United States Environmental Protection Agency

Office of Air and Radiation

Office of Air Quality Planning and Standards

Air Quality Policy Division

New Source Review Group

INFORMATION COLLECTION 

REQUEST FOR CHANGES TO 

40 CFR PARTS 51 AND 52: 

Prevention of Significant 

Deterioration (PSD) for 

Particulate Matter Less Than 2.5 

Micrometers (PM2.5) – Increments, 

Significant Impact Levels (SILs) 

and Significant Monitoring 

Concentration (SMC)

EPA

June 2010

EPA No. 2276.02
E-1

The EPA is revising the regulations governing the Prevention of 

Significant Deterioration (PSD) program mandated by part C of title I of 

the Clean Air Act (the Act). The PSD and nonattainment major New 

Source Review (NA NSR) programs collectively comprise the major NSR 

program. Specifically, the PSD regulations are being revised to add 

increments, significant impact levels (SILs), and a significant monitoring 

concentration (SMC) for particulate matter with an aerodynamic diameter 

less than or equal to a nominal 2.5 micrometers (PM2.5). This action is 

being taken as part of our efforts to implement the National Ambient Air 

Quality Standards (NAAQS) for PM2.5.

The PSD program is a preconstruction review and permitting program for 

new major sources of air pollutants and major modifications at existing 

major sources, which applies to sources located in areas that meet the 

NAAQS for one or more regulated NSR pollutants (called “attainment 

areas”) and in areas where there is insufficient information to determine 

whether they meet the NAAQS (“unclassifiable areas”). The types of 

information collection activities associated with the PSD program are 

those necessary for the preparation and submittal of construction permit 

applications and the issuance of final permits. The PSD rule changes 

addressed in this ICR add increments, SILs, and an SMC for PM2.5 , but 

do not otherwise change the requirements of the program. For 

convenience, we refer to this rulemaking as the “PM2.5 Increments Rule” 

hereafter.

This purpose of this Information Collection Request (ICR) (OMB Control 

Number 2060-0609; EPA ICR Number 2276.02) is to show the burden 

and cost associated with the PM2.5 Increments Rule. Table E-1 

summarizes the overall burden and cost for respondents – sources who 

must obtain PSD permits and state and local agencies who issue the 

permits (called “reviewing authorities”). 

TABLE E-1

BURDEN FOR RESPONDENTS RESULTING FROM PM2.5 INCREMENTS RULE

Type of Respondent

Average Annual 

Burden (Hours)

Average Annual 

Burden per 

Respondent (Hours)

Average Annual 

Costc

($ 2008)

Average Annual 

Cost per 

Respondent

Sourcesa

Reviewing Authoritiesb

28,770

7,521

105

67

$2,808,239

$580,797

$10,249

$5,186

Total 36,291 N/A $3,389,036 N/A

a We estimate 274 PSD permits per year. 

b We assume that there are 112 state and local reviewing authorities.

c All costs are labor costs associated with increased burden; there is no increase in capital, start-up, or O&M costs.

Executive Summary
E-2

The EPA is the only federal entity that will experience burden and cost as 

a result of the PM2.5 Increments Rule. We estimate that the average 

annual burden for EPA will be 461 hours, at a cost of $19,887 annually.

CAVEAT: This analysis overstates the impact of the rulemaking over the 

3 years following promulgation because it has been prepared as if the rule 

revisions would be fully implemented upon the effective date of the rule. 

In actuality, the full effect of the PSD rule changes for PM2.5 will lag the 

promulgation of this rulemaking due to the time needed for reviewing 

authorities with approved PSD programs to modify their Implementation 

Plans.

CONCLUSION:

This rulemaking represents a POTENTIAL INCREASE IN BURDEN to sources 

and Reviewing Authorities related to permit actions.

This rulemaking represents a ONE-TIME INCREASE IN BURDEN to states and 

other Reviewing Authorities to revise their Implementation Plans.

Because the PSD program rarely affects small entities, the Agency determined 

this rulemaking represents

NO SIGNIFICANT IMPACT ON A SUBSTANTIAL NUMBER OF SMALL ENTITIES.
INFORMATION COLLECTION REQUEST FOR CHANGES TO 40 CFR PART 51 AND 52: 

Prevention of Significant Deterioration (PSD) for Particulate Matter Less Than 2.5 Micrometers (PM2.5) –

Increments, Significant Impact Levels (SILs) and Significant Monitoring Concentration (SMC)

Page 1

The title of this ICR is “Information Collection Request for Changes to 

40 CFR Parts 51 and 52: Prevention of Significant Deterioration (PSD) for 

Particulate Matter Less Than 2.5 Micrometers 

(PM2.5) – Increments, Significant Impact Levels 

(SILs) and Significant Monitoring 

Concentration (SMC).” This document fulfills 

the Agency’s requirements under the 

Paperwork Reduction Act (PRA) with regard to 

determining the regulatory burden associated 

with adding increments, SILs, and an SMC for 

PM2.5 to the PSD program required under part C of title I of the Act. It has 

been assigned EPA tracking number 2276.02 and OMB Control 

Number 2060-0609. 

The program called the “PSD program” under authority of part C of Title I 

of the Act is a preconstruction review and permitting program applicable to 

new and modified major stationary sources of air pollutants. The PSD 

program applies in attainment areas (areas meeting the NAAQS) and in 

areas where there is insufficient information to determine whether they

meet the NAAQS (“unclassifiable areas”). The applicability of the PSD 

program must be determined in advance of construction and is pollutantspecific. When a source triggers PSD, it must install best available control 

technology (BACT) and conduct modeling, monitoring, and other analyses

for the regulated NSR pollutant(s) for which the area is designated as 

attainment or unclassifiable.

In 1997, EPA promulgated NAAQS for PM2.5 to address fine particle 

pollution, while retaining the NAAQS for particulate matter with an 

aerodynamic diameter less than or equal to a nominal 10 micrometers 

(PM10) to address coarse particle pollution. In 2006, we revised the PM2.5

and PM10 NAAQS. After delays associated with litigation over the

NAAQS and with building up technical capacity to address PM2.5, we are 

proceeding with implementation of the PM2.5 program, including 

implementation of the NSR program for PM2.5. In a related rulemaking 

action we added PM2.5 and its precursors to both the PSD program and the 

NA NSR program as regulated NSR pollutants.

