DRAFT SUPPORTING STATEMENT

– INFORMATION COLLECTION REQUEST (ICR) Federal Implementation Plans t o Reduce Interstate Transport of

Fine Particulate Matter and Ozone ( Final Rule)

1. 0 I dentification of the Information C ollection

1.1 Title of the Information Collection

Federal Implementation Plans to Reduce Interstate Transport of Fine Particulate Matter

and Ozone , EPA ICR Number 239 1.0 2 , OMB Control Number 2060

- NEW

.

1.2 Short Characterization/Abstract

The United States (U.S.) Environmental Protection Agency (EPA) is finalizing Federal Implementation Plans to Reduce Interstate Transport of Fine Particulate Matter and Ozone (Transport Rule) that will supersede the Clean Air Interstate Rule (CAIR) . It includes new reporting requirements

, and combines these new requirements with existing requirements from

the Emission Reporting Requirements for Ozone State Implementation Plan (SIP) Revisions Relating to Statewid e Budgets for NO X Emissions to Reduce Regional Transport of Ozone ( NO X SIP Call) and the Acid Rain Program (ARP) under Title IV of the C lean A ir A ct (CAA)

Amendments of 1990. Each of these existing requirements has an approved ICR in place

. The

current I CRs are : CAIR ( EPA ICR Number 2152.04/ OMB Control Number 2060

- 0570)

, NO X SIP Call ( EPA ICR Number 1857.0 5 / OMB Control Number 2060

- 0445) and ARP ( EPA ICR

Number 1633.15 / OMB Control Number 2060

- 0258)

.

Thi s supporting statement and ICR are being submitted to account for the incremental

burden associated with the Transport Rule (TR) as it supersedes CAIR beginning in 2012

. As such, this supporting statement references the burden analysis include d in EPA ICR Numbers

2152.0 4

, 1857.0 5

, and 1633.1 5

, and estimates the change in burden resulting from the TR beyond the scope of the existing ICRs for the NO X SIP Call requirements and the Acid Rain Program

. The burden included in this ICR includes start

- up and capital costs for units newly

affect ed by an emissions trading program and/or whose reporting status has changed (e.g.

, from ozone season only to annual reporting)

, annualized capital costs for units previously subject to

the NO X SIP call requirement s or CAIR, as well as the incremental oper ation and maintenance

costs for all TR

- affected units. Under the TR , the burden and costs a ccounted for under the CAIR ICR ( EPA ICR Number 2152.04) would no longer occur past 2011

. Instead, all those burdens and costs would be accounted for under this ICR as part of T R implementation.

In addition to the state s and facilities li sted in the actual rule text, EPA h as included

costs/burdens associated with TR ozone season

- affected unit s for the following s tate s: IA , KS, MI, MO, OK, and WI. The TR NO X O zone S eason T rading P rogram does not list these s tate s in

the current rule package, however EPA propos es to add them as part of a future supplemental rule package to the Transport Rule

. In anticipation of this ru l emaking, the costs/burdens

associate d with these facilities are included in the ICR to allow for a full accounting of the TR program at maturity. See Appe n dix A for a separate breakout of the cost/burdens associated withTransport Rule ICR May 9, 2011

2 these f acilities. In the event that some or all of these s tate s are not included in the future rulemaking, EPA will amend this ICR accordingly.

EPA has publish ed a Notice of Proposed Rulemaking in the Federal Re gister that detail s the additions and changes to r eporting requirements associated with the TR

. These changes can be logically divided in to two categories: ( 1 ) c hanges to existing requirements for emission reporting under the previous CAIR and NO X SIP Call

, and ( 2 ) t he addition of reporting requirements t o support emissions trading and compliance in s tates covered by the TR

. Throughout this Supporting Statement, the burden analysis associated with these two categories will be discussed sequentially as " Emission Reporting Requirements " and " E mission Trading Requirements. "

Emission Reporting Requirements

Taken together, the existing emission reporting requirements under CAIR, the Acid Rain Program , and the previous NO X SIP Call cover many of the same sources and have similar or

identical emission reporting requirements as the TR

. The incremental burden imposed by the TR in general is described below.

First, sources located in Georgia and Texas are now required to report NO X emissions during the five

- month ozone season, in addition to the existing requirement for reporting emissions for the full year

. These states are not among the 21 s tates previously subject to the

NO X SIP Call or the 26 state s subject to CAIR ozone season (CAIROS) reporting and as a result, these changes will require sources to modify DAHS reporting software.

Second, sources located in Mississippi, Florida, and Louisiana

, which under CAIR were required to report NO X and SO 2 emissions annually, are now only required to rep ort NO X for the

TR ozone season

. This requirement would not impose any additional start

- up/ capital burden on

s tate s, and is a reduction in reporting for sources subject to CAIR

.

Third, sources located in Kansas, Minnesota , Nebraska, and Oklahoma are now affected

under the TR. Specifically

, sources in Minnesota and Nebraska are subject to TR NO X and SO 2

a nnual reporting, sources in Oklahoma are subject to TR NO X o zone season reporting, and sources in Kansas are subject to both the TR NO X and SO 2 a nnu al and NO X o zone season reporting requirements. These sources were not previously subject to CAIR or the NO X SIP Call

, and will need to install and operate CEMS (or an approved alternative) and meet 40 CFR p art 75 requirements for NO X and SO 2

, as applicab le.

Fourth, sources located in Alabama, Illinois, Iowa, Indiana, Kentucky, Maryland, Missouri, Michigan, New Jersey, New York, North Carolina, Ohio, Pennsylvania, South Carolina, Tennessee, Virginia, West Virginia, and Wisconsin will continue to monitor and report

NO X and SO 2 emissions on a year round b asis under the TR as currently required under CAIR.

Sources located in Arkansas will , under the TR, continue to report for the o zone season only as currently required under CAIR.Transport Rule ICR May 9, 2011

3 Emission Trading Requirements

For this ICR, it is assumed that each s tate will eventually either adopt , in whole or in part,

the relevant TR SO 2 , NO X annual

, and /or NO X ozone season trading rules . Initially, however,

EPA will administer the program s under the Federal Implementation Plan s (FIP) promulgated at

40 CFR Part 97. The trading program burden would include the paperwork burden related to (1) transferring and tracking allowances; ( 2 ) permitting; ( 3 ) annual y ear end compliance ; and ( 4 )

monitori ng and reporting starting in 2014

. The monitoring and reporting requirements of a trading program will require capital and labor expenditures by industry, and these are evaluated

,

as are labor expenditures accrued by states and EPA, in managing the tradin g programs.

Similar to the ARP

, the NO X SIP Call , and CAIR , the ability to buy and sell (or transfer) allowances is expected to provide some economic benefits

. Allowance trading cannot be implemented, however, unless regulations governing emissions monitoring and permitting of sources are in place as well

. To ensure compliance with the state

- specific e mission reduction requirements and to provide the consistency needed to foster the allowance market, the designated representative s of the owners and operators of each source with affected units are required to have TR requirements integrated into their Title V permits for the affected source and to certify that an approved NO X and SO 2 emissions monitoring system has been installed and is properly opera ted at each affected unit. Emissions data reported under 40 CFR part 75 by TR

affected sources is also relied upon in part by the Agency in determining allowance allocations to

such TR

- affected sources.

While many sources have already installed the necessary emissions monitoring equipment due to requirements under other regulations, some sources will need to install new monitors or upgrade existing monitors. Capital costs also usually include the cost of initial

certification of new or upgraded moni tors , and this is included as part of start

- up costs. Capital costs addressed by this ICR include costs borne by newly affected units under the TR and annualized capital costs for existing CAIR or NO X SIP Call units that are not subject to the ARP

.

Emi ssions monitoring and reporting by sources in the trad ing program s is fundamental to the allowance trading system an d compliance with the TR

. EPA will use the data contained in the reports to verify actual emissions

. Without accurate monitoring and reporting of emissions

, the integrity of the allowance system would be undermined, and there would be no assurance that

emissions had been reduced

. To meet the emission s monitoring, recordkeeping and reporting requirements, affected units are required to : ( 1) submit a monitoring plan and certification

reports for each monitoring system, (2) record hourly emissions data, and (3) submit reports of

their emissions and operating data to EPA

. All sources affected by the TR will be required to monitor and repo rt NO X and/or SO 2 emiss ions in accordance with 40 CFR p art 75

. Sources with monitors already certified under 40 CFR part 75 may be exempt from initial certification requirements.

All participants in the Allowance Management S ystem (AMS) are required to e ither

c omplete and submit an allowance transfer form for each allowance transfer

, or to perform the

transfer on

- line

. Part icipants in AMS that are not cover ed sources, such as allowance brokers,Transport Rule ICR May 9, 2011

4 fuel suppliers

, and environmental groups are also required to file a one

- time account information application to establish accounts i n AMS

.

2. 0 N eed for and U se of the C ollection

2.1 Need/Authority for the Collection

Emissions data are of vital importance to the EPA for fulfilling a host of monitoring,

standard

- setting, rulemaking, reviewing, and reporting duties

. Section 110(a)(2)(D) of the CAA, often referred to as the “good neighbor” provision of the Act, requires states to prohibit certain emissions because of their impact on air quality in downwind states. Specifically, it requires all states, within 3 years of promulgation of new or revised NAAQS, to submit SIPs that prohibit certain emissions of air pollutants because of the impact they would have on air quality in other

states. This action addr esses the requirement in section 110(a)(2)(D)(i)(I) regarding the prohibition of emissions within a state that will significantly contribute to nonattainment or interfere with maintenance of NAAQS in any other state. EPA has previously issued two rules

in terpreting and clarifying the requirements of section 110(a)(2)(D)(i)(I). The NO X SIP Call, promulgated in 1998, was largely upheld by the U.S. Court of Appeals for the D.C. Circuit in Michigan ( 213 F.3d 663 ) . CAIR, promulgated in 2005, was remanded by t he D.C. Circuit in North Carolina ( 531 F.3d 896 )

, and modified on rehearing

, ( 550 F.3d. 1176 ) . These decisions provide additional guidance regarding the requirements of section 110(a)(2)(D)(i)(I) and are

discussed later in this notice.

Section 301(a)(1) of the CAA also gives the Administrator of EPA general authority to prescribe such regulations as are necessary to carry out her functions under the Act

, 42 U.S.C. § 7601(a)(1). Pursuant to th is section, EPA has the authority to clarify the applicability of CAA requirements. In this action, among other things, EPA is clarifying the applicability of section 110(a)(2)(D)(i)(I) by identifying NO X and SO 2 emissions that must be prohibited with respect to

the PM 2.5 NAAQS promulgated in 1997 and 2006 and the 8

- hour ozone NAAQS promulgated in 1997. In addition, section 110(k)(1)(A) calls for the Administrator to establish criteria for determining whether SIP submissions are complete

, 42 U.S.C. sec. 7410(k)(1)(A). Among other things, this action helps to clarify what SIP submissions must contain to address the requirements of section 110(a)(2)(D)(i).

