2495ss01

______________________________________________________________________________
Supporting Statement
Data Requirements Rule for the 1-Hour Sulfur Dioxide Primary National Ambient Air
Quality Standard (NAAQS)
EPA ICR #2495.01
PART A
1. Identification of the Information Collection
(a) Title of the Information Collection
“Data Requirements Rule for the 1-Hour Sulfur Dioxide Primary National Ambient Air
Quality Standard (NAAQS) - Proposal”
(b) Short Characterization/Abstract
This Information Collection Request (ICR) includes estimates for ambient air monitoring
data reporting and recordkeeping activities associated with the 40 CFR part 51 Requirements for
Preparation, Adoption and Submittal of Implementation Plans.1 These data and information are
collected by State and local air quality management agencies and reported to the U.S.
Environmental Protection Agency (EPA). This ICR also includes estimates for ambient air
dispersion modeling which State and local air quality management agencies may choose to do to
meet the requirements under the proposed Data Requirements Rule (RIN 2060-AR19).
The EPA is proposing a rule directing state, local, and tribal air quality management
agencies to provide data to characterize current air quality in areas with large sources of sulfur
dioxide (SO2) emissions for use in the NAAQS designations process.
The EPA is proposing that states characterize ambient air quality around sources with
emissions greater than 1,000 tons per year which are located within any Core Based Statistical
Area (CBSA) having 1,000,000 or more persons; and around sources with emissions greater than
2,000 tons per year located outside CBSAs having 1,000,000 or more persons. Based upon 2011
emissions data and 2013 census estimates, the proposed action would identify 443 SO2 sources
nationwide, which account for 75 percent of the total SO2 emissions inventory.
The proposed rule describes criteria for identifying the source areas where air agencies
would need to characterize SO2 air quality. It also describes a process and timetables by which
air quality management agencies would characterize air quality in source areas through ambient
monitoring and/or air quality modeling techniques and submit such data to the EPA. The air
quality data developed by the states in accordance with this rule would be used by the EPA in
future rounds of area designations for the 1-hour SO2 NAAQS.

1

Subpart J of Part 51: Ambient Air Quality Surveillance refers back to CFR 40 Part 58; throughout the rest of this
ICR, reference will be made to Part 58 for monitoring requirements

For those air quality management agencies electing to conduct ambient monitoring to
provide necessary air quality data, the EPA anticipates that they may take varied approaches to
identify where and how many SO2 monitors are appropriate. Those approaches likely include the
following: 1) conduct new modeling to aid in monitoring site placement; 2) conduct exploratory
monitoring to inform permanent monitor placement; and 3) take advantage of existing emissions
data, existing monitoring data, and existing modeling, where possible, to aid in determining
permanent monitoring site placement.
The State and local air quality management agencies with responsibility for reporting
ambient air quality data and information as requested in this ICR submit these data electronically
to the EPA’s Air Quality System (AQS) and voluntary databases. Quality assurance/quality
control records and monitoring network documentation are also maintained by each State and
local agency, in AQS electronic format where possible.
Although the State and local air quality management agencies are responsible for the
operation of this air monitoring network, they may have opportunities to work with industry to
help support modeling exercises and/or monitor network installation, operations, and
maintenance. There are two cost estimates shown in this ICR: 1) total estimated costs for the
modeling option regardless of the source of the funding, and 2) total estimated costs incurred for
the monitoring option regardless of the source of the funding.
(1) Modeling Option. Modeling can be used to designate an area around a source as
attainment or nonattainment of the NAAQS. It is anticipated that electing to model to produce
air quality data for designations purposes will use EPA’s preferred near-field dispersion model,
the AERMOD modeling system.2 The use of AERMOD will include the following regulatory
components:
 AERMOD dispersion model
 AERMAP terrain processor
 AERMET meteorological processor
Other components can be used with AERMOD, depending on the application, including:
 BPIPPRIME building processor (for downwash)
 AERMINUTE 1-minute ASOS winds pre-processor for input into AERMET
 AERSURFACE surface characteristics pre-processor for input into AERMET
 AERSCREEN, a screening version of AERMOD.
The dispersion modeling that will be used for SO2 designations under the Data Requirements
Rule requires:
 Source characterization information and emissions inputs for modeled sources
 Representative meteorological data of the area
EPA’s preferred near-field dispersion model is AERMOD, the American
Meteorological Society/Environmental Protection Agency Regulatory Model. See 40 CFR Part
51 Appendix W for more information.
2

2






Terrain data to generate elevations for sources and receptor
Receptor locations
Background concentrations, and
Building data for sources that will be affected by downwash.