This ICR addresses rule changes to add increments, SILs, and an SMC for 

PM2.5 to the PSD rules. For some sources, this will add to the burden of 

obtaining a PSD permit because it will add to the number of air quality

analyses that must be carried out in the application process. Similarly, state 

and local reviewing authorities will incur increased burden to review such 

permit applications and issue the permits. In addition, reviewing 

1 Identification of the Information Collection

2

1.2 Description

1.1 Title

EPA TRACKING 

NUMBER: 

2276.02

OMB CONTROL 

NUMBER: 

2060-0609
INFORMATION COLLECTION REQUEST FOR CHANGES TO 40 CFR PART 51 AND 52: 

Prevention of Significant Deterioration (PSD) for Particulate Matter Less Than 2.5 Micrometers (PM2.5) –

Increments, Significant Impact Levels (SILs) and Significant Monitoring Concentration (SMC)

Page 2

authorities will incur a one-time burden to revise their Implementation 

Plans to incorporate the PSD rule changes.
INFORMATION COLLECTION REQUEST FOR CHANGES TO 40 CFR PART 51 AND 52: 

Prevention of Significant Deterioration (PSD) for Particulate Matter Less Than 2.5 Micrometers (PM2.5) –

Increments, Significant Impact Levels (SILs) and Significant Monitoring Concentration (SMC)

Page 3

Title I of the Act authorizes EPA to collect this information. Through the 

PSD program it requires owners or operators of emissions units that emit 

air pollutants to submit an application for a permit to construct, modify, or 

significantly alter the operations of each source of criteria pollutants.

For EPA to carry out its required oversight function of reviewing 

construction permits and assuring adequate implementation of the program, 

it must have available to it information on proposed construction and 

modifications. The burden estimates included in this ICR cover activities 

to provide PM2.5 air quality impact projections for the PSD program.

The information in this ICR is based upon the best data available to the 

Agency at this time. However, inconsistencies in reviewing authority

reporting techniques, incomplete data sets, and sampling limitations 

necessitated a certain amount of extrapolation and “best-guess” 

estimations. Consequently, the reader should not consider the conclusions 

to be an exact representation of the level of burden or cost that will occur. 

Instead, this ICR should be considered a directionally correct assessment of 

the impact the programmatic changes included in this rulemaking.

In fact, this ICR clearly overstates the impact of the PM2.5 Increments 

rulemaking over the 3 years following promulgation because it has been 

prepared as if the rule revisions would be fully implemented upon the 

effective date of the rule. In actuality, the full effect of these PSD rule 

changes for PM2.5 will lag the promulgation of this rule due to the time 

needed for state and local agencies with approved PSD programs to modify 

their Implementation Plans. We believe that this approach provides a more 

realistic assessment of the long-term impact of the rulemaking.

Throughout this ICR, the reader will observe estimated values that show 

accuracy to the single hour or dollar. However, reporting values at the 

single unit level can be misleading. In most situations, the proper way to 

present estimated data would be to determine an appropriate level of 

accuracy and truncate values accordingly, usually in terms of thousands or 

millions of units. For instance, a spreadsheet-generated estimation of 

$5,456,295 could be presented in the text as $5.5 (millions) or $5,456 

(thousands). One problem with such an approach is the loss of data 

richness when the report contains a mixture of very large and very small 

numbers, which is the case with this ICR. Consequently, to avoid the loss 

of information through rounding, this ICR reports all values to the single

unit, and we remind the reader that there is no implied precision inherent in 

this style of reporting.

2.1 Need / Authority 

for the Collection

2.2 Practical Utility / 

Users of the Data

2.3 Caveats and 

Considerations

2 Need For and Use of Collection
INFORMATION COLLECTION REQUEST FOR CHANGES TO 40 CFR PART 51 AND 52: 

Prevention of Significant Deterioration (PSD) for Particulate Matter Less Than 2.5 Micrometers (PM2.5) –

Increments, Significant Impact Levels (SILs) and Significant Monitoring Concentration (SMC)

Page 4

For approval of a proposed ICR, the Agency must ensure that it has taken 

every reasonable step to avoid duplication in its paperwork requirements in 

accordance with 5 CFR 1320.9. Although the reviewing authorities may be 

required to revise their Implementation Plans, this action imposes no new 

paperwork requirements. 

The proposal notice for this rulemaking was published in the Federal 

Register on September 21, 2007 (72 FR 54112). A 60-day public comment 

period was provided for this ICR, during which all affected parties were 

given the opportunity to comment on the burden analysis. No comments 

on the ICR were received.

In an earlier proposed rulemaking,1 we solicited comment on the 

programmatic aspects of PM2.5 increments, SILs, and SMCs. We received 

numerous comments from sources and state and local reviewing authorities

on the need for these elements in the PM2.5 PSD program and the level of 

effort associated with them. We considered these comments in developing 

this ICR.

The Act defines the rate of reporting by sources, states, and local entities. 

Consequently, less frequent collection is not possible.

The OMB’s general guidelines for information collections must be adhered 

to by all federal agencies for approval of any rulemaking’s collection 

methodology. In accordance with the requirements of 5 CFR 1320.5, the 

Agency believes:

1. The PM2.5 Increments Rule does not require periodic reporting more 

frequently than semi-annually.

2. The PM2.5 Increments Rule does not require respondents to 

participate in any statistical survey.

3. Written responses to Agency inquiries are not required to be 

submitted in less than 30 days.

4. Special consideration has been given in the design of the PM2.5

Increments Rule to ensure that the requirements are, to the greatest 

extent possible, the same for federal requirements and those 

reviewing authorities who already have PSD programs in place.

 

1 “Proposed Rule to Implement the Fine Particle National Ambient Air Quality 

Standards,” 70 FR 65984, November 1, 2005.

3 Non-Duplication, Consultation, and Other Collection Criteria

3.1 Non-Duplication

3.2 Public Notice 

Requirements

3.3 Consultations

3.4 Less Frequent

Collection

3.5 General

Guidelines
INFORMATION COLLECTION REQUEST FOR CHANGES TO 40 CFR PART 51 AND 52: 

Prevention of Significant Deterioration (PSD) for Particulate Matter Less Than 2.5 Micrometers (PM2.5) –

Increments, Significant Impact Levels (SILs) and Significant Monitoring Concentration (SMC)

Page 5

5. Confidential, proprietary, and trade secret information necessary for 

the completeness of the respondent’s permit are protected from 

disclosure under the requirements of section 114(c) of the Act.

6. The PM2.5 Increments Rule does not require more that one original 

and two copies of the permit application, update, or revision to be 

submitted to the Agency.

7. Respondents do not receive remuneration for the preparation of 

reports required by the Act or 40 CFR part 51 or 52.

8. To the greatest extent possible, the Agency has taken advantage of 

automated methods of reporting.

9. The Agency believes the impact of the PM2.5 Increments Rule on 

small entities to be insignificant and not disproportionate.

The recordkeeping and reporting requirements contained in the PM2.5

Increments Rule do not exceed any of the Paperwork Reduction Act 

guidelines contained in 5 CFR 1320.5, except for the guideline which limits 

retention of records by respondents to 3 years. The Act requires both 

respondents and state or local agencies to retain records for a period of 

5 years. The justification for this exception is found in 28 U.S.C. 2462, 

which specifies 5 years as the general statute of limitations for federal 

claims in response to violations by regulated entities. The decision in U.S. 

v. Conoco, Inc., No. 83-1916-E (W.D. Okla., January 23, 1984) found that 

the 5-year general statute of limitations applies to the Clean Air Act.

Confidentiality is not an issue for this rulemaking. To the extent that the 

information required in a PSD permit under the PM2.5 Increments Rule is 

proprietary, confidential, or of a nature that could impair the ability of the 

source to maintain its market position, that information is collected and 

handled subject to the requirements of section 114(c) of the Act. 

