2258ss03

DRAFT Information Collection Request
Supporting Statement for the
PM2.5 National Ambient Air Quality Standards
State Implementation Plan Requirements Rule
EPA ICR Number 2258.03
OMB Control No. 2060-0611

Prepared by:
Office of Air Quality Planning and Standards
Office of Air and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711

March 23, 2015

2

EPA Information Collection Request Renewal for the
PM2.5 National Ambient Air Quality Standards
State Implementation Plan Requirements Rule

Table of Contents
1. Identification of the Information Collection Request…...............……page 3

2. Need for and Use of the Collection…………………………………...page 4

3. Non-Duplication, Consultation, and other Collection Criteria……… page 6

4. Respondents and the Information Requested…………………………page 9

5. Information Collected—Agency Activities, Collection Methodology and Information
Management……………………………………………..page 12

6. Estimating the Burden and Cost of the Collection……………………page 14

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1.
1(a)

Identification of the Information Collection Request
Title of the Information Collection

The title of the Information Collection Request is PM2.5 National Ambient Air Quality
Standards (NAAQS) State Implementation Plan Requirements (SIP) Rule, ICR number 2258.03,
and OMB Control Number 2060-0611, expiration date: May 1, 2018.
1(b)

Abstract/Executive Summary

The EPA has established a suite of PM2.5 standards based on evidence and numerous health
studies demonstrating that serious health effects are associated with exposures to elevated levels
of PM2.5. Estimates show that attainment of the PM2.5 standards would result in tens of thousands
fewer premature deaths each year, tens of thousands fewer hospital admissions each year, and
hundreds of thousands fewer doctor visits, absences from work and school, and respiratory
illnesses in children annually. EPA initially established annual and 24-hour PM2.5 standards in
1997. The 24-hour standard was subsequently revised in 2006, and the annual standard was
revised in 2012.
The EPA is proposing the PM2.5 NAAQS SIP Requirements Rule to describe the CAA
requirements that must be met by states with nonattainment areas required to develop attainment
plans for attaining and maintaining the NAAQS. The intended effect of the SIP Requirements
Rule is to provide certainty to states regarding their planning obligations such that states may
begin SIP development. Only states with nonattainment areas are required to submit SIPs that
meet the requirements of the rule.
The information collection activities in this proposed rule have been submitted for approval
to the Office of Management and Budget (OMB) under the Paperwork Reduction Act (PRA).
The PRA requires the EPA to assess the administrative burden (in hours and dollars) for state air
agencies to develop plans to attain the PM2.5 NAAQS, and for EPA to review and take action on
such plans.
The EPA estimates the additional administrative burden for states with nonattainment areas
for the 2012 PM2.5 NAAQS to be 126,000 hours, and the estimated administrative burden for
EPA to be 13,860 hours. With respect to ongoing implementation of the 1997 and 2006 PM2.5
standards, the EPA estimates the total additional administrative burden for states to be 145,800
hours, and the estimated administrative burden for EPA to be 16,038 hours. In this analysis, fifty
percent of the hours are assumed to be expended in the first year, with the remaining hours
evenly divided between the second and third years of the ICR period.
For the newly designated nonattainment area burden, the present value of the total additional
costs for state governments, the respondents, estimated at $7.6 million for the 3 year period. On
an equivalent annual basis that is $2.5 million per year during the 3 year period of the ICR. For
the remaining 1997 and 2006 PM25 nonattainment burden, the present value of the total