Section 110(c)(1) of the Act also requires EPA to act in certain circumstances where state SIP deficiencies exist, regardless of the reason for the deficiency. EPA action may be required even if the SIP deficiency is not in any way the fault of the affected state, such as, for example, if the deficiency is caused by factors beyond the state’s control. Specifically, section 110(c)(1) requires the Administrator to pr omulgate a FIP at any time within two years after the

Administrator finds that (1) a s tate has failed to make a required SIP submission ; or (2) a SIP

submission is incomplete ; or (3) the Administrator disapproves a SIP submission . The Administrator must promulgate a FIP in the above

- described scenarios unless the s tate corrects the deficiency and the Administrator approves the SIP revision before the Administrator promulgates the relevant FIP

. 42 U.S.C. sec. 7410(c)(1).Transport Rule ICR May 9, 2011

5 2 .2 Practical Utility/Users of the Data

Emission Reporting Requirements

Emission s data and related information on stationary point and nonpoint sources, as well

as non

- road mobile and on

- road mobile sources, are routinely used by OAP, OAQPS, and the

EPA Reg ional Offices in carrying out a variety of activities

. These activities support regulatory functions as well as functions that are more programmatic in nature such as trends analyses

. Such projects include:

● Evaluation of existing control strategies, such as the NO X SIP Call, for s tates and larger

areas;

● Evaluation of proposed contr ol strategies for s tates and larger areas, including applications of regional scale models;

● Development of national control strategies and preparation of Regulatory Impact Analyses (RIA s );

● Preparation and publication of national summaries of emissions

, including trend analyses;

● As a data base to assist in the identification of important source categories for future regulation; and

● Preparation of the stationary source portion of a report to Congress on SO 2 emissions

. This report is required by Section 406 of the CAA and is due on a five year cycle that began on January 1, 1995

. The report must contain an inventor y of national annual SO 2 emissions from industrial sources (as defined in Title IV of the CAA).

EPA ' s Office of Research and Development (ORD) uses emission source data in determining priorities for control technology research and as a key data component in the application of regional scale models

. The EPA ' s Regional Offices use emission and other source parameters to support source inspections and in the analyses of the impact of new or modified

sources within an area

. EPA ' s Emission Factor and Invento ry Group (EFIG) use the data to assess and analyze trends in criteria pollutant emissions over time.

In addition to supporting projects and initiatives inte rnal to EPA, both OAQPS

, and the Regional Offices respond to numerous requests for reports on emiss ion s from sources

. Typically

this is done under the Freedom of Information Act

. Most requests come from contractors and consultants involved in special studies; a smaller number come from the press, universities

, and

others involved in research.

The col lection of emissions data specific to nonattainment areas for certain criteria air pollutants is necessary to comply with requirements specified in Title I of the CAA

. States withTransport Rule ICR May 9, 2011

6 nonattainment areas rely on current emissions informati on from point, nonpo int, and mobile

sources to revise their SIPs and to plan for emission reductions mandated by the CAA

. In addition, a s tate

- wide inventory compiled at least every three years for all point, nonpoint, and

mobile sources is considered to be a key tool to assist s tates in meeting CAA requirements that address emissions tracking, compliance issues, and mid

- course adjustments

. State

- wide emission inventories can be used by s tates affected by pollution transport from upwind areas to develop more efficient con trol strategies to meet NAAQS

. State

- wide emission inventories that were developed by EPA (the N ational E missions I nventory, or NEI ) are being used by the Regional Planning Organizations (RPOs) as the starting point for the development of s tate

- wide

emiss ion inventories used in the regional haze program to define control strategies.

Emission Trading Requirements

Permit applications, including pr oposed compliance plans, are us ed by s tates and EPA to issue operating permits

. A permit application is legall y binding on the owners, operators, and designated representative of a source until the permit is issued

. Affected sources rely on the permit for information regarding the applicable requirements with which they must comply

. Because permit applications and permits are public documents, they may be used by the public to examine activities undertaken by affected sources.

Accurate d ata from emissions monitoring under 40 CFR part 75 is indispensable to successful implementation of the trading programs for t wo reasons:

● Accurate emissions data is integral in EPA and state assessment of the impact of the trading programs in reducing NO X and SO 2 emissions, and therefore in assist ing s tates in meeting the ozone and fine particulate matter NAAQS. By reducing levels of NO X and

SO 2 emissions, the trading programs reduce the adverse effects of the transport of ozone,

ozone precursors
, and fine particles from upwind s tates

.

● EPA enforce s the program (in part) by comparing emissions data measured, recorded,

and r eported under 40 CFR part 75 from affected sources with the number of allowances

held in the respective compliance accounts of such affected sources

.

Information collected on allowance transfers is used by EPA to track allowances for the purpose of determining compliance with the NO X and SO 2 t rading p rograms

. Information on allowance transfers is also used by participants in the allowance market and the public to evaluate the activities of affected sources, and by EPA f or program evaluation.

Toge ther, the AMS , operating permits, and emission s data help to provide the accountability to allow the NO X and SO 2 trading p rograms to function without more stringent command and control approaches.Transport Rule ICR May 9, 2011

7 3. 0 N onduplication , C o nsultations

, and Other C ollection C riteria

3 .1 Nonduplication

Emission Reporting Requirements

EPA will allow the direct reporting of point source data from sources to EPA to satisfy

the requirement for s tates to report such data if the sources are subject to the monitoring and

re porting requirements of 40 CFR p art 75. The direct reporting of data from sources to EPA will

mi nimize the reporting burden on s tates. Also, direct reporting will avoid duplication of effort for sources subject to 40 CFR part 75 requirements.

Emission Trading Requirements

Reporting requirements for affected sources for the TR NO X and SO 2 t rading p rograms are i ntegrated with existing reporting formats under 40 CFR part 75

. The se reporting formats are currently used by ARP

- affected units under Title IV of the Act

, as well as by CAIR

- affected

units. Thus, for units subject to Acid Rain or TR quarterly reporting requirements, or both, only

one submission will need to be made on a quarterly basis

. ( CAIR trading pr ogram re porting will be superseded by TR reporting.)

3.2 Public Notice Required Prior to ICR Submission to OMB

The preamble to the proposed rule w as provide d to the public with notice of and the opportunity to comment on this ICR.

3 .3 Consultations

Emission Reporting Requirements

During the development of CAIR, d iscussions were held with the National Association of Clean Air Agencies (NACAA) to clarif y EPA ' s logic in developing the emissions reporting requirement s contained within the rule and to answer que stions. Information ari sing from those discussions, as well as the decision handed down in the North Carolina v. EPA court case related

to CAIR (531 F.3d at 908) , were taken into consideration when developing the TR emission reporting requirements

.

Emission Trading Requirements

The requirements for the TR have been developed using the methodology found in existing trading programs

, consultations with interested parties , and reflections on the decision

handed down in the North Carolina court case (53 1 F.3d at 908)

. EPA modified the cap and trade strategy used in the ARP , Ozone Transport Commission ' s NO X Budget Program, and the

NO X SIP Call to address the court ' s concerns related to " emissions from sources that contributeTransport Rule ICR May 9, 2011

8 significantly and interfere with maintenance " in another s tate

. North Carolina (531 F.3d at 908). This resulted in the development of an unlimited intrastate and limited interstate trading program

based on state

- specific budgets rather than regional caps.

EPA held two workshops wi th s tate s that participated in the NO X SIP Call or OTC programs to discuss lessons learned in those programs when formulating the emissi on trading requirements of CAIR

. Additionally, EPA has had frequent interaction with affected sources and

s tate s in the course of implementing the Acid Rain

, NO X SIP Call , and CAIR Trading Programs

. In 2009, EPA held a series of conference calls and meetings with stakeholders to identify potential options for addressing the North Carolina v. EPA court decision

. EPA has r eceived comments following the workshops and through other interactions and considered and incorporated those comments into the TR and this ICR.

Finally, as part of updating the ICR for the ARP monitoring requirements (40 CFR part 75) , EPA contacted vario us affected parties to ga ther information on CEM capital costs, CEM operation and maintenance costs, fuel meter capital costs, and CEM/fuel meter testing costs

. That information has been used in this ICR , as appropriate.

3.4 Effects of Less Frequent Collection

Emission Reporting and Trading Requirements

Submittal o f allowance trading and emissions information on an annual basis (and/or on

an ozone

- season basis, as applicable) provides the data necessary to determine whether state
b udgets have been exceede d

. If this information collection were not carried out annually for

sources subject to the TR , EPA would not be able to verify that emission red uctions necessary to

meet each s tate ' s NO X and SO 2 emission budgets were being achieved

. Because the NO X and

SO 2 budgets prescribed have been deemed essential in order to aid downwind s tates in attaining the NAAQS in a timely manner, data collected less frequently would be of little or no use.

Quarterly collections of emissions data allows for frequent check ing of data for errors

and provide s rapid feedback to industry of needed adjustments to data collection systems, thereby promoting more accurate and reliable emissions data

. Also , existing federal and s tate
emission monitoring programs often require quarterly reporting, or in some cases, monthly

. Less frequent collection, such as semi

- annually or annually, would increase the amount of preparation

and review time at the end of the reporting period both for regulated sources and for EPA

, and would slow down the process of compliance determination

.

3 .5 General Guidelines

This ICR does not violate any of OMB ' s guidelines for information collections.

3 .6 Confidentiality

Any data that is submitted to EPA under this rule will be considered in the public domain

and cannot be treated as confidential.Transport Rule ICR May 9, 2011

9 As required by Section 114 of the CAA , estimates or measurements of emissions must be

treated as non

- confidential

. Under Agency procedures, data items relating to the computation of

e missions may be identified as sensitive by a s tate and are then treated as " s tate

- sensitive " by

EPA

. The potentially s tate

- sensitive items include the following: Process rate, boiler design capacity, emission estimation codes, percent space heat, operatin g rate, and maximum operation

rate/hour

. Where f

ederal and s tate requirements are inconsistent, the appropriate EPA Regional

Office should be consulted.

3 .7 Sensitive Questions

This information collection does not ask any questions concerning sexual behavior or attitudes, religious beliefs, or other matters usually considered private.

