1 **Part A of the Supporting Statement 1.**  **Identification of the Information Collection** (a) Title of the Information Collection "National Volatile Organic Compound Emission Standards for Aerosol Coatings." The Environmental Protection Agency (EPA) tracking number for this information collection request (I CR) is 2289.0 3 . This is a renewal of a continuing I CR, OMB No. 2060
- 0617, which is due to expire January

31, 2015 . (b) Short Characterization/Abstract (i) Ty

pe of collection. Compliance with the aerosol coatings rule was required by January 1, 2009 . The final rule included a requirement for an Initial Notification from all regulated entities to the EPA at least 90 days before the complian ce date. This notification provide s basic information about the regulated entity

as well as contact information for the certifying official. In addition, this notification need s to explain the product date code sy stem used to label products and the category code s ys tem, if the facility is not using the default category codes included in Table 1 of the rule. The regulated entity is required to submit a revised notification if there is a change in the information in the Initial Notification, with the exception of changes to product formulations. The regulated entity

is not required to submit a revised notification if the VOC formulations submitted in its Initial Notification change. The regulated entity is required to submit a revised notification if the manufacturer, for example, adds a new coating category , changes the product date code s ys tem or batch definition, or begins to use a VOC that is not listed in the rule. The regulated entity is also required to maintain compliance calculations for each of its aerosol coatings formulations, maintain records of the date(s) the batch was m anufactured, the volume of the batch, and the VOC formula for the formulation. Records of these calculations must be maintained for 5 ye ars after the product is manufactured, processed, distributed for wholesale, or imported for sale or distribution in int erstate commerce in the United State, and the regulated entity must supply

this information to the EPA within 60 days of a written request. Beginning this calendar ye ar (2011), each regulated entity must submit a triennial report. The triennial report woul d provide updated VOC formulation data and, for each VOC formulation, the total mass of each individual VOC or mixture used as ingredients in the aerosol coatings manufactured, imported, or distributed that year. This information must be provided only for the second year of the reporting cycle, which in the case of the first report would be information from 2010. Subsequent reports will be required at three year intervals. In other words, a report containing data from 2013 will be due in 2014, a report cont aining data from 2016 will be due in 2017, and so forth. Regulated entities submit an initial notification when aerosol coatings are first manufactured, distributed, or imported
. Regulated entities also will be required to submit notifications of change s in the products or company information and to maintain records
. In2

addition, regulated entities will be required to submit triennial reports of formulation data and VOC usage . Respondent and burden estimates are included in Tables 2 and 3. **2 .**  **Need for and Use of the Collection**  (a) Need/Authority for the Collection. The EPA is charged under section 183 (e) of the Clean Air Act (CAA), as amended, to establish emission standards for aerosol coatings
. Section 183(e) of the CAA requires the EPA to regulate consumer or commercial products that account for at least 80 percent of the VOC emissions, on a reactivity - adjusted basis, in areas that violate the national ambient air quality standards for ozone
. The CAA also directs the EPA to divide the consumer or commercial products into four groups, and establish priorities for regulation until all 4 groups are regulated
. Of the 22 source categories identified and divided into four groups, the aerosol coatings source cat egory is in Group III. The information collection requirements are based on recordkeeping and reporting requirements
. These recordkeeping and reporting requirements are specifically authorized by CAA section 114 (42 U.S.C. 7414)
. Initial notifications and reports, as described in this information collection request, are necessary to enable the Administrator to determine if the standards are being achieved. The emission standards require an initial notification report from all regul ated entities to the EPA 90 day s before the compliance date
. The regulated entity is required to maintain compliance calculations for each of its aerosol coatings formulations
. Records of these calculations must be maintained 5 years after the product is m anufactured, processed, distributed for wholesale, or imported for sale or distribution in interstate commerce in the United States
. The retention of records for 5 years would allow the EPA to establish the compliance history

of a regulated entity and any pattern of compliance for purposes of determining the appropriate level of enforcement action
. Historicall y, the EPA has found that the most flagrant violators frequently have violations extending beyond the 5 years . The EPA would be prevented from pursuing the worst violators due to the destruction or nonexistence of records, if records were retained for less than 5 years. Respondents seeking a variance are required to submit an application which includes the grounds upon which the v ariance is being sought, the proposed date for coming into compliance, and a plan for achieving compliance. Simil arly , some respondents may qualify for, and seek, either a small quantity

manufacturer exemption or a compliance extension
. The estimates for c ompleting these reports are included in the estimates for the Initial Notification. (b) Practical Utility