4
additional costs for state governments, the respondents, estimated at $8.8 million for the 3 year
period. On an equivalent annual basis that is $2.9 million per year during the 3 year period of the
ICR. Therefore, the present value of the total additional costs for state governments, the states
having to respond with SIP revision, estimated at $16.4 million for the 3 year period. On an
equivalent annual basis that is $5.4 million per year during the 3 year period of the ICR.
For the newly designated nonattainment area burden, the present value of the Agency
administrative cost burden is estimated at $0.8 million dollars for the 3 year period. This is
equivalent to equal annual basis of $0.3 million per year during the three year period. For the
remaining 1997 and 2006 PM25 nonattainment burden, the present value of the Agency
administrative cost burden is estimated at $1.0 million dollars for the 3 year period. This is
equivalent to equal annual basis of $0.3 million per year during the three year period. Therefore,
the present value of the Agency administrative cost burden is estimated at $1.8 million dollars
for the 3 year period. This is equivalent to equal annual basis of $0.6 million per year during the
three year period.
The incremental administrative burden for the areas and activities covered by this ICR is
mitigated by the fact that many states may be able to attain the standards based on existing
federal and state emission reduction programs and may not need substantial additional emissions
reductions from new state regulations. In addition, the fourteen areas designated in December
2014 as not attaining the 2012 PM2.5 NAAQS are located in 6 states, all of which previously had
areas designated as nonattainment for the 1997 or 2006 PM2.5 NAAQS. Thus, these states all
have experience with developing state implementation plans for attaining previously established
PM2.5 NAAQS.

2.

Need For and Use of the Collection
2(a) Need/Authority for the Collection

The Clean Air Act, which was last amended in 1990, requires the EPA to establish National
Ambient Air Quality Standards (NAAQS) for air pollutants that may reasonably be anticipated to
endanger public health or welfare, and which result from numerous or diverse sources. On July
18, 1997, the EPA revised the NAAQS for particulate matter to add new standards for fine
particulate matter (particles of solid and liquid material less than 2.5 microns in aerodynamic
diameter), using PM2.5 as the indicator. The EPA established health-based (primary) annual and
24-hour standards for PM2.5 (62 FR 38652). The annual standard was set a level of 15
micrograms per cubic meter, based on the 3-year average of annual mean PM2.5 concentrations.
The 24-hour standard was set a level of 65 micrograms per cubic meter, based on the 3-year
average of the 98th percentile of 24-hour concentrations. The welfare-based secondary standards
were established identical to the primary standards.
The initial PM2.5 National Ambient Air Quality Standard Implementation rule was proposed
November 1, 2005 (70 FR 65983) and was promulgated on April 25, 2007 (72 FR 20586). The
preamble to the proposed and final regulation addresses the administrative burden in general
terms. The preamble to the final rule stated that an ICR would be prepared. The first ICR (No.
2258.01) covered a period from April 5, 2008 through April 4, 2011.

5
On October 17, 2006, the EPA revised the NAAQS for fine particles. The EPA established a
new primary 24-hour standards for PM2.5 (71 FR 61144). The 24-hour standard was set a level of
35 micrograms per cubic meter, based on the 3-year average of the 98th percentile of 24-hour
concentrations. The annual standard remained unchanged at a level of 15 micrograms per cubic
meter, based on the 3-year average of annual mean PM2.5 concentrations. The time period
covered in the second ICR (2258.02) was a three year period from June 1, 2011 through May 31,
2014.
On December 14, 2012, the EPA revised the NAAQS for fine particles. The EPA established
a new primary annual standard PM2.5 (78 FR 3086). The annual standard was set at a level of 12
micrograms per cubic meter, based on the 3-year average of annual mean PM2.5 concentrations.
The 24-hour standard remained unchanged at a level of 35 micrograms per cubic meter, based on
the 3-year average of the 98th percentile of 24-hour concentrations. The time period covered in
the third ICR (2258.03) is anticipated to be a three year period from May 1, 2015 through May
31, 2018.
Part D of Title I of the Clean Air Act sets forth the implementation plan requirements for
areas designated nonattainment for a National Ambient Air Quality Standard. This rule provides
the framework for states to follow in developing SIPs to attain the 2012 PM2.5 NAAQS and any
future revisions to the PM2.5 NAAQS. The rule also applies to the remaining nonattainment areas
for the 1997 PM2.5 NAAQS and the 2006 PM2.5 NAAQS.
This framework reflects the applicable requirements described in the CAA part D
nonattainment area provisions found in sections 172 (subpart 1) and sections 188-190 (subpart
4). A PM2.5 SIP must include rules requiring emission reductions and a demonstration showing
whether the particular area can attain the standard by its attainment date. A state plan submittal
for attaining the PM2.5 NAAQS is due to EPA within 18 months after the date the area is
designated as nonattainment. After a state submits a SIP, the CAA requires the EPA to review
the plan, and approve or disapprove it.
2(b)

