INFORMATION COLLECTION REQUEST RENEWAL

FOR THE ACID RAIN PROGRAM

UNDER THE CLEAN AIR ACT AMENDMENTS TITLE IV

January 26, 2009

INFORMATION COLLECTION REQUEST RENEWAL

FOR THE ACID RAIN PROGRAM

UNDER THE CLEAN AIR ACT AMENDMENTS TITLE IV

(AUGUST 2009 THROUGH JULY 2012)

SUPPORTING STATEMENT

1.	IDENTIFICATION OF THE INFORMATION COLLECTION

	1.1	Background

	Title IV of the Clean Air Act Amendments of 1990 (the acid rain title)
established goals to reduce annual emissions of sulfur dioxide (SO2) and
nitrogen oxides (NOX) and placed a national cap on sulfur dioxide
emissions beginning in the year 2000.  Emissions reductions were
mandated in two phases:

During Phase I, which covered 1995 through 1999, emissions were reduced
about 50 percent for SO2 and 32 percent for NOX  from 1990 levels from
the 263 highest-emitting sources;

Phase II, which began in 2000 for both SO2 and NOX, affects more than
3,500 sources at virtually all fossil fuel power plants.

	To help meet emissions reduction goals, Title IV provides for a program
that allocates emissions allowances to affected utility units based on a
national target for SO2 reductions, and allows market forces to achieve
the targeted reductions in the most cost-effective manner.  Under this
program, each affected unit receives its allocation of allowances for
every year.  An affected unit must hold one allowance for each ton of
SO2 it emits.  Affected utilities and individuals may buy and sell
allowances, or save them for future use or sale.

	The ability to buy and sell (or transfer) allowances provides
substantial economic benefits, by encouraging the greatest emissions
reductions where costs of reductions are lowest.  This concept of
allowance transfers cannot be implemented, however, unless regulations
governing emissions monitoring and permitting of acid rain sources are
in place as well.  To ensure compliance with the emissions reduction
requirements and to provide the national consistency needed to foster
the allowance market, sections 408 and 412 of Title IV require the
designated representative of the owners and operators of each affected
acid rain source to obtain an operating permit for the affected source
and to certify that an approved emissions monitoring system has been
installed and is properly operated at each affected unit's source of
emissions.

	Emissions monitoring and reporting is the foundation upon which the
allowance trading system is based.  Without accurate monitoring and
reporting of emissions, the integrity of the allowance system would be
undermined, and there would be no assurance that emissions had been
reduced.

	Acid rain permits allow sources the flexibility to comply with the
emissions reduction requirements of Title IV for both SO2 and NOX.  The
procedures specified in the acid rain permits regulations, including the
use of standardized forms, ensure that the intended flexibility and
accountability is preserved as the Acid Rain Program is implemented
nationwide by different permitting authorities.

	Participation in the annual auction is voluntary.  Information is
collected by EPA’s Clean Air Markets Division and used to conduct and
facilitate the administration of the auction.  Auction participants must
submit a bid form and payment method.

	Section 410 of Title IV provides that sources of SO2 emissions that are
not regulated, i.e., small utility units and industrial boilers, may
elect to "opt in" to the allowance allocation and trading program.  To
opt in, the source owner or operator must submit an opt-in permit
application to EPA.  Sources that opt in (1) become affected sources,
(2) receive an annual allocation of allowances, and (3) may sell any
allowances they do not use for their own emissions.  Because opting in
is voluntary, only those unaffected sources that would profit by opting
in are expected to do so.

	Although the principal purpose of Title IV of the Clean Air Act is to
reduce acid rain by requiring reductions in emissions of SO2 and NOX, it
is also the purpose of this title to encourage energy conservation and
pollution prevention as a long-range strategy for reducing air pollution
and other adverse effects of energy production and use.  As an incentive
for electric utilities to (1) implement energy conservation measures and
(2) use renewable energy, section 404(f) of Title IV establishes
provisions for qualifying electric utilities to receive allowances from
the Conservation and Renewable Energy Reserve for SO2 emissions avoided
through either of these two options.

	The NOX emission reductions are achieved through maximum allowable
emission rates for coal-fired utility boilers.  The allowable rate for a
given boiler depends on the type of boiler.  The NOX regulations for
coal-fired boilers are applied to two groups of boilers, as specified by
the Clean Air Act Amendments of 1990 (CAAA).  Boilers in each group
become affected at different times, as described below.  Group 1 boilers
are (1) dry bottom wall-fired boilers that do not apply cell burner
technology or (2) tangentially fired boilers.  Group 2 boilers are all
other types of utility boilers, including (1) wet bottom wall-fired
boilers, (2) cyclones, and (3) boilers applying cell burner technology.
In Phase II, which began January 1, 2000, NOX emission limitations
became effective for both groups of boilers.

1.2	Information to Be Collected

	EPA has developed regulations to implement the emissions reduction
provisions of Title IV of the Clean Air Act Amendments that cover

Allowance tracking and transfers (section 403);

Energy conservation and renewable energy incentives (section 404);

Permits (section 408);

Emissions monitoring (section 412);

Auctions (section 416);

Opt-in (section 410 a-g); and

NOX permitting (section 407).

	This Information Collection Request (ICR) addresses the paperwork
burden related to (1) transferring and tracking allowances; (2)
obtaining and distributing allowances from the Conservation and
Renewable Energy Reserve; (3) obtaining and issuing permits (e.g.,
submitting permit applications); (4) submitting and certifying emissions
monitoring data; (5) the opt-in program; (6) NOX permitting.  Burden
estimates provided in this ICR are for the period from July 1, 2006 to
June 30, 2009 (i.e., the years 2007 through 2009).

Allowance Transfers

	Participants in the allowance transfer system now have two options for
submitting transfers: to submit electronically using the internet to
record their own allowance transfers, either by entering the data on
screen or by submitting an XML file; or complete a paper form and send
it the Agency.  Participants in the transfer system that are not
affected sources under Title IV are also be required to file a one time
account information application using a paper form to establish an
account in the Allowance Tracking System (ATS).  As part of the annual
compliance determination process, designated representatives have the
option of submitting an allowance deduction form to identify specific
serial numbered allowances to be deducted for annual compliance

Conservation and Renewable Energy Reserve

	To receive allowances for emissions avoided through the use of energy
conservation measures or renewable energy, utilities must submit an
application to receive allowances that (1) designates and verifies the
measures used to avoid emissions, (2) calculates the tons of emissions
avoided, and (3) demonstrates qualification to receive allowances from
the Conservation and Renewable Energy Reserve.

Permits

	Permit applicants are required to submit an acid rain permit
application for each affected source.  The permit application must
include, for each unit at the source, (1) general information on the
unit, (2) a complete compliance plan for each unit, and (3) the Acid
Rain Program standard requirements.

Emissions Monitoring

	To meet the emissions monitoring record-keeping and reporting
requirements, affected units are required to (1) submit a monitoring
plan and certification of monitors, (2) record hourly pollutant and flow
monitor data, and (3) submit electronic quarterly reports of their
emissions data to EPA.  Operators of new electric generating units of 25
megawatts (MW) capacity or less may receive a CEMS exception if they
certify their use of very-low-sulfur fuel.

Submissions Purposes and Procedures

	Allowance transfer notifications may be submitted to EPA electronically
or on paper.  Emissions reports must be submitted electronically. All
Phase II permit applications must be submitted on paper.

	The allowance transfer submittal is used to record allowance transfers
for compliance purposes and to track the disposition of all allowances
in the system.  Applications for allowances from the Energy Conservation
and Renewable Energy Reserve provide information on the emissions
avoided through the use of energy conservation measures and renewable
energy, and are used to allocate allowances from the reserve.

	Acid rain permit applications are used to issue operating permits to
affected sources under the Acid Rain Program.  Because the permit
applications and permits are public documents, they provide an
opportunity for the affected public to examine activities undertaken by
affected sources.  The designated representative certification, which
designates a responsible official through whom the owners and operators
of each affected source and each affected unit can trade allowances and
obtain and maintain permits, serves to remove EPA from involvement in
disputes between owners and operators of affected units.

	Monitoring plan submissions are used by EPA to verify that the
emissions monitoring system at a unit meets the requirements set forth
in Title IV of the Act and in the implementing regulations.  Results of
continuous emission monitoring system performance tests allow EPA to
certify that monitors perform well enough to produce accurate emissions
data.  Emissions data is used to monitor compliance with emissions
requirements under Title IV and to provide a basis for analyzing
progress in meeting air quality objectives.  Allowance tracking
information, emissions data, and the contents of permit applications all
provide information for the allowance market and the general public.

Opt-in Program

	This ICR also addresses the paperwork burden for small utility units
and industrial boilers that opt-in.  The Agency has identified five
burden areas associated with a source’s opting in to the allowance
allocation and trading program.  These areas are (1) completing the
permit application, (2) recording and reporting emissions data, (3)
compliance reporting, and (4) withdrawing from the program. Estimates
for the opt-in program detail the burden for both operating and
shut-down opt-ins.

	The Opt-in program requires respondents to submit an acid rain permit
application.  For all respondents, the application must provide (1)
general information about the source, (2) specific data about the
source’s fuel consumption and operating data for 1985, 1986, 1987, and
(3) data on the source’s actual and allowable emission rates for 1985,
as well as the current allowable emission rate. The permit application
and proposed thermal energy compliance plan for sources that opt in and
shut down must include information describing the source’s plans for
the replacement of thermal energy.

	To meet emissions monitoring, record-keeping and reporting
requirements, sources that opt-in and continue operating will be
required to (1) submit a monitoring plan and certification of monitors,
(2) record hourly pollutant and flow monitor data, and (3) submit
quarterly reports of their emissions data to EPA.  Sources that opt in
and shut down will not have to perform tasks associated with emissions
monitoring, reporting, and recording.

	Meanwhile, to meet requirements for reporting compliance, respondents
must submit an annual compliance report in which they (1) report their
utilization information, (2) report any replacement of thermal energy,
and (3) report on allowances transferred as a result of the replacement
of thermal energy. Finally, all sources that have opted in and later
decide to withdraw are required to complete withdrawal notification.

NOX Permitting

	An owner or operator of a unit subject to a NOX emission limitation may
meet the requirements through one of three compliance options:

meeting the standard limit

obtaining approval for an emissions averaging plan

obtaining an alternative emissions limitation (AEL)

	Two or more units may average their NOX emissions, as provided for by
Title IV.  In an approved NOX emissions averaging group, the NOX
emission rates of some of the individual units may exceed their
respective emission limitations, as long as the Btu-weighted average NOX
emission rate for the entire group is less than or equal to the weighted
average of the emission limitations for the individual units.  The
ability to average emissions allows utilities to meet the NOX
requirements at lower cost.

	Title IV also provides that an owner or operator of an affected unit
may petition EPA for a higher, alternative emission limitation (AEL) if
the unit cannot meet the emission limitations even after a retrofit with
low NOX burner technology .  The opportunity to obtain AELs will allow
for adjustment of emission limitations for specific units where the
technologies on which the limitations were based do not provide the
expected level of emission reductions in practice.

	Meeting the standard limit is the least burdensome administratively for
sources.  All owners and operators of affected units are eligible to
comply with the NOX regulations using this option.  The submission of an
application for emissions averaging, or an AEL, is optional and
voluntary.

	For units that comply by meeting the standard limits applicants are
required only to identify the unit.

	Applicants seeking approval for emissions averaging are required to
identify the units in the group, assign alternative contemporaneous
emissions limitations to each unit, and demonstrate that the
Btu-weighted average of these alternative limits is less than or equal
to the Btu-weighted average of the limits that would apply in the
absence of averaging.

	All applicants for AELs are required to demonstrate that they are
eligible for an AEL, by providing (1) evidence that the appropriate
emissions control equipment has been installed, and (2) monitoring data
showing that the unit cannot meet the applicable emission rate.

	The respondent reporting burden for this collection of information is
estimated to be 1,971,276 hours each year for the years 2007 through
2009.  The burden to EPA is estimated to be 31,974 hours in each year
for the years 2007 through 2009.

	1.3 	Terms of Clearance

Below are the Terms of Clearance for the previous ICR renewal.

This ICR is approved for three years. The agency should continue to
ensure that future extensions of the ICR appropriately represent capital
costs that have been capitalized over more than three years. Also, the
agency should continue to include in future extensions of the ICR  any
cyclical reporting such as NOx compliance plans.

A discussion of the capital cost issue can be found in section 6.4.2 of
this document, and the cyclical nature of reporting is taken into
account for both Permitting, sections 4.2.2 and 6.3.1, and NOx
Compliance, sections 4.2.2 and 6.7.1.

2.	NEED FOR AND USE OF THE COLLECTION

	This section describes EPA's need for the information collections
described above and the legal authority for conducting collections.  The
users of collected information are also described.

	2.1	Need/Authority for the Collection

	Section 403(b) of Title IV of the Clean Air Act Amendments of 1990
provides for the transfer of allowances among designated representatives
of owners and operators of affected sources and any person who holds
allowances.  Transfers of allowances are not deemed effective until
written certification of the transfer, signed by a responsible official
of each party to the transfer, is received and recorded by EPA.  Section
403(d) of Title IV requires that EPA develop a system for issuing,
recording, and tracking allowances (intended to help ensure an orderly
and competitive allowance system).