/Users of the Data. The data collected under this I CR are essential to ensure compliance with the rule and to evaluate its effectiveness
. Agency enforcement personnel will use the information collected to (1) identify

manufacturers and importers subject to the rule; and (2) ensure that consumer products comply

with the VOC content standards , and (3) to better assess the efficacy of the reactivity- based approach, including the manner in which the program’s requirements are being achieved
. These activities are essential to compliance assurance.3

**3. Nonduplication, Consultations, and Other Collection Criteria**  (a) Nonduplication The subject emission standards are delegated to the EPA and information is sent directly to the appropriate EPA Regional Office . The EPA has not duplicated the recordkeeping and reporting requirements for regulated entities that may be subject to the rule covered under this ICR. (b) Public Notice Required Prior to I CR Submission to OMB On May 2, 2011 the EPA published a notice in the Federal Register (76 FR 24476) entitled, Agency Information Collection Activities: Proposed Collection; Comment Request; Natio nal Volatile Organic Compound Emission Standards for Aerosol Coatings
. The purpose of the notice was to announce that the EPA was planning to submit this continuing I CR to OMB for review and approval, and to solicit comments on the proposed continued colle ction . The EPA received no comments during the comment period. (c) Consultations Significant input and information was received from the affected industry , State and local governments, and environmental groups during development of the rule
. In addition, in preparing to submit this I CR to OMB for renewal, the EPA contacted parties within the affected industry to obtain information on the universe of affected sources and feedback on accuracy of the burden estimates. **Table 1. CONSULTATIONS**  Dave Darling National Paint and Coatings Association Heidi McAuliff National Paint and Coatings Association Clark Ferris Perry Chemical Manufacturing Mark Kruzer Sherwin Williams (d) Effects of Less Frequent Collection This I CR rule includes the minimum requirements needed to demonstrate compliance with the rule
. The proposed rule request ed comment on the feasibility and need for a requirement for regulated entities to submit to the Agency their VOC formulations for each product or product formulation in the initial report and on a periodic basis thereafter. Numerous commenters provided input on the need, or lack of need, for additional reporting requirements, in general, and the annual reporting of formulation data, in particular. Some commenters, mostly aerosol industry

representatives, contended that no additional periodic reporting was warranted
. Others, particularl y regulatory agencies and environmental groups, stated their belief that the rule4

is not enforceable without additional reporting
. Based on this input, and the EPA’s own review, the EPA has determined that initial reporting of formulation data and ongoing reporting on a triennial basis are needed
. The initial reporting is needed to ensure that the rule is implementable as a practical matter
. The triennial reporting will enable the EPA to better assess the efficacy of the reactivity
- based approach, including the manner in which the programs requirements are being achieved. (e) General Guidelines This I CR adheres to the guidelines for Federal data requesters, as provided at 5 CFR 1320.6. Initial notifications and reports, as described in this information collection request, are necessary

to enable the Administrator to determine if the standards are being achieved. The emission standards require an initial notification report from all regulated entities to the EPA 90 days before the compliance date
. The regulated entity is required to maintain compliance calculations for each of its aerosol c oatings formulations
. Records of these calculations must be maintained 5 years after the product is manufactured, processed, distributed for wholesale, or imported for sale or distribution in interstate commerce in the United States
. The retention of records for 5 years would allow the EPA to establish the compliance history of a regulated entity and any pattern of compliance for purposes of determining the appropriate level of enforcement action
. Historically , the EPA has found that the most flagrant violators frequentl y have violations extending beyond the 5 years . The EPA would be prevented from pursuing the worst violators due to the destruction or nonexistence of records, if records were retained for less than 5 years . Triennial reports of formulation and usage data are also required, as discussed above. (f) Confidentiality All information submitted to the EPA for which a claim of confidentiality is made will be safeguarded according to the EPA policies set forth in title 40, chapter 1, part 2, subpart B