User/Users of the Data

The data collected from the state or local air agency respondents will include the
nonattainment SIP elements required by the CAA and described in more detail in the PM2.5 SIP
requirements rule. The PM2.5 SIP must contain state rules and other requirements designed to
achieve the NAAQS by the deadlines established under the CAA.
The PM2.5 SIP submitted by the state must include the various requirements in subpart 1 and
subpart 4, including:



Baseline emission inventory and projection year inventory for stationary, mobile, and
area emissions sources in the nonattainment area consistent with section 51.1008 of the
rule.
For Moderate areas, an analysis of economic and technological feasibility of potential
control measures (i.e., reasonably available control measures (RACM) and reasonably
available control technology (RACT)), and the adoption of state rules requiring emission

6








reductions to ensure attainment of the standard “as expeditiously as practicable,”
consistent with sections 51.1007 and 51.1009 of the rule.
For Serious areas, an analysis of economic and technological feasibility of potential
control measures (i.e., best available control measures (BACM) and best available control
technology (BACT)), and the adoption of state rules requiring emission reductions to
ensure attainment of the standard “as expeditiously as practicable,” consistent with
sections 51.1010 of the rule.
A proposed attainment date consistent with section 51.1004 of the rule.
An attainment demonstration with air quality modeling showing that existing federal and
state emission reduction programs, plus any new emission reduction programs adopted by
the state, will result in expeditious attainment by the attainment date, consistent with
section 51.1011 of the rule. The attainment demonstration must meet the requirements of
40 CFR 51.112 and Part 51, Appendix W, and must include emission inventory data,
modeling results, and emission reduction analyses on which the state has based its
projected attainment date. The attainment demonstration and supporting air quality
modeling should be consistent with the EPA’s PM2.5 modeling guidance
A plan showing that future emission reductions will provide for reasonable further
progress (RFP) toward attainment of the standard for the period prior to the area’s
attainment date, consistent with section 51.1012 of the rule; and annual reporting on
quantitative milestones showing progress in the implementation of the attainment plan
and associated control measures, consistent with section 51.1013 of the rule.

The states use this information and analysis to fulfill federal obligations under Title I,
Subpart D of the Clean Air Act and the PM2.5 Implementation Rule. They also use the attainment
demonstrations, RFP, RACT and RACM determinations to inform their citizenry, including
potentially regulated entities. The potentially regulated entities use this information in assessing
future emission reduction requirements.
The EPA regional and headquarters offices will use the submitted information in determining
the adequacy of the various elements of the PM2.5 implementation plan. After a state submits a
SIP with the appropriate technical supporting documentation, the EPA is required under the
CAA to approve or disapprove the SIP within 12 months. Emission reduction regulations
developed by the states become federally enforceable when approved by the EPA.

3.

Non-Duplication, Consultations, and Other Collection Criteria

3(a)

Non-Duplication

As noted in section 2(b) above, the state respondent will submit an implementation plan
for each nonattainment area that will need to include a number of separate and unique
elements. For example, each implementation plan will need to include a unique
RACM/RACT analysis, attainment demonstration, and RFP plan.
However, there are other activities covered by existing ICRs which complement the
elements required in the PM2.5 SIP. For example, the existing fine particle monitoring

7
network, covered under a separate, existing ICR, provides essential data for use by states and
EPA in identifying key categories of emissions and tracking progress toward attainment.
EPA encourages the states to account for control measures and expected emission
reductions from existing regulations and implementation planning processes, such as for the
1997 and 2006 PM2.5 NAAQS, the Ozone NAAQS, the regional haze program, the cross
state air pollution rule (CSAPR), the Mercury and Air Toxics Standards. Taking such steps,
where appropriate, may enable states to reduce the incremental administrative burden
associated with this rule and enable identification of control strategies that achieve multipollutant environmental progress at a lower cost.
Relevant ICRs and their titles are identified below.