Conservation and Renewable Energy Reserve

	Section 404(f) of Title IV establishes provisions for qualifying
electric utilities to receive allowances from the Conservation and
Renewable Energy Reserve for SO2 emissions avoided through the use of
qualifying energy conservation measures or renewable energy.  The
allowances are allocated on a first come, first served basis during the
period from January 1, 1992 to December 31, 2009.

Permits

	Section 408 of Title IV and Title V of the Clean Air Act Amendments of
1990 require that the designated representative of the owners and
operators of each affected source under the Acid Rain Program obtain a
permit.  In Phase II, section 408 also specifies that the permitting
authority, usually a State or local agency, issue the permits with a
term of five years.

Emissions Monitoring

	Section 412(a) of Title IV requires the use of CEM systems (or
alternative monitoring systems demonstrated to be equivalent) at each
affected unit's source of emissions. Section 504(a) of Title V requires
that the results of any required monitoring be submitted to the
permitting authority no less often than every six months. The
information collection is consistent with satisfying these minimum
statutory requirements.  Note that reports are submitted quarterly
rather than semiannually. The Acid Rain Advisory Committee recommended
that EPA collect emissions data on a quarterly basis and this schedule
has proven to allow for effective implementation of the program.

Auctions

	Although participation in the annual auction is voluntary, the
information to be collected is necessary to operate and administer the
program and is required specifically under Title IV, Section 416(d)(2).

Opt-in

	Section 410(a) of Title IV of the Clean Air Act Amendments of 1990
allows the owner or operator of any SO2 source that is not an affected
unit under section 403(e), 404, or 405 to elect to designate that source
as an affected source and receive allowances under Title IV.  Section
410(a) requires sources opting in to submit a permit application and a
compliance plan to the Administrator.

	Section 410(b) requires the Administrator to establish a baseline
utilization rate for SO2 emissions for opt-in sources based on fuel
consumption and operating data for calendar years 1985, 1986, 1987.
Section 410(c) requires the Administrator to establish a limit for SO2
emissions based on the baseline utilization rate and the lesser of the
source’s actual or allowable 1985 emissions.

	Section 410(e) requires that the Administrator issue allowances to
sources that become affected sources under Section 410.  The number of
allowances is to be based on calculations made under Section 410(c).

NOX Permitting

	Section 408 of Title IV of the Clean Air Act Amendments of 1990
specifies that utility owners and operators of units affected under
Title IV must submit permit applications and compliance plans (including
NOX compliance plans), and that EPA must issue permits.

Section 408 provides general authority for the information collections
under this ICR related to compliance options.  In addition,

Section 407(e) of Title IV allows the owner or operator of two or more
affected units to petition the permitting authority for a NOX averaging
plan.

Section 407(d) provides for AELs for utility units that cannot meet the
applicable limitation using low NOX burner technology or the technology
on which the limitation was based.  Section 407(d) specifies that an
owner or operator requesting an AEL must show the permitting authority
that (1) appropriate control equipment has been properly installed, and
(2) the equipment has been properly operated for a period of fifteen
months (or another period of time as established by regulation) and
operating and monitoring data for such period demonstrate that the unit
cannot meet the applicable emission rate.  The owner or operator must
also specify an emission rate that the unit can meet on an annual
average basis.

	2.2	Practical Utility/Users of the Data

Allowance Transfers

	Information collected on allowance transfers is used by EPA to track
allowances for the purpose of determining compliance with the Acid Rain
Program.  Information on allowance transfers is also used by
participants in the allowance market and the public to evaluate the
activities of utilities, and by EPA for program evaluation.

Auctions

	EPA or its designated agent uses the information collected for the
allowance auction to conduct and facilitate administration of auctions.
The basic information requested requires little evaluation.  Bids
submitted for auctions are ranked to select winning bidders and to
conduct transfers of emission allowances.  The auction information
results are also used by participants in the allowance market.

Conservation and Renewable Energy Reserve

	Information collected on the use of energy conservation measures and
renewable energy is used by EPA to issue allowances from the
Conservation and Renewable Energy Reserve.

Permits

	Acid rain permit applications are used by EPA and permitting
authorities to issue operating permits.  A permit application is legally
binding on the owners, operators, and designated representative of a
source until the actual permit is issued.  This aspect of the permit
application reduces significantly the uncertainty imposed on a source
due to possible delays at EPA or the permitting authority.  Affected
sources may rely on the permit for information on the requirements with
which they must comply.  Because permit applications and permits are
public documents, they may be used by the public to examine activities
undertaken by affected sources.

Emissions Monitoring

	Data from emissions monitoring is indispensable to successful
implementation of the Acid Rain Program for two reasons:

Title IV of the Act clearly states that its primary purpose is to reduce
the adverse effects of acid deposition by reducing annual emissions of
sulfur dioxide and nitrogen oxides. For sulfur dioxide emissions, the
statutory objective is achieved through an emissions trading program.
For nitrogen oxide emissions, the statutory objective is achieved
through annual emission limitations on certain units.

EPA can only enforce the sulfur dioxide trading program and the nitrogen
oxide emission limitation program by having accurate emissions data for
each affected unit.

	Electric utilities, energy consultants, and power marketing companies
can use the Acid Rain program emissions data to project future SO2
allowance costs and availability.  Academic institutions can perform
data modeling to evaluate environmental benefits and estimate health
effects of SO2 reductions.  EPA and other agencies use it to try to
correlate the reduction of SO2 and NOX emissions with a decrease in acid
precipitation, and also to measure the impacts of other existing and
proposed emissions trading programs.

	Together, the allowance trading system, operating permits, and
emissions data provide the accountability to allow the Acid Rain Program
to function without more stringent command and control approaches.

Opt-in

	Information collected on opt-in respondents is used by EPA to record
which sources are to be designated affected sources, and hence are to be
bound by the regulations of the CAAA that are relevant to affected
sources.

	Opt-in permit applications are used by EPA to issue operating permits.
Fuel usage and emissions rate data in the opt-in application is used to
allocate allowances to the opt-in source.

	The information on annual utilization and the replacement of thermal
energy, if covered by a Thermal Energy Plan, contained in the annual
compliance report is used by EPA to determine compliance with the Act.

	For respondents who choose to withdraw from the program, the withdrawal
notification is essential to notify EPA to discontinue the allocation of
allowances to the source and enforcement of the acid rain provisions.

NOX Permitting

	Information collected on NOX compliance plans is used by EPA to
evaluate these compliance plans.  Information collected on applications
for emissions averaging groups or AELs is used by EPA to determine
whether to approve these applications.  This information may also be
used by the regulated community and the public to evaluate the
activities of utilities, and by EPA for program evaluation.

3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

	This section describes (1) efforts by EPA to learn whether the
information requested is available from other sources, (2) consultations
with respondents and data users to plan collections, monitor their
usefulness, and minimize the collection burden, (3) effects of less
frequent collections, and (4) justification for deviations from OMB's
general guidelines.

	3.1	Nonduplication

	Almost all information requested from respondents under this ICR is
required by statute and, in most cases, is not available from other
sources.  Review of earlier and proposed forms resulted in the
elimination of many redundant requirements.  Where EPA needs information
that has already been submitted, EPA is simply requiring a photocopy of
the prior submittal.

	EPA notes that many of the units that are subject to the Acid Rain
Program are also subject to other programs, such as the New Source
Performance Standards (NSPS).  Under programs such as NSPS, sources are
required to submit monitoring data reports that match the particular
format and averaging time of the applicable emission limits under those
standards.  Although not the same information as the information
provided under the Acid Rain Program, the information is often generated
by the same monitoring equipment.

3.2	Consultations

	The data requirements for the Acid Rain Program were developed with the
benefit of extensive consultation with the Acid Rain Advisory Committee
(ARAC) during five meetings in 1991 lasting two to three days each.  The
Committee was composed of representatives of those entities most
affected by or interested in the information requirements of the Acid
Rain Program.  Representation on the Committee was provided for
industry, states, and environmental groups.  Other parties consulted
include the Utility Air Regulatory Group (UARG), the State and
Territorial Air Pollution Program Administrators (STAPPA), and the
Association of Local Air Pollution Control Officers (ALAPCO).

	Recommendations provided by ARAC strongly supported the use of
standardized reporting forms for acid rain permit applications:

Utilities affirmed that standardized forms reduce uncertainty about what
constitutes a complete application and thus reduce the need to supply
additional information in a second submission;

States asserted that the use of standardized forms developed by EPA
would reduce the time and effort states will need to implement an acid
rain permit program; and

Environmental groups argued that the use of standardized forms provides
greater assurance that permits will be enforceable in a consistent
manner nationwide.

	Many ARAC recommendations were incorporated into the acid rain
regulations regarding permits and the related standardized forms.

            Furthermore, since the beginning of implementation of the
Acid Rain Program, representatives from the utility industry, monitoring
equipment vendors, software programmers, consultants working together
with utilities, and other interested parties have offered comments on
the existing rule requirements, standard forms and electronic data
reporting formats used to implement the Part 75 program.  The EPA has
used these comments to revise the rules, forms and reporting formats,
especially changes in the formats to cover a wider group of units.  In
particular, the revised forms and electronic data reporting format have
been revised in the past to address reporting requirements for gas-fired
units and oil-fired units that are using pre-approved monitoring
exceptions to the use of CEMS.  Industry groups have also worked
together with EPA to revise the recordkeeping and reporting requirements
in revisions to Part 75 in 1995, 1996, and 1999.  Comments and
suggestions from working groups, comprised of UARG, Class of 85
Regulatory Response Group, and the PJM Powerpool also were incorporated
in designing the annual compliance forms.

	Finally, EPA promulgated revisions to Part 75 in May 2002.  For these
revisions, EPA solicited and obtained input from a number of affected
utilities and other interested parties.  The Agency received numerous
written comments on the proposed revisions, and used those comments, in
part, to develop the final revisions.  In particular, EPA modified the
proposal to avoid certain changes that would have imposed reporting and
recordkeeping burdens where the comments indicated that the benefit of
the proposed changes would not necessarily outweigh the burdens.
Examples of these changes include treatment of partial hour reporting
for determining regulatory grace periods and the approach to allowing a
new option for missing data for units that operate control devices on a
seasonal basis.  The result of the final rules were minor changes to the
reporting and recordkeeping requirements for the majority of sources
that should have only a minimal impact on respondents' burdens and
costs, with some increased one-time software costs, especially for
sources that decide to adopt one or more of the new options allowed for
under the final rule revisions.

	3.3	Effects of Less Frequent Collection

	Collection of allowance transfer information for each transfer of
allowances is necessary to effectively implement a system for issuing,
recording, and tracking allowances, which is required by statute.

Conservation and Renewable Energy Reserve

	Collection of applications for allowances from the Conservation and
Renewable Energy Reserve for emissions avoided through the use of
conservation measures or renewable energy is required by statute and is
vital to (1) determine qualification for these allowances, and (2)
establish the sequence for allocating allowances on a first-come,
first-served basis.

Permits

	The requirement for the designated representatives of owners and
operators of affected sources to submit permit applications every five
years is a statutory requirement.

Emissions Monitoring

	Submission of monitoring plans once and submission of the results of
any required monitoring to EPA no less often than every six months are
required by statute.  More frequent collections of emissions data (i.e.,
quarterly), however, allows the opportunity to check data for errors and
provide rapid feedback on needed adjustments to data collection systems,
and thereby promotes accurate and reliable emissions data.  For this
same reason, existing federal and state emission monitoring programs
often require quarterly reporting, or in some cases, monthly.  Less
frequent collection, such as semi-annually or annually, would increase
the amount of preparation and review time at the end of the year both
for regulated sources and for EPA.  This would slow down the process of
true up and end of year verification of compliance.

	Records of monitoring information are to be kept at the source for
three years after the date of creation of the record.  In certain
circumstances, fuel flowmeter calibration and Appendix E testing records
may have to be kept for up to five years if the owner or operator takes
advantage of rule provisions that allow up to five years between tests.
These five year recordkeeping requirements only apply if the owner or
operator voluntarily elects either of these options as a cost-effective
approach for the owner or operator's specific circumstances.

Opt-in

	Collection of permit applications for the opt-in program occurs only
once every five years, thus minimizing the respondent burden.  This
collection is necessary for the operation of the program; without it,
EPA would not know which sources wanted to opt in, nor their baseline
utilization, nor the lower of their 1985 actual or allowable emission
rate.  Collection of withdrawal notifications also occurs once; this is
also a necessary collection.

NOX Permitting

	The Agency is required by statute to include NOX compliance plans as
part of the Acid Rain permits. As mentioned earlier, Acid Rain permits
are renewed every five years, so NOX affected sources must submit a NOX
compliance plan once every five years.

	3.4	General Guidelines

	Section 403(d) of Title IV requires that EPA establish a system for
issuing, recording, and tracking allowances.  To track allowances
accurately and to help ensure the orderly and competitive functioning of
the allowance system, it is essential that participants be able to
report information on allowance transfers as they occur.