– Confidentiality

of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976, amended b y 43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR 17674, March 23, 1979). (g) Sensitive Questions This sec tion is not applicable because this ICR does not involve matters of a sensitive nature . **4. The Respondents and the Information Requested**  (a) Respondent/NAI CS Codes Respondents to this information collection are manufacturers, distributors, and importers of aerosol coatings
. These regulated entities fall within the North American Industry Classification System (NAI CS) Code 32551 , " Paint and Coating Manufacturing " and NAICS Code 325998 " All Other Miscellaneous Chemical Production and Preparation Manufacturing " .5

(b) In formation Requested (i) Data items. Regulated entities are required to maintain records of the following at the location specified in §59.511 (a)(4) for each product subject to the product
- weighted reactivity limits: Recordkeeping  Product category ;  All product calculations;  The product
- weighted reactivity ;  Weight fraction of all ingredients including water, solids, each VOC, and any compounds assigned a reactivity factor of zero, as specified in §59.505.  A cop y of each notification submitted, the documentation supporting each notification, and a cop y of the label for each product
. Reporting  Initial report (including small quantity manufacturer exemption requests) ;  Supplemental report;  Variance application ; and  Tri ennial report. (ii) Respondent activities
. The respondent activities required for all manufacturers and importers of regulated products are listed in Table s 2 and 3
. Both new and existing sources must read the rule and understand the rule requirements
. Respondents must also submit notifications and supplemental reports according to the requirements specified in the rule. Respondents must submit triennial reports of formulation and usage data. Each source must maintain all applicable re cords for 5 years. **5. T**  **he Information Collected**
**— Agency Activities, Collection Methodology, and**  **Information Management** (a) Agency

Activities
. A list of Agency

activities is provided in Table s 4 and 5. (b) Collection Methodology and Management
. Reports submitted to the Agency and records maintained by the regulated entities may be tabulated and published for use in compliance and enforcement programs. (c) Small Entity

Flexibility
. The E PA has included a small quantity manufacturer exemption
. This exemption is targeted to particularl y s mall entities that would otherwise bear particularl y high costs for compliance relative to the small amount of products they produce and, therefore, the small6

amount of total VOC emissions from such products. Inaddition, there are provisions that allow facilities additional time to develop compliant products if they have not previously

developed products to meet the limits of the California Air Resource Board aerosol coating rule, which co ntains identical limits to the EPA’s final rule . The EPA maintains that the majority of facilities that would qualify

for this extended compliance time would likely be small entities
. Finally , companies subject to the rule can apply for variances in cases where the company , because of extraordinary

reasons beyond reasonable control, cannot compl y with the rule
. While all variance applications will receive close scrutiny, the EPA will give full consideration to the special needs of small manufacturers and importers. (d) Collection Schedule. The specific frequency

for each information collection activity within this request is shown in Table 2
. **6. E**  **stimating the**  **B urden**  **and C**  **ost of**  **the C**  **ollection** Tables 2 through 5 document the individual burden items for the recordkeeping requirements resulting from the IC R . The individual burdens are expressed under standardized headings consistent with the concept of burden under the Paperwork Reduction Act
. Where appropriate, spe cific tasks and major assumptions have been identified
. Responses to this information collection are mandatory
. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currentl y val id OMB Control Number. (a) Estimating Respondent Burden. The average annual burden estimates for reporting, recordkeeping, and labeling requirements are presented in Table s 2 and 3 for all manufacturers
. These numbers were derived from estimates based on the EPA's experience with other standards and from information obtained from the industry representatives listed under “Consultations”
. Because this is a renewal of an existing I CR, these estimates represent the average annual burden that will be incurred b y the affected industry in the 3
- ye ar period beginning October 1, 2011
. The hours shown in column A of Table 2 are the burden estimate per manufacturer. (b) Estimating Respondent Costs. (i) Estimating Labor costs. Table s 2 and 3 also presents estimated costs for the required recordkeeping and reporting activities
. In dustry

labor rates are based on an average of occupational wage rates for the affected NAI CS groupings 3256 and 3259 (from the United States Dep artment of Labor, Bureau of Labor Statistics, 2010, http://data.bls.gov/oes/search.jsp?data_tool=OES )
. Management wages were based on industrial production managers, technical wages were based on health and safety engineers, and clerical rates were based o n production, planning, and expediting clerks
. The resultant average wage rates were: management ($45. 99 ); technical ($ 37.60 ); and clerical7