Each modeling application is unique and the following inputs can require analyses that affect
modeling costs:
 Determining the appropriate size of the modeling domain to capture potential modeled
NAAQS violations
 Determining sources to model explicitly in the modeling, and sources to characterize in
the modeling via background concentrations
 Estimating time-varying emissions for modeled sources
 Obtaining stack parameters for modeled sources
 Obtaining building information for sources subject to downwash effects
 Determination of the receptor grid and creating the elevations in the receptor grid via
AERMAP
 Determining the representative meteorological surface and upper air stations for the
model domain, downloading the meteorological and land use data for input into
AERMINUTE, AERMET and AERSURFACE
 Calculating the appropriate background concentrations
Once these inputs have been generated and processed through the appropriate programs,
AERMOD can be run and post-processed to generate design values to compare against the
NAAQS. The level of post-processing (charts, tables, maps, etc.) can affect modeling costs as
well.
Based on market research, stakeholder feedback, and the assumptions of the use of modeling
for designations, an estimate of modeling costs is $30,000 for a single modeling run centered on
an identified source. If the air quality around all 443 sources expected to exceed the threshold in
the proposed rulemaking was to be characterized through modeling, total national costs are
estimated at $13,300,000. If these costs were incurred over the course of three years, then the
approximate annual cost for each year over that period would be $4,433,333.
(2) Ambient Monitoring Option. Ambient monitoring costs are estimated under the
assumption that each anticipated SO2 source around which air quality is to be characterized will
be done through monitoring (443 sources). Estimates are provided for a three year period and
include a calculation for equipment amortization over seven years (as is typically done in
monitoring-related ICRs). For the period of 2016, 2017, and 2018 (the SO2 requirement begins
in 2016), the total approximate average annual monitoring cost, including a calculation for
equipment amortization is $9,308,824 (total capital, and labor and non-labor operation and
maintenance) with a total burden of 110,543 hours. The annual labor costs associated with these
hours is $7,608,287. Included in the $9,308,824 total are other annual costs of non-labor
operations and maintenance of $760,011 and equipment and contract costs of $940,526. For

3

reference purposes, an estimate for initial establishment of a new SO2 monitoring station is
$92,614 (does not include equipment amortization). In addition to the costs at the State and local
air quality management agencies, there is a burden to EPA of total of 52,717 hours and
$776,005.

2. Need for and Use of the Collection
(a) Need/Authority for the Collection
The information requirements included within this ICR are necessary to provide the EPA
with ambient air quality surveillance data and/or modeling data to determine the United States air
quality status, to make attainment decisions with respect to the NAAQS, to assist in developing
necessary control strategies to ensure attainment of the NAAQS, to assess national trends in air
pollution, to inform the public of air quality, and to determine the population’s exposure to
various ambient air pollutants. The EPA’s goal of attaining the NAAQS in all areas of the
United States is directly dependent upon the availability of ambient air quality data and/or
modeling data requested in this information collection. Additionally, the EPA, State, and local
air quality management agencies, environmental groups, industrial groups, and academic
organizations use these data to study atmospheric chemistry, e.g., the formation and fate of SO2,
to determine the most appropriate and effective control strategies necessary to reduce air
pollution.
The principal legal authority for this information collection is the Clean Air Act, 42
U.S.C. 7403, 7410, and 7511a, from which the 40 CFR part 51 regulations were promulgated.
Under 7403(c), the Administrator is required to conduct a program of research, testing,
and development of methods for sampling, measurement, monitoring, analysis, and modeling of
air pollutants, specifically including a requirement to establish a national network to monitor,
collect, and compile data with quantification of certainty in the status and trends of air emissions
and air quality. This program will also include the development of improved methods and
technologies to increase understanding of the sources of nitrogen oxides, its formation, transport,
regional influences and trends, and interactions with other pollutants.
Section 7410 (a) and (k) contain the SIP requirements, which include a requirement that
each State submit a SIP that: 1) provides for the establishment and operation of appropriate
devices, methods, systems, and procedures necessary to monitor, compile, analyze, and make
available to the Administrator data on ambient air quality and 20 provides for the performance of
such air quality modeling as the Administrator may prescribe for the purpose of predicting the
effect on ambient air quality of any emissions of any air pollutant for which the Administrator
has established a national ambient air quality standard, and the submission, upon request, of data
related to such air quality modeling to the designee as stipulated in the proposal.