4. 0 T he R espon d e n ts and the I nformation R equested

4.1 Respondents/Standard Industrial Classification (SIC) Codes

Emission Reporting and Trading Requirements

This ICR estimates a burden for affected industry sources to monitor NO X and SO 2 mass emissions and demonstrate compliance with NO X and SO 2 control measures

. Sources report data directly to EPA as required to meet the monito ring and reporting requirements of 40 CFR p art
75

. This rule affects large el ectric utility sources which are generally classified as either SIC

4911

- Electric Services, or 4931

- Electric and Other Services Combined [NAICS 221112 Electric Power Distribution].

4.2 Information Requested

Emission Reporting Requirements

The ARP and NO X SIP Call established the basic emission reporting requirements

. CAIR modified these requirements and the TR would continue to impleme nt the changes

included in the CAIR requirements such that the previously accounted for reporting burden would also change

. Only the incremental changes to the ARP and NO X SIP Call reporting requirements that would change reporting burden are discussed here.

Emission Trading Requirements

This section describes the data items requested from affected sources for the collections

described in this ICR

. This section also defines the activities i n which respondents must engage

to assemble, submit, or store these data items.

(i) Data Items, Including Recordkeeping R equirements

(a) Allowance TrackingTransport Rule ICR May 9, 2011

10 There are several data items required for allowance tracking activities

. For each affected

source , the designated representative must submit a certificate of representation

. Under 40 CFR §§ 97.41 6

, 97 .51 6

, 97. 61 6 , an d 97.716 , a complete certificate of representation include s :

● Identi fication of the source and unit;

● Dates on which the unit commenced commercial operation;

● Name and contact information for the TR designat ed representative and alternate (if applicable) ;

● A list of the owners and op erators of each unit; and

● A certification statement and signature of the TR designated representative and alternate (if applicable)

.

Certification applications are to be kept for a period of five years pursuant to the general requirements imposed for Title V permitted facilities.

Second, sources and other trading program participants must submit allowance transfer, allowance deduction, and compliance assurance information, as necessary.

(b) Pe rmitting

The basic requirement for permitting is an application for a permit revision to a source ' s operating permit issued under Title V of the Act

. Although there is some possibility that a non

Title V source could be affected under the TR , all TR

- affected sources are assumed to be Title V sources for purposes of this ICR

. It is assumed t he permit revision application and all other monitoring, reporting

, or recordkeeping requirements associated with Title V permitting are either part of the baselin e Title V requirements or are covered separately under section 4(c)

. Title V permit applications must be kept for five years pursuant to Title V recordkeeping requirements

.

(c) Monitoring and Reporting

TR

- affected so urces are required to monitor NO X an d SO 2 mass emissions, and record and report emissions data using the requirements of 40 CFR p art 75

. The emissions monitoring requirements specify that affected sources must (1) submit a monitoring plan for each affected unit at a source, (2) submit data for cer tification of each monitor, (3) record hourly operational, pollutant monitor, and flow monitor data for each affected unit

, and (4) submit quarterly reports
of their emissions data to EPA.

Respondents are required under 40 CFR 75.64 to submit the q uarterly NO X and SO 2 mass emissions data via direct electronic submission to EPA . S uch data must include a certification statement by the designated representative of th e facility attesting to the accuracy, truthfulness,Transport Rule ICR May 9, 2011

11 and completeness of the submission

. Generally, a ll monitoring records are required to be kept for three years.

(ii) Respondent Activities

The primary tasks that will be performed by respondents to meet the em issions monitoring requirements are : (1) completing and su bmitting appropriate monitoring plan forms

for each affected source and each affected unit at a source; (2) conducting tests to certify monitors and submitting test resul ts to EPA; (3) recording hourly emissions data (this activity is generally performed e le ctronically); (4) performing operation and maintenance activities associated with monitoring, including quality assurance activi ties; (5) assuring data quality

, preparing quarterly reports of emissions data

, and submitting these reports to EPA; and (6)

r esponding to error messages generated by such submissions

. In addition, respondents will have to purchase the necessary monitoring hardware and electronic data reporting software (or software upgrades).

5. 0 T he I nformation C ollected

– A gency A ctivities

, C ollection Methods

, and I nformation Management

5.1 Agency Activities

Emission Reporting Requirements

The EPA activities associated with the rule include:

● Receiving, reviewing, and storing emission in ventory data submitted by each source ;

● Processing and updating data submitted by sources , including performing quality assurance of data, and coordination of efforts to resolve errors and anomalies; and

● Fulfilling information requests.

Emission Trading Requirements

The major EPA activities related to the TR include (1) allocation of allowances to affected units, (2) maintenance and administration of the NO X and SO 2 Allowance Management System , ( 3 ) reviewing and processing certificates of representation, (4) reviewing permit applications, ( 4 ) reviewing monitoring plans and certification applications, ( 5 ) processing, reviewing

, and evaluating reports of quarterly emission s data from affected units, ( 6 ) calculating/reviewing annual emissions from affected source s , and aggregating such annual

emissions for compliance ass urance purposes , and ( 7 ) reviewing total annual emissions data

submitted to track each s tate ' s progress toward meeting its budgets and creating a summary report of emissions. EPA use s a computer s ystem to track and maintain monitoring and

emissions information , and will also answer respondent questions and conduct audits of data

submissions.Transport Rule ICR May 9, 2011

12 5 .2 Collection Methodology and Management

Emission Reporting Requirements

The EPA has establish ed a central reposi tory of inventory data for all s tates termed the National Emissions Inventory (NEI) database

. Emissions inventory data reported electronically

is stored in the NEI database an d us ed by the EPA and by s tates for air modeling, tracking

prog ress in meeting CAA requirements, setting policy

, and answering questions from the public.

The EPA has created and maintains the NEI database as a central repository of inventory

data for all s tates, but the data must be supplied b y the s tates in an elect ronic form at

. The EPA currently requires that s tates use the Consolidated Emissions Reporting Schema (CERS) for electronic data reporting (EDR).

Emission Trading Requirements

To ensure consistency region wide and to expedite data entry, EPA requires that standard

formats used for reporting under 40 CFR part 75 be used to submit the information collected for

the TR

.

Several computer systems and associated databases have been developed to (1) track allowance activity , (2) record quarterly emissions mon itoring data, and (3) calculate the number

of allowances to be deducted each year

. The se systems and database s are designed to provide

easy access to information for use by the Agency, s tate s, regulated community, and general public.

The EPA has also est ablished a Clean Air Markets website , which includes detailed information collected from emissions reports

. Those without access to the i nternet may use the Clean Air Markets Hotline to request information, including summary reports

. The Agency will rely on these electronic means to disseminate information about the TR as the program is implemented.

5 .3 Small Entity Flexibility

Emission Reporting and Trading Requirements

The TR applies to fossil fuel

- fired units (stationary boilers and combustion turbines) that serve an electrical generator with nameplate capacity greater than 25 MWe

. Units with a lower capacity ( such as those with an annual generating capacity of less than four million kWh ) are not subject to the TR because of the high cost of mo nitoring emissions from these sources and the de

minimis nature of their emissions. In addition, some cogener ation units and solid waste

incinerators are exempt from the TR if they me e t certain criteria.

The low mass emissions provisions under 40 CFR 75.19 provide for optional reduced monitoring, quality assurance, and reporting requirements for units that combust natural gas

and/or fuel oil . Such units must emit no more than 100 tons of NO X annually, 50 ton s of NO XTransport Rule ICR May 9, 2011

13 during the ozone season (May 1

– September 30)

, 25 tons of SO 2 annually

, and calculate no

more than the se same amount s based on specified procedures for calculating and reporting

emissions

. Units that qualify are exempted from certain requirement s to install and operate monitoring equipment, conduct fuel sampl ing, and perform quality assu rance or quality control

tests

. Moreover, emissions reporting requirements are significantly simplified for these units.

G as

- or oil

- fired unit s that do not qua lify for the low mass emissions unit p rovisions

under 40 CFR part 75 may still meet criteria that allows for the use of alternative methods to

measure emissions

. As discussed in the R egulatory Impact Analysis of the final ARP regulations (October 19, 1992), smaller utilities are more like ly to be dependent on these oil

- and gas

- fired units, especially very small utilities

.

5 .4 Collection Schedule

Collection frequency under the TR is on a quarterly basis. All affected industry sources will use ECMPS to submit monitoring plan, quality assurance, certification test, and emissions data to EPA quarterly . In addition, the TR requires the collection of allowance trading

information as transfers are submitted

, as well as information regarding other " event "

submissions made on a one

- time or annual basis

.

6. 0 E stimating the B urden and C ost of the C ollection

6.1 Estimating Respondent Burden

Emission Reporting and Trading Requirements

This section estimates the paperwork burden and cost of submitting permit applications, certificates of representation, allowance tracking and transfer materials

, year

- end compliance

activities , submittal of monitoring plans, obtaining certification of each monitori ng system, conducting monitor quality assuran ce activities, and recording and reporting data from CEM systems (or approved alternatives).

To estimate the burden and/or cost of each requirement, EPA utilized prior estimates of the costs of activities, estimates provided by affec ted utilities in comme nts to the Agency, and /or

estimates base d on the Agency ' s experience in implementing existing trading programs.

For the purposes of this analysis, the trading sources are grouped into the following categories:

● Trading units located in SO 2 Group 1 ( Georgia, Illinois, Indiana, Iowa, Kentucky, Michigan, Missouri, New York, North Carolina, Ohio, Pennsylvania, Tennessee, Virginia, West Virginia, and Wisconsin ) ;

● Trading units located in SO 2 Group 2 (Alabama, Kansas, Maryland, Minnesota, Nebraska, New J ersey, and South Carolina);Transport Rule ICR May 9, 2011

14 ● Trading units located in a TR NO X Annual state ( Alabama, Illinois, Iowa, Indiana, Kentucky, Maryland, Missouri, Michigan, New Jersey, New York, North Carolina, Ohio, Pennsylvania, South Carolina, Tennessee, Virginia, West Virginia, Wisconsin, Georgia, Texas, Kansas, Minnesota, and Nebraska);and

● Trading units located in a TR NO X ozone s tate

.

The TR requires all affected sources to monitor their NO X emission rate, SO 2 emission

rate

, and heat input in order to determine NO X mass emissions and SO 2 mass emissions

. Coal

fired units use NO X , SO 2 , and flow CEMS to meet those requirement s. Oil and gas units have

alternatives. For SO 2 , these units can use fuel sampling and analysis (or an SO 2 default factor for pipeline natural gas) combined with a fuel flowmeter. In addition, peaking units that burn natural gas and/or fuel oil may use an alternative method for calculating NO X emission rates

. EPA will also allow certain low mass emissions un its to use assumed emissions factors together with operational data to calculate emissions.