	The general requirement that permit applicants submit information on
standard forms is established by Section 502(b) of Title V.  The
five-year life of an acid rain permit is established by Section 408(a)
of Title IV.  This information collection does not violate the
guidelines set forth by OMB.  In some cases, records of Part 75,
Appendix E test results or fuel flowmeter calibration test results may
need to be retained for up to five years, but only if the owner or
operator chooses to take advantage of the ability to extend the period
between tests up to five years.  In all other circumstances, Part 75
monitoring records must be kept for only three years.

3.5  Confidentiality and Sensitive Questions

	Information collected through this activity is not confidential or of a
sensitive nature.

	3.6 Public Notice

	EPA received a single non-substantive comment in response to the public
notice that was published in the Federal Register.  This comment can
found in Docket ID No. EPA-OAR-2005-0509, which is available for   SEQ
CHAPTER \h \r 1 online viewing at   HYPERLINK
"http://www.regulations.gov"  www.regulations.gov ,   SEQ CHAPTER \h \r
1 or in person viewing at the Air and Radiation Docket in the EPA Docket
Center (EPA/DC), EPA West, Room B102, 1301 Constitution Ave., NW,
Washington, DC.

4.      	THE RESPONDENTS AND THE INFORMATION REQUESTED

	This section lists the major categories of businesses that participate
in the Acid Rain Program, the data items requested from program
participants, and the activities in which the participants must engage
to assemble or submit the required data items.

	4.1	Respondents/NAICS & SIC Codes

	Title IV applies to "utility units," which are defined to include units
that serve a generator producing electricity for sale or that did so in
1985.  Entities owning "utility units" that are likely to participate in
allowance transactions are Fossil Fuel Electric Power Generators (NAICS
code 221111) electric service providers (SIC code 4911) and selected
firms in the non-utility generation industry, such as Coal Mining (NAICS
code 2121) coal mining service companies (SIC code 1241). Participants
in transactions and the annual auctions include security and commodity
contracts intermediation and brokerages (NAICS code 5231) (SIC code 62).

Emissions Monitoring

	Utility units are required to submit emissions monitoring data under
this ICR.

Opt-in

	Potential participants in the opt-in program are facilities that emit
SO2 but are not designated affected units under Title IV.  Such
facilities include utility units that serve an electric generator of
less than 25 MW that produces electricity for sale or that did so in
1985.  Entities owning utility units under 25 MW that may participate in
the opt-in program are electric service providers (SIC code 4911).
Other potential participants are industrial boilers that are represented
in a wide range of SIC categories.

	4.2	Information Requested

	This section lists the data items requested from affected sources for
the collections described in this ICR.  This section also defines the
activities in which respondents must engage to assemble, submit, or
store these data items.

	4.2.1      Data items, Including Recordkeeping Requirements

Allowance Transfers

	All participants to allowance transfers are required to provide the
following information for each allowance transfer:

Allowance tracking system account number;

Name, phone number, and facsimile number of the authorized account
representative, along with the representative's signature and date of
submission; and

Serial numbers of allowances to be transferred.

	In addition, if the designated representative chooses to identify the
specific serialized allowances to be deducted from the unit's ATS
account for annual reconciliation, then the following information is
required:

Allowance Tracking System account number;

Type of deduction;

Serial numbers of the allowance blocks to be deducted; and

Dated signature of the designated representative.

Certificate of Representation

	Affected sources are assigned an allowance tracking system number and
appoint a designated representative by submitting a certificate of
representation. The data items requested for the certificate of
representation are as follows:

Source identification;

Unit identification, including;

		a)  unit type and category

		b)  commence commercial operation date

		c)  generator IDs of generators served by unit

		d)  nameplate capacity(s) of the generators served by the unit

		e)  list of applicable programs that the unit is subject to

		f) NAICS Code

Name, address, e-mail, telephone and facsimile number of the designated
representative;

Name, address, e-mail, telephone and facsimile number of the alternate
designated representative;

List of "owners and operators" of the source and each unit at the
source;

Certification statement;

Signature of designated representative;

Signature of alternate designated representative; and

Date signed.

Notification for Distribution of Proceeds from EPA Auctions

	EPA disburses one payment using electronic funds transfer/direct
deposit (EFT/DD) for each plant represented for the proceeds from the
annual auctions of allowances.  The following information is required
for this notification for distribution of proceeds:

Authorized Account Representative (AAR) Identification;

Name of the company receiving the payment;

The company’s taxpayer identification number;

Bank account information;

Plant name and plant code; and

Signature of AAR.

General Account Holders (Allowance Market Participants)

	Entities that are not affected sources (such as individuals holding
allowances) are required to submit a completed account information
application or provide the following information to obtain an allowance
tracking system account number, prior to or simultaneous with the first
transfer:

Organization or company name (if applicable);

Name, mailing address, phone number, facsimile number, and e-mail
address of the authorized account representative;

Name of the alternate authorized account representative (optional);

A list of all persons subject to a binding agreement for the authorized
account representative to represent their ownership interest with
respect to the allowances held in the account; and

Certification statement and the signatures and date for the authorized
account representative, and alternate authorized account representative,
if any.

Conservation and Renewable Energy Reserve

	In order to receive allowances from the Conservation and Renewable
Energy Reserve for emissions avoided, each electric utility must submit
an application to EPA.  The application requires the following items:

Name and phone number of the person(s) who completed the application;
and name and phone number of contact person.

Demonstration of qualification to receive allowances for emissions
avoided;

A list of the qualified energy conservation measures implemented and the
qualified renewable energy sources used for purposes of avoiding
emissions during the previous calendar year;

Verification of (1) installation of energy conservation measures and the
energy savings attained, and (2) plant operation using renewable energy
and the energy

generation attributable to renewable energy input;

For utilities using the EPA Conservation Verification Protocol, the
information and methodologies used in determining energy savings,
including a description of the conservation measures, the dates of
claimed savings, the number of installations, the calculations used to
determine energy savings, aggregate statistical information needed to
calculate confidence levels, and a description of any comparison groups;

Calculations of the number of tons of emissions avoided by implementing
conservation measures or using renewable energy; and

Identification of allowance tracking account(s) to which the Reserve
allowances are to be allocated.

Permits

	Every affected source is required to have an Acid Rain permit.  Acid
Rain permits have five year permit terms.  The permitting authority’s
operating permits rule governs the issuance of permits to new units and
for renewal of existing Acid Rain permits.

	A complete Acid Rain permit application includes the following
information:

Identification of the source (plant name, ORIS code, State);

Identification of affected units;

A complete compliance plan;

Standard requirements at 40 CFR 72.9;

For new units, commence operation date and monitor certification
deadline;

Standard certification; and

Name and signature of designated representative.

New Unit Exemption §72.7

	Operators of new units that serve generators with a nameplate capacity
of 25 MW or less and use fuel with a sulfur content by weight of less
than 0.05 percent may obtain an exemption from monitoring, permitting,
and allowance requirements if they submit a certification with the
following information:

Unit Identification;

Nameplate capacity of each of the generators served by the unit;

The first full calendar year that the unit will meet the exemption
requirements;

The fuels currently burned by the unit, and that will be burned in the
future, and their sulfur content by weight;

Certification that the owners and operators will comply with all
necessary requirements; and

Standard certification at §72.21(d)(2).

Retired Unit Exemption

	Operators of affected units that are retired may obtain an exemption
from the Acid Rain Program if they submit a retired unit exemption form
with the following information:

Unit identification;

The date that the unit was (or will be) permanently retired;

The first full calendar year that the unit will meet the exemption
requirements;

Certification that the unit is permanently retired and will comply with
all necessary requirements; and

Standard certification at §72.21(d)(2).

	All data items requested from permit applicants must be submitted on
standard forms. Most of the information requested in the forms is
specifically required by law.

Emissions Monitoring

	Emissions monitoring requirements specify that affected sources must
(1) submit a monitoring plan for each affected unit at a source, (2)
submit data for certification of each monitor, and (3) record hourly
operational, pollutant monitor, and flow monitor data for each affected
unit and submit quarterly reports of their emissions data to EPA.
Appendices A and B to this ICR contain a list of the data items required
by the recordkeeping and reporting provisions of Part 75.

	Respondents are required by 40 CFR 75.64 to submit the quarterly
emissions data electronically, by direct electronic submission to EPA,
and must also include a certification statement by the designated
representative of the unit.  Under the 2002 rule revisions, EPA requires
the certification statement to be submitted electronically unless it
approves a hardcopy submission.  All records are to be kept for three
years, with two possible exceptions under voluntary options that are
discussed in section 3.3 of this ICR.

	The 2002 Part 75 revisions add or revise some recordkeeping and
reporting terms.  Some of these are necessary for the rule requirements
to match the actual reporting practices incorporated in the Electronic
Data Reporting formats used for the Acid Rain Program.  Others reflect
minor rule changes.

Auctions

	For auctions, participants are required to submit a bid form and
payment method at least six days prior to the date of the auction.
Sealed bids are submitted on a standard bid form developed by EPA.  Each
bid provides the following basic information:

Name;

Account number (or new account information);

Allowance quantity and price; and

Type of auction.

	The bid also specifies an acceptable method of payment for the total
bid price regardless of the type of auction (spot or advance).  Full
payment for allowances -- in an acceptable form -- is required with the
bid at the time of submission.

Opt-in

	To obtain an opt-in permit, applicants are required to submit a
certificate of representation and an opt-in permit application for each
source.  For all respondents, the application must provide (1) general
information on the source, (2) specific data about the source’s fuel
consumption and operating data for 1985, 1986, and 1987, and (3) data on
the source's actual and allowable emission rates for 1985, as well as
the current allowable emission rate.  For permit applicants who plan to
opt in and shut down, the compliance plan is based on a statement
describing the source's plans for shutting down and replacing thermal
energy.

	The general information required of all opt-in sources include the
following items, as listed in Section 74.16 or another section as listed
below:

Source name and location;

Name, address, telephone and facsimilie number of the designated
representative;

Name, address, telephone and facsimilie number of the alternate
designated representative;

Statement of certification;

Complete record of fuel consumption and operating data for calendar
years 1985, 1986, 1987, or other acceptable baseline;

Actual and allowable emission rates for 1985, or if source was not
operating in 1985, for a calendar year to be determined by the
Administrator, as well as the current allowable emission rate;

Statement provisions as indicated at 72.9; and

Signature of designated representative and date of signature.

In addition, sources that opt in and continue to operate must meet the
emission monitoring requirements that were listed above.

As part of the annual compliance certification report required in
Section 74.43 for opt-in units, respondents must report utilization
information, and replacement of thermal energy and resulting transfer of
allowances.  The following information must be reported, as required in
Sections 74.44 and 74.47:

Source name and location;

Name, mailing address, telephone and facsimilie number of source
representative;

Benchmark utilization, annual utilization, average utilization,
end-of-year determination of reduced utilization, and the calculation of
allowances deducted for reduced utilization (if any);

Amount of thermal energy replaced (if the source has shut down or if the
utilization rate has fallen due to replacement of thermal energy by
another source), and the name and location of the source or sources
providing replacement thermal energy;

A calculation of the number of allowances transferred to each source
providing replacement thermal energy;

Allowance tracking system account number of the replacement units; and

Dated signatures for all designated representatives.

	All respondents who choose to withdraw from the program are required to
notify the Agency of their decision and provide the following
information, as required in Section 74.18:

Source account number;

Name, address, telephone and facsimilie number of the designated
representative; and

A certification that emissions requirements will be met through Dec. 31
of the current year, and that all remaining allowances will be
surrendered at that time.

NOx Permitting

	Regardless of the compliance option selected, the following elements
must be included in the compliance plan for each source:

Identification of the source;

Identification of each affected unit at the source that is subject to
these regulations;

Identification of the boiler type of each unit; and

Identification of the compliance option proposed for each unit.

	For units that are choosing either standard or early election limits,
the designated representative must simply check the appropriate box(es)
to indicate the NOx compliance plan that is chosen.

	For units that are in an averaging plan, the following additional
information must be submitted:

Identification of each unit in the plan;

Each unit's standard emission limitation;

The alternative contemporaneous applicable emission limitation for each
unit (in lb/mmBtu);

The annual heat input limit for each unit (in mmBtu);

The calculation for the equation outlined in Step 2 of the EPA form for
emissions averaging; and

The calendar years for which the averaging plan applies..

	For an AEL, the designated representative must submit the following
information:

AEL Demonstration Period

	For an AEL, the designated representative must first submit an
application for an AEL demonstration period.  The application must
contain the following information in accordance with 40 CFR §76.10(d):

Identification of the unit;

The type of control technology installed.  If low NOx burner technology
incorporating advanced and/or separated overfire air is technically
infeasible, a justification including a technical analysis and
evaluative report from the vendor of the system or from an independent
architectural and engineering firm explaining why;

Documentation that the installed NOx emission control system has been
designed to meet the applicable emission limitation and that the system
has been properly installed;

The date the specific unit commenced operation following the
installation of the NOx control equipment, or the date the specific unit
became subject to the emission limitations (whichever is later);

The dates of the operating period (minimum of 3 continuous months);

Certification by the designated representative that the unit and the NOx
control equipment were operated during the operating period in
accordance with specifications and procedures designed to achieve the
applicable emission limitation, with the operating conditions upon which
the design of the NOx control equipment was based, and with vendor
specifications and procedures;

A brief statement describing the reason or reasons an AEL demonstration
period is required for the specific unit;

For the control technology, load range, O2 range, coal volatile matter
range, and percentage of combustion air introduced through overfire air
ports;

Description of planned modifications;

List of parametric tests to be conducted in accordance with 40 CFR
§76.15;

Identification of the continuous emission monitoring data submitted
pursuant to 40 CFR Part 75 that is to be used in assessing this
application;

An interim AEL, in lb/mmBtu; and

The proposed dates of the demonstration period.

