEE receipt on W WW, provide copies t o interested Federal agencies and public, if requested 2. Review IEE and any public comments, provide comments to and consult with operator 3. Provide copies of revised/final IEE to interested Federal agencies, review, and notify operator, if necessary 4. Maintain file Supplemental Information 1. Review supplemental information Post

- Expedition Assessment & Verification 1. Review A/V information

- Revised IEE

40

1

15

56 $ 2, 8 00

$ 70

$ 1050

$ 3, 920 Revised

IEE

None

Supp. Info. None

Post

- Exp A/V

None Revised IEE

Copy ing $ 261 Store Files 10*

___________ $ 271 *File storage includes Supp. and A/V Infor mation

Supp. Info. Included above

Post

- Exp A/V Copy ing $ 15 File Storage *

___________

_ $ 15 *Included above $ 286 See

Table 2 $ 4 , 206

### 58 Fed eral Gov't. Federal Gov't. Capitol/ O & M No. of Total ICR Activity: IEEs hours/y ear $ 70 /hour Startup Cost Cost Respondents Cost/Y ear Environmental Documentation MODEL 3: "Multi

- Ye ar" IEE Ye ar 1: "R evised" IEE

Ye ars 2 and 3: "Subsequent Ye ars Multi

- Ye ar" IEE 1. Review supplemental information 2. Review A/V information

- 40

1

15 $ 2, 8 00

Ye ars 2 and 3 $ 70
$ 1050

_____ ___ $ 1, 120 None

None Ye ar 1

Copy ing $ 261 Store Files 10*

___________ $ 271 *File storage includes Supp. and A/V Information Ye ars 2 and 3 Copy ing $ 15 File Storage *

____________

$ 15 See

Table 2 See

Table 2

Assumptions: 1. I EEs would need to comply with the Rule at Section 8.4, preparation of environmental documents, generally, and Section 8. 7, initial environmental evaluation. 2. A "Core" IEE and associated supplemental information comprises the IEE package for the initial submittal of an IEE by an operat or. 3. A "Revised" IEE and associated supplemental information comprises the IEE package for a current year's submittal develope d through revision of a previous year's submittal. 4. A A Multi

- Year @ IEE consists of a A Revised @ IEE and the associated supplemental information in the initial year and, for each of the subsequent four years, an annual sub mission of the advance notice and c onfirmation that the information provided in the Multi

- Year I EE is unchanged. 5. Supplemental information for purposes of the costs estimated in Exhibit 2B and Table 2 refers to supplemental information submitted regarding the specifics of the tours/exped ition (e.g., dates, number of tours, etc.) rather than supplemental information of a more technical nature that is incorporated into the "Core" or "Revised" IEE by reference. The one hour for review of the supplemental information is assigned to EPA to si mplify the model and calculations.

### 59 ______________________________________________________________________________________________________ TABLE 2. IEEs

- TOTAL ESTIMATED HOURS AND COST FOR THE THREE IEE MODELS, 3.5% ESCALATION RATE

A Core @ IEE for One O perator and One IEE

- (Core IEE + Supplemental Information + A/V Information) HOURS COST YEAR ONE 96 $ 7 , 006 YEAR TW O (3.5% estimated CPI escalation rate) 96 7 , 251 YEAR THREE (3.5% estimated CPA escalation rate) 96 7 , 504 TOTAL ESTIMATED POTENTIAL HOURS and COST: 288 $ 2 1 , 761 AVERAGE EST. HOURS and COST PER YEAR PER OPERATOR 96 $ 7 , 254

A Revised @ IEE for One Operator and One IEE

- (Revised IEE + Supplem ental Information + A/V Information) HOURS CO ST YEAR ONE 56 $ 4 , 206 YEAR TW O (3.5% estimated CPI escalation rate) 56 4, 353 YEAR THREE (3.5% estimated CPA escalation rate) 56 4, 5 05 TOTAL ESTIMATED POTENTIAL HOURS and COST: 168 $ 1 3 , 064 AVERAGE EST. HO URS and COST PER YEAR PER OPERATOR 56 $ 4, 355 "Multi

- Year" IEE for One Operator and One IEE

- A "Multi

- Year" IEE consists of a "Revised" IEE and, for each of the subsequent four y ears, an annual submission of the advance notice and confirmation t hat the information provided in the Multi