For purposes of thi s ICR, burdens and costs are calculated only in terms of incremental impacts for units located in TR s tates or subject to the ARP

. Under the TR , and for purposes of this ICR, the incremental ozone s eason burdens were limited to GA, KS, MN, NE, OK, and TX

. Several states in the NO X SIP Call region are excluded from the TR ' s NO X O zone S eason
T rading P rogram : CT, DC, DE, and MA

. Similarly, units sub ject to the ARP already have much of the monitoring and reporting capability required under the TR

. Finally, sources not subject to

the TR could still have existing requirements for CEMS in some cases

. Thus, it should be noted

that the labor hour s and cost estimates per u nit identified in this document represent the weighted average burden and cost for all units and do not represent the actual burden and cost for a particular unit

. See the following table for a grap hical reference of s tate re porting classifications

related to CAIR, the NO X SIP Call, and the TR

.Transport Rule ICR May 9, 2011

15 Table 6

- 1 : State Reporting Classifications for the NO X SIP Call, CAIR, and the TR

State NO X SIP Call

Ozone CAIR

Ozone CAIR

Annual (NO X & SO 2 ) TR Ozone TR Annual (NO X & SO 2 )

No Change in Classification

Arkansas X X

Alabama X X X X X

Illinois X X X X X

Iowa X X X X

Indiana X X X X X

Kentucky X X X X X

Maryland X X X X X

Missouri X X X X X

Michigan X X X X X

New Jersey X X X X X

New York X X X X X

North Carolina X X X X X

Ohio X X X X X

Pennsylvania X X X X X

South Carolina X X X X X

Tennessee X X X X X

Virginia X X X X X

West Virginia X X X X X

Wisconsin X X X X

Annual Reporters with Ozone Status Changes

Georgia X X X

Texas X X X

(cont.)Transport Rule ICR May 9, 2011

16 Table 6

- 1 : State Reporting Classifications for the NO X SIP Call, CAIR, and the TR (cont.)

State NO X SIP Call

Ozone CAIR

Ozone CAIR

Annual (NO X & SO 2 ) TR Ozone TR Annual (NO X & SO 2 )

Now Ozone

- Only

Mississippi X X X

Florida X X X

Louisiana X X X

New States

Kansas X X

Minnesota X

Nebraska X

Oklahoma X

States No t Covered under the TR

Connecticut X X

Delaware X X X

District of Columbia X X X

Massachusetts X X

The following discussion highlights some of the basic differences for the categories of

units

. Included in this discussion is the consideration of monitoring and reporting that is done by

many of th ese sources under the ARP and CAIR Program s

.

Trading units in NO X / SO 2 annual and ozone season states , in NO X / SO 2 annual

- only s tates
in the CAIR region

, or which report for the ARP

, will hav e the smallest incremental burden with regard to monitoring and reporting

. Acid Rain

- affected units are already monitoring and reporting both NO X and SO 2 emissions on a year round basis and will not incur additional burdens (or capital

, operating

, and maintenance costs) as a result of the TR since they have already installed and are operating a CEMS (or approved alternative) and meet 40 CFR part 75 requirements for bot h NO X and SO 2

. Similarly, CAIR annual units will not incur any additional capital costs as they have alr eady installed and operate a CEMS (or approved alternative) and

meet 40 CFR part 75 requirements for both NO X and SO 2

. However, this ICR incorporates the

burden and costs associated with monitoring at these CAIR units, including annualized capital

costs that would continue to be born under the TR

.

Sources that are not affected by the ARP but were subject to the NO X SIP call are already monitoring and reporting NO X emissions during the ozone season

. I n a TR

- affected NO X /SO 2Transport Rule ICR May 9, 2011

17 annual s tate

, these sources will need to extend their monitoring and reporting throughout the year

and add SO 2 monitoring for the TR

. T hese units will have a small additional burden associated with permit applications and certain allowance transactions.

T R

- affected units in NO X /SO 2 annual and ozone season states

, or NO X /SO 2

- only st ates
not in the NO X SIP Call or CAIR region are similarly impacted by the TR reporting requirements

. These s tates have ARP

- affected units that are already monitoring and reporting

SO 2 emissions and NO X rates on a year round basis and in accordance with 40 CFR part 75

. These sources will need to report NO X mass emissions year rou nd and

, for the NO X /SO 2 annual

and ozone season states

, must also report ozone season NO X mass emissions

. T hese sources are already measuring and reporting SO 2 mass emissions, which requires heat input measurement
that can be used with the NO X emission rate information to calculate NO X mass emissions

. Therefore, these sources would need to make minor modifications to their reporting practices in order to report NO X mass emissions under the TR , but would not likely need to purchase

additional m onitoring equipment

. The non

- ARP

- affected units in these s tate s were required to

monitor under 40 CFR part 75 with the implementation of CAIR

, and these requirements

continue under the TR

. The monitoring burden depend s in part on the type of fuel combusted

and the amount of time the unit is operated

. Therefore, the costs will vary depending on what monitoring alternative is appropriate for the unit and what monitoring requirements apply to the

unit under other regulatory programs

. This ICR includ es updated estimates for all units previously affected under CAIR and adds newly a ffected sources in TR states

.

T R

- affected units in TR ozone season s tates that are in CAIR will contin ue monitoring

NO X under 40 CFR part 75 during the ozone season. The burdens and costs associated with monitoring and reporting were previously reflected in the CAIR ICR but are now included in this

ICR . TR

- affected units in TR ozone season s tates that are not subject to the ARP, CAIR, or in

the NO X SIP Call region must in stall NO X monitoring systems to comply with 40 CFR part 75 during the ozone season.

Sources will be subject to TR NO X and SO 2 monitoring and reporting requirements starting in 2012

. Table 6

- 5 shows the burden associated with monitoring NO X and SO 2 under the

TR at various types of sources.

The primary tasks performed by owners and operators of affected units are (1) permitting, (2) monitoring, recording, and reporting emissions data, and (3) allowance trading activities.

(i) Respondent Permitting Activi ties

Some sources will also be required to construct additional facilities, and therefore will

need to complete a permit to construct application

. Based on the existing CAIR ICR, t he Agency

estimates that th is task will take 20 hours of managerial and 20 hours of technician time , per permit.

Under the TR, the designated representative for e ach affected source must submit a certificate of representation to EPA

. Since most existing TR

- affected sources are already subject to the ARP and/or CAIR, t he Agency believes that the DRs for most TR

- affected sourcesTransport Rule ICR May 9, 2011

18 will only need to revise their certificates of representation, and that such revision s are routine

. The Agency therefore estimates that, on a per unit basis, about one half hour of managerial tim e and one half hour of technical time will be requi red to revise the certificate of representation

.

(ii ) Agency Permitting Activities

Agency permitting activities include receiving and processing certificates of

represe nt ation and retired unit exemptions. The Agency estimates that these activities will require 2,992 hours per year (see Table 6

- 6 )

.

(ii i ) Respondent Monitoring Activities

For monitoring, the burdens differ greatly based on the amount and type of monitoring

the unit is already subject to and the particular subtask of monitoring being conducted

. The specific elements of this burden are described below.

Start

- up Activities

A large part of start

- up activities involves both capital expenditures and labor costs associated with the acquisition, installation, and testing of monitoring equipment, as foll o ws :

1) For Acid Rain units in CAIR OS states

, the TR imposes no start

- up burdens beyond existing programs.

2) For Acid Rain units in other TR ozone season s tat es, the owner or operator will incur

some small amount of burden and costs associated with DAHS upgrades for reporting

ozone season emissions

.

3) For the non

- Acid Rain units in NO X /SO 2 annual and ozone season TR s tates that are in

the CAIR region , the burdens and costs reflect arranging for SO 2 CEMS purchase (as required) and oversight of the certification process.

4) For non

- Acid Rain / CAIR a nnual units in NO X /SO 2 annual and ozone season TR s tates burdens reflect purchase and certification of NO X and SO 2 monitoring systems.

Note that w here the start

- up burdens were already incurred as a result of CAIR, this ICR

reflects minimal burden hours or non

- capital costs, but continues to account for annualized capital costs.

Regulatory Review

The ICR includes an allocation of time for the managerial and technical staff to review the regulatory requirements as well as the XML formats and instructions associated with

electronic emissions data submissions

. The units not in the ARP or CAIR programs wi ll have a

burden similar to that estimated for ARP units in the ARP ICR

-- 16 hours of managerial time

and 16 hours of technician time in year one of the program and four hours each for managerialTransport Rule ICR May 9, 2011

19 and technician time, per year, after year one

. The burden estimates for all units previously

included in the ARP or CAIR is reduced because of the similar requirements involved in these trading programs

. The estimates for these units are ten hours of managerial time and ten hours of

technician time in year one and one hour each per year after year one

.

Response to Error Messages

The Agency provid es feedback for errors that are found in monitoring plans or other

reports

. The Agency estimates that for each unit not previously included in the Acid Rain or CAIR , an owner or operator will spend approximately four hours of managerial time and eight

hours of technician time res ponding to these error messages each year

. (The time for the other sources is accounted for in other ICRs.)

DAHS Debugging

Based on experience with the ARP and CAIR Program s , some effort will be involved to fix problems with the DAHS software used to report in the 40 CFR part 75 formats

. This burden is assumed to fall primarily on units that have not previously been affected under the ARP,
CAIR, or NO X SIP Call programs

. Consistent with the existing 40 CFR part 75 ICR, the Agency

estimates that about 1 4 managerial and 80 technician hours will be spent on this task in the first year of implementation, and then one managerial and four technician hours will be required in

the second and subsequent years of implementation

. Units that are subject to the ARP, and/or

were previously subject to CAIR

, are expected to incur the " subsequent years " burden.

Monitoring Plans

The regulations require submittal of monitoring plans

. Because most of the monitoring plan elements are now part of the reporting format, the effort involved in developing and maintaining the plans are incorporated into the overall reporting burden estimate.

Monitor Certification/Recertification

Initial certification burdens and costs for new monitoring equipment are addressed above

under start

- up activities since these costs are often part of the overall purchase expense for the equipment

. For some non

- ARP

- affecte d units, however, there will be burdens associated with certifying existing monito rs used under other programs , as well as burdens for recertification to the extent a change in a monitoring system requires recertification

. Based on the current CAIR
ICR, E PA estimates that approximately ten percent of all units will have to recertify each year following the year in which the initial certification occurs

. The ICR incorporates a labor burden estimate generally consistent with existing Agen cy models for the l abor burdens associated with

certification

. However, note that the ICR reduces the labor hours for this activity to avoid double counting hours that are already accounted for in the quality assurance activity area (see the following subsection)

. The doub le counting would occur because a portion of the labor incurred for the certification or recertification event replaces the labor burden that is generally allocated to the annual relative accuracy test audit (RATA) in the year in which the certification ev ent occurs.Transport Rule ICR May 9, 2011

20 Quality Assurance

Quality assurance (QA) activities and other routine maintenance for monitoring systems is the largest burden item under the TR

. These requirements generally include daily, quarterly

, and annual QA requirements, depending on the monitoring approach being used

. For reporting units that use a CEMS, the Agency has assumed a per unit labor burden based on a variety of sources, including the existing ARP ICR, information provided by ARP an d CAIR sources, a CEM cost model developed by EPA, and comments submitted in response to the section 110 SIP

Call for ozone transport

. For units that rely on alternative methodologies, reduced labor burden estimates apply because the quality assurance act ivities for the excepted methods are less than

for a CEMS

. Consistent with the existing ARP and CAIR ICR s , the labor burden is expected to

be almost entirely technician labor.