Final AEL

	After the demonstration period, the owner or operator may petition the
permitting authority for a final AEL.  The petition must include the
following information in accordance with 40 CFR §76.10(e):

Identification of the unit;

Certification that the affected unit and the NOx control equipment have
been properly operated during the demonstration period;

Certification that the affected unit has installed all emission control
equipment, made any operational modifications, and completed any
upgrades and/or maintenance to equipment specified in the demonstration
period plan;

A clear description of each step or modification taken during the
demonstration period;

Engineering design calculations and drawings that show the technical
specifications for installation of any additional operational or
emission control modifications installed during the demonstration
period;

Identification of the continuous monitoring data submitted pursuant to
40 CFR Part 75 that is to be used in assessing this application;

A report, based on the parametric testing, that describes the reasons
for the failure of the installed NOx control equipment to meet the
applicable emission limitation;

The minimum NOx emission rate, in lb/mmBtu, that the affected unit is
able to achieve on an annual average basis;

All supporting data and calculations documenting the determination of
the proposed AEL; and

For affected units that have installed an alternative technology,
demonstration that the annual average reduction of NOx emissions is
greater than 65 percent.

Recordkeeping

	All records are to be kept for three years, except for permitting
records which are to be kept for the duration of the permit, or up to
five years and certain new monitoring provisions.

	4.2.2	Respondent activities

Allowance Transfers

	Participants in the allowance transfer system that are not affected
units are required to perform two tasks:  (1) negotiate an agreement to
designate an authorized account representative and file an account
information application to open an Allowance Tracking System general
account; and (2) complete and submit allowance transfers.  Designating
an authorized account representative and filing an account information
application is required one time only, prior to or concurrent with
conducting the first transfer of allowances.  For each transfer of
allowances, participants are required to complete and submit an
allowance transfer form or provide the required information using the
On-line Allowance Transfer System (OATS).  Affected units that were
required to submit a certification of representation under the initial
ICR, must continue to prepare and submit allowance transfer information
for each allowance transfer, and if the designated representative
chooses, identifying the serial numbers of allowances to be deducted for
annual reconciliation using the Allowance Deduction Form.

	General account holders and affected units may change the authorized
account representatives by submitting a subsequent allowance account
information form or certificate of representation form respectively.

Conservation and Renewable Energy Reserve

	The tasks that must be performed by utilities applying for allowances
from the Conservation and Renewable Energy Reserve are (1) designate the
qualified energy conservation measures implemented and the qualified
renewable energy sources used to avoid emissions, (2) verify
installation of energy conservation measures or the plant operation
using renewable energy, and the resulting benefits, (3) calculate the
tons of emissions avoided, and (4) demonstrate qualification to receive
allowances for emissions avoided.  Generally, because utilities already
perform these tasks to satisfy state requirements, utilities do not need
to duplicate these efforts to apply for allowances from the Reserve.
Rather, utilities primarily assemble the information resulting from
these activities in an application and submit this application to EPA.

Obtaining a Permit

	The primary tasks to obtain a permit are listed below.  These tasks are
performed by existing sources required to renew their permits and new
units during the period covered by this ICR. In general, sources with
existing units, must reapply at least 6 months prior to the expiration
of an existing permit, but the actual timeframe is governed by the
permitting authority’s operating permits rules.

Designate a representative of the owners and operators of a source.
Read the designated representative certification procedures.  Negotiate
an agreement to designate a representative for each unit at a source.
Complete and submit the certification.  This task is only relevant for a
new Phase II source or if a source changes the designated
representative.

Prepare the permit application.  Read the permit application
instructions, then collect relevant information for the permit
application. Complete the Phase II acid rain permit application. Where
appropriate, provide specific information to support the use of
compliance options for NOX.  Review the information for accuracy and
appropriateness and report the information to the permitting authority.

Emissions Monitoring

	The primary tasks that are performed by respondents to meet the
emissions monitoring requirements are (1) completing and submitting
appropriate monitoring plan forms for each affected source and each
affected unit at a source; (2) conducting tests to certify the
operation of monitors, and submitting test results to EPA;
(3) recording hourly emissions data (this activity generally is
performed electronically); (4) operation and maintenance activities
associated with the monitoring, including quality assurance activities;
(5) assuring data quality, preparing quarterly reports of emissions
data and submitting these reports to EPA; and (6) responding to error
messages generated by EPA as a part of automated data checks or
electronic audits, or to field audits conducted by EPA.  In addition,
respondents must purchase the necessary monitoring hardware (or pay for
fuel sampling and analysis in some cases) and purchase the electronic
data reporting software (or software upgrades).  To enable sources to
perform self-audits of submissions, EPA also has developed the
Monitoring Data Checking (MDC) software for use by affected sources.
This software enables sources to run automated quality checks of reports
prior to submittal to EPA and reduces the burden of having to respond to
EPA generated error messages or follow-up EPA audits.

Opt-in

	In order to provide the information discussed in the previous section,
participants must complete three tasks to participate in the opt-in
program: (1) submit a permit application, (2) meet monitoring
requirements, and (3) submit annual compliance reports.  Respondents who
choose to withdraw are required to submit a withdrawal notification.

	The primary tasks that must be completed to obtain a permit and the
activities associated with them are listed below.  These tasks will be
performed only once during the period covered by this ICR.

Designate a representative of the owners and operators of a source.
Read the designated representative certification procedures.  Negotiate
an agreement to designate a representative for each source.  Complete
and submit the certification.

Prepare the permit application.  Read the permit application
instructions, then collect relevant information for the permit
application.  Complete written forms, including an application for an
opt-in permit.  Review the information for accuracy and appropriateness.
 Submit the information to EPA, sending copies to the appropriate EPA
regional office.

	Respondents who opt in and continue to operate must also perform the
task required under the emissions monitoring section above.  Respondents
who opt in and shut down do not need to perform any tasks related to
monitoring.

	To withdraw from the program, respondents must notify EPA of their
decision to withdraw.  Notification entails providing EPA with the data
items presented in Section 3.2.1..

	Opt-in sources covered by a thermal energy plan, must also report
information concerning the replacement of thermal energy, including the
identification of the source or sources providing replacement thermal
energy, and the allowances transferred as a result of the replacement of
thermal energy.

NOX Permitting

	The primary tasks for a NOX compliance plan are listed below.

Prepare the NOX compliance plan application.  Read the application
instructions, then collect relevant information.  Analyze compliance
options and plan compliance.  Complete written forms.  Review the
information for accuracy and appropriateness and report the information
to the permitting authority and send a copy to the EPA.  Preparing a NOX
compliance plan application may include interpreting the rule,
collecting information and completing and submitting a NOX averaging
plan, or an AEL petition.

	Because each source must renew its Acid Rain permit every five years,
EPA assumes the tasks for permitting will be performed by 20% of all NOX
affected sources annually, in accordance with Section 408.

5.	THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT

	The first part of this section describes Agency (EPA) activities
related to the acquisition, analysis, storage, and distribution of the
information collected from (1) participants in allowance transfers, (2)
applicants for allowances from the Conservation and Renewable Energy
Reserve, (3) permit applicants, (4) designated representatives of
affected sources that are required to submit monitoring plans and
emissions data, (5) participants in the annual auction, and (6) the
opt-in program, and (7) NOX permitting.  The second part describes the
information management techniques employed to increase the efficiency of
collections.  The third part discusses the burden or benefits of the
collection activities described in this ICR to small entities.  The last
part outlines the schedule for collecting information.

	5.1	Agency Activities

Allowance Transfers

	Collections associated with operating the allowance transfer system
requires EPA to (1) track allowance holders and maintain allowance
accounts, (2) review allowance transfer information for completeness and
ensure that all requirements are met, (3) record allowance transfers,
and (4) notify both participants in a transfer whether the transfer was
recorded.  EPA has developed a computer system called the Allowance
Tracking System (ATS) to track allowances and maintain information on
accounts. In addition, EPA now has a system that allows market
participants to submit transfers over the internet and that provides
real time transfers and instantaneous confirmation.

Conservation and Renewable Energy Reserve

	Activities that must be performed by EPA to distribute  allowances from
the Conservation and Renewable Energy Reserve include (1) registering
applications and reviewing applications for completeness, (2) performing
substantive reviews of applications to determine whether all necessary
criteria to receive allowances have been met, (3) transferring
allowances from the Reserve or notifying applicants of their failure to
qualify for allowances from the Reserve, and (4) for utilities using the
EPA Conservation Verification Protocol, verifying the quantified energy
savings from conservation measures.

Permits

EPA staff administering the permit program perform the following task:

Review certificates of representation, enter the information in the
Clean Air Markets Database (CAMD), and notify the representative.

Permitting authority staff, generally at the state or local level,
perform the following tasks:

Review permit applications and issue permits.  Receive and review permit
applications and record submissions.  Provide notice to applicants
whether permit applications are complete.  Reformat collected data items
to constitute proposed and final permits.  Provide opportunities for
public comment and participation.

Emissions Monitoring

	The major EPA activities related to emissions monitoring and reporting
include (1) reviewing monitoring plans and certification applications,
and (2) processing, reviewing and evaluating reports of quarterly
emissions data from affected units.  EPA has developed a computer system
called the Emissions Tracking System (ETS) to track and maintain this
information.  EPA also answers respondent questions and conducts audits
of data submissions and field audits of monitoring systems.  The use of
the Monitoring Data Checking software streamlines EPA's process for
conducting many of these checks.

Auctions

	EPA staff administering the auctions receive the sealed bids and
payments, enters the information provided on bid forms into a computer
system, and deposits the checks into a designated bank account.
(Collectively, these activities comprise handling of bids and checks.)
After bids are recorded, they are ranked using a computer program and
then the allowances  are allocated.  EPA announces the results by
posting them on the EPA website. Finally, after payment is verified, EPA
records the transfer of allowances and transfers the proceeds from the
auction to the owners and operators from whom the allowances were
withheld.  EPA has developed a computer system to track the payment of
proceeds.

Opt-in

	EPA staff administering the opt-in permit program perform the following
tasks for each opt-in applicant:

Review certificate of representation, record information, and notify
representative.

Review permit application.  Receive and review permit application and
record submission. Provide notice to applicant as to whether permit
application is complete.  Reformat collected data items to constitute
proposed and final permit.

Notify applicant regarding allowances.  Notify the opt-in permit
applicant of the number of allowances the applicant would receive each
year as an opt-in source.

	EPA activities related to withdrawals will be to process the withdrawal
notification, and ensure that all unused allowances have been
surrendered at the end of the calendar year.

NOX Permitting

Agency staff perform the following task.

Review NOx compliance plan applications.  Receive and review
applications and record submissions.  Provide notice to applicants
whether applications are complete.

	5.2	Collection Methodology and Management

	To ensure consistency nationwide and to expedite (1) data entry, (2)
the allocation of allowances from Reserves, and (3) permit issuance, EPA
requires that standard reporting forms or equivalent formats or standard
electronic reporting formats be used to submit all information to be
collected under this ICR.  The standard forms are included in Appendix
C.

	Currently, respondents to collections for allowance transfer
information may submit the required information on a standard written
form, or using an electronic format.  Permit applications are submitted
on standard paper forms, as are certifications for new and retired unit
exemptions.  EPA requires that standard electronic data reporting (EDR)
formats be used to submit information to be collected under Part 75 and,
under the 1999 rule revisions, EPA also required that data be sent via
direct electronic submission to EPA beginning in the year 2001.  The
current EDR formats (version 2.2) are included in Appendix C to this
document.

	Several computer systems and associated databases have been developed
to (1) track allowances, (2) record quarterly emissions monitoring
data, (3) track auction proceed payments, and (4) calculate the number
of allowances to be deducted each year.  In 2001, EPA also made
available the On-line Allowance Transfer System to permit online
allowance transfers and allowance account maintenance activities.  The
systems and databases are designed to coordinate the information for
easy access and use by the Agency, states, regulated community, and the
public.

	The Data and Maps section of the EPA’s Clean Air Markets Home Page on
the Internet, includes detailed information collected from emissions
reports, allowance transfer activity, and facility or source data.
Those without access to the Internet may use the Acid Rain Hotline to
request information.

	5.3	Small Entity Flexibility

	For the purposes of the Acid Rain Program, EPA has adopted the Small
Business Administration's definition of a "small" electric power utility
as one that generates a total of less than 4 billion kilowatt-hours per
year.  Generally, although about two-thirds of the affected sources in
Phase II generate a total of less than 4 billion kilowatt-hours per year
and are required to participate in some collections under this ICR
(e.g., submitting information for certification of monitors and
submitting quarterly emissions monitoring reports), the costs to these
sources for collections under this ICR are small relative to the
revenues they generate.  This is based on an analysis that was included
in the Regulatory Impact Analysis of the Final Acid Rain Implementation
Regulations, dated October 19, 1992.