- Year IEE is unchanged. See above for the hours and cost per operator for the "Revised" IEE for the initial y ear. The hours and cost per operator for the subsequent y ears follows for which hours and cos t are calcu lated for "Subsequent Year Multi

- Year" IEE subm issions. “Subsequent Year Multi

- Year” IEE for One Operator

- (Supplemental Information + A/V Information) HOURS COST YEAR ONE 16 $ 1, 120 YEAR TWO (3.5% estimate d CPI escalation rate) 16 1, 159 YEAR THREE (3.5% estimated CPA escalation rate) 16 1,200 TOTAL ESTIMATED POTENTIAL HOURS and COST: 48 $ 3,479 AVERAGE EST. HOURS and COST PER YEAR PER OPERATOR 16 $ 1,159 Average Estimated Hours and Cost for One Operator Initiating and Continuing with a Multi

- Year IEE During This ICR Renewal Period
A Revised @ IEE for One Operator and One IEE HOURS COST "Revised" IEE 56 $ 4, 355 "Subsequent Year Mu lti

- Year" IEE

- cost for 2 y ears 16 hrs x 2 = 32 $1, 1 59 x 2 = 2, 318 TOTAL ESTIMATED POTENTIAL HOURS AND COST: 88 $ 6, 673 (over 3

- ye ar life of this ICR Renewal) AVERAGE EST. HOURS and COST PER YEAR PER OPERATOR: 29 $ 2, 224 (over 3

- ye ar life of this ICR Renewal)

### 60 _________________________________________________________________________________________

### 61 Exhibit 2C: CEEs - ESTIMATED FEDERAL GOVERNMENT HOURS AND COST

Federal Gov't. Federal Gov't. Capitol/ O & M No. of Total ICR Activity: CEE hours/y ear $ 70 /hour Startup Cost Cost Respondents Cost/Y ear CEEs from U.S.

- Based Operators : 1. Post CEE receipt on W WW, provide copies to interested Federal agencies and publi c, if requested 2. Prepare/publish FR notices for receipt of draft CEE and NOA for final CEE; copy and transmit final CEE to Parties 3. Review draft CEE and any public comments, provide comments to and consult with operator 4. Provide copies of revised/fin al CEE to interested Federal agencies and public, if requested, and to Parties, review, and notify operator, if necessary 5. Maintain file

Post

- Expedition Assessment & Verification 1. Review A/V information

- CEE

135

Post

- Exp A/V

30

165 CEE

$ 9 , 450

Post

- Exp A/V
$ 2 , 100

$ 1 1 , 550 CEE

None

Post

- Exp A/V

None CEE

Copy ing $1710 FR Pub. 326 Store Files 10*

____________

_ $2046* *Includes CEE and A/V Information

Post

- Exp A/V
Copy ing $ 30 FR Pub. 0 Store Files *

____________

_ $ 30 * Included above $2,076 1 $ 1 3 , 626

YEAR ONE 165 $1 3 , 626 YE AR TWO (3.5% estimated CPI escalation rate on $12,590) 165 $1 4 , 103 YEAR THREE (35% estimated CPI escalation rate on $13,031) 165 $1 4 , 597 TOTAL ESTI MATED POTENTIAL BURDEN and COST: 495 $ 42 , 326 AVERAGE EST. BURDEN and COST PER YEAR PER OPERATOR: 165 $1 4 , 1 09 Assumptions: 1. Exhibit 2C represents the estimated hours and cost for CEEs. In fact, no CEEs were submitted during the ten austral summ er seasons the Rule has been in effect. For purposes of estimating the potential maximum hours and cost associate d with CEEs over the three

- year life of the ICR, the three

- year projection assumes submittal of one CEE per year for each of the next three years. Although one respondent per year is estimated for purposes of the cost calculations, EPA anticipates that th e actual number of nongovernmental expeditions with activities that will likely proceed with less than minor or transitory im pacts may

well be reduced to less than one respondent per year.

### 62

2. Estimates for review of a CEE is estimated as 50% of the respon dent's time, or 120 hours, to prepare a CEE that would be in compliance with the Final Rule at Section 8.4, preparation of en vironmental documents, generally, and Section 8.8, comprehensive environmental evaluation, with an additional 15 hours for administ rative activities, and 50% of respondent's time for assessment and verification procedures for review of the information. 3. EPA would publish Federal Register notices for domestic CEEs, and the Department of State would publish the Federal Regist er notice and circulate copies of CEEs to all Parties and others that may request copies.

