1601t08

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Overview

RATES
UNIVERSE
Exhibit 1
Exhibit 2
Exhibit 3
Exhibit 4
Exhibit 5
Exhibit 6
Exhibit 7
Exhibit 8
Exhibit 9
Exhibit 10
Exhibit 11
Exhibit 12
Exhibit 13
Exhibit 14

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Sheet 1: RATES

		Appendix A-1
		LABOR RATES *
Contractor Rates [1]
	2011 Hourly	Loaded Labor Rate	Overhead	Total
	$99.00	$47.22	2.1	$99.16
Respondent Rates [2]
	2011 Hourly	Loaded Labor Rate	Overhead	Total
	$66.00	$31.55	2.1	$66.26
State/Local Agency Rates [3]
	2011 Hourly	Loaded Labor Rate	Overhead	Total
	$85.00	$40.40	2.1	$84.84
EPA Rates [4]
	2011 Hourly	Hourly Wage Rate	Benefits	Total
	$46.00	$28.88	1.6	$46.21
[1] Respondent contractor rate obtained from "Employer Costs for Employee Compensation, Table 2: Employment Costs for Civilian Workers by Occupational and Industry Group (Professional and Related)" U.S. Dept. of Commerce, BLS, June 2011. (http://www.bls.gov/news.release/ecac.t02.htm accessed 9/19/11) 110% overhead assumed.
[2] Respondent in-house rates obtained from "Employer Costs for Employee Compensation, Table 2: Employment Costs for Civilian Workers by Occupational and Industry Group (Construction, Extraction, Farming, Forestry, and Fishing)" U.S. Dept. of Commerce, BLS, June 2011. (http://www.bls.gov/news.release/ecac.t02.htm accessed 9/19/11) 110% overhead assumed.
[3] State/Local rates obtained from "Employer Costs for Employee Compensation, Table 4: Employment Costs for State and Local Government Workers" U.S. Dept. of Commerce, BLS, June 2011. (http://www.bls.gov/news.release/ecac.t04.htm accessed 9/19/11) 110% overhead assumed.
[4] Federal Labor Cost obtained from U.S. Office of Personnel Management 2011 General Schedule Table 2011-GS. Hourly labor rate assumed is GS-12, Step 1 (Technical Labor). 60% benefits assumed.

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Sheet 2: UNIVERSE

	Appendix A-2
	Universe of Respondents
Universe Estimates
Sources under EPA authority
# New exploration sources	5	see below - 5 represents the number of expected primary permits to be issued during ICR period
# Existing exploration sources	5	2012 added this row - see below; 5 represents the number of drill ships for which exploratory permits were issued in 2011 (2 in AK; 3 in Gulf)
# New development/production sources	0
# Existing sources	0	this refers to existing development/production sources
# New alternative energy sources	4	2 major source permits, 2 minor source permits
# Existing alternative energy sources	1	2012 added this row - accounting for Cape Wind project which has been permitted (NA NSR) but not built
Sources under State/local authority
# New exploration sources	0
# New development/production sources	0
# Existing sources	23	include two sources making minor permit mods.
# Construction mod to existing sources	2	the two minor mods above require minor NSR permits as well
# New alternative energy sources	0	per Herkhof
Total Number of Sources	40
New and existing exploration sources under EPA authority - 2012 renewal
Alaska
2 PSD permits issued in 2011 for the same drill ship, one for Beaufort and one for Chukchi Sea, each covering an unspecified number of wells drilled over an unspecified number of years. Assuming will operate under only one of these permits (probably in the Chukchi) in any single year, so burden is as if one permit. No burden included for preconstruction permitting; burden is included for recordkeeping and reporting for one of the two permits for each year. Counts as 1 existing source.
1 exploratory permit (title V/mNSR) pending (completed public comment in Sep 2011) for same company as 2 PSD permits above; this one for the Beaufort Sea with stipulation that will not operate there at the same time as any other source permitted by same company. No burden included for preconstruction permitting (i.e., treat as existing); burden is included for recordkeeping and reporting. Counts as 1 existing source.
1 exploratory permit (title V) went through public comment in Sep 2011 but was then withdrawn. Expect to rework and resubmit, possibly in 2011. Is for an unspecified number of wells over multiple years in the Chukchi. Assuming permitting burden included in this ICR as well as recordkeeping and reporting. Counts as 1 new source.
2 additional permits assumed, each for one ship for multiple years, based on Herkhof estimate of 3-4 additional exploratory wells per year in the Arctic. Counts as 2 new sources.
Eastern Gulf
1 permit (PSD) for exploratory drilling issued in 2011. No burden for preconstruction permitting; burden for recordkeeping and reporting. Counts as 1 existing source.
2 exploratory permits (PSD/title V) pending (completed public comment in Sep 2011). No burden included for preconstruction permitting (i.e., treat as existing); burden is included for recordkeeping and reporting. Counts as 2 existing sources.
2 additional permits assumed, each for one ship for multiple years, based on Herkhof estimate of 3-4 additional exploratory wells per year in the eastern Gulf of Mexico. Counts as 2 new sources.