	All affected sources under the Clean Air Act Amendments of 1990 are
required to submit permit applications and to respond to other
collections under this ICR, according to the same parameters (with the
exception of operators of new units of 25 MW or less, who may receive an
exemption from the Acid Rain Program requirements if they qualify).
Retired units may also be exempted from some reporting requirements.

	The use of standardized forms will enable small entities to understand
and complete permit application submissions without the level of
staffing which would be necessary in the absence of such forms.

	In the January 11, 1993 final Acid Rain Core Rules, EPA provided for a
conditional exemption from the emissions reduction, permitting, and
emissions monitoring requirements of the Acid Rain Program for new units
having a nameplate capacity of 25 MWe or less that burn fuels with a
sulfur content no greater than 0.05 percent by weight, because of the
high cost of monitoring emissions from these sources and the de minimis
nature of their emissions.

	The Part 75 rule revisions also create an additional small unit
exception.  This exception incorporates optional reduced monitoring,
quality assurance, and reporting requirements into Part 75 for units
that combust gas and/or fuel oil and that have low levels of mass
emissions (referred to as low mass emissions (LME) units).  Originally,
EPA required that LME units emit no more than 25 tons of SO2 and no more
than 50 tons of NOx annually, and that they calculate no more than 25
tons of SO2 and no more than 50 tons of NOx annually based on required
procedures for calculating and reporting emissions.  As part of the 2002
Part 75 revisions, EPA has increased the NOx threshold to <100 tons per
year (and, for units that are subject to the NOx SIP Call, no more than
50 tons per ozone season).  Qualifying LME units are no longer required
to keep monitoring equipment installed on (or conduct sulfur-in-fuel
sampling for) low mass emissions units, nor are they required to perform
quality assurance or quality control tests.  Moreover, emissions
reporting requirements are significantly simplified for these units.

	Even if a gas- or oil-fired unit does not qualify for the LME
provisions, Part 75 allows gas and oil-fired units to use methods other
than continuous emission monitoring systems (CEMS).  The 1999 Part 75
revisions significantly reduced the costs and burdens associated with
fuel sampling and QA activities for these non-CEMS methods.  As
discussed in the Regulatory Impact Analysis (RIA) of the final Acid Rain
Implementation Regulations (October 19, 1992), smaller utilities are
more likely to be dependent on these oil- and gas-fired units,
especially very small utilities (see p. 5-14 of that RIA document).

	Further reductions in requirements aimed specifically for small
entities are limited because of the statutory requirements that all
affected units use CEMS (or an equivalent method) to record and report
emissions data for Title IV purposes.

	5.4	Collection Schedule

Allowance Transactions

	There is no specific collection schedule associated with allowance
transactions.

Conservation and Renewable Energy Reserve

	Submitting applications for allowances from the Conservation and
Renewable Energy Reserve is voluntary.  Allowances from the Reserve will
be allocated on a first-come, first-served basis during the period from
January 1, 1992 to December 31, 2009.

Permits

	In general, each Acid Rain permit is effective for five years.
Revisions to the permit may be submitted at any time.

Emissions Monitoring

	Monitoring plans must be submitted only once, although certain elements
of the monitoring plan are submitted (and updated as necessary)
routinely as part of the EDR format.  Only new units will have to apply
for certification during the 2007-2009 time period.  While some monitors
will be required to apply for recertification, there is no set schedule
for recertification.

	Quarterly reports are due for each quarter during the life of this
information collection request.  In addition, EPA has provided for
notifications to the Agency for semi-annual or annual quality assurance
testing and for situations where a unit will have a revised
certification deadline (for example, notifications of unit start-up for
new units).

Auctions

	The spot and advance auctions are currently held before March 31 of
each year.  The cutoff date for submission of bids is only a few days
prior to the auction in order to limit the time EPA holds the bidders'
money.

Opt-in

	Opting in to the allowance program requires just one information
collection (although monitoring information for affected sources must be
collected quarterly).  Opt-in permit applications may be submitted to
EPA and the permitting authority at any time.  Permits must be renewed
at that time, and every five years thereafter.  Revisions to the permit
may be submitted at any time.

	Monitoring plans must be submitted only once, at the time the opt-in
permit application is submitted.  The data upon which EPA will base its
certification of each emissions monitor may be submitted after the
source receives a draft opt-in permit, but must be submitted before the
source may be designated an affected source.  (Monitors must be
installed, certified by EPA, and operating before the source may be
designated an affected source.)  Emissions data to meet reporting
requirements are collected quarterly, 30 days after the end of each
calendar quarter, beginning at the end of the first quarter in which the
source becomes an affected source.

	Compliance reports must be sent annually.  Allowance transfer
information must be submitted once for each transfer; a certificate of
representation needs to be submitted only once, at the same time as the
opt-in application.

Withdrawing requires only one information collection.

NOX Permitting

	Acid Rain permits, including  NOX compliance plans must be renewed
every five years.

6.	ESTIMATING THE BURDEN AND COST OF COLLECTIONS

	This section estimates the paperwork burden and cost of (1) tracking
and transferring allowances, (2) obtaining and distributing allowances
from the Conservation and Renewable Energy Reserve, (3) obtaining and
issuing permits, (4) submitting monitoring plans, obtaining
certification of each monitor, and recording and reporting data from CEM
systems, (5) the auction program, (6) the opt-in program, and (7) NOX
permitting.

	First, assumptions regarding allowance transfers are presented,
followed by the annual respondent and Agency burden and cost estimates
associated with allowance transfers.  Subsequent sections separately
address allowances for energy conservation and renewable energy use,
permits, emissions monitoring, auctions, opt-in, and NOX permitting.
Finally, aggregate annual burden hour and cost estimates to respondents
and to EPA for collections covered by this ICR are presented.

Estimating Labor Costs

	To calculate labor costs, EPA used the following amounts: $84.43 per
hour for managers, $58.00 per hour for technicians and clerical workers.
 As noted above, these rates were derived by using the rates from the
previous ICR and updating them with the Employment Cost Index to January
2006.

	The labor cost to the Agency, $54.65 per hour, was also derived by
updating the rate from the previous ICR.

6.1	Tracking, Transferring, and Deducting Allowances

	Labor burden and costs for collections associated with tracking and
transferring allowances are functions of the number of transfers
anticipated.  Based on number of transfers recorded by EPA in 2004 and
2005, EPA could assume that about 5,200 privately submitted allowance
transfers will be made each year, 2007 through 2009.  However, given
that the Acid Rain Program is moving to facility level compliance
beginning in 2006, this number would turn out to be a substantial
overestimate.  That’s because a large number of transfers are made to
move allowances among the different unit accounts at a facility for
compliance purposes.  Switching to a single facility account for
compliance will eliminate all of these transfers. Since there are an
average of three units per facility, EPA is assuming that the number of
privately submitted allowance transfers will be about 1,700 (one third
of the 5,200 from prior years) each year, 2007 through 2009.

	Affected facilities have the option of identifying specific serial
numbered allowances to be deducted by EPA.  Based on past experience,
EPA assumes that approximately half of all affected facilities will
submit an optional allowance deduction form each year.   EPA estimates
that an average of 645 facilities will be submit the optional deduction
forms each year during the period covered by this ICR (2007 - 2009).

6.1.1  Estimate of Respondent Burden and Costs for Transfers and
Deductions

	Exhibit 1 presents the annual burden and costs to participants in
allowance transfers and deductions.  Participants that are not affected
units are required to negotiate an agreement to designate an authorized
account representative and file a new account application; this activity
is required only one time, prior to or simultaneous with the
participant's first transfer of allowances.  All participants are
required to complete and submit allowance transfer information for each
transfer of allowances.  EPA estimates about 10 hours to designate an
authorized account representative and to open a general account, about 2
hours to prepare and submit information for an allowance transfer, and
about 3 hours to prepare and submit an optional allowance deduction.

Assuming that 55 participants file new general account applications,
1,700 transfers will be made annually, and 645 deduction forms are
submitted the burden to respondents will be about 5,885 hours annually.
 The cost to respondents will be about $407,669 annually.

EXHIBIT 1

ANNUAL RESPONDENT BURDEN/COST ESTIMATES FOR ALLOWANCE TRANSFERS AND
DEDUCTIONS

Tasks	Burden Hours per Occurrence	Cost per Occurrencea	Total Burdenb

Total Cost

Designate an authorized account representative and file new account
application

     Managerial	3	$253.29	165	$13,930.95

     Technical	7	$406.00	385	$22,330.00

Prepare and submit allowance transfer information

     Managerial	1	$84.43	1,700	$143,531.00

     Technical	1	$58.00	1,700	$98,600.00

Allowance deduction form (optional)

     Managerial	1	$84.43	645	$54,457.35

     Technical	2	$116	1,290	$74,820.00

TOTAL

	5,885	$407,669.30

a 2006 dollars.

b Assumes 55 participants file new account applications, 1,700 transfers
are made, and 645 optional deduction forms are submitted.

6.1.2  Estimate of Agency Burden and Costs for Transfers

	Agency burden and costs are divided into those costs associated with
enhancing a tracking system, and those associated with transferring and
deducting allowances.

Allowance Tracking System

	The allowance system regulations set the general requirements for the
tracking system, which has been developed by EPA. In order to track
allowances, the allowance tracking system must include information on
(1) allowance allocations for each affected facility, (2) allowance
transfers and deductions, and (3) allowance holders.  Also, to allow for
the transfer of future year allowances, the allowance tracking system
will contain allowance information for thirty years into the future.
EPA has made the information compiled in the allowance tracking system
publicly available in several formats on the internet and is continually
working to improve electronic access.

	EPA incurs annual operation and maintenance (O&M) costs for running an
electronic transmission network, system enhancement, general
maintenance, and employee salaries.  These O&M costs are estimated at
$1.5 million annually.

Allowance Transfer System

	Upon receipt of an allowance transfer notification in hard copy form,
EPA will (1) review allowance transfer information for completeness and
ensure that all requirements have been met, (2) record allowance
transfers, and (3) notify both participants to a transfer whether the
transfer was recorded.  EPA estimates that it will require an average of
one hour to perform these activities for each notification.  Upon
receipt of an optional allowance deduction form, in hard copy, EPA will
record the data into the EPA data system.  This is estimated to take
about 30 minutes per form.

	Assuming 500 (out of the 1,700 total) transfers will be made using
paper forms each year and 100 (out of the 645 total) deduction
submissions will be on paper, the annual burden to EPA will be about 550
hours. There is no Agency burden when participants use the electronic
on-line transfer system (also used for the optional deduction
submission), since all EPA functions are automated.  Costs for
maintaining the on-line system are included in the O&M costs.  The total
cost to EPA will be about $30,058 annually. Exhibit 2 summarizes the
Agency burden and cost estimates for recording and transferring
allowances.

EXHIBIT 2

ANNUAL AGENCY BURDEN/COST ESTIMATES FOR ALLOWANCE TRANSFERS

Tasks	Burden Hours Per Occurrence	Cost Per Occurrencea	Total Burdenb

(Hours)

Total Cost

Review allowance transfer information, record transfer, and notify
transfer participants	1	$54.65	500	$27,325.00

Enter deduction data and deduct allowances	0.5	$27.33	50	$2,733.00

TOTAL

	550	$30,058.00

a 2006 dollars.

b Assumes 500 transfers and 100 optional deduction forms are submitted
annually.

6.2	Obtaining and Distributing Allowances From the Conservation and
Renewable Energy Reserve

	Although it is difficult to predict the number of utilities that will
apply for allowances from the Conservation and Renewable Energy Reserve,
based on the previous two years this analysis assumes that no
applications will be submitted each year (2007 through 2009).

	6.2.1  Estimate of Respondent Burden and Costs

	Exhibit 3 depicts the annual respondent burden and costs associated
with obtaining allowances from the Conservation and Renewable Energy
Reserve.  Each utility applying for allowances from the Reserve is
required to perform the following tasks: (1) designate energy
conservation measures implemented and renewable energy sources used to
avoid emissions; (2) verify savings from energy conservation measures
and/or amount of generation from renewable energy; (3) calculate the
tons of emissions avoided; and (4) demonstrate qualification to receive
allowances for emissions avoided.  Because most states already collect
information on these activities from utilities, the primary burden to
utilities would be that associated with assembling and submitting to EPA
the application to receive allowances from the Reserve. If someone chose
to apply, EPA assumes it would take about 46 hours to assemble and
submit an application to receive allowances from the Reserve to EPA, and
an additional 32 hours if the applicant chose to assemble and submit the
information required in the EPA Conservation Verification Protocol.