Information received and identified by owners or operators as confidential 

business information (CBI) and approved as CBI by EPA, in accordance 

with Title 40, Chapter 1, Part 2, Subpart B, shall be maintained 

appropriately (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended 

by 43 FR 39999, September 8, 1978; 43 FR 42251, September 28, 1978; 

44 FR 17674, March 23, 1979).

The consideration of sensitive questions, (i.e., sexual, religious, personal,

or other private matters), is not applicable to this rulemaking. The 

information gathered to establish a PSD permit does not include personal 

data on any owner or operator.

The President’s priorities in promoting environmental justice (EJ) are 

contained in Executive Order 12898. Because the PSD program operates 

nationwide and across all industry classifications, the Agency does not 

believe there is a disproportionate EJ effect in the PSD program. 

3.6 Confidentiality

3.7 Sensitive 

Questions

3.8 Environmental 

Justice 

Considerations
INFORMATION COLLECTION REQUEST FOR CHANGES TO 40 CFR PART 51 AND 52: 

Prevention of Significant Deterioration (PSD) for Particulate Matter Less Than 2.5 Micrometers (PM2.5) –

Increments, Significant Impact Levels (SILs) and Significant Monitoring Concentration (SMC)

Page 6

Table 4-1 lists the industrial groups that we expect will contain the 

majority of the industrial respondents affected by the NSR program. These 

categories were chosen because of their historic relative incidence in 

seeking NSR permits as established in prior ICRs and confirmed by a 

nationwide air pollutant emission inventory developed by the EPA in 1986-

87. These industries have been used as the basis for impact analysis since 

that inventory. 

Table 4-1. Most Numerous Industrial Respondents by Industrial Group

Industry Group SIC NAICS

Electric Services 491 221111, 221112, 221113, 221119, 221121, 221122

Petroleum Refining 291 32411

Industrial Inorganic Chemicals 281 325181, 32512, 325131, 325182, 211112, 325998, 331311, 325188

Industrial Organic Chemicals 286 32511, 325132, 325192, 325188, 325193, 32512, 325199

Miscellaneous Chemical Products 289 32552, 32592, 32591, 325182, 32551

Natural Gas Liquids 132 211112

Natural Gas Transport 492 48621, 22121

Pulp Mills 261 32211, 322121, 322122, 32213

Paper Mills 262 322121, 322122

Automobile Manufacturing 371 336111, 336112, 336712, 336211, 336992, 336322, 336312, 33633, 

33634, 33635, 336399, 336212, 336213

Pharmaceuticals 283 325411, 325412, 325413, 325414

The respondents also include state and local air regulatory agencies. 

Because of the national scope of the PSD program, these governmental 

respondents are in all 50 states.

This section discusses the data items that must be collected and reported

and the activities that respondents must carry out under the PM2.5

Increments Rule.

The data required from sources for a complete PSD permit application can 

be found in parts 51 and 52 of title 40 of the Code of Federal Regulations 

(40 CFR). Section 51.166 specifies the minimum requirements that a PSD 

permit program under title I, part C of the Act must contain to warrant 

approval as a revision to an Implementation Plan. Section 52.21 delineates 

the federal PSD permit program which applies to all federally controlled 

areas, such as tribal lands, outer continental shelf sources, and states that 

4 The Respondents and the Information Requested

4.1 Respondents/SIC 

and NAICS Codes

4.2.1 Data items, 

including 

recordkeeping 

requirements 

4.2 Information 

Requested
INFORMATION COLLECTION REQUEST FOR CHANGES TO 40 CFR PART 51 AND 52: 

Prevention of Significant Deterioration (PSD) for Particulate Matter Less Than 2.5 Micrometers (PM2.5) –

Increments, Significant Impact Levels (SILs) and Significant Monitoring Concentration (SMC)

Page 7

have not submitted a PSD program meeting the requirements of 40 CFR 

51.166.2

Respondent data and information requirements for PSD permits can be 

found in the Supporting Statement for the 2008 ICR renewal for the entire 

major NSR program (ICR No. 1230.23, OMB Control Number 2060-

0003), including appropriate references in 40 CFR part 51 for the data and 

information requirements that govern the way states implement NSR 

programs.3

The data requirements associated with the PM2.5 Increments Rule are a 

small subset of the total data required for PSD permits. Specifically, this 

rule enables the air quality impact analyses that already must be carried out 

for other significant pollutants to be implemented for PM2.5. Thus, when 

the rule is implemented, the modeling analyses required by 40 CFR 

51.166(k) and (l) or 52.21(k) and (l), whichever is applicable, will have to 

be conducted by sources for PM2.5 and submitted for review by reviewing 

authorities.

The Supporting Statement for the 2008 ICR renewal for the entire major 

NSR program (ICR No. 1230.23) identifies the activities for PSD

permitting for source and reviewing authority respondents.

4

 For source

respondents, the activities are divided into three broad categories: 

(1) preparation and planning, (2) data collection and analysis, and 

(3) permit application. The PM2.5 Increments Rule will add new burden for 

the data collection and analysis category as sources will have to conduct 

these activities for PM2.5.

Reviewing authority respondents’ activities involve interacting with the 

source during its preparation of an application, reviewing the application 

and making a determination, implementing the public notice and comment 

process, issuing the permit, and transmitting information to EPA. The 

PM2.5 Increments Rule will add new burden for attending pre-application 

meetings, answering sources’ questions, and logging in and reviewing data 

 

2 These citations can be accessed from the electronic Code of Federal Regulations 

(eCFR) website at: http://ecfr.gpoaccess.gov/cgi/t/text/textidx?sid=15afbd009d0485fc06fb4f566f3bfc3b&c=ecfr&tpl=/ecfrbrowse/Title40/4

0tab_02.tpl

3 United States Environmental Protection Agency. Information Collection Request 

for Prevention of Significant Deterioration and Nonattainment New Source 

Review (40 CFR Part 51 And 52). ICR No. 1230.23. 2008. Appendix A.

4 United States Environmental Protection Agency. Information Collection Request 

for Prevention of Significant Deterioration and Nonattainment New Source 

Review (40 CFR Part 51 And 52). ICR No. 1230.23. 2008. Pages 17 and 18.

4.2.2 Respondent 

activities
INFORMATION COLLECTION REQUEST FOR CHANGES TO 40 CFR PART 51 AND 52: 

Prevention of Significant Deterioration (PSD) for Particulate Matter Less Than 2.5 Micrometers (PM2.5) –

Increments, Significant Impact Levels (SILs) and Significant Monitoring Concentration (SMC)

Page 8

submissions, as reviewing authorities will have to conduct these activities 

for PM2.5.