### 63 Exhibit 2D: Reporting for Em ergencies
- Estim ated Federal Governm ent Hours and Cost

Federal Gov't. Federal Gov't. Capitol/ O & M No. of Tot al ICR Activity: CEE hours/y ear $ 70 /hour Startup Cost Cost Respondents Cost/Y ear Reporting for Cases of Emergency 1. Notify Parties 2. Provide initial and full report to interested Federal agencies and review 3. Provide full r eport to Parties 4. Review A/V information 5. Maintain files

165 $ 1 1 , 550 None Copy ing $1740 FR Pub. 0 Store Files 10

____________

_ $1750 1 $ 10,660 1,750

_______

_ $1 3 , 300

YEAR ONE 165 $1 3 , 300 YEAR TWO (3.5% estimated CPI escalation rate of $12,410) 165 1 3 , 766 YEAR THREE (3.5% estimated CPI escalation rate for $12,845) 165 1 4 , 248

Assumptions: 1. Repor ting for Cases of Emergency is based on the Final Rule at Section 8.10, Cases of emergency, which would require notice and re porting for activities taken in cases of emergency which would have otherwise required the preparation of a CEE. The estimate is b ased on reporting requirements only, not the actual cost of the emergency response action. The hours and cost estimate assum es one such emergency per 10 years. 2. Only one incident requiring emergency reporting is estimated to occur over a 10

- year period . I n fact, there was no emergency reporting during the seven austral summer seasons the Rule has been in effect. An inciden t requiring emergency reporting could occur in the subsequent years. The cost estimates for reporting for cases of emergency a re n ot additive because only one such emergency in 10 years is estimated. 3. Estimates for review of an Emergency Report is estimated as 50% of the respondent's time to prepare the Emergency Report t hat would be in compliance with the Final Rule at Section 8.1 0, or 120 hours, and 50% of respondent's time for assessment and verification procedures for review of the information, or 30 hours, with an additional 1 5 hours for administrative activities. 3. The Department of State is responsible for notification of Pa rties and follow

- up coordination with the Parties; hours have been allocated to the DOS accordingly.

### 64 Exhibit 2E: Coordinating Review of Inform ation Received from Other Parties
- Estim ated Federal Governm ent Hours and Cost

Federal Gov't. Federal Go v't. Capitol/ O & M No. of Total ICR Activity: Other Party Docs. hours/y ear $ 70 /hour Startup Cost Cost Respondents Cost/Y ear Coordinate Review of Information Received from Other Parties 1. Prepare and publish FR notice of receipt of draft CEE, provide copies to interested Federal agencies and public, if requested 2. Review draft CEE and provide inter

- agency response to Party 3. Provide copies of other documents (including final CEEs, annual list of IEEs , national procedures, significant monitoring information) to interested Federal agencies and public, if requested 4. Post receipt of significant monitoring information on W WW and provide copies to interested Federal agencies and public, if requested 5. M aintain files 110 $7, 700 None Copy ing $ * FR Pub 326 Store Files 10

____________ $ 336 * Copy ing per document: Draft CEE $360 Final CEE 180 Other doc. 50 IEE list 10 See:

Assum. 2, below See:

Assum. 2, below

Assumptions: 1. The Department of State would be responsible for compliance with the Final Rule at Section 8.12, Coordination of reviews from other Parties. 2. The calculatio ns in Exhibit 2E are based on receipt of a CEE from another Party . One Draft CEE was received from other Parties during the ten austral summer seasons the Rule has been in effect other than the annual list of IEEs. There is no way to anticipate receipt o f environmental documents from the Parties, other than the annual list of IEEs, on an annual basis. There is no burden or co st to the respondents associated with receipt of documents from the Parties, therefore, the costs are not further defined.

### 65 Exhibit 3: SUMMARY
- ESTIMATED RESPONDENT/FEDERAL GOVERNMENT HOURS AND COST CHART 1: Summary for Respondents and Federal Government

- Estimated Total and Annual Average hours and cost for each type of environmental document that is submitted by a Respondent u nder the Final Rule PERM Core IEE Revised IEE Subsequent Year Multi

- Year IEE CEE Emergency Reporting Respondent Year 1 Year 2 Year 3 TOTAL Annual Average 40 $ 3,079