EXHIBIT 3

ANNUAL RESPONDENT BURDEN/COST ESTIMATES FOR CONSERVATION AND RENEWABLE
ENERGY ALLOWANCES

Tasks	Burden Hours per Application	Cost per Applicationa	Total Burden

(Hours)	Total Costs

Assemble and submit an application to receive allowances from the
Reserveb

     Managerial	11	$928.73	0	$0

     Technical	35	$2,030.00	0	$0

Assemble and submit the information required in the EPA Conservation
Verification Protocolc

     Managerial	7	$591.01	0	$0

     Technical	25	$1,450.00	0	$0

TOTAL	0	$0

a 2006 dollars.

b Assumes 0 applications  each year (2007-2009).

c Assumes 0 applicants will utilize the EPA Conservation Verification
Protocol each year.

	6.2.2 Estimate of Agency Burden and Costs

	Exhibit 4 depicts the annual burden and costs to EPA associated with
distributing allowances from the Conservation and Renewable Energy
Reserve.  Tasks performed by EPA related to the distribution of
allowances from the Reserve include the following: (1) register
applications and review applications for completeness; (2) perform
substantive reviews of applications to determine whether all necessary
criteria to receive allowances have been met; (3) transfer allowances
from the Reserve or notify applicants of their failure to qualify for
allowances from the Reserve; and (4) for utilities that choose to use
the EPA Conservation Verification Protocol, verify the quantified energy
savings from conservation measures.  EPA assumes it takes  about 11
hours to process each application and transfer allowances (or notify
applicants).

EXHIBIT 4

ANNUAL AGENCY BURDEN/COST ESTIMATES FOR CONSERVATION AND RENEWABLE
ENERGY ALLOWANCES

Tasks	Burden Hours per Application	Cost per Applicationa	Total Burden

(Hours)	Total Costs

Register application and review for completenessb	1	$54.65	0	$0

Perform substantive review of applicationb	4	$218.60	0	$0

Transfer allowances from the Reserve or notify applicantsb	1	$54.65	0	$0

Verify energy savings based upon the EPA Conservation Verification
Protocolc	5	$273.25	0	$0

TOTAL	0	$0

a 2006 dollars.

b Assumes 0 applications each year (2007-2009).

c Assumes 0 applicants will utilize the EPA Conservation Verification
Protocol.

6.3	Obtaining and Issuing Permits

	This part presents estimates of the level of effort required and the
associated costs to permit applicants and either EPA or the permitting
authority of obtaining and issuing permits.  This analysis estimates the
cost and burden for new sources required to obtain permits for Phase II,
for sources changing designated representatives, and sources renewing
their permit.

	All applicants for permits will be required to submit a general acid
rain permit application for each affected source that covers all units
at the source.

	6.3.1  Estimate of Respondent Burden and Costs for Permiting

	Exhibit 5 depicts the burden and costs to respondents for (1) selecting
a new designated representative, (2) submitting Phase II permit
application, (3) submitting a retired unit exemption, and (4) submitting
a new unit exemption. Based on the past two years of operation, EPA
assumes that each year 800 Certificate of representation forms will be
submitted to appoint new designated representatives, 20% of all sources
will submit Phase II permit applications (this number includes both new
sources and sources renewing their permits), 33 units will submit
retired unit exemptions, and 33 units will submit new unit exemptions.

	 The total annual respondent burden is estimated to be 13,531 hours.
The costs associated with the permitting process are estimated at
$1,012,000 annually.

EXHIBIT 5

RESPONDENT BURDEN/COST ESTIMATES FOR PERMITS

Tasks	Burden Hours Per Occurrence	Cost Per Occurrencea

Total Burden

Total Cost

Change Designated Representaiveb

   Managerial	10	$844.30	8,000	$675,440.00

   Technical	5	$290.00	4,000	$232,000.00

Phase II Permit Applicationsc

   Managerial	2	$168.86	520	$43,903.60

   Technical	3	$174.00	780	$45,240.00

Retired Unit Exemptiond

   Managerial	1	$84.43	33	$2,786.19

   Technical	2	$116.00	66	$3,828.00

New Unit Exemptione

   Managerial	1	$84.43	33	$2,786.19

   Technical	3	$174.00	99	$5,742.00

TOTAL	13,531	$1,011,726.00

a 2006 dollars.

b Assumes that 800 certificate of representation forms will be
submitted.

c Assumes 260 sources (20% of all affected sources) will submit Phase II
permit applications each year.

d Assumes 33 units will submit retired unit exemptions each year.

e Assumes 33 units will submit new unit exemptions each year.

Estimate of Agency/Permitting Authority Burden and Costs for Permitting

	Exhibit 6 presents the burden and costs to EPA and the permitting
authority  to review and process permit information.  The primary tasks
performed by EPA are reviewing certificates of representation, and
reviewing permit applications.  The primary tasks performed by the
permitting authority are reviewing and processing permit applications,
notifying the public, and issuing proposed and final permits, and
reviewing new and retired unit exemptions.  Reviewing a certificate of
representation and determining completeness notice is estimated to
require half an hour.  Reviewing the permit application, notifying the
public, and issuing proposed and final permits is estimated to require 9
hours per occurrence.  The Agency's total annual effort will be 680
hours. The total cost to EPA for all permitting activities will be about
$37,156.  The total annual estimated burden and cost to the Permitting
Authorities is 2,212 hours and $120,885.

EXHIBIT 6

ANNUAL AGENCY/PERMITTING AUTHORITY BURDEN/COST ESTIMATES FOR PERMITS

Tasks	Burden Hours Per Occurrence	Cost Per Sourcea	Total Burden (Hours)

Total Cost

EPA reviews certificates of representation and records informationb	0.5
$27.33	400	$21,864.00

Review permit application, and issue draft, proposed, and final permitc

     Permitting Authority action	8	$437.20	2,080	$113,672.00

     EPA review	1	$54.65	260	$14,209.00

Receive and process retired and new unit exemptionsd

     Permitting Authority action	2	$109.30	132	$7,213.80

     EPA review	0.3	$16.40	20	$1,082.40

TOTAL	2,892	$158,041.20

a 2006 dollars.

b Assumes 800 sources submit a certificate of representation.

c Assumes 260 sources (20% of all affected sources) will submit Phase II
permit applications each year.

d Assumes 33 retired and 33 new unit exemptions are submitted each year.

Emissions Monitoring Recording and Reporting

This section estimates the paperwork burden and cost of submitting
monitoring plans, obtaining certification of each monitoring system,
conducting monitor quality assurance activities, and recording and
reporting data from CEM systems (or approved alternatives), and other
ancillary activities (such as responding to EPA generated error
messages, or responding to EPA audits).

The legislative requirements in Title IV require all affected Phase I
and Phase II sources to install SO2 and NOx CEM systems, opacity
monitors (COMS), and flow monitors (or approved alternatives). Data
handling or reporting is required by the law, but not specified. Under
the promulgated regulations, however, EPA imposes data handling,
reporting, and recordkeeping requirements. The EPA requires that all
affected units required to install CEM systems use a data acquisition
and handling system (DAHS) to record hourly CEM and flow monitor data in
the EDR format. Affected gas- and oil-fired units may elect to use the
approved alternative SO2 monitoring method and record fuel sulfur
analysis data, and then use a DAHS to record and report hourly fuel flow
values from a fuel flow meter in the EDR format. In addition, peaking
units that burn natural gas and/or fuel oil may use an excepted method
for calculating NOx emission rates. Finally, EPA allows certain low mass
emissions (LME) units to use assumed emission factors together with
operational data to calculate emissions.

Affected sources are required to complete and submit a monitoring plan
and obtain certification of each monitor (on standard forms) for each
affected unit at the source. These plans and certifications, which are
only submitted once, have already been submitted for most units.
Sources, however, may need to submit revised plans or even recertify if
they change some aspect of their existing plan. New units will still
need to submit plans and certifications for the first time. In addition,
all affected units are required to submit quarterly reports of their
emissions data to EPA; these reports include much of the basic
monitoring plan data as well.

To develop this renewal ICR, EPA relied primarily on the extensive
efforts to identify and calculate burdens for the prior two ICR renewals
and the CAIR ICR.  In 1999, EPA promulgated significant revisions to
Part 75 to address a number of implementation concerns that affected
sources had raised. In 2002, EPA promulgated less significant revisions
to Part 75 that addressed a number of procedural and technical issues,
the possibility of non-load based units using Part 75 as part of the NOx
SIP Call, and the expanded use of the LME provisions.

To quantify the respondents' burdens and costs, EPA has analyzed
existing data reported by the affected sources and developed model unit
categories to classify and characterize the affected population.

A projection of the number of new units that will come on line in 2007 -
2009 was also made and included in the unit counts. The new unit
estimates were based on the four year average of new units coming on
line in the 2002 – 2005 period (203 units/year).  New units were
apportioned to the different monitoring methodologies based on the four
year average of new units coming on line for each methodology.

The result of this analysis characterizes the total number of reporting
units into the following model categories:

Model A (units with SO2, flow, NOx, and CO2 CEMS):  1010 total units.

Model B (units with opacity CEMS solely as a result of Title IV):  500
total units.

(Note: these units also are classified under other models for SO2, NOx,
and CO2 requirements.)

Model C (units with Appendix D monitoring for SO2 and CEMS for NOx):
2111 total units.

Model D (units using both Appendix D and Appendix E for SO2 and NOx):
308 total units.

Model E (units using the LME methodology):  108 total units

Model F (units with moisture monitors necessary for moisture
correction):  100 total units. (Note: These units are also classified
under other models for SO2, NOx, and CO2 requirements.)

To estimate the burden and/or cost for each model, EPA has relied on the
estimates included in the prior ICR renewal for labor hour estimates of
each activity. In addition, the hourly labor rates for managerial,
technical and clerical staff reflect the labor rates used in the
existing ICR but are updated to 2006 dollars using the Employment Cost
Index, consistent with Agency ICR guidance.

6.4.1 Estimating Respondent Burden

The primary tasks performed by owners and operators of affected units
are (1) reviewing the regulations, forms and instructions,
(2) responding to EPA generated error messages and audits,
(3) reprogramming a DAHS and debugging the software, (4) completing
and submitting monitoring plans for each unit at the source,
(5) performing appropriate tests and providing test results to certify
each monitor, (6) performing quality assurance testing and maintenance
upon monitors, (7) assuring the quality of emissions data, preparing
quarterly reports of emissions data, and submitting reports to EPA; and
(8) fuel sampling.

(i) Regulatory Review.

The estimate for time to review instructions and requirements remains
consistent with the labor estimates used in previous ICRs (4 manager
hours and 4 technician hours) where no substantial changes have been
made to the Rule.  EPA continues to make available online fully
searchable versions of the Part 75 Emissions Monitoring Policy Manual
and the Electronic Data Reporting Instructions (Versions 2.1 and 2.2),
and is in the process of adding a fully searchable unofficial version of
Part 75 to this integrated search Webpage.  In addition, EPA in 2005
posted online a text version of its Plain English Guide to Part 75.

(ii) Response to Error Messages/Audits.

The EPA provides feedback to sources so that suspected errors in
submissions by sources are noted and corrected. With the use of the MDC
software, EPA believes that the burdens for this activity have decreased
over time. At the same time, however, EPA has increased its audit
oversight and expects to conduct a number of electronic and field audits
of facilities over the next few years. In particular, EPA anticipates
making significant use of electronic audits as a means to provide
continuous data quality improvement. This effort will result in
increased burdens for respondents. In addition, if EPA conducts a field
audit, the burden to a source could involve from 24 to 36 hours.
However, on a per unit basis, these field audit impacts are less
significant because not every unit will be subject to an audit in a
particular year. EPA projects no more than 10 audits per year. If the
average burden of an audit is 30 hours per audit, the per unit burden
for all units that would be associated with EPA's audit activities is
less than one hour of burden per respondent.  Note that, because this
activity should be inapplicable for the simplified reporting required of
low mass emissions units, the total number of respondents for this
activity excludes the LME units.

(iii) DAHS Upgrade and Debugging.

Each source must purchase (or create) and install computer software
designed to implement the electronic data reporting (EDR) formats
required under the Acid Rain Program. EPA anticipates that EPA will
promulgate revisions to Part 75 in late 2006 to accommodate planned
changes in EPA’s data systems that manage the data submitted by
respondents.  These data system changes are necessary to modernize
EPA’s data systems, and over time should streamline reporting.  The
costs of the required upgrade are being analyzed in a separate ICR that
will be issued in conjunction with the Part 75 revisions.  At this time,
EPA does not believe that there is adequate information to expect
reduced reporting burdens under the Acid Rain Program as a result of
those rule revisions, although EPA anticipates that will be the long
term result.  Upon the next renewal of this ICR, EPA will examine this
issue in more detail as the impacts of the rule revisions and data
system changes on the reporting burdens will be better understood at
that time. For the time period of this ICR, 2007-2009, no other changes
would require a DAHS upgrade and therefore the burden hours for this
activity are reduced to zero."

(iv) Monitoring Plans.

Consistent with the existing ICR, completing and submitting monitoring
plans is estimated to require an average of about 20 hours per unit
initially. For existing units, initial monitoring plan submissions will
be received prior to the time period covered in this renewal ICR, and,
consistent with the existing ICR, EPA does not include burden hours for
existing units under this initial monitoring plan development task area
during 2007-2009. The burden associated with revising the monitoring
plan is included in the time for preparing and submitting each quarterly
emissions report.