In addition to the activities associated with reviewing and issuing major 

NSR permits under the revised regulations, reviewing authority 

respondents may have to revise their Implementation Plans to add 

increments, SILs, and an SMC for PM2.5 to their PSD programs.
INFORMATION COLLECTION REQUEST FOR CHANGES TO 40 CFR PART 51 AND 52: 

Prevention of Significant Deterioration (PSD) for Particulate Matter Less Than 2.5 Micrometers (PM2.5) –

Increments, Significant Impact Levels (SILs) and Significant Monitoring Concentration (SMC)

Page 9

The Supporting Statement for the 2008 ICR renewal for the entire major 

NSR program (ICR No. 1230.23) identifies EPA’s activities associated 

with PSD permitting.5 These activities generally involve oversight review 

of PSD permitting actions to verify that the requirements of the Act and the 

implementing part 51 and 52 regulations are being met. The PM2.5

Increments Rule will add new burden for oversight review of air quality

analyses. In addition, EPA will have to review the Implementation Plan 

revisions submitted by the reviewing authorities.

The owner or operator of a new or modified major stationary source 

affected by the PM2.5 Increments Rule must conduct PM2.5 air quality

analyses and submit the data and conclusions in a construction permit 

application to the reviewing authority, who logs in the permit application, 

stores the application in a central filing location, notifies the Federal Land 

Manager (FLM) of the permit, and provides a copy of the application (if 

applicable) to the FLM and transmits a copy of each application to EPA.

The reviewing authority reviews the PM2.5 air quality analyses and checks 

the quality of data submitted by the applicant on a case-by-case basis. The 

applicant will be required to submit information on how the data were 

obtained and how the calculations and modeling were performed. The 

reviewing authority personnel will check data quality by reviewing the 

modeling documentation and checking engineering calculations. 

Confidential information submitted by the applicant (if any) will be 

handled by the reviewing authority’s confidential information handling 

procedures. The public will be provided the opportunity to review a permit 

application and other materials relevant to the reviewing authority’s 

decision on issuing the permit, including FLM findings, by obtaining a 

copy from the permit reviewing authority or by attending the public 

hearing. The PM2.5 Increments Rule will not require information through 

any type of survey. 

The Regulatory Flexibility Act (RFA) requires regulatory agencies, upon 

regulatory action, to assess that action’s potential impact on small entities 

(businesses, governments, and small non-governmental organizations) and 

report the results of the assessments in (1) an Initial Regulatory Flexibility

Analysis (IRFA), (2) a Final Regulatory Flexibility Analysis (FRFA), and 

(3) a Certification. For ICR approval, the Agency must demonstrate that it 

“has taken all practicable steps to develop separate and simplified 

 

5 United States Environmental Protection Agency. Information Collection Request 

for Prevention of Significant Deterioration and Nonattainment New Source 

Review (40 CFR Part 51 And 52). ICR No. 1230.23. 2008. Page 19.

5 The Information Collected - Agency Activities, Collection Methodologies, and 

Information Management

5.2 Collection 

Methodology

and

Management

5.3 Small Entity

Flexibility

5.1 Agency

Activities
INFORMATION COLLECTION REQUEST FOR CHANGES TO 40 CFR PART 51 AND 52: 

Prevention of Significant Deterioration (PSD) for Particulate Matter Less Than 2.5 Micrometers (PM2.5) –

Increments, Significant Impact Levels (SILs) and Significant Monitoring Concentration (SMC)

Page 10

requirements for small businesses and other small entities” (5 CFR 

1320.6(h)). In addition, the agencies must assure through various 

mechanisms that small entities are given an opportunity to participate in the 

rulemaking process. 

A Regulatory Flexibility Act Screening Analysis (RFASA) developed as 

part of a 1994 draft Regulatory Impact Analysis (RIA) and incorporated 

into the September 1995 ICR renewal analysis reported an initial regulatory 

flexibility screening analysis showed that the changes to the NSR program 

due to the 1990 Clean Air Act amendments would not have an adverse 

impact on small entities.6This analysis encompassed the entire universe of 

applicable major sources that were likely to also be small businesses. The 

Agency estimates there are approximately 50 “small business” major 

sources.7 Because the administrative burden of the NSR program is the 

primary source of the NSR program’s regulatory costs, the analysis 

estimated a negligible “cost to sales” (regulatory cost divided by the 

business category mean revenue) ratio for this source group. The new 

burden resulting from the PM2.5 Increments Rule is small compared to the 

overall burden of the PSD program. Thus, there is no economic basis for a 

different conclusion regarding the PM2.5 Increments Rule.

The Agency may not, under any circumstances, exempt a major source of 

air pollution from the requirements of PSD. Since the impacts of PSD

regulations which may impact small entities occur predominantly at major 

sources, little room exists for regulatory flexibility to avert the impact of 

the proposed rulemaking on small entities through exemption. 

Even though the PSD program does not have an adverse impact on a 

significant number of small businesses, EPA takes measures to assist 

sources in affected small entities through the implementation of small 

business stationary source technical and environmental compliance 

assistance programs, as called for in section 507 of the Act. These 

programs reduce the reporting burden of small entities that are subject to 

PSD and may significantly alleviate the economic burden on small sources 

by (1) establishing programs to assist small businesses with determining 

what Act requirements apply to their sources and when they apply, and (2) 

providing guidance on alternative control technology and pollution 

prevention for small businesses.

 

6 “Economic Assessment of the Impacts of Part C and D Regulatory Changes,” 

June 2, 1994.

7 The definition for “small business” employed for all SIC categories in this 

analysis was any business employing fewer than 500 employees. 

5.3.1 Measures to avert 

impacts on small 

entities

5.3.2 Measures to 

mitigate impacts 

on small entities
INFORMATION COLLECTION REQUEST FOR CHANGES TO 40 CFR PART 51 AND 52: 

Prevention of Significant Deterioration (PSD) for Particulate Matter Less Than 2.5 Micrometers (PM2.5) –

Increments, Significant Impact Levels (SILs) and Significant Monitoring Concentration (SMC)

Page 11

Respondents are not subjected to a collection schedule per se under the 

PSD regulations. In general, each major stationary source is required to 

submit an application as a prerequisite to receiving a construction permit. 

Preparation of a major source construction permit application is a one-timeonly activity for each project involving construction of a new major 

stationary source or major modification of an existing major stationary

source. The applicable Implementation Plan typically states the time 

period that is necessary to process a permit application and issue a permit.

Consequently, a prospective source would be obliged to work backward 

from the desired commencement date for construction to determine the 

optimum submittal date for the application. 

5.4 Collection

Schedule
INFORMATION COLLECTION REQUEST FOR CHANGES TO 40 CFR PART 51 AND 52: 

Prevention of Significant Deterioration (PSD) for Particulate Matter Less Than 2.5 Micrometers (PM2.5) –

Increments, Significant Impact Levels (SILs) and Significant Monitoring Concentration (SMC)

Page 12

Burden means the total time, effort, or financial resources expended by 

persons to generate, maintain, retain, or disclose or provide information to 

or for a federal agency. This includes the time needed to review 

instructions; develop, acquire, install, and utilize technology and systems 

for the purposes of collecting, validating, and verifying information, 

processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously

applicable instructions and requirements; train personnel to be able to 

respond to a collection of information; and transmit or otherwise disclose 

the information. In addition to the labor hours expended by the 

respondents, the burden estimate should include: (1) total capital and startup costs annualized over the useful life of the purchased equipment, and 

(2) total costs for operation, maintenance, and purchases of services. Each 

component should be divided into burden borne directly by the respondent 

and any services that are contracted out.