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Sheet 3: Exhibit 1

EXHIBIT 1. NEW AND PREVIOUSLY PERMITTED EXPLORATION SOURCES UNDER EPA AUTHORITY
RESPONDENTS' ANNUAL BURDENS
Collection Activities	Number of Respondents	Number of Occurrences for 3 years	Occurrences per year	Hours per Occurrence1	Cost per Occurrence	Contractors Hours per Occurrence	Contractors Dollars per Occurrence	Total Hours per Year	Total Cost per Year	O&M Costs per Occurrence	Capital Costs per Occurrence	Total O&M Costs per Year	Total Capital Costs per Year
Labor Rates					$66.00		$99.00
Read regulations2	5	1	1.67	5	330.00	0	$0.00	8	$550.00	$0.00	$0.00	$0.00	$0.00
Consult with EPA, or State and local agency2	5	1	1.67	5	330.00	0	$0.00	8	$550.00	$0.00	$0.00	$0.00	$0.00
Prepare a NOI to construct2	5	1	1.67	30	1,980.00	0	$0.00	50	$3,300.00	$0.00	$0.00	$0.00	$0.00
Beth Friedman: 2009 renewal Added rows 9 and 10, major source burden is half of major source development/production permit, minor source is 25%. Prepare major source permit application3	3	1	1.00	50	3,300.00	293	$29,007.00	343	$32,307.00	$0.00	$0.00	$0.00	$0.00
Prepare minor source permit application3	2	1	0.67	25	1,650.00	146	$14,454.00	114	$10,736.00	$0.00	$0.00	$0.00	$0.00
Perform initial compliance test2	5	1	1.67	100	6,600.00	764	$75,636.00	1,440	$137,060.00	$0.00	$0.00	$0.00	$0.00
Prepare operating permit application4	5	1	1.67	42	2,772.00	0	$0.00	70	$4,620.00	$0.00	$0.00	$0.00	$0.00
Conduct record keeping and report data to EPA5	10	3	10.00	32	2,112.00	0	$0.00	320	$21,120.00	$0.00	$0.00	$0.00	$0.00
		Responses per Year**	20.00				Burden	2,354	$210,243.00			$0.00	$0.00
1. Assumes hours per occurrence is the same as that in the 1998 ICR, except hours added for preparing permit applications
2. Assumes all new permittees must perform these tasks
3. Assumes 50% of new permits are major sources permits and 50% minor souce permits; rounding up for major source permits to be conservative
4. Assumes that 50% of new and existing permittees must subsequently obtain an operating permit
5. Assumes that all new and existing permittees must conduct recordkeeping and reporting during each year of the ICR period
**This number is used in the summary (Exhibit 14)
Note: Added Row 11 during 2012 renewal to be consistent with Exhibit 4 and reflect permits issued by the EPA Regional Offices.

