INFORMATION COLLECTION REQUEST

SUPPORTING STATEMENT

Effluent Limitations Guidelines and New Source Performance Standards for the

Airport Deicing Category

Final Rule

U.S. Environmental Protection Agency

Office of Water

Office of Science and Technology

January 26, 2012

NOTE: EPA is presenting for public comment the estimates 

developed in the original Supporting Statement dated January

26, 2012. The estimates will be updated, reflecting 

consideration of any public comments received, before the final 

submission to OMB for renewal of this Information Collection 

Request. 
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TABLE OF CONTENTS

Page

PART A OF THE SUPPORTING STATEMENT......................................................................... 1

1. Identification of the Information Collection........................................................... 1

a. Title of the Information Collection............................................................. 1

b. Short Characterization/Abstract.................................................................. 1

2. Need for and Use of the Collection......................................................................... 1

a. Need/Authority for the Collection .............................................................. 1

b. Practical Utility/Users of the Data .............................................................. 1

3. Non-Duplication, Consultations, and Other Collection Criteria............................. 2

a. Non-Duplication ......................................................................................... 2

b. Public Notice Required Prior to ICR Submission to OMB ........................ 2

c. Consultations............................................................................................... 2

d. Effects of Less Frequent Collection............................................................ 2

e. General Guidelines...................................................................................... 2

f. Confidentiality ............................................................................................ 2

g. Sensitive Questions..................................................................................... 3

4. The Respondents and the Information Requested .................................................. 3

a. Respondent NAICS Codes.......................................................................... 3

b. Information Requested................................................................................ 3

i. Data Items, Including Record Keeping Requirements.......................... 3

ii. Respondent Activities.......................................................................... 3

5. The Information Collected – Agency Activities, Collection Methodology, and 

Information Management........................................................................................ 3

a. Agency Activities........................................................................................ 3

b. Collection Methodology and Management................................................. 4

c. Small Entity Flexibility............................................................................... 4

d. Collection Schedule .................................................................................... 4

6. Estimating the Burden and Cost of the Collection.................................................. 4

a. Estimating Respondent Burden................................................................... 4

b. Estimating Respondent Costs ..................................................................... 5

i. Estimating Labor Costs......................................................................... 5

ii. Estimating Capital and Operations and Maintenance (O&M) Costs... 5

iii. Capital/Start-up Operating and Maintenance Costs............................ 5

iv. Annualizing Capital Costs .................................................................. 5

c. Estimating Agency Burden and Costs ........................................................ 6

d. Estimating the Respondent Universe and Total Burden Costs................... 6

e. Bottom Line Burden Hours and Cost Tables.............................................. 6

i. Respondent and Agency Burden Hours and Costs ............................... 6

ii. Variations in the Annual Bottom Line................................................. 6

f. Reasons for Change in Burden ................................................................... 7

g. Burden Statement........................................................................................ 7
1

PART A OF THE SUPPORTING STATEMENT

1. Identification of the Information Collection

a. Title of the Information Collection

Effluent Limitations Guidelines and New Source Performance Standards for the Airport 

Deicing Category; Final Rule (40 CFR Part 449). EPA ICR No. 2326.02.

b. Short Characterization/Abstract

This Information Collection Request (ICR) seeks approval of the information 

requirements in the Final Rule for the Effluent Guidelines and Standards for the Airport Deicing 

Category. EPA is promulgating wastewater regulations (effluent guidelines and standards or 

ELGs) for airports that conduct deicing operations. Aircraft are deiced by the spraying of 

chemicals called aircraft deicing fluids (ADF), which contain water pollutants. Airports also 

apply airfield pavement deicing chemicals to runways, taxiways and ramps which similarly

contain water pollutants. 

The rule requires airports to certify that they are not using deicers containing urea for 

airfield pavement deicing operations. EPA and the states will use this information to determine 

permittee compliance with the regulations and administer enforcement actions if needed.