For new units, EPA has used the average number of new units for 2002,
2003, 2004, and 2005 as a projection for the average number of new units
expected in 2007-2009. These units have a separate line item for initial
monitoring plan preparation.

(v) Monitor Certification.

Based on information gathered as part of the 1999 rule revisions, EPA
included assumptions in the previous ICR renewal to include labor
burdens for monitor certification activity as well as test contractor
costs. For existing units, only recertifications are included in the
estimated activities for 2007-2009 The Agency estimates a labor burden
of 50 hours and a contractor cost of $3,400 per respondent. The cost and
burden figures exclude the costs and burdens associated with conducting
a RATA as part of the recertification process because those costs are
incorporated within the annual QA costs for previously certified
monitoring systems.

Under Part 75, sources are required to recertify the monitoring systems
whenever the source makes a replacement, modification, or change in a
certified CEMS or continuous opacity monitoring system that may
significantly affect the ability of the system to accurately measure or
record the SO2 or CO2 concentration, stack gas volumetric flow rate, NOx
emission rate, percent moisture, or to meet the QA and QC requirements.
Recertification is also necessary whenever the source makes a
replacement, modification, or change to the flue gas handling system or
the unit operation that may significantly change the flow or
concentration profile. Examples of changes which require recertification
include: replacement of the analyzer, change in location or orientation
of the sampling probe or site; and complete replacement of an existing
CEMS or continuous opacity monitoring system.

For new units, the monitor certification costs are included in the
capital/startup costs.

(vi) Quality Assurance.

Quality assurance (QA) testing and maintenance upon monitoring systems
is the largest burden item under the monitoring, reporting and
recordkeeping requirements for the Acid Rain Program. The requirements
include daily, quarterly and annual QA requirements, depending on the
monitoring approach being used. For reporting units that use a full set
of CEMS (SO2, flow, NOx and CO2), the Agency has developed a per unit
labor burden based primarily on information gathered from affected
sources. For units that also are required to install and maintain a
continuous opacity monitoring system (COMS) as a result of Part 75,
additional labor burdens apply. For units that rely on Appendix D
excepted methods for SO2 but use a NOx and CO2 CEMS, reduced labor
burden estimates apply because the quality assurance activities for the
excepted methods are less than for a CEMS. The labor burdens for these
excepted methods were derived primarily from cost estimates provided by
a group of affected utilities (see Docket A-97-35, Item II-D-48). For
units that rely on the excepted methods under both Appendix D and E
(i.e., units without CEMS), the burden estimates are reduced further
because no CEMS QA is required. For the relatively small number of units
that require moisture correction, labor burdens for moisture monitoring
QA activities have been added based on information supplied by an
affected utility (see Docket A-97-35, Item II-D-94). Finally, for units
that use the LME provisions, no QA requirements apply except for units
that use the unit-specific default value option. Those units are
required to test the unit to determine a unit specific value. That cost
has been included as a contractor cost for all new LME units. Using the
data discussed above, EPA estimates that the average respondent (using a
weighted average for the units that fall under Models A-F) will require
approximately 450 labor hours to meet the QA requirements of Part 75.
Consistent with the existing ICR, this labor is expected to be almost
entirely technician labor.

(vii) Quarterly Reports.

Tasks performed by utilities in preparing quarterly reports include:
(1) assuring the quality of the data, (2) preparing the quarterly
report, (3) revising the monitoring plan, if necessary,
(4) preparation of hard copy documentation accompanying the quarterly
reports, and (5) managerial review. EPA has been improving electronic
file transfer procedures over the past few years and has been developing
automated tools that allow sources to quality assure their reports. EPA
believes these efforts have reduced the average burdens per report over
time. In addition, because the program is maturing, the respondents have
developed procedures and methods to increase their efficiency with
reporting. The 1996 ICR estimated 240 hours per unit for this activity.
As a result of the 1999 Part 75 revisions, this estimate was decreased
to 204 hours, but that estimate was not based on consideration of
potential changes in burden that may have occurred outside the scope of
the specific reduced reporting requirements in the 1999 rule revisions.
Based on consultations with a few utility representatives in 2002, EPA
determined that this burden activity area significantly overstated the
average burden levels, although it may have been accurate for some
units.  The contacts provided a fairly wide range of estimates for this
activity, however, and thus EPA conservatively used a 102 hour per unit
estimate in the 2002 ICR renewal (a 50% reduction from the 1999 ICR).
This burden estimate is being used this renewal as well. As noted above,
future changes to EPA’s data systems may enable respondents to
streamline their reporting burdens, and EPA anticipates examining that
issue in detail as part of the next renewal of this ICR.  For LME units,
the estimate remains at 16 hours per year for each LME unit.

6.4.2 Estimating Respondent Costs

Exhibit 7 summarizes the annual respondent costs. The following
discussion describes how those costs were derived.

(i) Estimating Total Capital and Annual Operations and Maintenance Costs

Capital/start-up costs include the cost of installing required CEMS or
alternatives.  The Agency developed the capital cost estimates for the
CEM and other equipment based on EPA CEM cost models, existing ICRs, and
comments from various affected utilities.  The cost estimates vary
depending on the number and type of monitors that are required.
Annualized capital cost estimates are included for each of the Models
A-F on Exhibit 7. These annualized capital costs are from the Rule to
Reduce Interstate Transport of Fine Particulate Matter and Ozone (Clean
Air Interstate Rule) EPA ICR #2152.02.  The annualized costs ranged from
$28,879 for units with a full set of CEMS (Model A), to $18,750 for a
unit that uses NOx CEMS and Appendix D methods (Model C), to $2,250 for
units that use both Appendix D and Appendix E methods without any CEMS
(Model D). There are no capital/start-up costs for LME units. A
discussion of how the capital/start-up costs were annualized follows in
Section 1.2(iii).

In addition to capital/start-up costs, respondents incur operation and
maintenance costs (exclusive of labor costs) that reflect ongoing costs
to a unit. These costs include both contractor costs for the required
recertification, diagnostic, and quality assurance (QA) testing, and
other direct maintenance-related expenses (e.g., spare parts and
calibration gases). The cost estimates used in this renewal ICR are
generally the same as the Rule to Reduce Interstate Transport of Fine
Particulate Matter and Ozone (Clean Air Interstate Rule) EPA ICR
#2152.02, and have been derived from EPA CEM cost models, existing ICRs,
Agency staff experience under the Acid Rain Program, information
gathered during development of the 1999 and 2002 Part 75 revisions, and
supplemental estimates provided by affected utilities and others related
to the various cost items (see, e.g., EPA Air Docket A-97-35, Item
II-D-48). The total cost for these operation and maintenance cost items
(other than fuel sampling) is estimated at $31,200 for a unit with a
full set of CEMS, while units that use alternate methodologies have
reduced costs.

Note that testing contractor costs for certification, recertification
and annual RATAs also are presented as other direct costs and are not
converted to equivalent source labor hours. This approach is consistent
with the common business practice for obtaining outside contractors to
conduct certification/recertification tests and annual relative accuracy
test audits. For initial certification, the certification test costs are
commonly bundled with equipment purchase contracts, according to
information provided by a range of CEMS equipment vendors. For RATAs
that are conducted either as part of the annual quality assurance
requirements or as part of recertification, industry contacts have
indicated that RATA testing is usually performed under a fixed price
contract basis, except for travel costs that may be billed on an hourly
basis beyond the basic contract cost. For annual RATAs, the sources
indicated that an annual contract between a testing company and utility
is often used. One municipal utility representative indicated that the
applicable municipal regulations required that outside contracts be on a
flat fee, not hourly, basis.

(ii) Capital/Start-up vs. Operating and Maintenance (O & M) Costs

Capital costs reflect one-time costs for purchase of equipment which
will be used over a period of years. Conversely, operating and
maintenance costs are those costs which are incurred on an annual or
other scheduled basis. For instance, costs associated with quality
assurance activities, such as spare parts or contractor costs for work,
will be incurred on an annual basis.

(iii) Annualizing Capital Costs

The relevant capital costs for the emissions trading portion of this ICR
were annualized at a rate of 7% (i.e., the annualized capital cost was
calculated assuming money to purchase the capital equipment was borrowed
at a 7% annual interest rate).  The cost of the loan was amortized over
the life of the loan to repay original borrowed amount plus interest.
The result is the annualized capital cost reported.)  The annualized
cost of the necessary capital purchases varies from $2,250 to $ 28,879,
per year, per unit, depending on the type of monitoring methodology.
Exhibit 1 contains a breakdown of annual costs by monitoring
methodology.  The capital costs are from the Rule to Reduce Interstate
Transport of Fine Particulate Matter and Ozone (Clean Air Interstate
Rule) EPA ICR #2152.02.

 (iv)  Fuel Sampling

To calculate heat input where the source is using the fuel flowmeter
option for an oil or gas-fired unit, the source must obtain gross
calorific value data from sampling in accordance with Appendix D of Part
75.  For purposes of this ICR, it is assumed that the GCV data would be
collected as part of standard business operating procedures to assure
compliance with contractual specifications.  Thus no additional fuel
sampling burdens or costs should be incurred.  This is consistent with
the Rule to Reduce Interstate Transport of Fine Particulate Matter and
Ozone (Clean Air Interstate Rule) EPA ICR #2152.02.

6.4.3 Estimating Agency Burden and Cost

The tasks that will be performed by EPA include processing, reviewing,
and evaluating emissions data reports submitted by utilities, and
conducting appropriate audit activities to verify the information
provided. The estimated Agency burdens remain the same as the 2002 ICR
on a per report basis (two hours). Even though EPA intends to increase
its audit oversight efforts, there is no increased per report burden
because of offsetting burden reductions from increasing familiarity with
the program and improved automated tools. Assuming that affected sources
will submit 3,537 emissions reports to EPA per quarter, the total annual
burden incurred by the Agency will be 14,148 hours. The total annual
cost to EPA for processing, reviewing, and evaluating these quarterly
emissions reports will be approximately $1,546,376.  Exhibit 8
summarizes the Agency burden and costs associated with emissions
reporting.

6.4.4 Estimating the Respondent Universe and Total Burden and Costs

EPA estimates that: (a) 1,244 sources will review instructions and
requirements; (b) 1139 sources (this number excludes sources with only
low mass emissions units and new units) will reprogram and debug DAHS
computer software; (c) 3,537 units will submit quarterly reports; and
(d) 3,429 units will respond to EPA generated error messages (of which
about 10 units will also respond to EPA audit activities), and perform
QA testing and maintenance (units using the LME methodology are excluded
from these activities).  In addition, EPA estimates that approximately
294 units will recertify per year.  Exhibit 7 shows the total burden and
total cost based on this respondent universe.

EXHIBIT 7

ANNUAL RESPONDENT BURDEN/COST ESTIMATES FOR EMISSIONS MONITORING

INFORMATION COLLECTION ACTIVITY	Mgr. $84.43/ Hour	Tech. $58.00/ Hour
Respondent Hrs./Year	Labor Cost/Year	Cont./ O&M Cost	Capital/ Startup
Cost	No. of Respondents	Total Hours/Year	Total Cost/Year

1. Review Instructions and Requirements 	4	4	8	$570	$0	$0	1244	9,952
$709,080

2. Respond to EPA Generated Error Messages, Field Audits	6	18	24	$1,551
$0	$0	3429	82,296	$5,318,379

3a. DAHS Upgrade	0	0	0	$0	$0	$0	0	0	$0

3b. DAHS Debugging	4	12	16	$1,034	$0	$0	1139	18,224	$1,177,726

4. New Unit Monitoring Plans	10	10	20	$1,424	$0	$0	203	4,060	$289,072

5. Recertify Monitors	38	12	50	$3,904	$3,400	$0	294	14,700	$2,147,376

6. Startup/Capital Items and Perform QA Testing and Maintenance

(a) Model A (CEMS)	50	480	530	$32,062	$31,200	$28,879	1010	535,300
$93,062,410

(b) Model B (COMS)	0	171	171	$9,918	$288	$3,560	500	85,500	$6,883,000

(c) Model C (App D-Nox CEM)	20	375	395	$23,439	$17,400	$18,750	2111
833,845	$125,792,379

(d) Model D (App D and E)	5	30	35	$2,162	$1,800	$2,250	308	10,780
$1,913,296

(e) Model E (LME)	0	0	0	$0	$1,944	$0	108	0	$209,952

(f) Model F (H2O)	0	40	40	$2,320	$8,000	$854	100	4,000	$1,117,400

7a. Assure Data Quality, Prepare Reports (inc. monitor plan update),
Submit Reports	20	82	102	$6,445	$0	$0	3429	349,758	$22,099,905

7b. LME Reporting	4	12	16	$1,034	0	0	108	1,728	$111,672

8. Annual Fuel Sampling	0	0	0	$0	$0	$0	0	0	$0

TOTAL:	1,950,143	$260,831,647

EXHIBIT 8

ANNUAL AGENCY BURDEN/COST ESTIMATES FOR EMISSIONS REPORTING

Tasks	Quarterly Burden Hours Per Report	Quarterly Cost Per Reporta,b
Number of Reportsc	Total Burden Per Year (hours) (2007-2009)	Total Cost

Process, review, and evaluate quarterly report and issue feedback letter
2	$54.65	14,148	28,296	$1,546,376

a Based on an average total compensation rate of $54.65 per hour

b Updated from 2002 dollars using the same factor (1.15) as used to
update the Respondent labor cost.

c Assumes 3,537 emission data reports each quarter.