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Sheet 4: Exhibit 2

EXHIBIT 2. NEW AND PREVIOUSLY PERMITTED ALTERNATIVE ENERGY SOURCES UNDER EPA AUTHORITY
RESPONDENTS' ANNUAL BURDENS
Collection Activities	Number of Respondents	Number of Occurrences for 3 years	Occurrences per year	Hours per Occurrence1	Cost per Occurrence	Contractors Hours per Occurrence	Contractors Dollars per Occurrence	Total Hours per Year	Total Cost per Year	O&M Costs per Occurrence	Capital Costs per Occurrence	Total O&M Costs per Year	Total Capital Costs per Year
Labor Rates					$66.00		$99.00
Read regulations2	4	1	1.33	5	330.00	0	$0.00	7	$440.00	$0.00	$0.00	$0.00	$0.00
Consult with EPA, or State and local agency2	4	1	1.33	5	330.00	0	$0.00	7	$440.00	$0.00	$0.00	$0.00	$0.00
Prepare a NOI to construct2	4	1	1.33	30	1,980.00	0	$0.00	40	$2,640.00	$0.00	$0.00	$0.00	$0.00
Beth Friedman: 2009 renewal Added rows 9 and 10, major source burden is half of major source development/production permit, minor source is 25%. Prepare major source permit application3	2	1	0.67	50	3,300.00	293	$29,007.00	229	$21,538.00	$0.00	$0.00	$0.00	$0.00
Prepare minor source permit application3	2	1	0.67	25	1,650.00	146	$14,454.00	114	$10,736.00	$0.00	$0.00	$0.00	$0.00
Prepare operating permit application4	3	1	1.00	42	2,772.00	0	$0.00	42	$2,772.00	$0.00	$0.00	$0.00	$0.00
Conduct record keeping and report data to EPA5	5	3	5.00	32	2,112.00	0	$0.00	160	$10,560.00	$0.00	$0.00	$0.00	$0.00
		Responses per Year**	11.33				Burden	598	$49,126.00			$0.00	$0.00
1. Assumes hours per occurrence is the same as that in the 1998 ICR, except hours added for preparing permit applications
2. Assumes all new permittees must perform these tasks
3. Assumes 50% of new permits are major sources permits and 50% minor souce permits
4. Assumes that 50% of new and existing permittees must subsequently obtain an operating permit; rounding up to be conservative
5. Assumes that all new and existing permittees must conduct recordkeeping and reporting during each year of the ICR period
**This number is used in the summary (Exhibit 14)
Assume 2 major and 2 minor alternative energy sources

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Sheet 5: Exhibit 3

EXHIBIT 3. NEW DEVELOPMENT/PRODUCTION SOURCES UNDER EPA AUTHORITY
RESPONDENTS' ANNUAL BURDENS
Collection Activities	Number of Respondents	Number of Occurrences for 3 years	Occurrences per year	Hours per Occurrence1	Cost per Occurrence	Contractors Hours per Occurrence	Contractors Dollars per Occurrence	Total Hours per Year	Total Cost per Year	O&M Costs per Occurrence2	Capital Costs per Occurrence3	Total O&M Costs per Year	Total Capital Costs per Year
Rates					$66.00		$99.00
Read regulations	0	1	0.00	5	330.00	0	$0.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
Consult with EPA, or State and local agency	0	1	0.00	5	330.00	0	$0.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
Prepare a NOI to construct	0	1	0.00	30	1,980.00	0	$0.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
Prepare preconstruction permit application	0	1	0.00	100	6,600.00	585	$57,915.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
Perform initial compliance test	0	1	0.00	100	6,600.00	764	$75,636.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
Prepare operating permit application	0	1	0.00	42	2,772.00	0	$0.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
Conduct record keeping and report data to EPA	0	1	0.00	64	858.00	0	$0.00	0	$0.00	$1,517.40	$30,348.00	$0.00	$0.00
		Responses per Year**	0.00				Burden	0	$0.00	$1,517.40	$30,348.00	$0.00	$0.00
1. Assumes hours per occurrence is the same as that in the 1998 ICR.
2. Assumes O&M is 5 percent of capital costs
3. Capital costs calculated using the June 2011 (preliminary) index for process instruments (440.9) compared to the final December 1998 index (363.2) and applied to the 1998 estimate of $25,000
**This number is used in the summary (Exhibit 14)
Assume 0 new projects in any of the areas subject to EPA permitting.