Requirements for Preparation, Adoption, and Submittal of Implementation Plans
o 51.121-51.122 NOx SIP Call……………………………..2060-0445
o 51.160-51.166 New Source Review.......................………2060-0003
o 51.321-51.323 Air Quality Data Reporting………………2060-0088
o 51.353-51.354 Inspection/Maintenance………………….2060-0252
o 51.365-51.366 Inspection/Maintenance………………….2060-0252
Approval and Promulgation of Implementation Plans
o 52.21 Prevention of Significant Deterioration…..………...2060-0003
Ambient Air Monitoring Reference and Equivalent Methods
o 53.4 ………………………………………………………..2080-0005
o 53.9(f),(h),(i)……………………………………………….2080-0005
o 53.14……………………………………………………….2080-0005
o 53.15 ………………………………………………………2080-0005
o 53.16(a)-(d),(f)……………………………………………..2080-0005
Outer Continental Shelf Air Regulations
o 55.4-55.8 …………………………………………………..2060-0249
o 55.11-55.14 ………………………………………………..2060-0249
Ambient Air Quality Surveillance
o 58.11-58.14 ………………………………………………..2060-0084
o 58.20-58.23 ………………………………………………..2060-0084
o 58.25-58.28 ………………………………………………..2060-0084
o 58.30-58.31 ………………………………………………..2060-0084
o 58.33 ……………………………………………………….2060-0084
o 58.35 ……………………………………………………….2060-0084
o 58.40-58.41 ………………………………………………...2060-0084
o 58.43 ……………………………………………………….2060-0084
o 58.45 ……………………………………………………….2060-0084
o 58.50 ……………………………………………………….2060-0084
Determining Conformity of Federal Actions to State or Federal Implementation Plans
o 91.150-93.160 ……………………………………………..2060-0279
8-hour Ozone National Ambient Air Quality Standard Implementation Rule
o 2236.02…………………………………………………….2060 – 0594

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3(b)
Public Notice Required Prior to ICR Submission to the Office of
Management and Budget (OMB)
This is a rule-related ICR. Comments on this ICR will be requested when the rule is
proposed in the Federal Register in March 2015.
3(c)

Consultations

The EPA is soliciting comment on the proposed PM2.5 SIP requirements rule and also
intends to have a public hearing during the public comment period.
3(d)

Effects of Less Frequent Collection

The collections under this rule (as reviewed in section 2.b) are necessary to comply with
Clean Air Act requirements and provide assurances that identified levels of emission
reductions are adequate to ensure timely attainment and maintenance of the PM2.5 NAAQS.
3(c)

General Guidelines

The reporting and recordkeeping requirements in this proposed rule do not violate any of
the regulations promulgated by OMB under 5 CFR part 1320, section 1320.5. This
submission meets the current Paperwork Reduction Act guidelines set forth by OMB. Those
guidelines reflect the requirements of 5 CFR 1320.6. The proposed PM2.5 NAAQS SIP
requirements rule does not require:
 reporting more than once a year;
 respondents to participate in a statistical survey;
 responses to Agency inquiries in less than 30 days;
 respondents to receive remuneration for preparation of reports;
 records to be kept more than 3 years;1
 manual methods of reporting.
3(f)

Confidentiality

The information requested from the states to fulfill CAA requirements as described in
section 2(b) will rely on emissions levels and control efficiency data provided by certain
facilities in the private and public sectors. This information is available from a variety of
sources and states should already have information from emission sources, as facilities
should have provided this information to meet other NAAQS SIP requirements, operating
permits, and/or emissions reporting requirements. It is the assimilation and analysis of that
data (e.g., for RACM/RACT control measure determinations, the attainment demonstration,
etc.) that is required by this rule.

1

However, the states may choose to retain the information for more than 3 years.

9
Emissions and control technology information from emissions sources generally does not
reveal the details of production processes. But, to the extent that it may, the affected facilities
are protected. Specifically, the provision of the emissions and control efficiency information
that is confidential, proprietary, and trade secret is protected from disclosure under the
requirements of subsections 503(e) and 114(c) of the Clean Air Act.
3(g)

Sensitive Information

The requested PM2.5 SIP requirements rule submissions do not include questions whose
answers would require sensitive information.