This section discusses the development of burden estimates and their 

conversion into costs, which are separated into burden costs and capital and 

operating and maintenance (O&M) costs. According to the latest guidance 

for ICRs (EPA 2005), capital and O&M costs display the cost of any new 

capital equipment the source or reviewing authority may have to purchase 

solely for information collection, assimilation, and storage purposes. For 

example, if a source had to purchase a new computer to store and 

manipulate data, that computer would be a cost of administration subject to 

reporting in the ICR. In addition, the latest guidance instructs the Agency

to differentiate the burden associated with a source’s labor and that which it 

hires through outside contractors. To the extent a source contracts out for 

administrative purposes (e.g., employing consultants to perform modeling 

functions), the burden associated with those contracted tasks are not a 

burden to the source - but they still remain a cost. The reader should read 

this section with the following considerations in mind:

• The Agency believes the time necessary to perform a task is 

independent of the origins of its labor. In other words, if a 

source would employ 20 hours of burden to fully perform a 

function, then a contractor hired by the source would also take 

20 hours to perform that same task. Furthermore, the Agency

assumes no economies or diseconomies of scale. The linear 

combination of any amount of contractor and source effort will 

also sum to 20. Therefore, the burden estimates in this ICR act 

as an assessment of the total burden to affected sources and 

reviewing authorities, given the affected entity does not employ

contracted labor.

6 Estimating the Burden and Cost of the Collection
INFORMATION COLLECTION REQUEST FOR CHANGES TO 40 CFR PART 51 AND 52: 

Prevention of Significant Deterioration (PSD) for Particulate Matter Less Than 2.5 Micrometers (PM2.5) –

Increments, Significant Impact Levels (SILs) and Significant Monitoring Concentration (SMC)

Page 13

• For some burden categories, the Agency believes the hours 

assigned to them will be divided between the source and outside 

contractors. For these categories, the Agency established a 

composite cost per hour by developing a weighted average of 

the source and contractor wages, with the weight defined by the 

percentage of total effort each burden source applied. 

Consequently, the cost developed in this ICR should be 

interpreted as an upper bound on the actual cost of 

administration by the source or reviewing authority. The 

methodology for determining cost per hour can be found in 

greater detail in section 6.2, below.

The requirements of the PSD program apply to new or modified sources on 

a pollutant-by-pollutant basis (for those pollutants for which the area is 

designated as attainment or unclassifiable). That is, a source must meet the 

requirements of the program for each pollutant that it will emit in amounts 

greater than the applicable threshold, and must address each such pollutant 

in its permit application. Thus, PSD permitting actions very often involve 

more than one pollutant.

The PM2.5 Increments Rule adds increments, SILs, and an SMC for PM2.5

to the PSD program. When the rule is implemented, sources will be 

required to conduct the air quality impact analyses for PM2.5 that they are 

already required to conduct for other pollutants. Thus, the rule will add 

new burden as sources and reviewing authorities carry out the activities 

associated with such analyses for PM2.5.

8

Under PSD, sources are generally required to conduct dispersion modeling 

to determine the air quality impacts of the criteria pollutants that they emit 

in significant quantities.9 Up until now, the lack of PM2.5 increments, SILs, 

 

8 The PM2.5 SILs and SMC are actually de minimis levels that can reduce the 

number and/or complexity of the air quality analyses for PM2.5 that must be 

carried out through modeling and monitoring, respectively. Thus, they work to 

lessen the burden and cost that result from the addition of PM2.5 to the PSD 

program. The PSD program currently uses SILs and SMCs for other regulated

pollutants, as well, and the approved ICR for the major NSR program 

incorporates their impact on the average burden and cost of PSD permits without 

addressing them directly. Because in this ICR we derive the burden and cost of 

adding PM2.5 increments, SILs, and the SMC to the PSD program relative to the 

approved ICR, we also do not address the impact of the PM2.5 SILs and SMC 

directly.

9 “Criteria pollutants” are those for which NAAQS have been established, i.e., 

ozone, nitrogen dioxide (NO2), sulfur dioxide (SO2), carbon monoxide (CO),

lead, PM10, and PM2.5. Ozone is not emitted directly, but is formed in the 

atmosphere by complex photochemical reactions involving volatile organic 

compounds (VOCs) and oxides of nitrogen (NOx). Impact modeling is not 

6.1 Estimating 

Respondent 

Burden
INFORMATION COLLECTION REQUEST FOR CHANGES TO 40 CFR PART 51 AND 52: 

Prevention of Significant Deterioration (PSD) for Particulate Matter Less Than 2.5 Micrometers (PM2.5) –

Increments, Significant Impact Levels (SILs) and Significant Monitoring Concentration (SMC)

Page 14

and SMCs have prevented sources from carrying out the full range of air 

quality impact analyses that would otherwise have been required for 

significant sources of PM2.5. Instead, in accordance with our stated policy, 

sources and reviewing authorities have used PM10 analyses as a surrogate 

for PM2.5. As a result of the PM2.5 Increments Rule, we expect most PM2.5

sources to be required to carry out modeling analyses for both PM2.5 and 

PM10 (as well as any other criteria pollutants that they emit), resulting in a 

new burden to obtain a PSD permit. In addition, a corresponding new 

burden will result for reviewing authority respondents to review permit 

applications and issue permits.

To estimate the magnitude of the permitting burden that will result from the 

PM2.5 Increments Rule, we considered two factors: (1) which permitting 

activities are likely to be affected by an increase in the number of air 

quality impact modeling analyses, and (2) the new burden for carrying out 

the affected activities for PM2.5. These factors are discussed further below.

Since the 2008 ICR renewal for the overall NSR program (EPA ICR 

No. 1230.23), the ICR was revised to account for the Flexible Air 

Permitting rule (EPA ICR No. 1230.26). Based on this approved ICR, the 

average burden to a source to obtain a PSD permit is 879 hours. Of these, 

350 hours are associated with data collection and analysis activities, which 

we believe are the activities that will be most affected by an increase in the 

number air quality modeling analyses. Also based on the approved ICR,

the average burden to a reviewing authority for issuing a PSD permit is 

313 hours, of which 75 hours are associated with attending pre-application 

meetings, answering sources’ questions, and logging in and reviewing data 

submissions (the activities most related to air quality modeling analyses).

To determine the new burden per PSD permit for carrying out the affected 

activities for PM2.5, we assumed that PSD permit applicants who would be 

subject to the requirements for PM2.5 currently conduct an average of four 

modeling impact analyses.10 After implementation of the PM2.5 Increments 

 

required for ozone under PSD because existing models are not capable of 

accurately predicting the impacts of a single source.

10 Full modeling analyses must be conducted for each criteria pollutant emitted by 

the source for which PSD increments (i.e., maximum allowable increases above 

baseline ambient concentrations) have been established. These analyses must be 

carried out for each averaging period that has been established for the pollutants. 