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Sheet 6: Exhibit 4

EXHIBIT 4. NEW EXPLORATION SOURCES UNDER STATE/LOCAL AUTHORITY
RESPONDENTS' ANNUAL BURDENS
Collection Activities	Number of Respondents	Number of Occurrences for 3 years	Occurrences per year	Hours per Occurrence1	Cost per Occurrence	Contractors Hours per Occurrence	Contractors Dollars per Occurrence	Total Hours per Year	Total Cost per Year	O&M Costs per Occurrence	Capital Costs per Occurrence	Total O&M Costs per Year	Total Capital Costs per Year
Rates					$66.00		$99.00
Read regulations	0	0	0.00	5	330.00	0	$0.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
Consult with EPA, or State and local agency	0	0	0.00	5	330.00	0	$0.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
Prepare a NOI to construct and permit application	0	0	0.00	70	4,620.00	0	$0.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
Perform initial compliance test	0	0	0.00	100	6,600.00	748	$74,052.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
Conduct record keeping and report data to local agency	0	0	0.00	64	4,224.00	0	$0.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
		Responses per Year	0				Burden	0	$0.00			$0.00	$0.00
1. Assumes hours per occurrence is the same as that in the 1998 ICR.

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Sheet 7: Exhibit 5

EXHIBIT 5. NEW ALTERNATIVE ENERGY SOURCES UNDER STATE/LOCAL AUTHORITY
RESPONDENTS' ANNUAL BURDENS
Collection Activities	Number of Respondents	Number of Occurrences for 3 years	Occurrences per year	Hours per Occurrence1	Cost per Occurrence	Contractors Hours per Occurrence	Contractors Dollars per Occurrence	Total Hours per Year	Total Cost per Year	O&M Costs per Occurrence	Capital Costs per Occurrence	Total O&M Costs per Year	Total Capital Costs per Year
Rates					$66.00		$99.00
Read regulations	0	1	0.00	5	330.00	0	$0.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
Consult with EPA, or State and local agency	0	1	0.00	5	330.00	0	$0.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
Prepare a NOI to construct and permit application	0	1	0.00	70	4,620.00	0	$0.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
Perform initial compliance test	0	1	0.00	100	6,600.00	748	$74,052.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
Conduct record keeping and report data to local agency	0	1	0.00	64	4,224.00	0	$0.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
		Responses per Year	0.00				Burden	0	$0.00			$0.00	$0.00
1. Assumes hours per occurrence is the same as that in the 1998 ICR.