4.0

The Respondents and the Information Requested

4(a)

Respondents and Nonattainment areas

State and local air agencies2 are the primary respondents under this ICR. Table 1 lists the
14 areas designated in December 2014 as not meeting the 2012 PM2.5 NAAQS. These
nonattainment area designations will be effective in April 2015, and PM2.5 Moderate area
SIPs will then be due from each relevant state or local air agency in October 2016. Note that
two of the areas are multi-state nonattainment areas, with part of the nonattainment area
located in two contiguous states. A total of 6 states will need to submit PM2.5 Moderate area
SIPs for attaining the 2012 PM2.5 NAAQS.
Table 1 also includes an estimated 9,000 burden hours for each Moderate area
nonattainment plan and an estimated total weighted direct and indirect hourly equivalent
salary cost of $65.10 per hour. (Section 6 provides more details on these estimates.) Table 2
describes the estimated incremental burden hours for the initial 2012 PM2.5 NAAQS
nonattainment areas by state and by year.
Table 1. Initial Areas Designated Nonattainment for 2012 PM2.5 NAAQS: Estimated
Burden for 2012 PM2.5 Moderate SIP Requirements

Initial Nonattainment Area for
2012 PM2.5 NAAQS
Allegheny
Allentown
Canton-Massillon
2

State

EPA
Region

PA
PA
OH

3
3
5

3-year
Burden
Estimate
(Hours)

3-year
Burden
Estimate
(Dollars)

9,000
9,000
9,000

$585,900
$585,900
$585,900

Local, state, and federal agencies are part of the North American Industrial Classification
System code number 924110, which includes “administration of air and water resources, and
solid waste management programs.” See http://www.census.gov/naics.

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Initial Nonattainment Area for
2012 PM2.5 NAAQS
Cincinnati-Hamilton
Cincinnati-Hamilton
Cleveland-Akron-Lorain
Delaware County
Imperial county
Johnstown
Lebanon County
Los Angeles-South Coast Air
Basin
Louisville
Louisville
Plumas county
San Joaquin Valley
West Silver Valley
TOTAL

State

EPA
Region

KY
OH
OH
PA
CA
PA
PA

4
5
5
3
9
3
3

CA

9

IN
KY
CA
CA
ID

5
4
9
9
10

3-year
Burden
Estimate
(Hours)

3-year
Burden
Estimate
(Dollars)

4,500
4,500
9,000
9,000
9,000
9,000
9,000

$292,950
$292,950
$585,900
$585,900
$585,900
$585,900
$585,900

9,000
4,500
4,500
9,000
9,000
9,000
126,000

$585,900
$292,950
$292,950
$585,900
$585,900
$585,900
$8,202,600

Table 2 lists the nonattainment areas and states with remaining SIP submittal or
redesignation requirements for the 1997 PM2.5 NAAQS and the 2006 PM2.5 NAAQS that
potentially could be required during the ICR period. For purposes of this draft analysis, it has
been assumed that for the 1997 PM2.5 NAAQS, a Serious area SIP will be required during the
ICR period for one nonattainment area. It also has been assumed that for the 2006 PM2.5
NAAQS, a Serious area SIP will be required during the ICR period for seven nonattainment
areas. In addition, it has been assumed that redesignation requests will be submitted for seven
nonattainment areas for the 2006 PM2.5 NAAQS. (Note that these assumptions have been
made only for the purposes of this analysis, and a number of factors and future state or EPA
actions could change the assumptions put forth here.)
Table 2 also includes an estimated 18,000 burden hours for each Serious area
nonattainment plan, an estimated 300 hours for state development of a redesignation request,
and an estimated total weighted direct and indirect hourly equivalent salary cost of $65.10
per hour. Section 6 provides more details on these estimates.

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Table 2. Remaining 1997 PM2.5 and 2006 PM2.5 Nonattainment Areas with Estimated
Burden for SIP Revision or Redesignation Action

Area Name

State

EPA
Reg.