2(b) Practical Utility/Users of the Data
4

The EPA would use the ambient air quality data and/or the modeling data submitted
pursuant to this collection to make area designation decisions with respect to the SO2 NAAQS.
For those areas that are determined to not attain the SO2 NAAQS, the EPA intends to move
forward with area designations. The affected State or local air quality management agency will
work to develop an appropriate SIP for any area designated as nonattainment in order to improve
air quality in the area such that it meets the applicable NAAQS expeditiously.
To identify how the nation is progressing in improving air quality, the OAQPS prepares
annually the National Air Quality and Emissions Trends report (http://www.epa.gov/airtrends)
using the ambient air quality data collected through monitoring-related ICRs. The State and
local air quality management agencies use these data for multiple purposes including tracking
their progress toward achieving and maintaining air quality within the established NAAQS and
any statewide standards they have established.

3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA
3(a) Non-duplication
This collection is not unnecessarily duplicative of information otherwise reasonably
accessible to the agency. The AQS and AIRNow systems, which contain information based
solely on this collection, are the only national air quality data repositories available to the EPA.
The ambient air quality surveillance data and related information collected through this
information collection are not otherwise reasonably accessible to the EPA.
A few State and local air quality management agencies have their own data storage
systems (e.g., the California Air Resources Board); however, most State and local air quality
management agencies use the AQS and AIRNow as their primary repositories for all air quality
data.
3(b) Public Notice Required Prior to ICR Submission to OMB
The 1995 Paperwork Reduction Act requires that any agency developing a non-rule
related ICR must solicit public comments for a 60-day period prior to submitting the ICR to
OMB. This section is not applicable to this ICR because this is a rule-related ICR and we are
accepting public comments on this proposed rule and will address them in the final rulemaking.
3(c) Consultations
Through the course of planning, monitoring, and improving upon this collection and its
associated regulation, the EPA regularly consults with affected State and local air quality
management agencies through various methods including the regulatory process, regular
meetings, and training courses. The EPA conducts workshops and training on the AQS reporting
system. The EPA Regional Offices conduct annual ambient air monitoring meetings with their
5

affected State and local air quality management agencies to assist these affected agencies with
this collection and its associated regulation. The EPA’s OAQPS also meets regularly with
leading State and local air monitoring managers to discuss the Nation’s ambient air monitoring
program and this collection, via large monthly phone calls and smaller in person meeting two or
three times per year. Prior to this proposal, EPA conducted several stakeholder meetings to
discuss issues associated with implementation of the SO2 standard. In addition, EPA developed
two Technical Assistance Documents for Monitoring and Modeling. These documents provide
technical advice on the use of modeling and monitoring to determine if an area meets the 2010
SO2 air quality standard.
3(d) Effects of Less Frequent Collection
State and local air quality management agencies would collect and report ambient air
quality data without the 40 CFR 51 regulations associated with this collection. Sanctions do not
automatically accrue to State or local air quality management agencies that fail to meet these
requirements. The 40 CFR part 58 regulations and this associated collection do provide for a
consistent system for reporting and record keeping that would not exist without these
requirements. The effects of less frequent collection include:
•

A national database that is not consistently updated and available for public
consumption;

•

Less timely attainment designations with respect to the NAAQS;

•

More difficulty in identifying and repairing problems with an ambient air monitor-i.e., data are used as to check a monitor’s operating condition, and reporting data less
frequently would delay a State or local agency’s ability to recognize a problem with a
monitor or a laboratory procedure; and

•

The EPA would not be able to consistently answer questions from the public in a
timely fashion regarding air quality in various areas of the country.