Sources subject to PSD for PM2.5 currently must conduct modeling analyses for 

PM10 (as a surrogate for PM2.5) for two averaging periods – annual and 24-hour. 

Some such sources also are subject to PSD for SO2 and/or NOx. Sources subject 

for SO2 must conduct analyses for three averaging periods (annual, 24-hour, and 

3-hour), while NOx sources only need to conduct an analysis for the annual 

averaging period. To account for overlapping SO2 and NOx applicability, we 

believe it is a reasonable assumption that PM2.5 sources must conduct an average 
INFORMATION COLLECTION REQUEST FOR CHANGES TO 40 CFR PART 51 AND 52: 

Prevention of Significant Deterioration (PSD) for Particulate Matter Less Than 2.5 Micrometers (PM2.5) –

Increments, Significant Impact Levels (SILs) and Significant Monitoring Concentration (SMC)

Page 15

Rule, we believe that this number will increase by two (i.e., by 50 percent) 

to an average of six such analyses.11 Thus, for sources subject to PSD 

permitting for PM2.5, the new, additional burden associated with the 

affected activities will be 50 percent of the currently approved burden. We 

assumed the same percent increase for reviewing authorities where PSD 

permits must address PM2.5.

However, not all sources that must obtain a PSD permit will be subject to 

PSD for PM2.5. To estimate the percentage of permits that will have to 

address PM2.5, we consulted the RBLC to determine what percentage has 

historically been subject to major NSR for particulate matter.12 We found 

that over a 10-year period, approximately 60 percent of facilities that 

obtained control technology determinations obtained a determination for 

particulate matter. We used this percentage as a weighting factor to 

determine the weighted average increase in burden for the affected 

activities across all PSD permits (i.e., those that address PM2.5 and those 

that do not). This weighted average is 30 percent (0.60 x 0.50 = 0.30). We 

applied this weighted average burden increase to the affected PSD 

activities for both source respondents and reviewing authority respondents

to determine the average new burden per PSD permit associated with the 

PM2.5 Increments Rule. 

Table 6-1 shows the average new burden per PSD permit for source and 

reviewing authority respondents. As the table shows, we estimate an 

average burden for sources of 105 hours per PSD permit. Based on the 

current approved total burden for a PSD permit (879 hours), this represents 

an increase of about 12 percent. For reviewing authorities, we estimate an 

average burden of 22 hours per permit, or about 7 percent of the current 

approved total burden of 313 hours.

Table 6-1. Burden for Source and Reviewing Authority Respondents, Hours per PSD Permit

 

total of four modeling analyses (prior to the PM2.5 Increments Rule) – two for 

PM10 and an average of two for SO2 and/or NOx.

11 Under the PM2.5 Increments Rule, sources subject to PSD for PM2.5 will be 

required to conduct PM2.5 modeling analyses for two averaging periods – annual 

and 24-hour. Because most such sources also will be subject to PSD for PM10, 

they will also be required to conduct two PM10 modeling analyses, also for annual 

and 24-hour averaging periods. The rule will not affect the average of two 

analyses that we assume for SO2/NOx. Thus, the average total number of 

modeling analyses under the PM2.5 Increments Rule will be six.

12 The Reasonably Available Control Technology (RACT), Best Available Control 

Technology (BACT), Lowest Achievable Emission Rate (LAER) Clearinghouse, 

or RBLC, is a database of RACT/BACT/LAER determinations made in sitespecific permitting analyses. It is generated and updated using information 

provided by state and local permitting agencies.
INFORMATION COLLECTION REQUEST FOR CHANGES TO 40 CFR PART 51 AND 52: 

Prevention of Significant Deterioration (PSD) for Particulate Matter Less Than 2.5 Micrometers (PM2.5) –

Increments, Significant Impact Levels (SILs) and Significant Monitoring Concentration (SMC)

Page 16

Type of Respondent Activities Affected

Approved Burden 

Absent PM2.5 Increments 

Rule (hours)

Additional Burden 

Resulting from PM2.5

Increments Rule (hours)

Sources Data collection and analysis 350 105

Reviewing authorities Attending pre-application meetings

Answering sources’ questions

Logging in and reviewing data submissions

Total

38

21

16

75

11

6

5

22

In addition to issuing permits, the reviewing authorities must ensure that 

their PSD programs meet the requirements that EPA specifies for such 

programs pursuant to part C. The PM2.5 Increments Rule revises these 

requirements. Therefore, each reviewing authority must submit changes to 

its existing Implementation Plan program or demonstrate that its existing 

program is no less stringent than EPA’s new requirements. Because the 

changes needed for updating Implementation Plans are small and the 

requirements for Implementation Plan development differ from state to 

state, the EPA assumed it would take no more than 40 hours for each 

reviewing authority to fully incorporate this rulemaking into its plan. This 

assumption includes legislative review, public comment, and all legal and 

legislative processes necessary for all of the above components. This is a 

one-time burden that will occur during the 3-year period covered by this 

ICR. 

In order to allow a direct cost comparison with the existing approved ICR 

for the major NSR program (i.e., EPA ICR No. 1230.26), we use the same

cost factors in this ICR. These cost factors are laid out below.

As in the currently approved ICR for the major NSR program, the hourly

labor rate for source respondents used for this analysis is $97.61 per hour. 

Similarly, the labor rate used in this analysis for reviewing authority 

respondents is $77.22 per hour.

Capital/start-up and O&M costs are non-labor related costs. One-time 

capital/start-up costs are incurred with the purchase of durable goods 

needed to provide information. According to the Paperwork Reduction 

Act, capital/start-up cost should include among other items, preparations 

for collecting information such as purchasing computers and software, 

monitoring, sampling, drilling, and testing equipment.

Even if an applicant is a brand new company and the prospective source is 

a “greenfield” source (the EPA estimates less than 1 percent of source

respondents fit that description) most, and perhaps all, of the equipment 

needed to prepare permit applications (for example, the computers and 

basic software) will be part of the source’s business operation inventory. 

Furthermore, the models for performing ambient air impact analyses are 

6.2 Estimating 

Respondent 

Costs

6.2.1 Estimating 

labor costs

6.2.2 Estimating 

capital/start-up 

and O&M costs, 

including 

purchase of 

services
INFORMATION COLLECTION REQUEST FOR CHANGES TO 40 CFR PART 51 AND 52: 

Prevention of Significant Deterioration (PSD) for Particulate Matter Less Than 2.5 Micrometers (PM2.5) –

Increments, Significant Impact Levels (SILs) and Significant Monitoring Concentration (SMC)

Page 17

available in electronic form from several different EPA web sites for just 

the Internet access charges, which are typically absorbed in routine 

business overhead expenses. Thus, the PM2.5 Increments Rule will not 

cause any new capital costs to be incurred by any respondents.