2. Need for and Use of the Collection

a. Need/Authority for the Collection

EPA is promulgating the ELG pursuant to sections 301, 304, 306, 308, 402, 501 and 510 

of the Clean Water Act, as amended; 33 U.S.C. 1311, 1314, 1316, 1318, 1342, 1361 and 1370. 

Airports are required by existing regulations (40 CFR Parts 122-125) to obtain wastewater 

discharge permits (NPDES program) and conduct periodic monitoring of effluent. CWA sec. 

308 provides EPA and the states with explicit authority to require that permittees demonstrate 

compliance with regulatory requirements.

b. Practical Utility/Users of the Data

The users of the data include both the airports and their permit authorities. The rule 

requires airports to certify annually that no urea is used for airfield pavement deicing (i.e. 

runways, taxiways, aprons and ramps). A compliance alternative allows airports to meet an 

effluent limitation for ammonia, and the airport would demonstrate compliance by monitoring 

the effluent.
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3. Non-Duplication, Consultations, and Other Collection Criteria

a. Non-Duplication

The rule does not duplicate other information requirements. In developing the rule, EPA 

reviewed existing NPDES permits held by airports. Permittees do not currently provide data to 

permit authorities on the usage of deicing chemicals. There are no public sources available from 

which a permitting authority would be able to obtain this information; the information must be 

submitted directly from the permittee with a signed certification, for enforcement purposes.

b. Public Notice Required Prior to ICR Submission to OMB

A summary of the ICR for the rule is included in the Airport Deicing ELG Federal 

Register notice.

c. Consultations

EPA met with industry stakeholders and attended airport deicing conferences during the 

development of the rule. Participants included members of the Airports Council InternationalNorth America (ACI-NA), American Association of Airport Executives (AAAE) and Air 

Transport Association (ATA). Stakeholders offered recommendations on the design of airport 

and airline industry questionnaires (OMB No. 2040-0267) that were used to develop data for the 

proposed rulemaking, and discussed EPA's research findings, and related regulatory issues. EPA 

also consulted with the Federal Aviation Administration (FAA). Some stakeholders, as well as 

the general public, submitted comments on the 2009 proposed rule.

d. Effects of Less Frequent Collection

Airport permittees only provide the certification of no use of urea to the permitting 

authority annually. Data submission less frequent than annually would prevent the permitting

authorities from carrying out their duties to enforce the permit requirements. 

e. General Guidelines

The information collection requirements of the rule are in accordance with the Paperwork 

Reduction Act guidelines in 5 CFR 1320.5(d)(2).

f. Confidentiality

Applications for an NPDES permit may contain confidential business information. 

However, EPA does not consider the specific information being requested by the rule to be 

typical of confidential business or personal information. If a respondent does consider this 

information to be of a confidential nature, the respondent may request that such information be 

treated as such. All confidential data will be handled in accordance with 40 CFR 122.7, 40 CFR 

Part 2, and EPA's Security Manual Part III, Chapter 9, dated August 9, 1976.
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g. Sensitive Questions

The rule does not require respondents to divulge information of a sensitive nature, such 

as private or personal information.

4. The Respondents and the Information Requested

a. Respondent NAICS Codes

The respondents affected by this information collection request are commercial airports. 

The North American Industry Classification System (NAICS) identification number applicable

to airport respondents is: 488119: Other Airport Operations. The U.S. Census Bureau describes 

this U.S. industry as establishments primarily engaged in (1) operating international, national, or 

civil airports, or public flying fields or (2) supporting airport operations, such as runway

maintenance services, hangar rental, and/or cargo handling services.

b. Information Requested

i. Data Items, Including Record Keeping Requirements

The rule requires airports to certify that airfield pavement deicers containing urea are not 

used. The compliance alternative establishes effluent limitations for discharges resulting from 

the deicing of airfield pavement and requires an airport to provide monitoring data for ammonia. 