Quarterly Reports

Tasks performed by utilities in preparing quarterly report s include: (1) assuring the quality of the data, (2) preparing the quarterly report, (3) revising the monitoring plan, if necessary, (4) preparation of hard copy documentation accompanying the quarterly repor t s, and (5) managerial review

. The existing Ac id Rain ICR was used as the basis for these estimates.

Fuel Sampling

To calculate heat input where the source is using the fuel flow meter option for an oil or

gas

- fired unit, the source must obtain gross calorific value data from sampling in accordance with Appendix D of 40 CFR part 75

. For purposes of this ICR, it is assumed that the GCV data would be collected as part of standard business operating procedures to assure compliance with contractual specifications

. Thus no additional fuel sampling burdens or costs should be incurred.

(iv) Agency Monitoring Activities

Agency activities related to the monitoring and reporting of emissions data include processing, reviewing

, and evaluating reports of quarterly emi ssions data from affected u nits. The Agency estimates that these activities will require 4,500 hours per year (see Table 6

- 10)

.

( v ) Respondent Allowance Transaction A ctivities

The Agency anticipates the average number of additional allowance transactions will be approximately 7,500 per year beginning in 2012

. This estimate is based on transaction data associated with the current CAIR trading programs. A portion of all sources will likely conduct transactions in each year solely as a result of this program. The Agency believe s that each transaction will involve about one hour each of managerial and technician time.

( v i ) Agency Allowance Transaction A ctivities

Agency activities related to a llowance t ransactions include allocating allowances to existing and new units, r eview ing allowance transfer information, record ing transfe rs
, notify ingTransport Rule ICR May 9, 2011

21 transfer participants, e nter ing deduction data and deduct ing allowances , and ensuring compliance assurance provisions are met. In the event that compliance assurance provisions are not met it is

estimated that the burden for each s tate exceeding compliance assurance levels would be 160 hours, however the agency assumes that zero s tate s would exceed the limit during the 2012

- 2013 time pe riod. The Agency estimates that these activities will require 290 hours per year (see

Tables 6

- 8 and 6

- 9 )

.

6 .2 Estimating Respondent Costs

Table 6

- 4 presents s tate and local respondent annualized hours and costs for each

information collection activity

. To estimate annualized hours and costs for one

- time activities, the burden estimate is divided by three to estimate the burden over a three

- year period

. Table

6

- 5 summarizes the annual industry respondent costs

. The following discussion desc ribes how

the costs were derived.

(i) Estimating Labor Costs

For this ICR, the labor ra te used for technical staff at s tate agencies is $ 40.28 per hour,

and the labor ra te for managerial employees at s tate agencies is $ 48. 93

. These labor rates

include benefits and overhead , and are derived from data shown on the Bureau of Labor

Statistics web site at http://stats.bls.gov/news.release/ecec.toc.htm

. Wage and salary rates are

shown at the link “Table 3: State and local government, by major occupation and industry group (Dec ember 20 10 ). " The wage and salary rates from this table account for benefits provided to

workers

. When considering both technical and man agerial hours, labor costs for s tat e and

t erritorial agencies are estimated to be $53,000 per year per respondent, and labor costs for local agencies are estimated to be $34 ,000 per year per respondent for the emissions reporting requirements

.

In estimating labor costs for industry , EPA u sed the following amounts: $ 94.04 per hour for managers and $ 65.21 per hour for technicians

. These rates were used in the existing ARP

ICR ( EPA ICR Number 1633.15 ) and are the consistent with the Current Employment Cost Index year 20 10

.

Federal Agency labor rates were assumed to be $ 49. 49 per hour

. This labor rate was

derived from the federal government ' s 2009 U.S. Office of Personnel Management General

Schedule " Salary Table 20 11

- GS " (http://opm.gov/oca/ 11 tables/html/gs.asp) u sing the factors in

Table 6

- 2 below

.Transport Rule ICR May 9, 2011

22 Table 6

- 2: Determination of Federal Wage Rates

Labor Category Factors Total

Annual Salary of Technical Staff, GS 11 Step 3 $ 53,639

Annual Cos t of Supervisory Staff, GS 13, S tep 3 $76,452

Factor (1/11) 0.09

$6,881

Annua l Cost of Support Staff, GS 6, S tep 6 $35,672

Factor (1/8) 0.13

$4,637

Annual Applicable Salary of Permit Staff $65,157

Benefits 1.6

Total Cost per FTE $102,948

Total Hourly Cost (total per FTE dividend divided by 2,080 hours per year) $49.49

( ii) Estimating Capital and Operations and Maintenance Costs

Emission Reporting Requirements

Consistent with the CAIR ICR, EPA has concluded that the Capital and Operations and

Maintenance Costs estimated under the NO X SIP Call are sufficient to accommodate the modest changes in reporting burden for the TR

. Therefore, no further estimate of Capital and Operations

and Maintenance Costs were made for this ICR.

Emission Trading Requirements

Capital/start

- up costs include the cost of installing required CEMS or alternatives

. Operation and maintenance costs (exclusive of labor costs) reflect ongoing costs to a unit and

include both contractor costs for the required recertification, diagnostic, and quality assurance (QA) testing, and other direct maintenance

- related expenses (e.g., spare parts and calibration gases)

. These cost estimates have been derived from EPA CEM cost models, existing ICRs, Agency staff experience under the Acid Rain , CAIR, and NO X SIP Call prog rams, and supplemental estimates provided by affected utilities and others related to the various cost items.

ARP

- affected units in CAIR s tate s are not expected to incur any non

- labor costs

associated with this program

. Based on the existing CAIR ICR, t he total non

- labor cost for capital/start

- up items for Acid Rain units in other s tate s that would be subject to the TR is

estimated at $ 4 ,000 per unit for CAIR

- affected units that are not in the NO X SIP Call region (to account for a DAHS upgrade)

. For non

- Acid Rain / CAIR a nnual units, most units will require a DAHS upgrade ( estimated at $ 4 ,000 per unit ) and an SO 2 analyzer (estimated at $42,525 )

. ForTransport Rule ICR May 9, 2011

23 non

- Acid Rain units not in the CAIR region, the units using fuel flowmeters are expected to

incur DAHS and SO 2 analyzer costs, while the other units will require some combination of a

NO X diluent, SO 2

, and/or flow CEMS

. The costs for these units ranges from $15,000 to $192,000

. Cost variance is due to the monitoring methodology used and what monitoring equipment may already be in place at the unit.

Note that testing contractor costs for certification, recertification and annual relative

accuracy test audits (RATAs) are presented as other direct costs and are not converted to

eq uivalent source labor hours

. This approach is consistent with the common business practice for obtaining outside contractors to conduct certification/recertification tests and annual RATAs

. For initial certification, the certification test costs are comm only bundled with equipment purchase contracts, according to information provided by a range of CEMS equipment vendors

. For RATAs that are conducted either as part of the annual quality assurance requirements or as

part of recertification, industry contac ts have indicated that RATA tes ting is usually performed

under a fixed price contract basis, except for travel costs that may be billed on an hourly basis beyond the basic contract cost.

The Agency also notes that this ICR does not include a cost for the purchase of monitoring equipment for all affected units

. Many sources covered by the TR are already required to have CEMS under other regulatory programs

. Therefore, to the extent that no new equipment is needed by these sources, capital costs are not included because those costs were included in the ICRs of those other programs

. Thus, the capital and other costs included in Table

6

- 5 represent weighted average costs for each respondent, not the total individual cost for any particular respondent.

EPA has concluded that the Capital and Operations and Maintenance Costs estimated for the Agency under the ARP ICR are sufficient to accommodate the modest changes in reporting

burden for the TR . Therefore, no further estimate of Capital and Operations and M aintenance

Costs for the Agency were made for this ICR.

( iii) Capital/Start

- up vs. Operating and Maintenance (O & M) Costs

Capital costs for emissions trading reflect one

- time costs for purchase of equipment

which will be used over a period of years

. C onversely, operating and maintenance costs are

those costs which are incurred on an annual or other scheduled basis

. For instance, costs

associated with quality assurance activities, such as spare parts or contractor costs for work, will

be incurred on an annual basis.

(iv) Annualizing Capital Costs

The relevant capital costs for the emissions trading portion of this ICR were annualized at

a rate of seven percent , ( i.e., the annualized capital cost was calculated assuming money to purchase the capital equipment was borrowed at a seven percent annual interest rate )

. The cost

of the loan was amortized over the life of the loan to repay the borrowed amount plus interest

. The result is the annualized capital cost reported. ) The annualized cost of the necessary capitalTransport Rule ICR May 9, 2011

24 purchases varies from $ 2,304 to $ 29,572 per year per unit, depending on the type of monitoring methodology. Table 6

- 5 contains a breakdown of annual costs by monitoring methodology.

6.3 Estimating the Respondent Universe and Total Burden and Costs

Emission Reporting Requirements

The number of non

- industry respondents is estimated to be 5 0 s tates and the District of

Columbia

, four t erritories and 49 local agencies, totaling 104 respondents

. Table 6

- 4 details state, territory, and local agency burdens associated with reading the rule upon publication.

Emission Trading Requirements

The number of industry respondents varies depending on the activity in question

. Activities such as T itle V permit application submission or allowance transfers can involve nearly two thousand sources

. The number of units which will be required to install a particular type of monitoring equipment is fewer since many already have the necessary monitoring equipment

, especially if t hey are ARP units and/ or are in CAIR s tate s

. Table 6

- 5 gives

estimates of annual industry burden s beginning in 20 1 2

. These burden s include monitoring, reporting

, and other activities involved in participating in an emissions trading program

. The

total number of respondents is estimated to be 1,2 0 1 facilities. Table s 6

- 6 through 6

- 10 give estimates of Agency burden s associated with permitting and managing the emissions trading

programs.