In the 2008 ICR renewal for the entire major NSR program (EPA ICR 

No. 1230.23), EPA estimated that 34 PSD permit applicants are required to 

conduct preconstruction ambient monitoring each year at an average cost of 

approximately $335,000, and this estimate was unchanged in the current 

approved ICR for the program (EPA ICR No. 1230.26). This cost is 

considered a start-up, direct cost associated with preparing a permit 

application (not a fixed capital cost) because we believe that most sources 

contract out this activity, which is generally a one-time exercise. Based on 

this assumption, the cost of capital equipment for preconstruction 

monitoring is negligible. Because the effect of adding PM2.5 to the major 

NSR program on the start-up cost associated with preconstruction 

monitoring was previously accounted for in the ICR for the 2008 PM2.5

NSR Implementation Rule (EPA ICR No. 1230.21), we do not believe that 

the PM2.5 Increments Rule will have any effect on this cost. 

Since the purchase of capital equipment is believed to be an insignificant 

factor in permit application preparation, we assume that the O&M and

services for same are negligible. Further, once a permit is issued, there is 

no O&M cost associated with it. It remains unaltered unless the source or 

the reviewing authority discovers specific reasons to reexamine it and 

change any conditions or specifications. If purely administrative, the 

changes are handled exclusively by the reviewing authority. If changes 

have the potential for environmental consequences, the action may be 

significant enough to be counted as a separate and new application, to 

which a new burden and cost may be ascribed.

Typically, annualized capital cost would be derived from a discounted net 

present value of the stream of costs that would occur over the life of the 

permit, or the ICR, whichever is shorter. However as discussed above, 

there are no capital costs in the case of the PM2.5 Increments Rule. 

Therefore, the annualized capital costs for this ICR to industry respondents 

are zero.

Staff in EPA’s Regional Offices typically review PSD permits. Based on

the currently approved ICR for the overall NSR program (ICR 

No. 1230.26), the average EPA burden per PSD permit is 15 hours. Under 

the PM2.5 Increments Rule we expect an additional burden of 1 hour per 

permit associated with our review of additional PM2.5 air quality modeling 

analyses. This new burden was derived as discussed above in section 6.1 

for the source and reviewing authority burden increases. That is, for those 

6.2.3 Annualized

capital costs

6.3 Estimating 

Agency Burden 

and Cost
INFORMATION COLLECTION REQUEST FOR CHANGES TO 40 CFR PART 51 AND 52: 

Prevention of Significant Deterioration (PSD) for Particulate Matter Less Than 2.5 Micrometers (PM2.5) –

Increments, Significant Impact Levels (SILs) and Significant Monitoring Concentration (SMC)

Page 18

activities that will be affected by the number of modeling analyses

conducted for a PSD permit, the weighted average burden per permit will 

increased by 30 percent. The additional 1 hour of EPA burden will 

amounts to about 7 percent of the currently approved EPA burden for PSD 

permits.

To facilitate cost comparisons between this ICR revision and the currently

approved ICR for the NSR program (EPA ICR No. 1230.26), we have used 

the same federal labor rate, $43.17 per hour.

In addition, there will be Agency burden to review the revised 

Implementation Plans submitted by the reviewing authorities to verify that 

the revisions fully meet the requirements of the PSD program, as changed 

by the PM2.5 Increments Rule. Due to the nature of the Implementation 

Plan revisions needed, the Agency expects that each Implementation Plan

revision will require about 5 hours of review. We expect this one-time 

burden to occur during the period covered by this ICR.

For the purpose of estimating the total burden in this ICR, the respondent 

universe is defined by the annual number of permit applications prepared 

by sources and the number of reviewing authorities that must process such 

permit applications. It also includes the number of reviewing authorities

that will have to revise their Implementation Plans.

As discussed above in section 6.1, the PM2.5 Increments Rule will result in 

addition burden per PSD permit. However, we do not believe that the 

number of permits will be affected because the rule does not affect PSD 

applicability. For this reason, this analysis uses the number of PSD permits 

(274 per year) that results from implementation of the Flexible Air 

Permitting rule, as set out in EPA ICR No. 1230.26. For purposes of this 

ICR, we carried out the analysis as if the PM2.5 Increments Rule would be 

fully implemented immediately upon promulgation. That is, we have 

allowed for no lag time for reviewing authorities to submit Implementation 

Plan revisions and for EPA to review and approve the revisions. This 

approach results in a “worst-case” analysis for the 3-year period covered by 

this ICR, but more accurately reflects the long-term impacts of the rule.

For the number of respondent reviewing authorities associated with major 

NSR permitting and Implementation Plan revisions, we used the 

112 reviewing authority count used by other permitting ICRs. Again, we 

carried out this “worst-case” analysis as if all reviewing authorities would 

begin issuing PSD permits for PM2.5 immediately, with no lag time for 

Implementation Plan revisions. We also included the reviewing 

authorities’ burden for revising the Implementation Plans in this ICR.

6.4 Estimating the 

Respondent 

Universe and Total 

Burden and Cost

6.4.1 Estimating the 

number of 

respondents
INFORMATION COLLECTION REQUEST FOR CHANGES TO 40 CFR PART 51 AND 52: 

Prevention of Significant Deterioration (PSD) for Particulate Matter Less Than 2.5 Micrometers (PM2.5) –

Increments, Significant Impact Levels (SILs) and Significant Monitoring Concentration (SMC)

Page 19

Based on the estimates presented above for the new burden for PSD 

permits, the labor rates for source and reviewing authority respondents, and 

the number of respondents, we have estimated the total burden and costs

that will result from the PM2.5 Increments Rule. Table 6-2 presents the 

totals for source respondents for each year of the 3 years covered by this 

ICR. Table 6-3 shows the average annual totals for reviewing authority

respondents.

Table 6-2. Annual Burden and Costs for Source Respondents 

Activity

Number of 

Permits per 

Year

Burden per 

Permit

(Hours)

Annual 

Burden

(Hours) Labor Rate Annual Cost

PSD Permitting 274 105 28,770 $97.61/hr $2,808,239

Table 6-3. Annual Burden and Costs for Reviewing Authority Respondents 

Major NSR Permitting

Activity

Number of 

Permits per 

Year

Burden per 

Permit 

(Hours)

Annual 

Burden

(Hours) Labor Rate Annual Cost

PSD Permitting 274 22 6,028 $77.22/hr $465,482

Implementation Plan Revisions

Activity

Number of 

Plan

Revisions

per Yeara

Burden per 

Revision

(Hours)

Average

Annual 

Burdenb

(Hours) Labor Rate

Average

Annual Costc

Revision of Implementation Plan 37.33 40 1,493 $77.22/hr $115,315

Reviewing Authority Totals

TOTAL 7,521 $580,797

a

 Each of the 112 reviewing authorities may submit one Implementation Plan revision to conform their PSD programs to the 

revised rules over the 3-year period covered by this ICR. Thus, the average annual number of such revisions is 112 / 3 = 37.33 

per year.

b Each reviewing authority will revise its Implementation Plan once for a 3-year total burden of 4,480 hours. Average annual 

burden is 4,480 / 3 = 1,493 hours.

c

 Total 3-year cost is 4,480 hours x $77.22 = $345,946. Average annual cost is $345,946 / 3 = $115,315.