The airport would collect samples at each outfall receiving airfield deicing stormwater and 

provide the analytical results of the samples.

ii. Respondent Activities

For airfield pavement deicing, the airports would prepare a certification letter certifying 

non-use of urea-based deicers. EPA estimates that preparation of the certification letter would 

take 1 hour per airport. For the compliance alternative, airports that use urea-based deicers would

monitor their effluent and provide monitoring reports once a year. These airports would collect 

one sample a day at each deicing outfall impacted for five days a week during the deicing season 

(26 weeks). EPA estimates that up to 37 airports that reported use of urea could be required to 

monitor ammonia on an annual basis.

5. The Information Collected – Agency Activities, Collection Methodology, and 

Information Management

a. Agency Activities

Every airport is currently covered by either EPA’s Multi-Sector General Permit (MSGP), 

an equivalent state general permit, or an individual permit, and the NPDES permitting authorities

already receive, process, and review permit applications, and Notices of Intent (NOIs). 

Permitting authorities will also process and review certifications of non-use of urea-based 

deicers, and monitoring data as applicable.
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b. Collection Methodology and Management

Permittees will submit their certifications in a manner specified by the permitting 

authority. The permitting authority will review the information as part of the compliance review, 

and retain the information in the official permit file.

c. Small Entity Flexibility

The rule affects only a small number of “small” airports. (See section XI.C, Regulatory

Flexibility Act, in the preamble of the final rule.) The reporting requirements discussed in this 

document are intended to give flexibility to airports that must comply with the regulations. 

d. Collection Schedule

The rule requires annual certification of non-use of airfield pavement deicers containing 

urea. The frequency of monitoring requirements for ammonia, for airports choosing the urea 

compliance alternative, would be once a year or as directed by the permitting authority.

6. Estimating the Burden and Cost of the Collection

a. Estimating Respondent Burden

Airports will prepare a certification letter certifying non-use of urea-based deicers for 

airfield pavement deicing. EPA estimates it will take an average of 1 hour to prepare a 

certification letter, and the total respondent hours to prepare the letters is 198 hours.

Airports that elect to use the compliance alternative for airfield pavement are required to 

monitor their discharges and comply with an ammonia limit. EPA anticipates that airports will 

discontinue urea use and prepare certification letters, as opposed to continuing use of urea-based 

deicers, because the capture and treatment of airfield runoff is prohibitively expensive, much 

more so than not using urea. However, EPA has prepared a burden estimate for the compliance 

alternative, as it is included in the rule.

EPA estimates that 37 airports currently use urea-based deicers. If these airports would 

collect one sample per day at each affected airfield outfall for five days for 26 weeks during the 

deicing season, EPA estimates it would take an average of 1,212 hours per airport to monitor for 

ammonia. EPA estimates the maximum total respondent burden to monitor ammonia would be 

44,844 hours. For the compliance alternative, EPA estimates the total potential respondent 

burden to monitor ammonia and prepare certification letters would be 45,005 hours. Table A.6-1 

presents the average hour burden for airports to monitor ammonia or prepare certification letters

and the total respondent burden to demonstrate compliance with the ammonia effluent 

limitations.

Because EPA anticipates that airports will choose to prepare certification letters, the 

Agency estimates that the Total Minimum Response Burden of 198 hours is the most 

representative.
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Table A.6-1. Estimated Respondent Burden for Certification of No Use of Urea or 

Ammonia Monitoring

Activity

Estimated 

Hours 

Burden

Estimated 

Cost 

Burden a

Number of 

Airports 

Conducting 

Activity

Total 

Hours Total Cost

Total Minimum Respondent Burden (all airports certify)

Certify No Use of Urea 1 $33 198 198 $6,534

Total Maximum Respondent Burden – Compliance Alternative

(airports currently certifying + remaining airports monitor for ammonia) 