6.4 Bottom Line Burden Hours and Cost Table

Table 6

- 3 summarizes the bottom line burden and costs for state, industry, and Agency respondents.

Table 6

- 3 : Total Estimated Emissions Trading Respondent Burden and Cost Summary

Number of Respondents Total Hours Per Year

(All Respondents) Total Costs Per Year (All Respondents)

State Respondents 104 69 $ 3, 016

Industry Respondents 1,201 185,132 $26,225, 946

Agency 1 7,716 $380,306Transport Rule ICR May 9, 2011

25 6.5 Reasons for Change in Burden

Emission Reporting and Trading Requirements

The large st burden associated with this rule is the cost of monitoring, certifying, quality assuring and reporting emissions data from the large electric generating units regulated under the

TR

. This burden is tempered

, however

, by the integration of these monitorin g and reporting requirements with those already required under the A RP and CAIR

. Otherwise, the burden would be significantly higher and the number of sources would be greater.

6.6 Burden Statement

The annual public reporting and recordkeeping burden f or this collection of information is estimated to average 11 hours per response. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, disclose or provide information to

, or for

, a f ederal agency

. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information ; processing

, maintaining, disclosing

, and providing information; adjus t ing the existing ways to comply with any previously applicable instructions and requirements;

train ing personnel to be able to respond to a collection of information; search ing data sources; complet ing and review ing the collection of information; and tran smit ting or otherwise disclos ing the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number

. The

OMB control numbers for EPA ' s regu lations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the

use of automated coll ection techniques, EPA has established a public docket for this ICR under

Docket ID No. EPA

- HQ

- OAR

- 2009

- 0491 , which is available for public viewing at the Air and Radiation Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West,

Room 333 4, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the Air and Radiation Docket and Information Center is (202) 566

- 1742. An electronic version of the public docket is available at www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the co ntents of the public docket, and to access those documents in the public docket that are available electronically. When in the system, select “search,” then key in the Docket ID Number identified above. Also, you can send comments to the Office of Inform ation and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office

for EPA. Please include EPA Docket ID No. EPA

- HQ

- OAR

- 2009

- 0491 and OMB Control

Number 2060

- NEW in any correspondence.Transport Rule ICR May 9, 2011

26 T able 6

- 4 : Annual State Respondent Burden and Cost by Activity

Hours and Costs Per Respondent Total Hours and Costs

Information

Collection or Trading Rule Activity Mgr.

$ 48. 93 /Hr 1 Tech.

$ 40.28 /Hr 1 Respondent

Hours/Yr Labor

Cost/Yr Number of

Respondents Total

Hours/Yr 2 Total

Cost/Yr 3

One

- time (Annualized)

Read the reporting requirements of the

rule 0.33 0.33 0.66 $29 10 4 69 $3, 016

Total 10 4 69 $ 3, 016

1 See Section 6 .2 (i) for labor and overhead rates.

2 Hours per year are rounded to the nearest hour.

3 Costs per year are rounded to the nearest dollar.Transport Rule ICR May 9, 2011

27 Table 6

- 5 : Annual Industry Respondent Burden and Cost by Activity

Respondent

Labor

Cost/Year Annual Capital

Manager $9 4

. 0 4

Per Hour ( 20 10 ) Technical

$ 65.21

Per Hour ( 20 10 ) Respondent

Hours/Year Startup

Costs O&M

Cost Number of Respondents Total

Hours/Year Total

Cost/Year

Permit to Construct (units) 20 20 40 $3,185 8 317 $25,257

Certificate of Representation 0.50 0.50 1 $80 1201 1,201 $95,630

Startup/ Capital Items

Kansas, Minnesota, Nebraska, Oklahoma (Previously Not Affected)

a. DAHS modification (facilities) 2 4 6 $449 $1,333 35 210 $62,367

b. Solid Fuel: SO 2 , NO X , and Flow CEMS (units) 34 2 3 57 $4,697 $29,752 7 399 $241,144

c . Gas

- Oil: NO X CEMS and Appendix D fuel monitoring (units) 64 10 74 $6,671 $19,200 17 1,258 $439,801

d . Gas

- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 20 10 3 0 $2,533 $2,304 29 870 $140,270

(cont.)Transport Rule ICR May 9, 2011

28 Table 6

- 5 : Annual Industry Respondent Burden and Cost by Activity (cont.)

Respondent

Labor

Cost/Year Annual Capital

Manager $9 4

. 0 4

Per Hour (20 10 ) Technical

$ 65.21

Per Hour (20 10 ) Respondent

Hours/Year Startup

Costs O&M

Cost Number of Respondents Total

Hours/Year Total

Cost/Year

Startup/ Capital Items (cont.)

Georgia and Texas (Ozone Status Changes, Annual Status R emains)

a. DAHS modification (facilities) 2 4 6 $449 $600 161 966 $168,876

b . Solid Fuel: NO X , and Flow CEMS (units) 0 0 0 $0 $29,752 1 0 $29,752

c . Gas

- Oil: NO X CEMS and Appendix D fuel monitoring (units) 0 0 0 $0 $19,200 38 0 $729,600

d . Gas

- Oil Peaking Units: Appendix D fuel sampling, Appendix E,

or LME methods (units) 0 0 0 $0 $2,304 39 0 $89,856

(cont.)Transport Rule ICR May 9, 2011

29 Table 6

- 5 : Annual Industry Respondent Burden and Cost by Activity (cont.)

Respondent

Labor

Cost/Year Annual Capital

Manager $9 4

. 0 4

Per Hour (20 10 ) Technical

$ 65.21

Per Hour (20 10 ) Respondent

Hours/Year Startup

Costs O&M

Cost Number of Respondents Total

Hours/Year Total

Cost/Year

Startup/ Capital Items (cont.)

Mississippi

, Florida

, and Louisiana (Now Ozone Season Only)

a. DAHS modification (facilities) 2 4 6 $449 $600 27 162 $28,321

b . Solid Fuel: NO X , and Flow CEMS (units) 0 0 0 $0 $22,500 6 0 $135,000

c . Gas

- Oil: NO X CEMS and Appendix D fuel monitoring (units) 0 0 0 $0 $19,200 6 0 $115,200

d . Gas

- Oil Peaking Units: Appendix D fuel sampling, Appendix E,

or LME methods (units) 0 0 0 $0 $2,304 62 0 $142,848

States with No Change in Classification

a . Solid Fuel: NO X , and Flow CEMS (units) 0 0 0 $0 $29,752 64 0 $1,904,128

b . Gas

- Oil: NO X CEMS and Appendix D fuel monitoring (units) 0 0 0 $0 $19,200 67 0 $1,286,400

c . Gas

- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 0 0 0 $0 $2,304 533 0 $1,228,032

(cont.)Transport Rule ICR May 9, 2011

30 Table 6

- 5 : Annual Industry Respondent Burden and Cost by Activity (cont.)

Respondent

Labor

Cost/Year Annual Capital

Manager $9 4

. 0 4

Per Hour (20 10 ) Technical

$ 65.21

Per Hour (20 10 ) Respondent

Hours/Year Startup

Costs O&M

Cost Number of Respondents Total

Hours/Year Total

Cost/Year

Review Instructions and Requirements

States with No Change in

Classification 4 4 8 $637 26 1 2,088 $166,257

States in which Ozone

Season Status Changes,

Annual Status Remains 4 4 8 $637 161 1,288 $102,557

States now Ozone Season Only

- Mississippi, Florida, Louisiana 4 4 8 $637 27 216 $17,199

States Not Previously

Covered

- Kansas, Minnesota, Nebraska,

Oklahoma 8 8 16 $1,274 35 560 $44,590

(cont.)Transport Rule ICR May 9, 2011

31 Table 6

- 5 : Annual Industry Respondent Burden and Cost by Activity (cont.)

Respondent

Labor

Cost/Year Annual Capital

Manager $9 4

. 0 4

Per Hour (20 10 ) Technical

$ 65.21

Per Hour (20 10 ) Respondent

Hours/Year Startup

Costs O&M

Cost Number of Respondents Total

Hours/Year Total

Cost/Year

Respond to EPA Generated Error Messages

States with No Change in

Classification 6 18 24 $1,738 261 6,264 $453,623

States in which Ozon e Season Status Changes,

Annua l Status Remains 6 18 24 $1,738 161 3,864 $279,821

States now Ozone Season Only

– Mississippi, Florida, Louisiana 6 18 24 $1,738 27 648 $46,927

States Not Previously

Covered

- Kansas, Minnesota, Nebraska,

Oklahoma 6 18 24 $1,738 35 840 $60,831

Debug Computer Software

States with No Change

in Classification 1 4 5 $355 261 1,305 $92,624

States in which Ozone

Season Status Changes,

Annual Status Remains 6 18 24 $1,738 161 3,864 $279,821

(cont.)Transport Rule ICR May 9, 2011

32 Table 6

- 5 : Annual Industry Respondent Burden and Cost by Activity (cont.)

Respondent

Labor

Cost/Year Annual Capital

Manager $9 4

. 0 4

Per Hour (20 10 ) Technical

$ 65.21

Per Hour (20 10 ) Respondent

Hours/Year Startup

Costs O&M

Cost Number of Respondents Total

Hours/Year Total

Cost/Year

Debug Computer Software (cont.)

States now Ozone Season Only

- Mississippi, Florida, Louisiana 1 4 5 $355 27 135 $9,582

States Not Previously

Covered

- Kansas, Minnesota, Nebraska,

Oklahoma 16 88 104 $7,243 35 3,640 $253,509

Certify Monitors

Kansas, Minnesota, Nebraska, Oklahoma (Previously Not Affected)

a. Solid Fuel: SO 2 , NO X , and Flow CEMS (units) 15 48 63 $4,541 $2,800 1 63 $7,341

b. Gas

- Oil: NO X CEMS and Appendix D fuel monitoring (units) 10 32 42 $3,027 $2,800 1 42 $5,827

c. Gas

- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 8 24 32 $2,317 $10,000 5 160 $61,587

(cont.)Transport Rule ICR May 9, 2011

33 Table 6

- 5 : Annual Industry Respondent Burden and Cost by Activity (cont.)

Respondent

Labor

Cost/Year Annual Capital

Manager $9 4

. 0 4

Per Hour (20 10 ) Technical

$ 65.21

Per Hour (20 10 ) Respondent

Hours/Year Startup

Costs O&M

Cost Number of Respondents Total

Hours/Year Total

Cost/Year

Certify Monitors (cont.)