40 $ 3,187 40 $ 3,298 120 $ 9,564 40 $ 3,188 185 $14,176

185 $14,672 185 $15,186 555 $44,034 185 $14,678 65 $ 5,176

65 $ 5,357 65 $ 5,544 195 $16,077 65 $ 5,359 30 $ 2 , 297

30 2 , 377 30 2 , 460 90 $ 7 , 134 30 $ 2 , 378 300 $ 22,906

300 $ 23,708 300 $ 24,538 900 $ 71,152 300 $ 23,717 300 $22,724

300 $23,519 300 $24,342

Federal Government Year 1 Year 2 Year 3 TOTAL Annual Average 12 $ 8 80 12 $ 911 12 $ 943 36 $ 2, 734 12 $ 911 96 $ 7 , 006

96 $ 7 , 251 96 $ 7 , 504 288 $2 1 , 761 96 $ 7 , 254 56 $ 4 , 206

56 $ 4, 353 56 $ 4, 505 168 $1 3 , 064 56 $ 4, 355 16 $ 1, 120

16 $ 1, 159 16 $ 1, 200 48 $ 3, 479 16 $ 1, 159 165 $ 1 3 , 626

165 $ 1 4 , 103 165 $ 1 4 , 597 495 $ 42 , 326 165 $ 1 4 , 109 165 $1 3 , 300

165 $1 3 , 766 165 $1 4 , 248

TOTAL Annual Average 156 $12, 298

52 $ 4,0 99 843 $6 5 , 795

281 $21, 931 363 $2 9 , 141

121 $ 9, 714 1 38 $ 10 , 613

4 6 $ 3, 538 1395 $11 3 , 478

465 $ 3 7 , 826 CHART 2: Summary for Respondents and Federal Government

- Estimated total hours and costs for Multi

- Year IEE as the anticipated level and type of environmental document mo st respondents submit under the Final Rule for the 3

- year ICR renewal (Year 1 = "Revised" IEE, Years 2 and 3 = "Subsequent Year Multi

- Year" IEE)
Multi

- Year IEE Total Hours 3

- Year T otal Annual 3

- Yr Average Total Cost 3

- Year Total Annual 3

- Yr Average Respondent (for one operator) 1 25 hours 42 hrs per op per yr $ 10 , 115 $ 3, 372 per operator per year Federal Government (for one op.) 88 hour s 29 hrs per op per year $ 6, 673 $ 2, 224 per op per year TOTALS

- For one operator 2 1 3 hours 71 hrs per op per yr $ 1 6 , 366 $ 5, 456 per op per year NOTES: Annual Average is the average per respondent per year. Chart 1 presents the maxi mum hours and cost for a respondent. Chart 2 presents the maximum hours and cost based on the anticipated level and type of environmental document a respondent would likely submit under the Final Rule. The $75/hour intermediate rate is used for sum mary p urposes. The hours and cost estimates for Emergency Reporting assume one such emergency per 10 years.

### 66 CHART 3: Summary for Respondents and Federal Government

- Estimated hours and costs for environmental documentation for 3

- year period of this ICR renewa l. Summary assumes 2 2 operators per year w ith 5 new operators and 1 7 repeat operators each year. For the 1 7 repeat operators, the assumptions are that 3 will prepare "Revised" IEEs and 1 4 will prepare "Multi

- Year" IEEs. For Chart 3, the calculations use the "Annual Average" from Chart 1for "Core," "Revised," and "Subsequent Year, Multi

- Year" IEEs and the hours and cost in Chart 2 for the "Multi

- Year" IEE. Operators: 2 2 operators each year for the 3

- year ICR renewal period Respondent Burden Hours Cos t Federal Government Burden Hours Cost 5 new operators submit "Core" IEEs each year Burden per year Total 3

- year burden 185 x 5 = 925 $14,678 x 5 = $ 73,390 925 x 3 = 2,775 $73,390 x 3 = $220,170 96 x 5 = 480 $ 7 , 254 x 5 = $ 3 6 , 270 4 80 x 3 = 1,440 $3 6 , 270 x 3 = $10 8 , 810 3 of 1 7 repeat operators submit "Revised" IEEs each year Burden per year Total 3

- year burden 65 x 3 = 1 95 $ 5,359 x 3 = $ 1 6 , 077 1 95 x 3 = 585 $ 16,077 x 3 = $ 48 , 231 56 x 3 = 168 $ 4, 355 x 3 = $ 13 , 065 1 68 x 3 = 504 $ 13 , 065 x 3 = $ 39 , 195 1 4 of 1 7 repeat operators submit new "Multi