($ 21.19 )
. To estimate the actual l abor costs to be used in Table 2 , an overhead of 125 percent was added to the raw labor rates resulting in the following loaded labor rates: management ($103); technical ($8 5 ); and clerical ($ 48 )
. There are no capital or O&M costs associated with the I CR. Labor rates and associated costs are based on the hourly rates estimated above in paragraph 6 (b) as follows: $48 for clerical personnel, $85 for technical personnel, and $103 for management personnel
. For the estimated industry burden, the number of clerical hours is assumed to equal 10 percent of the number of technical hours (see Table 2 ). For the estimated government burden, the number of management hours is assumed to equal 5 percent o f the number of technical hours and the number of clerical hours is assumed to equal 10 percent of the number of technical hours (see Table 4 ). ( ii ) Estimating Ca

pital/Startup and Operation and Maintenance Costs
. N o capital/startup and operation and maintenance costs are associated with this rulemaking
. (iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs
. No c apital/startup and operation and maintenance costs are associated with this rulemaking. (c) Estimating Agency Burden and Cost Because the information collection requirements were estimated as an incidental part of the standard development, no costs can b e attributed to the development of the information collection requirements
. Because reporting and recordkeeping requirements on the part of respondents are required under section 183(e) of the Act, no operational costs will be incurred b y the Federal gover

nment . Examination of records to be maintained b y the respondents will occur incidentally

as a part of the periodic inspection of sources that is part of the EPA's overall compliance and enforcement program and is not attributable to this ICR . The only cos ts that the Federal government will incur are costs associated with the review of reported info rmation, as presented in Table s 4 and 5
. (d) Estimating the Respondent Universe and Total Burden Costs

The following assumptions were used to determine the respondent universe and total burden and costs for industry to compl y with the various requirements of the rule:

 The total number of regulat ed entities in Year 1 will be 63 ;  Assumes 10 percent of respondents will request a variance.  Assumes each respondent will have one incident per year that will require supplemental reporting (also referred to as a “notice of change” report)  Total number of respondents in Year 2 will be 64 and in Year 3 wi ll be 65
.  Same 10% requesting a variance;  Assume s each respondent will have one incident per year that will require supplemental reporting8  Assumes each respondent will maintain records on 37 formulations (average for industry).  Assumes 9 respondents per year will be required to respond to enforcement questions, or other Agency requests for information.  Assumes each respondent will submit a triennial report of formulations and VOC usage. (e) Bottom Line Burden Hours and Cost Tables. (i) Respondent Tall y The bottom line respondent burden hours and cost for year s 1 and 2 , presented in Table 2, are calculated b y summing all total costs for the reporting activities and the total costs for the recordkeeping activities
. The annual burden and costs are 9,478 hours and $ 786, 475. The bottom line respondent burden hours and cost for Year 3, presented in Table 3 , are calculated b y summing all total costs for the reporting activities and the total costs for the recordkeeping activities
. The annual burden and costs for year 3 are 17,838 hours and $ 1,527,927 . Thus, the annual avera ge burden equals the sum of the burden hours in Years 1 ( 9,478 ), 2 ( 9,478 ), and 3 ( 17,838 ), divided b y 3, or 12,265 and the cost of years 1 and 2 ($786,475 each year) and year 3 ($ 1,527,927 ) divided by 3, or $ 1,033,626 . (ii) Agency

Tally The bottom line Agency

burden an d costs are presented in Table s 4 and 5 . The average annual cost to the federal government is $ 81,795 ($ 48,582 ye ar 1, $48,582 year 2, $148,222 ye ar 3). ( ii i) Variations to the annual bottom line. The EPA anticipates that the annual burden after Year 3 will be equal to the burden in Year 2 for 2 of every

3 years and equal to Year 3 for 1 of every 3 years. (f) Reasons for Change in Burden. Year 1 and 2 burden estimate s include an initial number of respondents that will be required to perform recordkeeping and reporting activities, and assumes 1 additional initial and supplemental reports will be required to be completed due to new aerosol coating product formulations being introduced into the market, or changes in existing aerosol coatings formulations
. Beginning in Year 3, triennial reports will be submitted, increasing the burden for those years where a report is due. (i) A gency

Tall y The bottom line Agency

burden and costs are presented in Table s 4 and 5
. The average annual cost to the federal government is $ 81,795 . (ii) Variations in the annual bottom line
.9