Georgia and Texas (Ozone Status Changes, Annual Status R emains)

a. Solid Fuel: SO 2 , NO X , and Flow CEMS (units) 15 48 63 $4,541 $2,800 1 63 $7,341

b. Gas

- Oil: NO X CEMS and Appendix D fuel monitoring (units) 10 32 42 $3,027 $2,800 4 168 $23,308

c. Gas

- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 8 24 32 $2,317 $10,000 4 128 $49,269

Mi ssissippi , Florida

, and Louisiana (Now Ozone Season O nly)

a. Solid Fuel: SO2, NO X , and Flow CEMS (units) 15 48 63 $4,541 $2,800 1 63 $7,341

a. Gas

- Oil: NO X CEMS and Appendix D fuel monitoring (units) 10 32 42 $3,027 $2,800 1 42 $5,827

b. Gas

- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 8 24 32 $2,317 $10,000 6 192 $73,904

(cont.)Transport Rule ICR May 9, 2011

34 Table 6

- 5 : Annual Industry Respondent Burden and Cost by Activity (cont.)

Respondent

Labor

Cost/Year Annual Capital

Manager $9 4

. 0 4

Per Hour (20 10 ) Technical

$ 65.21

Per Hour (20 10 ) Respondent

Hours/Year Startup

Costs O&M

Cost Number of Respondents Total

Hours/Year Total

Cost/Year

Certify Monitors (cont.)

States With No Change in Classification

a. Solid Fuel: NO X , and Flow CEMS (units) 15 48 63 $4,541 $2,800 6 378 $44,044

b. Gas

- Oil: NO X CEMS and Appendix D fuel monitoring (units) 10 32 42 $3,027 $2,800 7 294 $40,790

c. Gas

- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 8 24 32 $2,317 $10,000 50 1,600 $615,868

Perform QA Testing and Maintenance

Kansas, Minnesota, Nebraska, Oklahoma (Previously Not Affected)

a. Solid Fuel: SO 2 , NO X , and Flow CEMS (units) 50 600 650 $43,828 $31,949 7 4,550 $530,439

b. Gas

- Oil: NO X CEMS and Appendix D fuel monitoring (units) 20 375 395 $26,335 $17,818 17 6,715 $750,593

c. Gas

- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 5 30 35 $2,427 $1,843 29 1,015 $123,816

(cont.)Transport Rule ICR May 9, 2011

35 Table 6

- 5 : Annual Industry Respondent Burden and Cost by Activity (cont.)

Respondent

Labor

Cost/Year Annual Capital

Manager $9 4

. 0 4

Per Hour (20 10 ) Technical

$ 65.21

Per Hour (20 10 ) Respondent

Hours/Year Startup

Costs O&M

Cost Number of Respondents Total

Hours/Year Total

Cost/Year

Perform QA Testing and Maintenance (cont.)

Georgia and Texas (Ozone Season Status Changes, Annual Status R emains)

a. Solid Fuel: NO X , and Flow CEMS (units) 40 400 440 $29,846 $31,949 1 440 $61,795

b. Gas

- Oil: NO X CEMS and Appendix D fuel monitoring (units) 20 375 395 $26,335 $17,818 38 15,010 $1,677,797

c. Gas

- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 5 30 35 $2,427 $1,843 39 1,365 $166,511

Mi ssissippi

, Florida and Louisiana (Now Ozone Season O nly)

a. Solid Fuel: NO X , and Flow CEMS (units) 40 400 440 $29,846 $31,949 6 2,640 $370,768

b. Gas

- Oil: NO X CEMS and Appendix D fuel monitoring (units) 20 375 395 $26,335 $17,818 6 2,370 $264,915

c. Gas

- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 5 30 35 $2,427 $2,209 62 2,170 $287,401

(cont.)Transport Rule ICR May 9, 2011

36 Table 6

- 5 : Annual Industry Respondent Burden and Cost by Activity (cont.)

Respondent

Labor

Cost/Year Annual Capital

Manager $9 4

. 0 4

Per Hour (20 10 ) Technical

$ 65.21

Per Hour (20 10 ) Respondent

Hours/Year Startup

Costs O&M

Cost Number of Respondents Total

Hours/Year Total

Cost/Year

Perform QA Testing and Maintenance (cont.)

States With No Change in Classification

a. Solid Fuel: NO X , and Flow CEMS (units) 40 400 440 $29,846 $31,949 64 28,160 $3,954,854

b. Gas

- Oil: NO X CEMS and Appendix D fuel monitoring (units) 20 375 395 $26,335 $17,818 67 26,465 $2,958,221

c. Gas

- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 5 30 35 $2,427 $1,843 533 18,655 $2,275,644

Assure Data Quality, Prepare Reports, Submit Reports

States with No Change

in Classification 16 42 58 $4,243 261 15,138 $1,107,543

States in which Ozone

Season Status Changes,

Annual Status Remains 16 42 58 $4,243 161 9,338 $683,197

(cont.)Transport Rule ICR May 9, 2011

37 Table 6

- 5 : Annual Industry Respondent Burden and Cost by Activity (cont.)

Respondent

Labor

Cost/Year Annual Capital

Manager $9 4

. 0 4

Per Hour (20 10 ) Technical

$ 65.21

Per Hour (20 10 ) Respondent

Hours/Year Startup

Costs O&M

Cost Number of Respondents Total

Hours/Year Total

Cost/Year

Perform QA Testing and Maintenance (cont.)

States now Ozone Season Only

- Texas and Mississippi 8 21 29 $2,122 27 783 $57,287

States Not Previously

Covered

- Kansas, Minnesota, Nebraska,

Oklahoma 16 42 58 $4,243 35 2,030 $148,521

Other Trading Program Activities

Allowance Transfers 1 1 2 $159 7500 15,000 $1,194,375

Compl ia nce Assurance

Activites 1. .5 1 1.5 $112 0 0 0

TOTAL 185,1 32 $26,2 25

, 946

1. Assumes that no State s will exceed their limits for the years covered by this ICR (i.e., compliance years 2012 and 2013), so, overall there would be zero burden for these provisions to industry.Transport Rule ICR May 9, 2011

38 Table 6

- 6 : Agency Burden

– Permitting Authority

Information Collection Activity Burden Hours per

Occurrence Cost per

Source 1 Total Burden

(H ours) Total Cost

EPA reviews certificates of representation and records

information. 2 0.5 $24.75 600 $29,628

Review permit application, and issue draft, proposed, and final permit. 3

Permitting Authority action

. 8 $395.92 2,000 $98,760

EPA review

. 1 $49.38 240 $11,851

Receive and process retired unit exemptions

. 4

Permitting Authority action

. 2 $98.98 66 $3,259

EPA review

. 0.3 $14.85 20 $988

TOTAL 2,926 $144,486

1. 20 11 dollars

. 2

. Assumes 12 0 1 sources submit a certificate of representation.

3. Assumes 2 4 0 sources (approximately 20% of all affected sources) will submit a permit application each year.

4. Assumes 33 retired unit exemptions are submitted each year.

Table 6

- 7 : Agency Burden

– Emissions Reporting

Information Collection Activity Quarterly

Burden Hours per Report Quarterly Cost

per Report 1 Number

of Reports 2 Total Burden

per Year (H ours) Total

Cost

Process, review, and evaluate quarterly report

and issue feedback letter. 1 $49.49 4,500 4,500 $222,705

1

. Based on an average total compensation rate of $ 49. 49 per hour.

2

. Assumes 1125 TR only emissions data reports are submitted each quarter.Transport Rule ICR May 9, 2011

39 Table 6

- 8 : Agency Burden

- Allowance Allocations

Information Collection Activity Total Burden (H ours) Total Cost

Initial and annual allocation of allowances to existing and new units. 200 $9,898

Table 6

- 9 : Agency Burden

– Allowance Transfer & Deduction Burden

Information Collection Activity Burden Hours

per Occurrence Cost per

Occurrence 1 Total Burden 2

(H ours) Total Cost

Review allowance transfer information, record transfer, and notify transfer participants. 1 $49.49 40 $1,980

Enter deduction data and deduct

allowances. 0.5 $24.75 50 $1,237

Compliance Assurance Provisions 3 1 $49.49 40 $1,980

TOTAL 90 $3,21 7

1. 2011 dollars.

2. Assumes 20 transfers and 100 optional deduction forms are submitted annually.

3. Assumes zero s tate s would exceed the limit during the time period 201 2

- 2013.

Table 6

- 10 : Agency Burden

– Aggregate

Information Collection Activity Total Burden (H ours) Total Cost 1

Annual a llocation of a llowances to existing and new units. 200 $9,898

Allowance transfers and deductions. 90 $3,217

Permits.

Permitting Authority

. 2,066 $102,019

EPA

. 860 $42,467

Emissions reporting. 4,500 $222,705

TOTAL 7,716 $380,306

1. 2011 dollars.Transport Rule ICR May 9, 2011

40 SUPPORTING STATEMENT

Rule To Reduce Interstate Transport of Fine Particulate Matter and Ozone (Final Rule)

Appendix A

In addition to the s tate s and facilities lis ted in the final rule text, EPA ha s included costs/

burdens associated with TR NO X O zone S eason Trading Program for the following s tate s: IA, KS, MI, MO, OK, and WI. The TR NO X Oz one Season Trading P rogram does not list these

s tate s in the current rule package

, however EPA will propose
, as part of a future supplemental rule package , that these s tates be covered by the TR NO X Ozone Season Trading Program. In anticipation of this rule making, the costs/burdens associate d with this Program in these states are included in the ICR to allow for a full accounting for the TR program at maturity

. In the

event that some or all of these s tate s are not included in t he future rulemaking, EPA will amend this ICR accordingly.

Table A

- 1 : Total Estimated Emissions Trading Respondent Burden and Cost Summary

Number of Respondents Total Hours Per Year

(All Respondents) Total Costs Per Year (All Respondents)

Industry Respondents 58 31,538 4,412,094

Agency 1 452 $22,074Transport Rule ICR May 9, 2011

41 T able A

- 2 : Annual State Respondent Burden and Cost by Activity

Hours and Costs Per Respondent Total Hours and Costs

Information

Collection or Trading Rule Activity Mgr.

$48. 93 /Hr 1 Tech.

$40.28 /Hr 1 Respondent

Hours/Yr Labor

Cost/Yr Number of

Respondents Total

Hours/Yr 2 Total

Cost/Yr 3

One

- time (Annualized)

Read the reporting requirements of the

rule

. 0.33 0.33 0.66 $29 2 69 $ 59

Total 749 30,645.48 2 3,749 $ 49,391

1 See Section 6 .2 (i) for labor and overhead rates.

2 Hours per year are rounded to the nearest hour.

3 Costs per year are rounded to the nearest dollar.Transport Rule ICR May 9, 2011

42 Table A

- 3 Agency Burden

– Permitting Authority

Information Collection Activity Burden Hours per

Occurrence Cost per

Source 1 Total Burden

(H ours) Total Cost

EPA reviews certificates of representation and records

information. 2 0.5 $25 24 $1,188

Review permit application, and issue draft, proposed, and final permit. 3 $0

Permitting Authority action

. 8 $395 80 $3,959

EPA review

. 1 $49 10 $495

Receive and process retired and new unit exemptions

. 4 $0

Permitting Authority action

. 2 $99 4 $198

EPA review

. 0.3 $15 20 $990

TOTAL 138 $ 6,8 30

1. 20 11 dollars

. 2

. Assumes 48 sources submit a certificate of representation.