3(e) General Guidelines
All of the OMB’s general guidelines for information collections in 5 CFR 1320.6 are met
by this ICR. None of the guidelines are exceeded.
• Monitoring data reporting would be required on a quarterly basis. Nearly all
respondents voluntarily report on a monthly basis. If the modeling option is chosen
for some areas, one initial dispersion modeling run would be required.
• Record retention is for no more than 3 years (most records are kept by the EPA data
repository, not the affected State and local air quality management agencies)
• Monitoring information is maintained and reported in the standardized electronic AQS
format.
6

3(f) Confidentiality
Information that is considered personal, private, proprietary, or confidential is not
required for this collection. One purpose of collecting ambient air data through AQS and
AIRNow is to inform the public of general air quality in ambient air (air considered generally
accessible to the public), and as such, does not present a need for maintaining a confidential
nature. Security measures are taken to prevent tampering with the AQS electronic database by
limiting the access to the AQS mainframe only to authorized users
3(g) Sensitive Questions
This section is not applicable to this ICR because no information involving matters of a
sensitive nature is collected.
4. THE RESPONDENTS AND THE INFORMATION REQUESTED
4(a) Respondents/SIC Codes
This ICR affects State and local governments (SIC code 951, Administration of
Environmental Quality Program) that are currently operating and maintaining established
ambient air quality networks. The 40 CFR part 51 regulations associated with this request
require that State and local air quality management agencies conduct either modeling or the
ambient air quality surveillance and report the data to the EPA. Although industrial,
environmental, and research organizations may use the data available through the AQS, they are
not required to report any information for this information collection. Monitoring data submittal
to AIRNow is voluntary for all organizations, but most State and local agencies reporting to AQS
also report to AIRNow.
4(b) Information Requested For Areas Where Monitoring Option is Implemented
(i) Data items, including record keeping requirements
These data items are submitted electronically to EPA’s AQS as required by 40 CFR part
58. These data are stored electronically within the EPA’s AQS, and separate records kept by the
State or local air quality management agency are not required.
•

Hourly and sub-hourly (5-minute) ambient air pollutant concentrations of SO2
collected at SLAMS sites or any third party monitoring sites identified and eligible to
satisfy proposed requirements of the data requirements rule.

•

Precision and accuracy data for all SLAMS sites, Special Purpose Monitors (SPM),
and any third party monitor identified as eligible to satisfy proposed requirements of
the data requirements rule.

7

•

Monitoring network description information, including the site AQS identification
number, site location, sampling and analysis method, operating schedule, monitoring
objective, site’s scale of representation, identity of the urban area represented, and
quality assurance plan.

•

Results of the annual ambient air monitoring network and quality assurance plan
review.

•

Annual SLAMS summary report which includes the location, date, pollution source,
and duration of each incident of air pollution during which ambient levels of a
pollutant reached or exceeded the significant harm levels as defined in 40 CFR
51.151, the certification of the report’s accuracy by a designated State air pollution
control officer, and various other summary statistics as provided by the AQS system.

(ii) Respondent Activities
A typical respondent would engage in the following activities to comply with this
information request:
•

Read the 40 CFR part 51 regulatory provisions and other EPA guidance (for example,
please reference our Internet site at www.epa.gov/ttn/amtic.)

•

Plan ambient air monitoring activities, such as developing a quality assurance plan
for the network operation and maintenance, developing and reviewing the ambient air
quality surveillance network design, planning where to locate sites, plan how to
maintain and operate each site, develop a data reporting and validation plan.

•

Write the quality assurance plan for network operation and maintenance, the ambient
air quality surveillance network plan, and the data reporting and validation plan.
Submit these plans to the EPA Regional or Headquarters office for review, and
approval if appropriate.