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Sheet 8: Exhibit 6

EXHIBIT 6. EXISTING SOURCES UNDER STATE/LOCAL AUTHORITY
RESPONDENTS' ANNUAL BURDENS
Collection Activities	Number of Respondents	Number of Occurrences for 3 years	Occurrences per year	Hours per Occurrence1	Cost per Occurrence	Contractors Hours per Occurrence	Contractors Dollars per Occurrence	Total Hours per Year	Total Cost per Year	O&M Costs per Occurrence2	Capital Costs per Occurrence	Total O&M Costs per Year	Total Capital Costs per Year
Rates					$66.00		$99.00
Prepare permit to operate application3	5	3	5	42	2,772.00	0	$0.00	210	$13,860.00	$0.00	$0.00	$0.00	$0.00
Perform annual compliance test	23	3	23	100	6,600.00	764	$75,636.00	19,872	$1,891,428.00	$0.00	$0.00	$0.00	$0.00
Conduct record keeping and report data to EPA	23	3	23	64	858.00	0	$0.00	1,472	$19,734.00	$1,517.40	$0.00	$34,900.20	$0.00
Prepare a NOI to construct4	2	1	0.67	30	1,980.00	0	$0.00	20	$1,320.00	$0.00	$0.00	$0.00	$0.00
Prepare minor source permit application4	2	1	0.67	50	3,300.00	293	$29,007.00	229	$21,538.00	$0.00	$0.00	$0.00	$0.00
Prepare major source permit application	0	1	0.00	100	6,600.00	585	$57,915.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
		Responses per Year	52.33				Burden	21,803	$1,947,880.00	$1,517.40	$0.00	$34,900.20	$0.00
1. Assumes hours per occurrence is the same as that in the 1998 ICR, except that hours for minor preconstruction permit are half the major source level.
2. O&M costs equal those calculated in Exhibit 3.
3. Assumes 5 sources will apply to renew their permits to operate each year. (In the 2009 ICR renewal, assumed all these 23 existing sources would renew these 5-year title V permits, so would be excessive to do so again.)
4. Assumes 2 of the existing sources will undergo minor NSR preconstruction permitting for changes at their facilities.
Note: Added Row 10 during 2012 renewal to account for lesser burden for minor NSR permitting.
Linked cell K8 to Exhibit 3 cell K12

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Sheet 9: Exhibit 7

EXHIBIT 7. NEW EXPLORATION SOURCES UNDER STATE/LOCAL AUTHORITY
STATE AND LOCAL AGENCIES' ANNUAL BURDENS
Collection Activities	Number of Respondents	Number of Occurrences for 3 years	Occurrences per year	Hours per Occurrence*	Cost per Occurrence	Total Hours per Year	Total Cost per Year
Rates					$85.00
Consult with sources	0	1	0.00	5	$425.00	0	$0.00
Review NOI to construct	0	1	0.00	55	$4,675.00	0	$0.00
Review permit to operate application	0	1	0.00	40	$3,400.00	0	$0.00
Oversee initial compliance test	0	1	0.00	67	$5,695.00	0	$0.00
Conduct inspections	0	2	0.00	16	$1,360.00	0	$0.00
Review data reports	0	1	0.00	8	$680.00	0	$0.00
					Burden	0	$0.00
			0.00
* Assumes hours per occurrence is the same as that in the 1998 ICR.
Note: Created sum in D13 to calculate "responses" during 2011 renewal.

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Sheet 10: Exhibit 8

EXHIBIT 8. NEW ALTERNATIVE ENERGY SOURCES UNDER STATE/LOCAL AUTHORITY
STATE AND LOCAL AGENCIES' ANNUAL BURDENS
Collection Activities	Number of Respondents	Number of Occurrences for 3 years	Occurrences per year	Hours per Occurrence*	Cost per Occurrence	Total Hours per Year	Total Cost per Year
Rates					$85.00
Consult with sources	0	1	0.00	5	$425.00	0	$0.00
Review NOI to construct	0	1	0.00	55	$4,675.00	0	$0.00
Review permit to operate application	0	1	0.00	40	$3,400.00	0	$0.00
Oversee initial compliance test	0	1	0.00	67	$5,695.00	0	$0.00
Conduct inspections	0	2	0.00	16	$1,360.00	0	$0.00
Review data reports	0	1	0.00	8	$680.00	0	$0.00
					Burden	0	$0.00
			0.00
* Assumes hours per occurrence is the same as that in the 1998 ICR.
Project 0 new alt energy sources per Herkhof.