3. Assumes ten sources (approximately 20% of all affected sources) will submit a permit application each year.

4. Assumes two retired and two new unit exemptions are submitted each year.

Table A

- 4 : Agency Burden

– Emissions Reporting

Information Collection Activity Quarterly

Burden Hours per Report Quarterly Cost

per Report 1 Number

of Reports 2 Total Burden

per Year (H ours) Total

Cost

Process, review, and evaluate quarterly report

and issue feedback letter. 1 $49.49 318 318 $15,738

1

. Based on an average total compensation rate of $49. 49 per hour.

2

. Assumes 318 Ozone emissions data reports are submitted each year

.Transport Rule ICR May 9, 2011

43 Table A

- 5 : Agency Burden

- Allowance Allocations

Information Collection Activity Total Burden (H ours) Total Cost

Initial and annual allocation of allowances to existing and new units. 1 0 $ 0

1. Assumes the allocation for these units would be performed as part of the TR allocations.

Table A

- 6 : Agency Burden

– Allowance Transfer & Deduction Burden

Information Collection Activity Burden Hours

per Occurrence Cost per

Occurrence 1 Total Burden 2

(H ours) Total Cost

Review allowance transfer information, record transfer, and notify transfer participants. 1 $49.49 10 $495

Enter deduction data and deduct

allowances. 0.5 $24.75 10 $248

Compliance Assurance Provisions

. 3 160 7901 0 0

TOTAL 20 $ 741

1. 20 11 dollars.

2. Assumes 10 transfers and 10 optional deduction forms are submitted annually.

3. Assumes zero s tate s would exceed the limit during the time period 2012

- 2013.

Table A

- 7 : Agency Burden

– Aggregate

Information Collection Activity Total Burden (H ours) Total Cost 1

Annual Allocation of Allowances to existing and new units. 20 $742

Allowance transfers and deductions.

Permits. 84 $4,157

Permitting Authority

. 54 $2,672

EPA

. 318 $15,738

Emissions reporting. 476 $23,310

TOTAL 20 $742

1. 20 11 dollars.Transport Rule ICR May 9, 2011

44 Table A

- 8 : Annual Industry Respondent Burden and Cost by Activity

Respondent

Labor

Cost/Year Annual Capital

Manager $9 4

. 0 4

Per Hour (20 10 ) Technical

$ 65.21

Per Hour (20 10 ) Respondent

Hours/Year Startup

Costs O&M

Cost Number of Respondents Total

Hours/Year Total

Cost/Year

Permit to Construct (units) 20.00 20.00 40.00 $3,185 1.00 40.00 $ 3

, 11 4

Certificate of Representation 0.50 0.50 1.00 $80 48.00 48.00 $ 3

, 736

Startup/ Capital Items

Kansas, Minnesota, Nebraska, Oklahoma (Previously Not Affected)

a. DAHS modification (facilities) 2.00 4.00 6.00 $449 $1,333 10 60 $17,819

b. Solid Fuel: SO2, NO X

, and Flow CEMS (units) 34.00 23.00 57.00 $4,697 $29,752 4 228 $137,79 7

c. Gas

- Oil: NO X CEMS and Appendix D fuel monitoring (units) 64.00 10.00 74.00 $6,671 $19,200 2 148 $51,741

d. Gas

- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 20.00 10.00 30.00 $2,533 $2,304 19 570 $91,90 1

(cont.)Transport Rule ICR May 9, 2011

45 Table A

- 8 : Annual Industry Respondent Burden and Cost by Activity (cont.)

Respondent

Labor

Cost/Year Annual Capital

Manager $9 4

. 0 4

Per Hour (20 10 ) Technical

$ 65.21

Per Hour (20 10 ) Respondent

Hours/Year Startup

Costs O&M

Cost Number of Respondents Total

Hours/Year Total

Cost/Year

Startup/ Capital Items (cont.)

Iowa, Michigan, Missouri, Wisconsin (Ozone Status Changes, Annual Status Remains)

a. DAHS modification (facilities) 2.00 4.00 6.00 $449 $600 48 288 $50,348

b. Solid Fuel: NO X , and Flow CEMS (units) 0.00 0.00 0.00 $0 $29,752 6 0 $178,512

c. Gas

- Oil: NO X CEMS and Appendix D fuel monitoring (units) 0.00 0.00 0.00 $0 $19,200 34 0 $652,8 00

d. Gas

- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 0.00 0.00 0.00 $0 $2,304 31 0 $71,424

(cont.)Transport Rule ICR May 9, 2011

46 Table A

- 8 : Annual Industry Respondent Burden and Cost by Activity (cont.)

Respondent

Labor

Cost/Year Annual Capital

Manager $9 4

. 0 4

Per Hour (20 10 ) Technical

$ 65.21

Per Hour (20 10 ) Respondent

Hours/Year Startup

Costs O&M

Cost Number of Respondents Total

Hours/Year Total

Cost/Year

Review Instructions and Requirements

States in which Ozone

Season Status Changes,

Annual Status Remains 4.00 4.00 8.00 $637 48 384 $30,576

States Not Previously

Covered

- Kansas and

Oklahoma 8.00 8.00 16.00 $1,274 10 160 $12,740

Respond to EPA Generated Error Messages

States in which Ozone

Season Status Changes,

Annual Status Remains 6 18 24 $1,738 48 1152 $83,42 5

States Not Previously

Covered

- Kansas and

Oklahoma 6 18 24 $1,738 10 240 $17,380

Debug Computer Software

States in which Ozone

Season Status Changes,

Annual Status Remains 6 18 24 $1,738 48 1152 $83,42 5

(cont

. )Transport Rule ICR May 9, 2011

47 Table A

- 8 : Annual Industry Respondent Burden and Cost by Activity (cont.)

Respondent

Labor

Cost/Year Annual Capital

Manager $9 4

. 0 4

Per Hour (20 10 ) Technical

$ 65.21

Per Hour (20 10 ) Respondent

Hours/Year Startup

Costs O&M

Cost Number of Respondents Total

Hours/Year Total

Cost/Year

Debug Computer Software (cont.)

States Not Previously

Covered

- Kansas and

Oklahoma 16 88 104 $7,243 10 1040 $72,431

Certify Monitors

Kansas and Oklahoma (Previously Not Affected)

a. Solid Fuel: SO2, NO X

, and Flow CEMS (units) 15 48 63 $4,541 $2,800 1 63 $7,34 1

b. Gas

- Oil: NO X CEMS and Appendix D fuel monitoring (units) 10 32 42 $3,027 $2,800 1 42 $5,827

c. Gas

- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 8 24 32 $2,317 $10,000 2 64 $24,63 5

(cont.)Transport Rule ICR May 9, 2011

48 Table A

- 8 : Annual Industry Respondent Burden and Cost by Activity (cont.)

Respondent

Labor

Cost/Year Annual Capital

Manager $9 4

. 0 4

Per Hour (20 10 ) Technical

$ 65.21

Per Hour (20 10 ) Respondent

Hours/Year Startup

Costs O&M

Cost Number of Respondents Total

Hours/Year Total

Cost/Year

Certify Monitors (cont.)

Iowa, Michigan, Missouri, Wisconsin (Ozone Status Changes, Annual Status Remains)

a. Solid Fuel: SO2, NO X

, and Flow CEMS (units) 15 48 63 $4,541 $2,800 1 63 $7,34 1

b. Gas

- Oil: NO X CEMS and Appendix D fuel monitoring (units) 10 32 42 $3,027 $2,800 3 126 $17,481

c. Gas

- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 8 24 32 $2,317 $10,000 3 96 $36,952

Perform QA Testing and Maintenance

States Not Previously Covered

- Kansas and Oklahoma

a. Solid Fuel: SO2, NO X

, and Flow CEMS (units) 50 600 650 $43,828 $31,949 4.00 2600 $303,108

b. Gas

- Oil: NO X CEMS and Appendix D fuel monitoring (units) 20 375 395 $26,335 $17,818 2.00 790 $88,305

(cont.)Transport Rule ICR May 9, 2011

49 Table A

- 8 : Annual Industry Respondent Burden and Cost by Activity (cont.)

Respondent

Labor

Cost/Year Annual Capital

Manager $9 4

. 0 4

Per Hour (20 10 ) Technical

$ 65.21

Per Hour (20 10 ) Respondent

Hours/Year Startup

Costs O&M

Cost Number of Respondents Total

Hours/Year Total

Cost/Year

Perform QA Testing and Maintenance (cont.)

c. Gas

- Oil Peaking Units: Appendix D fuel sampling, Appendix E, or LME methods (units) 5 30 35 $2,427 $1,843 19.00 665 $81,12 1

Iowa, Michigan, Missouri, Wisconsin (Ozone Season Status Changes, Annual Status Remains)

a. Solid Fuel: NO X , and

Flow CEMS (units) 40 400 440 $29,846 $31,949 6.00 2640 $370,76 8

b. Gas

- Oil: NO X CEMS and Appendix D fuel monitoring (units) 20 375 395 $26,335 $17,818 34.00 13430 $1,501,18 7

c. Gas

- Oil Peaking Units: Appendix D fuel sampling, Appendix E,

or LME methods (units) 5 30 35 $2,427 $1,843 31.00 1085 $132,35 5

(cont.)Transport Rule ICR May 9, 2011

50 Table A

- 8 : Annual Industry Respondent Burden and Cost by Activity (cont.)

Respondent

Labor

Cost/Year Annual Capital

Manager $9 4

. 0 4

Per Hour (20 10 ) Technical

$ 65.21

Per Hour (20 10 ) Respondent

Hours/Year Startup

Costs O&M

Cost Number of Respondents Total

Hours/Year Total

Cost/Year

Assure Data Quality, Prepare Reports, Submit Reports

States in which Ozone

Season Status Changes,

Annual Status Remains 16 42 58 $4,243 48 2,784 $203,686

States Not Previously

Covered

- Kansas and

Oklahoma 16 42 58 $4,243 10 580 $42,43 5

Allowance Transfers

1 1 2 $159 500 1,000 $79,625

TOTAL

31,538 $4,461,49 2