•

Obtain on-site leases or agreements to locate ambient air quality surveillance
equipment.

•

Investigate vendors, and procure equipment necessary to meet the ambient air quality
network plan.

•

Receive training for site operation and maintenance, quality assurance procedures,
and data processing and reporting.

•

Make arrangements for appropriate utility hookups for each ambient air quality
surveillance site, i.e., electricity, telephones, data lines for electronic submission of
concentrations from automated analyzers.
8

•

Install ambient air quality surveillance equipment and equipment shelter. Ensure
security of the site.

•

Conduct or otherwise provide oversight to ambient air quality monitoring,
incorporating all appropriate quality assurance procedures such as calibrations,
precision and accuracy checks, and, if necessary, concurrent monitoring.

•

Validate the ambient air data for quality assurance considerations.

•

Electronically submit the complete and validated ambient air data to AQS.

•

Prepare and submit to EPA annually the SLAMS sites summary report.

Each of these activities are conducted using existing reporting and recordkeeping
practices, including electronic submittal to the AQS.

5. THE INFORMATION COLLECTED--AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT
5(a) Agency Activities
The EPA conducts the following activities to implement the monitoring option of this
ICR and associated regulation:
•

Periodically review the 40 CFR part 58 regulations to update the information
collection and monitoring requirements in light of new technological developments
or new air pollutant standards. Develop revisions to the regulations in response to
legislative action and program changes.

•

Establish, maintain, and support the AQS national repository for all State and local
air quality management agency ambient air quality data and monitoring information.
Periodically evaluate and improve upon this system as new technologies, and new
regulatory requirements would dictate.

•

Answer respondent (generally State and local air quality management agencies, but
also industrial organizations, environmental groups, and others) questions about
ambient air monitoring, the 40 CFR part 58 regulatory requirements, and AQS. This
includes the establishment of the Ambient Monitoring Technology Information
Center bulletin board, the AQS toll-free hotline, and other written or verbal
communication.

•

Support the quality assurance program by working within the EPA and with the
respondents to evaluate precision and accuracy data, oversee the National

9

Performance Audit Program, participate in systems audits, and conduct data
validation checks on the AQS data submittal.
•

Provide within the AQS mechanisms for statistical calculations, such as the number
of times a particular ambient air quality monitoring site exceeds the NAAQS.
Distribute the AQS data in various ways including upon written request, by Freedom
of Information Act request, by press release, and in the annual National Air Quality
and Emissions Trends Report.

•

Provide adequate electronic storage space within the AQS for all ambient air quality
surveillance data and information.

5(b) Collection Methodology and Management
All State and local ambient air monitoring networks have access to and use wellestablished quality assurance procedures as defined in the Quality Assurance Handbook for Air
Pollution Measurement Systems, Volumes I and II, EPA/600/R-94/038a & b. These documents
ensure that all ambient air quality data are accurate and reliable.
The EPA has provided and will continue to provide resources for the maintenance and
operation of AQS. All monitoring data required by this collection are submitted electronically to
reduce the burden of the collection and to improve data quality, agency efficiency, and
responsiveness to the public. Various statistical and graphical summaries are also provided by
AQS which enhance the utility of the information for consumption by the public and all affected
State and local air quality management agencies. In submitting ambient air data into AQS, we
ensure that the data are publicly available, electronically stored, and electronically retrievable.
State and local air quality management agencies and the EPA have been submitting data to the
AQS since its inception in 1987.
5(c) Small Entity Flexibility
This collection contains a minimum amount of information in order to manage the air
quality program for the United States. The smallest entities affected by this collection are local
air quality management agencies, typically consisting of the governing agencies for a county or
group of counties, or a smaller metropolitan area (e.g., cities with a population of 50,000). This
collection reduces to the extent practicable and appropriate the burden on entities that provide
ambient air quality data and information to or for the EPA, including with respect to small
entities, as defined in the Regulatory Flexibility Act (5 U.S.C. 601(6)), the use of such
techniques as:
•