- Year" IEEs Burden per year Total 3

- year burden 42 x 1 4 = 58 8 $ 3, 372 x 1 4 = $ 4 7 , 2 08 58 8 x 3 = 1 764 $4 7 , 2 08 x 3 = $ 14 1 , 624 29 x 1 4 = 4 06 $ 2, 224 x 1 4 = $3 1 , 136 4 06 x 3 = 1 218 $3 1 , 136 x 3 = $ 93 , 408 ANNUAL TOTAL BURDEN for 2 2 operators ANNUAL TOTAL BURDEN per operator TOTAL 3

- YEAR BURDEN for 2 2 operators TOTAL 3

- YEAR BURDEN per operator 1, 708 $13 6 , 675 7 8 $ 6,213 5 , 124 $40 9 , 975 2 33 $ 1 8 , 635 105 4 $ 80 , 471 4 8 $ 3, 658 3,16 2 $ 2 41 , 413 1 44 $ 10 , 973

### 67 EXHIBIT 4: SUMMARY FOR RESPONDENTS AND FEDERAL GOVERNMENT
- O&M COSTS Estimated O&M costs for Respondents and the Federal Government and O&M breakout within the total cost burden. Operators: 23 operators each year for the 3

- year ICR renewal period Respondent Burden O&M Cost O&M + Labor = Total Cost Fede ral Government Burden O&M Cost O&M + Labor = Total Cost 5 new operators submit "Core" IEEs each year Burden per year Total 3

- year burden $ 301 x 5 = $ 1,505 $1,505 + 71,885 = $ 73,390 $1,505 x 3 = $ 4,515 $4,515 + 215,655 = $220, 170 $ 271 x 5 = $1,355 $ 1,355 + 3 4 , 915 = $ 3 6 , 270 $1,355 x 3 = $4,065 $ 4,065 + 104 , 745 = $10 8 , 810 3 of 1 7 repeat operators submit "Revised" IEEs each year Burden per year Total 3

- year burden $ 301 x 3 = $ 903 $ 903 + 1 5 , 1 74 = $ 1 6 , 077 $ 903 x 3 = $ 2 , 709 $ 2 , 709 + 45 , 522 = $ 48 , 231 $ 271 x 3 = $ 813 $ 813 + 12 , 252 = $ 13 , 065 $ 813 x 3 = $ 2 , 439 $ 2 , 439 + 36 ,7 56 = $ 39 , 195 1 4 of 1 7 repeat operators submit new "Multi

- Year" IEEs 47 Burden per ye ar Total 3

- year burden $ 132 x 1 4 = $ 1 , 848 $ 1 , 848 + 4 5 , 360 = $ 4 7 , 208 $ 1 , 848 x 3 = $ 5 , 544 $ 5 , 544 + 1 36 ,08 0 = $ 14 1 , 6 24 $ 111 x 1 4 = $ 1 554 $ 1 554 + 31,568 = $ 3 1 , 136 $ 1 554 x 3 = $ 4 , 662 $ 4 , 662 + 94,704 = $ 93 , 408

ANNUAL TOTAL BURDEN for 2 2 operators ANNUAL TOTAL BURDEN per operator TOTAL 3

- YEAR BURDEN for 2 2 operators TOTAL 3

- YEAR BURDEN per operator O&M Labor Total Cost $ 4,2 56 + 1 32 , 419 = $13 6 , 675 $ 1 93 + 6 , 019 = $ 6 , 212 $12, 768 + 3 97 , 257 = $401, 025 $ 5 8 0 + 1 8 , 057 = $ 1 8 , 637 O&M Labor Total Cst $3, 722 + 7 8 , 735 = $ 82 , 457 $ 16 9 + 3, 579 = $ 3, 748 $11, 166 + 2 36 , 205 = $2 47 , 371 $ 508 + 10 , 737 = $ 11 , 245

47 New "Multi

- Year" IEE includes "Revised" IEE in the first year and "Subsequent Year, Multi

- Year" IEE in years 2 and 3. The average cost for the three year period of the ICR renewal is used in the calculations in Exhibit 4. For the total three years: Respondent $301 + (2 x $47) = $395 Federal Government $271 + (2 x $31) = $333 Average for the three years: Respondent $395  3 years = $132/year Federal Government $333  3 years = $111/year

###   1 PART B OF THE SUPPORTING STATEMENT

STATISTICAL SURVEY
This collection of information does not use or is otherwise based on a statistical survey

.