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Sheet 11: Exhibit 9

EXHIBIT 9. EXISTING SOURCES UNDERSTATE/LOCAL AUTHORITY
STATE AND LOCAL AGENCIES' ANNUAL BURDENS
Collection Activities	Number of Respondents	Number of Occurrences for 3 years	Occurrences per year	Hours per Occurrence1	Cost per Occurrence	Total Hours per Year	Total Cost per Year
Rates					$85.00
Oversee annual compliance test	23	3	23	67	$5,695.00	1,541	$130,985.00
Conduct inspections	23	12	92	16	$1,360.00	1,472	$125,120.00
Review permit to operate application2	5	3	5	40	$3,400.00	200	$17,000.00
Review data reports	23	3	23	8	$680.00	184	$15,640.00
Review NOI to construct and permit application3	2	1	0.67	35	$2,975.00	23	$1,983.33
					Burden	3,420	$290,728.33
			143.666666666667
1. Assumes hours per occurrence is the same as that in the 1998 ICR.
2. Assumes 5 sources will apply to renew their permits to operate each year. (In the 2009 ICR renewal, assumed all these 23 existing sources would renew these 5-year title V permits, so would be excessive to do so again.)
3. Assumes 2 of the existing sources will undergo minor NSR preconstruction permitting for changes at their facilities.

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Sheet 12: Exhibit 10

EXHIBIT 10. NEW AND PREVIOUSLY PERMITTED EXPLORATION SOURCES UNDER EPA AUTHORITY
EPA'S ANNUAL BURDEN
Collection Activities	Number of Respondents	Number of Occurrences for 3 years	Occurrences per year	Hours per Occurrence1	Cost per Occurrence	Total Hours per Year	Total Cost per Year
Rates					$46.00
Consult with sources2	5	1	1.67	5	$230.00	8	$383.33
Review NOI to construct and minor permit application3	2	1	0.67	35	$1,610.00	23	$1,073.33
Review NOI to construct and major permit application3	3	1	1.00	263	$12,098.00	263	$12,098.00
Oversee initial compliance test2	5	1	1.67	67	$3,082.00	112	$5,136.67
Review data reports4	10	3	10.00	8	$368.00	80	$3,680.00
					Burden	486	$22,371.33
1 Assumes hours per occurrence is the same as that in the 1998 ICR, except assumed same burden for major source application as in Exhibit 11.
2. Assumes these activities required with all new permittees
3. Assumes 50% of new permits are major sources permits and 50% minor souce permits; rounding up for major source permits to be conservative
4. Assumes that all new and existing permittees must conduct recordkeeping and reporting during each year of the ICR period
Note: Added Row 8 during 2012 ICR renewal to be consistent with Exhibit 11 treatment of major and minor construction permits.
Note: Added Row 9 during 2012 ICR renewal to be consistent with Exhibits 1 and 12 treatment of initial compliance tests.

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Sheet 13: Exhibit 11

EXHIBIT 11. NEW AND PREVIOUSLY PERMITTED ALTERNATIVE ENERGY SOURCES UNDER EPA AUTHORITY
EPA'S ANNUAL BURDEN
Collection Activities	Number of Respondents	Number of Occurrences for 3 years	Occurrences per year	Hours per Occurrence1	Cost per Occurrence	Total Hours per Year	Total Cost per Year
Rates					$46.00
Consult with sources	4	1	1.33	5	$230.00	7	$306.67
Review NOI to construct and minor permit application	2	1	0.67	35	$1,610.00	23	$1,073.33
Review NOI to construct and major permit application	2	1	0.67	263	$12,098.00	175	$8,065.33
Review data reports	5	3	5.00	8	$368.00	40	$1,840.00
					Burden	245	$11,285.33
* Assumes hours per occurrence is the same as that in the 1998 ICR.
Row 8 - previously repeated "minor permit application," so revised to say "major" to match increased hours per occurrence.