Based on the estimates presented above for the federal burden hours for 

each activity, the federal labor rate, and the number of permits and 

Implementation Plan revisions, we have estimated the total average annual 

federal burden and costs that will result from the PM2.5 Increments Rule. 

All of the federal burden and costs are incurred by EPA. Table 6-4

presents the estimated burden and costs.

6.4.2 Estimating total 

respondent 

burden and cost

6.4.3 Estimating total 

federal burden 

and cost
INFORMATION COLLECTION REQUEST FOR CHANGES TO 40 CFR PART 51 AND 52: 

Prevention of Significant Deterioration (PSD) for Particulate Matter Less Than 2.5 Micrometers (PM2.5) –

Increments, Significant Impact Levels (SILs) and Significant Monitoring Concentration (SMC)

Page 20

Table 6-4. Federal Annual Burden and Costs

Major NSR Permitting

Activity

Number of 

Permits per 

Year

Additional

Burden per 

Permit 

(Hours)

Additional 

Annual 

Burden 

(Hours) Labor Rate Annual Cost

PSD Permitting 274 1 274 $43.17/hr $11, 829

Implementation Plan Review

Activity

Number of 

Plans to 

Review per 

Yeara

Burden per 

Plan Review

(Hours)

Average

Annual 

Burdenb

(Hours) Labor Rate

Average 

Annual Costc

Review of Implementation Plans 37.33 5 187 $43.17/hr $8,058

Federal Totals

TOTAL 461 $19,887

a The EPA will review one Implementation Plan revision submitted by each of the 112 reviewing authorities over the 3-year period 

covered by this ICR. Thus, the average annual number of Implementation Plan reviews is 112 / 3 = 37.33 per year.

b

 The EPA will review a total of 112 Implementation Plan revisions for a 3-year total burden of 560 hours. Average annual burden 

is 560 / 3 = 187 hours.

b

 Total 3-year cost is 560 hours x $43.17 = $24,175. Average annual cost is $24,175/ 3 = $8,058.

Table 6-5 displays the annual burden and costs for source and reviewing 

authority respondents that we estimate will result from the PM2.5

Increments Rule, as well as the total across all respondents. Table 6-6

shows the annual burden and costs for the EPA that we estimate will result 

from the PM2.5 Increments Rule.

Table 6-5. Total Estimated Annual Respondent Burden and Costs 

Type of Respondent

Number of 

Responses

Total Burden 

(Hours/Year)

Total Labor 

Costs 

($/Year)

Total Capital 

Costs 

($/Year)

Total Costs 

($/Year)

Sources 274 28,770 $2,808,239 $0 $2,808,239

Reviewing Authoritiesa311.33 7,521 $580,797 $0 $580,797

TOTAL 585.33 36,291 $3,389,036 $0 $3,389,036

a During the 3-year period of this ICR, the 112 reviewing authorities will review 274 PSD permits each year and submit an average 

of 37.33 Implementation Plan revisions per year (112 / 3 = 37.33), for a total of 311.33 responses per year.

Table 6-6. Total Estimated Annual Federal Burden and Costs 

Type of Entity

Number of 

Entities

Total 

Incremental 

Burden 

(Hours/Year)

Total 

Incremental 

Labor Costs 

($/Year)

Total 

Incremental 

Capital Costs 

($/Year)

Total 

Incremental 

Costs 

($/Year)

Federal Agency (EPA) 1 461 $19,887 $0 $19,887

As discussed in the previous sections, the PM2.5 Increments Rule will result 

in new burden associated with obtaining and issuing PSD permits. This 

change in the PSD regulations is necessary under the Clean Air Act 

6.5 Bottom Line 

Burden and Cost

6.6 Reasons for 

Change in 

Burden
INFORMATION COLLECTION REQUEST FOR CHANGES TO 40 CFR PART 51 AND 52: 

Prevention of Significant Deterioration (PSD) for Particulate Matter Less Than 2.5 Micrometers (PM2.5) –

Increments, Significant Impact Levels (SILs) and Significant Monitoring Concentration (SMC)

Page 21

because EPA has, in other rulemakings, promulgated NAAQS for PM2.5 to 

protect the public health and welfare. This new rule adds increments, SILs, 

and an SMC for PM2.5 to the PSD program, but it does not otherwise 

change the requirements of the program. We expect the rule to add to the 

burden associated with applying for and issuing those PSD permits that will 

now involve PM2.5 air quality modeling analyses in addition to analyses for 

other pollutants, but we do not expect any change in the number of PSD

permits that must be issued (i.e., no change in the number of source 

respondents). In addition, reviewing authorities may incur a one-time 

burden to revise their Implementation Plans to incorporate the PSD rule 

changes. The magnitude of the new burden is presented above in 

Tables 6-5 and 6-6.

We estimate that the PM2.5 Increments Rule will result in a total annual 

burden on 274 source respondents of about 29,000 hours and $2,800,000

per year (see Tables 6-2 and 6-5), for an average burden of about 105 hours

and $10,000 per source. For the 112 reviewing authority respondents, we 

estimate that the total annual burden will be about 7,500 hours and 

$580,000 (see Tables 6-3 and 6-5), for an average burden of about 67 hours

and $5,200 per reviewing authority.

Burden means the total time, effort, or financial resources expended by

persons to generate, maintain, retain, or disclose or provide information to 

or for a federal agency. This includes the time needed to review 

instructions; develop, acquire, install, and utilize technology and systems 

for the purposes of collecting, validating, and verifying information, 

processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously

applicable instructions and requirements; train personnel to be able to 

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

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

information. An agency may not conduct or sponsor, and a person is not 

required to respond to, a collection of information unless it displays a 

currently valid OMB control number. The OMB control numbers for 

EPA’s regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the 

provided burden estimates, and any suggested methods for minimizing 

respondent burden, including the use of automated collection techniques, 

EPA has established a public docket for this ICR under Docket ID Number 

EPA-HQ-OAR-2007-0628, which is available for online viewing at 

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

Docket and Information Center in the EPA Docket Center (EPA/DC), EPA 

West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. The 

EPA Docket Center Public Reading Room is open from 8:30 a.m. to 

6.7 Burden

Statement
INFORMATION COLLECTION REQUEST FOR CHANGES TO 40 CFR PART 51 AND 52: 

Prevention of Significant Deterioration (PSD) for Particulate Matter Less Than 2.5 Micrometers (PM2.5) –

Increments, Significant Impact Levels (SILs) and Significant Monitoring Concentration (SMC)

Page 22

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

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

telephone number for the Air Docket is (202) 566-1742. An electronic 

version of the public docket is available at www.regulations.gov. This site 

can be used to submit or view public comments, access the index listing of 

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

public docket that are available electronically. When in the system, select 

“search,” then key in the Docket ID Number identified above. Also, you 

can send comments to the Office of Information and Regulatory Affairs, 

Office of Management and Budget, 725 17th Street, NW, Washington, 

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

Docket ID Number EPA-HQ-OAR-2007-0628 and OMB Control 

Number 2060-NEW in any correspondence.