Chico

CA

9

Fairbanks

AK

10

Imperial County

CA

9

KnoxvilleSevierville-La
Follette
Liberty-Clairton

TN

4

PA

3

Logan

ID

10

Logan

UT

8

Nogales, AZ

AZ

9

Provo

UT

8

Sacramento

CA

9

Salt Lake City

UT

8

San Francisco
Bay Area
San Joaquin
Valley
San Joaquin
Valley
West Central
Pinal

CA

9

CA

9

CA

9

AZ

9

Hours for SIP
Revision or
Redesignation
Action

3-year Burden
Estimate
(Dollars)

300

$19,530

18,000

$1,171,800

18,000

$1,171,800

300

$19,530

2006 PM25 Serious
Area SIP Revision
2006 PM25 Serious
Area SIP Revision
2006 PM25 Serious
Area SIP Revision
2006 PM25
Maintenance Plan
2006 PM25 Serious
Area SIP Revision
2006 PM25
Maintenance Plan
2006 PM25 Serious
Area SIP Revision
2006 PM25
Maintenance Plan
1997 PM25 Serious
Area SIP Revision
2006 PM25 Serious
Area SIP Revision
2006 PM25
Maintenance Plan

18,000

$1,171,800

9,000

$585,900

9,000

$585,900

300

$19,530

18,000

$1,171,800

300

$19,530

18,000

$1,171,800

300

$19,530

18,000

$1,171,800

18,000

$1,171,800

300

$19,530

TOTAL

145,800

$9,491,580

Potential Actions
during ICR period
5/2015 to 4/2018
2006 PM25
Maintenance Plan
2006 PM25 Serious
Area SIP Revision
2006 PM25 Serious
Area SIP Revision
2006 PM25
Maintenance Plan

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4(b)

Information Requested

The information requested under this proposed rule, as described in section 2(b) of this ICR,
is required to meet the requirements of the CAA. The implementation framework set forth in the
regulation does not adopt a “one-size-fits all” approach to meeting these requirements. This
additional flexibility enables the States to customize, to the extent allowed by the Clean Air Act,
their approach to attaining and maintaining the PM2.5 NAAQS.
Data Items. The emissions and control efficiency data required for the attainment
demonstration, RFP, RACT, and RACM is assumed to have been collected as a result of
reporting activities required by other OMB approved ICRs. For example, the collection of
emissions information for many stationary sources is required under other program requirements,
such as the Consolidated Emissions Reporting (CERR) Rule (see
http://www.epa.gov/ttn/chief/cerr/index.html). In developing PM2.5 SIPs, air agencies are
expected to use a range of other readily available data sources, such as existing federal rules that
are expected to reduce future emissions of particulate matter precursors, and economic and
population growth rates.
Respondents’ Activities. The states will compile and reference the data, set forth the
analytical methodology, conduct control technology, emission reduction and air quality modeling
analyses, develop initial drafts, hold hearings, adopt rules, regulations, and programs, have
discussions with EPA staff as appropriate, refine the draft attainment demonstration as
appropriate, adopt the SIP, and formally submit the SIP to the EPA.
Agency Activities. The EPA staff in the regional offices will facilitate timely receipt of the
attainment demonstration, RFP, RACT, and RACM requirements by reviewing materials and
answering questions from the states regarding regulatory requirements, potential data sources,
analytical tools, the draft attainment demonstration, and other draft SIP elements. The EPA
Regional Offices will evaluate the formal SIP submissions and take rulemaking actions to
approve or disapprove the SIP revisions. The EPA headquarters staff will facilitate policy
coordination and national consistency in the timely review and evaluation of plans from states
around the country. They will also facilitate information flow among the regions and states to
promote the development of acceptable demonstrations and SIP submissions.
Reporting Protocols. The dates for plan submissions and milestone reports are as set forth in
subpart 4 of Part D of the CAA (sections 188-190), and in the PM2.5 Implementation rule.