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Sheet 14: Exhibit 12

EXHIBIT 12. NEW and EXISTING DEVELOPMENT/PRODUCTION SOURCES UNDER EPA AUTHORITY
EPA'S ANNUAL BURDEN
Collection Activities	Number of Respondents	Number of Occurrences for 3 years	Occurrences per year	Hours per Occurrence*	Costs per Occurrence	Total Hours per Year	Total Cost per Year
Rates					$46.00
Consult with sources	0	1	0.00	5	$230.00	0	$0.00
Review NOI to construct and permit application	0	1	0.00	263	$12,098.00	0	$0.00
Review preconstruction permit application	0	1	0.00	100	$4,600.00	0	$0.00
Oversee initial compliance test	0	1	0.00	67	$3,082.00	0	$0.00
Review operating permit application	0	1	0.00	40	$9,200.00	0	$0.00
Review data reports	0	1	0.00	8	$598.00	0	$0.00
					Burden	0	$0.00
* Assumes hours per occurrence is the same as that in the 1998 ICR.

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Sheet 15: Exhibit 13

EXHIBIT 13. CONSISTENCY UPDATES AND OVERSEEING STATE/LOCAL ACTIVITIES
EPA'S ANNUAL BURDEN
Collection Activities	Number of Respondents	Number of Occurrences for 3 years	Occurrences per year	Hours per Occurrence*	Cost per Occurrence	Total Hours per Year	Total Cost per Year
Rates					$46.00
Annual Consistency Reviews	15	3	15	4	184.00	60	$2,760.00
Major NOI/Regulatory Changes Review	5	1	1.66666666666667	150	6,900.00	250	$11,500.00
Minor NOI/Regulatory Changes Review	4	1	1.33333333333333	40	1,840.00	53	$2,453.33
					Burden	363	$16,713.33
* Assumes hours per occurrence is the same as that in the 1998 ICR, except we have added concept of "minor" review
See supporting statement for explanation of Number of Respondents

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Sheet 16: Exhibit 14

EXHIBIT 14. OCS AIR REGULATIONS INFORMATION COLLECTION BURDEN
SUMMARY OF ANNUAL BURDENS AND COSTS
	Responses	Respondent Hours	Respondent Costs	O&M Costs	Capital Costs	Agency Hours	Agency Costs
New and Previously Permitted Exploration Sources Under EPA Authority (Exhibit 1)	20.0	2,354	$210,243	$0	$0
New and Previously Permitted Alternative Energy Sources under EPA Authority (Exhibit 2)	11.3	598	$49,126	$0	$0
New Development / Production Sources Under EPA Authority Exhibit 3)	0.0	0	$0	$0	$0
New Exploration Sources Under Local Authority (Exhibit 4)	0.0	0	$0	$0	$0
New Alternative Energy Sources under Local Authority (Exhibit 5)	0.0	0	$0	$0	$0
Existing Development / Production Sources Under Local Authority (Exhibit 6)	52.3	21,803	$1,947,880	$34,900	$0
Subtotal of Industry Burden (rounded)	84.0	24,754	$2,207,249	$34,900	$0
New Exploration Sources (Exhibit 7)	0.0	0	$0
New Alternative Energy Sources (Exhibit 8)	0.0	0	0
Existing Development/ Production Sources (Exhibit 9)	143.7	3,420	$290,728
Subtotal of State/Local Burden (rounded)	144.0	3,420	$290,728
New Exploration Sources (Exhibit 10)						486	$22,371
New Alternative Energy Sources (Exhibit 11)						245	$11,285
New and Existing Development/ Production Sources (Exhibit 12)						0	$0
Consistency Updates (Exhibit 13)						363	$16,713
Subtotal of EPA Burden						1,095	$50,370
Total Annual Cost /Burden for the Outer Continental Shelf Air Regulations	228	28,174	$2,497,977	$34,900	$0	1,095	$50,370