No significant variations in the annual respondent burden or cost are expected over the 3
- ye ar period beginning on October 1, 2011. (g) Burden Statement The annual public reporting and recordkeeping burden for this collection of information is estimated to average 1 33 hours per response
. Burden means the total time, effort, or financial resources expended b y 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 s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to compl y with any previously

applicable instructions and re quirements; 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 currentl y valid OMB control number
. The OMB control numbers for the 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, the EPA has established a public docket f or this ICR under Docket ID Number EPA
- HQ
- OAR
- 2006
- 0971 , 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 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 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 contents of the public docket, and to access those documents in the public docket that are available electronically
. When in the s ys tem, select “search,” then key in the Docket ID Number identified above
. Also, you can send comments to the Office of Information and Regulatory

Aff airs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for the EPA . Please include the EPA Docket ID Number EPA
HQ
- OAR
- 2006
- 0971 and OMB Control Number 2060
- 0617 in any correspondence.10

Table 2
. Industry Recordkeeping & Re porting Costs (D) (A) (B) (C) (E ) (F ) Burden Item Person Hours per Occurrence NOTES Number of Occurrences per Respondent per Year NOTES Person Hours per Respondent per Year Dollars

per Hour Person Hours/Respondent (clerical) (D=.1 x tech hours) Respondents

per NOTES Total Hours per Year Total

(C=AxB) Year (F= ( C +D) xE ) Cost in Year 1 ($) **Reporting** Read instructions 4 1 4 103 1 a 4 412 Gather information 4 1 4 85 .4 1 a 4.4 35 9 Initial report (incl. small quantity manufacturers) 25.25 1 25.25 85 .4 1 b 25.65 2, 631 Supplemental report 4 1 4 85 .4 6 3. 5 27 9 22, 809 Variance or compliance extension application 24 1 24 103 0.1 a 2.4 247 Responding to the EPA request for data 60 1 60 103 9 540 55,620
**Recordkeeping** Read instructions (above) Plan activities 16 1 16 103 1 a 16 1, 648 Calculation of reactivity 0.5 c 37 d 18.5 8 5 1.85 11 b 224 18,274 Maintenance of batch information 0.250 e 481 120 8 5 12 63 .5 f 8 382 684,276 **Total Industry**

**Burden -**  complying with rule 9478 $ 786,27 6 Additional Burden - variance $ 19911 **TOTA L INDUSTRY BURDEN**  **- Year 1 and 2**  **each 9**  **478 $**  **786.4 75**  NOTES: Average for first year of existing manufacturer 14 9

a - Assumes up to 1 new aerosol coating manufacturers each year
. Same 10% requesting variance Average in Year 2 for new manufacturer (same as Year 1 for existing) 14 9 b - Assumes 10 manufacturers add new coating category each year Average cost per respondent 14 9 $ 12 , 385 c - Same average time for calculating formulations for new category. d - Uses average of all existing manufacturers
. Likely to be an overestimate for both new manufacturers and for existing manufacturers adding a new coating category e - Same estimate as Year 1 for existing manufacturers. f- 60 existing manufacturers plus 1 new12

Table 3
. Respondent Cost in Year 3 and Average for First 3 Years (A) (B) (C) (D) (E ) (F)

Burden Item Person Hours per Occurren ce NOT

ES Number

of Occurren ces per Respond ent per Year NOT

ES Person

Hours per Respond ent per Year Dolla

rs per Hour Person Hours/Respon dent (clerical) (D=.1 x tech hours) Respondents per NOT ES Total Hours per Year Total