	6.5	Auctions

		This part presents estimates of the burden and costs to participants
and the Federal government associated with the auction program.

		Auctions are held only once a year.  No restrictions are placed on the
number of allowances for which a participant may bid.  Multiple bids
from a given participant are permitted, but each bid is treated
individually and requires a separate bid form.  Based on the average
number of bids in the past two auctions, EPA estimates that 111 bids
will be received each year.

	6.5.1  Estimate of Respondent Burden and Costs

		Exhibit 9 depicts the burden and costs to auction participants.
Auction participants must complete and submit the bid form along with a
certified check, letter of credit, or wire transfer.  EPA estimates that
the auction bid form takes approximately 30 minutes to prepare, and
obtaining a means of payment takes approximately one hour.  This
estimate includes time allocated to research the required information,
fill out the form, arrange for a certified check, letter of credit, wire
transfer, and send the material to EPA.  The burden and cost to auction
participants is estimated to be 166.5 hours and  $13,177 per year
respectively.

EXHIBIT 9

ANNUAL RESPONDENT BURDEN/COST ESTIMATES FOR AUCTIONS

Collection Activities	Burden Hours Per Bid	Cost Per Bida	Burden Hours
Per Year	Cost Per Year

1.  Completing bid formsb	0.5	$39.57	55.5	$4,392.27

2.  Obtaining means of paymentb	1	$79.14	111	$8,784.54

TOTAL:	1.5	$118.71	166.5	$13,176.81

a Based on an average rate of $79.14 per hour (For costing purposes, it
is assumed that 80 percent of the total hours will be Managerial
($84.43/hr.) and 20 percent will be Technical ($58.00/hr.).  These
estimates are based on 2006 dollars.

b The 111 bids represents an average number of bids over the past four
EPA auctions.

	6.5.2  Estimate of Agency Burden and Costs

	Exhibit 10 depicts the burden and cost to EPA for the auction program.
Based on past experience, the burden and cost to the Agency will be
about the same each year.  Setting up and revising allowance tracking
system (ATS) accounts for auction participants is estimated to take 10
hours, the handling of bids and checks is estimated to take 20 hours,
tabulation, checking, and announcing the auction results is estimated to
take 15 hours, and transferring allowances and proceeds is expected to
require 40 hours per year.  As Exhibit 10 shows, the total burden to EPA
for auction activities is 85 hours at a cost of $4,645.

						EXHIBIT 10

ANNUAL AGENCY BURDEN/COST ESTIMATES FOR AUCTIONS

Collection Activities	Burden Hours Per Year	Cost Per Yeara

1.  Setup ATS accounts	10	$546.50

2.  Handle bids and checks	20	$1,093.00

3.  Tabulate, check, and announce results		15	$819.75

4.  Transfer of allowances and proceeds	40	$2,186.00

TOTAL:	85	$4,645.25

 a 2006 dollars.

6.6	The Opt-in Program

	This subsection describes projections for (1) the number and types of
sources that elect to participate in the opt-in program for the time
period covered by this ICR, (2) the paperwork burden hours for both
respondents and EPA associated with the program, and (3) the total costs
of the tasks required by the opt-in program.

	Over the three years covered by this ICR, EPA estimates that no sources
will opt in to the program.  This figure is based on the number of
opt-in applications EPA has received over the past three years.

	6.6.1 Respondent Burden/Cost Estimates for The Opt-in Program

	The tasks under this program are divided into the major categories of
reporting -- permitting, emissions monitoring, and annual compliance
certification.  This section includes only the burden for these task
categories for opt-in sources.  Those affected sources covered by the
mandatory requirements of the Acid Rain Program are covered in previous
sections.

	A. Opt-in Permit Applications

	EPA estimates that no sources will submit a permit application in the
years covered by this ICR.  However, if a source would chose to submit
an application, the source must select a designated representative,
report operating and fuel consumption data from past years, and report
the actual and allowable emissions rates for 1985 as well as the current
allowable emission rate.  Since we expect no applications, there is no
burden or cost for this activity.

	B. Emissions Data Reporting

	Emissions reporting is performed only by operating sources.  The tasks
for opt-in sources are identical to other affected sources and are
listed in Exhibit 7. The burden and costs for emissions reporting from
opt-in sources are included in the total in Exhibit 7.

	C. Annual Reconciliation

	Annual reconciliation is performed by all opt-in sources.  Each unit at
an opt-in source is required to submit an opt-in utilization form.
Additionally, if the source is covered by a thermal energy compliance
plan, it must submit a thermal energy compliance report.  If an opt-in
source has reduced utilization due to energy conservation or improved
unit efficiency measures, it has the option of submitting an energy
confirmation and improved unit efficiency confirmation report to verify
the savings and offset the corresponding reduced utilization.  To date
none of the opt-in sources have verified energy conservation or improved
unit efficiency measures, so EPA is assuming no sources will do so
during the three years covered by this ICR.  Finally, EPA assumes that
half of the opt-in units will submit an optional allowance deduction
form, which specifies the serial numbered allowances for deduction.

	Total respondent burden and costs for annual compliance certification
by opt-in sources are an estimated 280 hours and $17,970, respectively.
Exhibit 12 presents respondent burden and costs for annual
reconciliation by opt-in sources.

	6.6.2. Agency Burden/Cost Estimates for the Opt-in Program

	In 2007-2009, the Agency's burden includes; processing opt-in
applications, processing quarterly emissions reports (which is included
in Exhibit 8), and processing annual reconciliation reports.  The
Agency's total annual estimated burden and cost related to the opt-in
program are 24 hours and $1,312, respectively.  Exhibit 13 presents the
Agency's burden and costs for opt-in program.

EXHIBIT 11

RESPONDENT BURDEN/COST ESTIMATES FOR OPT-IN PERMIT APPLICATIONS

Tasks	Burden Hours per Occurrence	Cost per Occurrencea	Total Burden
(hours)	Total Cost

Select a designated representativeb

     Managerial

     Technical

Prepare opt-in permit applicationb

     Managerial

     Technical

Prepare thermal energy compliance planc

     Managerial

     Technical

Complete withdrawal notificationd

     Managerial

     Technical

20

7

20

85

15

55

2

3

$1,688.60

$406.00

$1,688.60

$4,930.00

$1,266.45

$3,190.00

$168.86

$174.00

0

0

0

0

0

0

0

0

$0

$0

$0

$0

0

0

0

0

TOTAL	0	$0

a 2006 dollars.

b Assumes no opt-in sources submit applications.

c Assumes no sources file a thermal energy compliance plan.

d Assumes that sources that have made the investment to opt-in will not
withdraw.

EXHIBIT 12

ANNUAL RESPONDENT BURDEN/COST ESTIMATES FOR OPT-IN ANNUAL COMPLIANCE
CERTIFICATION

Tasks	Burden Hours Per Occurrence	Cost Per Occurrencea	Total Burden
(Hours)	Total Cost

Opt-in Utilization formb

     Managerial

     Technical

2

16

$186.86

$928.00

16

128

$1,494.88

$7,424.00

Thermal energy compliance report (shutdown opt-in sources and
replacement units)c

     Managerial

     Technical

10

21

$844.30

$1,218.00

40

84

$3,377.20

$4,872.00

Allowance deduction form (optional)d

     Managerial

     Technical

Energy conservation/Improved unit efficiency confirmation reporte

     Managerial

     Technical

Excess emissions penalty paymente

     Managerial

     Technical

1

2

5

25

4

5

$84.43

$116.00

$422.15

$1450.00

$337.72

$290.00

4

8

0

0

0

0

$337.72

$464.00

0

0

0

0

TOTAL	   	   	280	$17,969.80

a 2006 dollars.

b Assumes 3 opt-in sources and 8 opt-in units.

c Assumes 4 sources file reports.

d Assumes 4 opt-in units submit allowance deduction forms.

e EPA assumes no sources will claim savings from energy conservation or
improved unit efficiency or have excess emissions.

EXHIBIT 13

ANNUAL AGENCY BURDEN/COSTS FOR THE OPT-IN PROGRAM

Task	Burden Hours per Occurrence	Cost per Occurrencea	Total Burden Hours
Total Costs

Review certificates of representation and record informationb	1	$54.65	0
$0

Review permit application, issue proposed and final permit, and assign
allowancesb	80	$4,372.00	0	$0

Review and process annual reconciliation submissionsc	2	$109.30	16
$874.40

Deduct allowances and send reconciliation reportsc	1	$54.65	8	$437.20

Total	24	$1,311.60

a 2006 dollars.

b Assumes no opt-in sources submit a permit application.

c Assumes 3 opt-in sources and 8 opt-in units each year.

6.7	NOX Permitting

	This section estimates the paperwork burden and cost of renewing and
revising Phase II NOX compliance plans.

		6.7.1	Estimate of Respondent Burden and Costs

	Exhibit 14 presents the burden and costs to applicants for preparing
and submitting NOX Compliance Plan renewal applications and revising NOX
compliance plans. Permits, including NOX Compliance Plans for units
affected for NOX, must be renewed every five years. Therefore, EPA
assumes 20% of all units affected for NOX  (i.e., 200 units) will submit
NOX Compliance Plan renewal applications each year.  Based on the past
two years of the program, EPA expects to receive 27 NOX compliance plan
revisions each year.

	For each compliance plan renewal, EPA estimates that the applicant will
require about 5 hours, while compliance plan revisions will require
about 10 hours.  The total respondent burden for NOX permitting, as
shown in Exhibit 14, is estimated to be 1,270 hours each year.  The
costs associated with NOX permitting are estimated at $87,800 per year.

EXHIBIT 14

RESPONDENT BURDEN/COST ESTIMATES FOR NOX PERMITTING

Tasks	Burden Hours per Occurrence	Cost per Occurrencea	Total Burden
Hours	Total Cost

Prepare NOX Compliance Plan renewal applicationsb

              Managerial

              Technical

2

3

$168.86

$174.00

400

600

$33,772.00

$34,800.00

Revise NOX Compliance Plan (e.g., emissions averaging plans)c

              Managerial

              Technical

5

5

$422.15

$290.00

135

135

$11,398.05

$7,830.00

Total	1,270	$87,800.05

a 2006 dollars.

b Assumes 200 units (20% of all NOX affected units) submit NOX
compliance plan renewals each year.

c Assumes 27 respondents revise emissions averaging plans each year.

		6.7.2.	Estimate of Agency/Permitting Authority Burden and Costs for
NOX

	Exhibit 15 presents the paperwork burden and costs to EPA for NOX
permitting.  The total annual burden and cost for renewing and revising
NOX compliance plans is estimated at 127 hours and $6,942, respectively.

	The tasks involved in reviewing applications will include reviewing
forms for completeness and entering the revised data from the plans into
a NOX compliance database.

EXHIBIT 15

AGENCY BURDEN/COST ESTIMATES

FOR NOX PERMITTING

Tasks	Burden Hours Per Occurrence	Cost Per Occurrencea	Total Burden
Hours	Total Cost

Renew NOX compliance plansb	0.5	$27.33	100	$5,466.00

Revise NOX compliance plansc	1 	$54.65 	27	$1,475.55

Total	127	$6,941.55

a 2006 dollars.

b Assumes 200 units (20% of all NOX affected units) submit NOX
compliance plan renewals each year.

c Assumes 27 respondents revise emissions averaging plans each year.

	6.8	Summary of Burden Hours and Costs

	Exhibit 16 summarizes the annual aggregate burden and cost estimates to
respondents for the period of July 1, 2006 through June 30, 2009 for
collections associated with allowance transfers, energy conservation and
renewable energy allowances, permits, emissions reporting, auctions, the
opt-in program, and NOX permitting.  Exhibit 17 summarizes the aggregate
burden and cost estimates to EPA and permitting authorities for these
collections.

6.9	Reasons for Change in Burden

	This ICR renewal reflects a few differences from the previous ICR.
This section discusses the changes in burden since the last clearance.

	Overall, the estimated annual burden in 2003 from the last clearance
was 1,600,807 hours.  This ICR estimates the annual burden in 2007 will
be 1,971,276 hours, which increases the burden by 370,469 hours.  The
reasons for this burden increase are explained below.

	Most of the change in burden for this collection is due to adjustments.
 Adjustments stem from actions outside the Agency's control.  It
includes changes to the number of responses and the time it takes to
respond to a particular activity.  The adjustments and corresponding
change in burden are as follows.

The annual number of allowance transfer submissions decreased from 4,800
to 1,700. This changed the annual burden hours for allowance transfer
activities from 10,640 to 5,885.

The annual number of conservation and renewable energy reserve
applications dropped from 7 to 0, while the number of applicants using
EPA's conservation verification protocol decreased from 1 to 0.  These
changes decreased the net burden from 418 to 0 hours.

Permitting activities were estimated to require 15,410 burden hours in
2003.  The estimated annual burden hours for permitting under this ICR
are 13,531.  This burden change reflects a decrease in the number of
units submitting new and retired unit exemptions.

Adjustments increased the annual average burden for monitoring and