Sample Collection 1,212 $19,672 37 44,844 $727,864

Sample Analysis (by contract laboratory) NA $12,692 37 NA $469,604

Certify No Use of Urea 1 $33 161 161 $5,313

 Total for Compliance Alternative 198 45,005 $1,202,781

a – Labor rate of $33/hours based on average labor costs from EPA’s airport questionnaire database. Sample 

analysis costs estimated by EPA, for ammonia sample analysis by contract laboratory.

b. Estimating Respondent Costs

i. Estimating Labor Costs

EPA estimated respondent labor costs for the specific activities related to the reporting 

and monitoring requirements of the rule. Costs for the collection of data by airport personnel are 

based on average labor costs from EPA’s airport questionnaire database and the average labor 

rate is $33/hour. EPA used the estimated hours required to respond to the requirements of the 

rule and multiplied these costs by this labor rate. Table A.6-1 presents the total respondent costs 

to meet the reporting and monitoring requirements related to this rule.

ii. Estimating Capital and Operations and Maintenance (O&M) Costs

Because EPA is not requiring respondents to purchase any nonexpendable goods, 

including equipment or machinery, to perform compliance demonstration reporting, the Agency

does not expect capital costs to result from the administration of these reporting requirements. 

Operation and maintenance costs include only photocopying and postage for the completed 

permit application. These are costs that a facility would experience without the promulgation of 

this regulation. All airports are subject to existing NPDES permits.

iii. Capital/Start-up Operating and Maintenance Costs

There are no capital or start-up costs associated with compliance demonstration reporting, 

as described above.

iv. Annualizing Capital Costs

There are no capital costs associated with compliance demonstration reporting, as 

described above.
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c. Estimating Agency Burden and Costs

The costs to permitting authorities (EPA or state agencies) for review of the annual 

certification on pavement deicers, is negligible. 

d. Estimating the Respondent Universe and Total Burden Costs

The estimated respondent universe for compliance determination reporting under the rule 

is 198 airports. Airports must certify no use of urea for airfield pavement deicing. The annual

burden and costs are presented in Table A.6-1. Table A.6-2 below presents a summary of the 

total estimated activity burden for airport respondents.

Table A.6-2. Estimated Annual Respondent Burden

Activity Total Hours Total Cost

Urea Certification

Total Respondent Burden 198 $6,534

Total for All Respondent Activities

Total Respondent Burden 198 $6,534

e. Bottom Line Burden Hours and Cost Tables

i. Respondent and Agency Burden Hours and Costs

Table A.6-3 presents the average annual burden and costs for airports and permitting 

authorities for this ICR. The average annual airport burden uses the burden estimates 

summarized in Table A.6-2.

Table A.6-3. Summary of Average Annual Burden and Costs for 

Respondents (Airports) and Permitting Authority

Respondents

Average Annual Burden

(Hours) Average Annual Costs

Airports 198 198 $6,534 

Permitting Authority negligible $ 0

TOTAL 198 $6,534 

ii. Variations in the Annual Bottom Line

Respondent burden may vary as shown in Table A.6-1 if an airport decides to switch 

from product substitution and certification, to effluent monitoring.
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f. Reasons for Change in Burden

Not applicable, because this request does not renew or modify an existing ICR.

g. Burden Statement

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

is estimated to average 1 hour per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or disclose or provide information 

to or for a Federal agency. This includes the time needed to review instructions; develop, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable instructions and 

requirements; train personnel to be able to respond to a collection of information; search data 

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

the information. An agency may not conduct or sponsor, and a person is not required to respond 

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

OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15. 

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-OW-2004-0038, which is available for online viewing at 

www.regulations.gov, or in person viewing at the Water Docket in the EPA Docket Center 

(EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. The 

EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through 

Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-

1744, and the telephone number for the Water Docket is (202) 566-2426. 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-OW-2004-0038 and OMB Control Number 2040-

NEW in any correspondence.