(C=AxB) Year (E= (C+D) x F Cost in Year

1 ($) **Reporting** Read instructions 4 1 4 103 1 a 4 412 Gather information 4 1 4 8 5 .4 1 a 4.4 35 9 Initial report (incl. small quantity manufacturers) 25.25 1 25.25 8 5 .4 1 b 25.65 2,1 65 Supplemental report 4 1 4 8 5 .4 6 5 28 6 23,348 Variance or compliance extension application 24 1 24 103 0.1 a 2.4 247 Responding to the EPA request for data 60 1 60 103 9 540 55,620 **For triennial report** Establish account for NEI 2 1 2 8 5 .2 6 5 1 4 3 11, 674 Enter general information into database 0.5 1 0.5 8 5 .1 6 5 3 9 3,0 75 Enter product formulations into database 0.25 37 9.25 8 5 .925 6 5 6 61 53, 99213 Enter company wide volumes of coating constituents into database 2 1 2 8 5 .2 6 5 14 3 11, 674
**Recordkeeping** Read instructions Plan activities 16 1 16 103 1 a 16 1,648 Calculation of reactivity 0.5 c 37 d 18.5 85 1.85 11 b 244 18, 274 Maintenance of batch information 0.250 e 481 120 85 12 6 5 f 8 580 700,440 **For triennial report** Calculate company wide volume usage of coating constituents 56 g 1 56 85 5.6 65 f 4004 326,872 QA/QC and review 40 h 1 40 103 6 5 f 2600 267,800 Read instructions/take training for reporting - support 4 1 4 85 .4 6 5 f 286 23,348 Read instructions/take training for reporting - management 4 1 4 103 65 f 260 26,780

**Total Industry**

**Burden -**  complying with rule 17,8 38 $ 1, 527,728 Additional Burden - variance $ 199 **TOTA L INDUSTRY BURDEN**  **** **Year 3 17,8**  **38 1,**  **527,927**

NOTES: a - Assumes up to 2 new aerosol coating manufacturers in first 2 years (added both in Year 2). Same 10% requesting variance Average cost per respondent 27 5 $ 23, 507 b - Assumes 10 manufacturers add new coating category each year Average cost for triennia l report per respondent c - Same average time for calculating formulations for new category. 125 $11,15714

d - Uses average of all existing manufacturers. Likely to be an overestimate for both new manufacurers and for existing manufacturers adding a new coating category e - Same estimate as Year 1 for existing manufacturers. Total Year Costs f- 60 existing manufacturers plus 1 new Average Cost for Year 1 149 $12,385 $ 786,475 g - Assumes 2 days to gather information and 2.0 hours to sum all information for each constituent - assumes an average of 20 different constituents used by facility Average Cost for Year 2 149 $12,385 $ 786,4 75 h - assumes review of all information by senior official of company Average Cost for Year 3 274 $ 23, 507 $ 1, 527,927 Average of first 3

years 191 $

15,902 $

1, 033,62615

**Table 4. Government Recordkeeping & Reporting Costs Years 1 and 2**

(A) (B) (C) (D) (E) (F) (G) Burden Item Person Hours per Occurrence Number of Occurrences

per Respondent per Year Person Hours per Year @ $72 (Technical) Person Hours per Year

@ $100 (Management) Person Hours per Year @ $36 (Clerical) Total Person

Hours per Year Total Cost Per Year ($) (C=AxB) (D = C x 0.05) (E = C x 0.01) (F=C+D+E) Initial report 8 1 8 0.4 0.08 8.48 619 Supplemental report 4 61 244 12.2 2.44 258.64 18,876 Variance application 16 1 16 0.8 0.16 16.96 1,238 Supplemental data request 40 9 360 18 3.6 381.6 27,850

**Total Government Burden** 72 628 31.4 6.28 665.68 $ 48,58216

**Table 5 .**  **Government Burden -**  **Year 3 -**  **and A verage for First 3 Years** 
(A) (B) (C) (D) (E) Burden Item Person Hours per Occurrence Number of

Occurrences per Respondent per Year Person Hours

per Year @ $72 (Technical) Person Hours per

Year @ $100 (Management) Person Hours per

Year @ $36 (Clerical) Total Person Hours per Year Total Cost Per

Year ($) (C=AxB) (D = C x 0.05) (E = C x 0.01) (F=C+D+E) Initial report 8 1 8 0.4 0.08 8 619 Supplemental report 4 62 248 12.4 2.48 263 19,185 Variance application 16 1 16 0.8 0.16 17 1,238 Develop Database and Report Forms for Triennial Report 300 1 300 15 3 318 23,208 Populate Database for triennial report 12 62 744 37.2 7.44 789 57,556 QA/Review data for triennial report 600 1 600 30 6 636 46,416

**Total Government Burden** 128 1916 95.8 19.16 2,031 $ 148,222
Year 1 665.68 $ 48,582.08 Year 2 665.68 $ 48,582.08 Year 3 2,031 $ 148,221.76 Average of 3 years 1121 $ 81,795.31