Establishing differing compliance or reporting requirements or timetables that
account for the resources available to those who are to respond (e.g., the monitoring
and reporting requirements decrease as the population of an area decreases, and
various timetables for deploying ambient air monitoring stations are negotiated
between the affected State or local air quality management agency and the EPA with
consideration of the respondent’s resources);
10

•

Clarification, consolidation, or simplification of compliance and reporting
requirements (e.g., by establishing, maintaining, and improving as needed the AQS
and AIRNow national repositories for ambient air quality data and information);

•

Exemption from coverage of the collection of information, or any part thereof (e.g.,
the EPA negotiates with State and local air quality management agencies to
determine the most effective and most efficient ambient air quality networks with
respect to the monitoring needs, technical abilities, and resources available to each
affected agency).

5(d) Collection Schedule for Monitoring Data
Ambient air quality surveillance data and precision and accuracy data for criteria air
pollutants are submitted according to the schedule defined in 40 CFR 58.16. These current
regulations require that State and local air quality management agencies report their data within
90 days after the end of the quarter during which the data were collected.
The annual SLAMS report is submitted by May 1 of each year for data collected from
January 1 through December 31 of the previous year in accordance with 40 CFR 58.15. This
certification applies to all SLAMS and all SPM monitoring data that have been submitted by
May 1.
The annual air quality surveillance network reviews are conducted and reports are
submitted to the EPA on a schedule that is determined by the affected State or local air quality
management agency and the EPA Regional Office.
Ambient air quality data and information are made available to the public at any time in
various ways, including:
•

Upon request to the appropriate EPA Regional office, or to the OAQPS;

•

By Freedom of Information Act Request to the appropriate EPA Regional Office or
the OAQPS;

•

From the State or local air quality management agency responsible for collecting the
ambient air quality data and information;

•

By obtaining access, through appropriate EPA channels, to AQS;

•

Through EPA public reports, such as the annual “National Air Quality and Emissions
Trends Report“; or

•

Through AQI reporting mechanisms which include newspaper, television, Internet
and other publicly available notices (see www.epa.gov/airnow).

11

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION FOR THE
MONITORING OPTION
6(a) Estimating Respondent Burden
All activities listed with section 4 (b) (ii) of this ICR Supporting Statement are presented
in Worksheet 1. The detailed burden and cost estimates for the different types of monitors are
based on information provided in the version of Guidance for Estimating Ambient Air
Monitoring Costs for Criteria Pollutants and Selected Air Toxic Pollutants (prepared by Desert
Research Institute for the EPA Office of Air Quality Planning and Standards, Air Quality
Assessment Division, Ambient Air Monitoring Group, January 2005). The monitoring cost
estimates presented in this guidance document were based on existing literature and direct
monitoring experience. The costs for equipment and supplies were verified with vendors. The
monitoring costs were based on vendor quotes for the monitor type that EPA expects respondents
to use to comply with the requirements. Costs for level of effort estimates were verified with
selected State and local agencies.
For use in preparing the burden estimates for the monitoring option of this ICR, costs for
the monitoring requirements were inflated to 2016, 2017 and 2018. The cost escalation factors
were estimated based on the appropriate Gross Domestic Product (GDP) price indices. Tables
showing the detailed burden estimate calculations are presented below. A summary of the
average annual respondent burden costs follows.

Worksheet 1: Annual Average Respondent Burden Estimates
Total Labor Hours
Per Respondent Per Year
(113 respondents)

Collection
Activities
1. Network design

5.4

2. Site installation

11.3

3. Sampling & analysis

313.6

4. Maintenance & repairs

177.7

5. Data management

101.9

6. Quality assurance

203.6

7. Supervision

164.7

TOTAL

978.2

12

6(b) Estimating Respondent Costs
All activities listed with section 4 (b) (ii) of this ICR Supporting Statement are included
in the Worksheet 2. A summary of the average annual respondent burden costs follows.
Worksheet 2: Annual Average Respondent Cost Estimates
Total Labor Cost
Per Respondent Per Year
(113 respondents)

Collection
Activities
1. Network design

$415.1

2. Site installation

$697.7

3. Sampling & analysis

$22,038.1

4. Maintenance & repairs

$11,613.2

5. Data management

$6,826.6

6. Quality assurance

$13,992.4

7. Supervision

$11,746.9

TOTAL

$67,330.0

6(c) Estimating Agency Burden and Cost
We estimated the Agency burden and cost by using current burden and cost of the
ambient air monitoring program related to this collection. We included burden and cost for the
OAQPS, the ten Regional Offices, and associated contract activities. The in-house activities for
this collection are completed by a variety of individuals with a variety of salaries; therefore, we
used the actual salary as an average for computing the program costs. Actual contractor
expenses were used for those activities completed using extramural resources. We estimated a
total of 52,717 hours and $776,005 total agency burden.
6(d)

Estimating the Respondent Universe and Total Burden and Costs

Worksheet 3 shows the total respondent hourly burdens and costs which was taken from
section 6(b) above for the estimated 113 respondents. The total labor burden for the respondents
was estimated to be 110,543 hours at a total cost of $7,608,287.

13

Worksheet 3: Annual Total Respondent Labor Burden/Cost Estimates
Collection
Activities

Total Labor Hours
Per Year

Total Labor Cost
Per Year

1. Network design

613

$46,908

2. Site installation

1,278

$78,845

3. Sampling & analysis

35,440

$2,490,302

4. Maintenance & repairs

20,082

$1,312,286

5. Data management

11,518

$771,411

6. Quality assurance

23,004

$1,581,140

7. Supervision

18,606

$1,327,396

110,543

$7,608,287

TOTAL

6(e) Bottom Line Burden Hours and Cost Tables
(i) Respondent Tally
Respondent Total Annual Burden =110,543 hours
Respondent Total Annual Labor Cost for O & M = $7,608,287
Respondent Total Annual Cost for Non-labor O & M = $760,011
Respondent Total Equipment/Contract = $940,526
(ii) The Agency Tally
Agency Total Annual Burden = 52,717 hours
Agency Total Annual Cost = $776,005
(iii) Variations In The Annual Bottom Line.
We do not expect any significant variations in the annual bottom line for the ambient air
monitoring networks for the clearance period requested.

6(f) Reasons for Change in Burden

14

The new burden requested in this ICR results from the requirements under the Proposed
SO2 Data Requirements Rule.
6(g) Burden Statement
The annual public reporting and recordkeeping burden for this collection of information
is estimated to average 978 hours per respondent under the monitoring option. Burden means the
total time, effort, or financial resources expended by persons to generate, maintain, retain, or
disclose or provide information to or for a Federal agency. This includes the time needed to
review instructions; develop, acquire, install, and utilize technology and systems for the purposes
of collecting, validating, and verifying information, processing and maintaining information, and
disclosing and providing information; adjust the existing ways to comply with any previously
applicable instructions and requirements; train personnel to be able to respond to a collection of
information; search data sources; complete and review the collection of information; and
transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a
person is not required to respond to, a collection of information unless it displays a currently
valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40
CFR part 9 and 48 CFR chapter 15.
To comment on the Agency's need for this information, the accuracy of the provided
burden estimates, and any suggested methods for minimizing respondent burden, including the
use of automated collection techniques, EPA has established a public docket for this ICR under
Docket ID Number EPA-HQ-OAR-2013-0711, which is available for online viewing at
www.regulations.gov, or in person viewing at the Air Docket in the EPA Docket Center
(EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. The
EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through
Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 5661744, and the telephone number for the Air Docket is (202) 566-1742. An electronic version of
the public docket is available at www.regulations.gov. This site can be used to submit or view
public comments, access the index listing of the contents of the public docket, and to access
those documents in the public docket that are available electronically. When in the system,
select “search,” then key in the Docket ID Number identified above. Also, you can send
comments to the Office of Information and Regulatory Affairs, Office of Management and
Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please
include the EPA Docket ID Number EPA-HQ-OAR-2013-0711 and OMB Control Number
2060-NEW in any correspondence.

PART B OF SUPPORTING STATEMENT

This section is not applicable to this ICR because statistical methods are not used in the
data collection associated with the rule amendments.

15