5.0

The Information Collected—Agency Activities, Collection
Methodology, and Information Management

5(a)

States, EPA Regional Offices, and EPA Headquarters Offices

States. The state agencies’ activities include:

13






Develop baseline emissions inventory and projection year inventory.
Conduct analyses of economic and technological feasibility of potential control
measures and adopt state rules requiring emission reductions to ensure attainment of
the standard “as expeditiously as practicable.”
Develop and evaluate emission reduction strategies, and conduct air quality modeling
showing that existing federal and state emission reduction programs, plus any new
emission reduction programs adopted by the state, will result in expeditious
attainment by the attainment date.
Develop plans to ensure that future emission reductions will provide for reasonable
further progress toward attainment of the standard for the period prior to the area’s
attainment date.

EPA Regional Offices. The regional office activities include:




Respond to inquiries from the air agencies and providing guidance on SIP
development.
Review technical data, analyses, and draft SIP elements developed by the air
agencies.
Evaluate the formal SIP submissions and conduct rulemaking actions approving or
disapproving the SIP submissions.

EPA Headquarters. The EPA headquarters office activities include:
 Answer questions regarding application and interpretation of rule provisions.
 Facilitate policy coordination and national consistency in the timely review and
evaluation of plans from states around the country.
 Coordinate information flow amongst the regions and states to promote the
development of acceptable demonstrations and SIP submissions.
5(b)

Collection Methodology and Management

The PM2.5 SIP submitted by the air agency will set forth the data sources,
analytical methods, and the emission reduction and air quality improvement verification
procedures used in its development and implementation.
5(c)

Small Entity Flexibility

For an approved ICR, the Agency must demonstrate that it has taken all
practical steps to develop separate and simplified requirements for small businesses and other
small entities. See 5 CFR 1320.6(h). The PM2.5 NAAQS implementation regulation does not
provide a direct administrative burden on small entities.
5(d)

Collection Schedule

The SIP deadlines for implementing the PM2.5 NAAQS under Subparts 4 and 1 were
proposed in this rule consistent with CAA requirements. Moderate area SIPs will be due
within 18 months of the effective date of nonattainment area designation. The proposed rule

14
requests comment on due dates for certain elements of Serious area SIPs; however, under all
proposed options BACM/BACT requirements would be due within 18 months of the date an
area is reclassified as Serious. Quantitative milestone reports, as required under the CAA,
would be due annually.

6. Estimating the Burden of the Collection
This section provides information on the hours and costs associated with the information
collection for the respondents (the affected state and local air agencies) and EPA (regional
and headquarters offices). Hours and costs are presented for the activities associated with
each collection item for a nonattainment area (or portion thereof) in a given state, as well as
the equivalent annual and present value cost estimates.
6(a)

Estimating Respondent Burden

The estimated respondent burden represents the estimated staff time associated with the
activities required to develop the relevant PM2.5 SIP or redesignation request and implement
the plan each year.
The estimated burden in this ICR is incremental to the estimated burden of other EPA
environmental reporting obligations. The actual incremental burden is expected to vary
across areas for a number of reasons, such as the severity of the nonattainment problem and
whether existing federal and state emission reduction programs are projected to bring the
area into attainment by the 2021 Moderate area attainment date.
Burden Estimate for Initial Nonattainment Areas for the 2012 PM2.5 NAAQS
Table 1 provides the list of 14 areas initially designated as nonattainment for the PM2.5
NAAQS in December 2014 and the states responsible for developing the SIP revisions to
meet the standard in December 2021. Table 3 below summarizes the number of
nonattainment SIPs due by state and provides a 3-year breakdown of expected burden hours
by state.
When the 2012 PM NAAQS were revised in December 2012, EPA released a regulatory
impact analysis (RIA) at the same time.3 The purpose of the RIA was to provide the public
with illustrative estimates of the potential costs and health and welfare benefits of attaining
the revised annual standard. The control strategies presented in the RIA were illustrative and
represent one set of control strategies states might choose to implement in order to meet the
final standards. The RIA analysis developed a base case scenario for the year 2020 that
assessed the projected air quality concentrations in 2020 that would be expected with
ongoing implementation of a number of national rules, including the following:
“Regulatory Impact Analysis for the Final Revisions to the National Ambient Air Quality
Standards for Particulate Matter.” U.S. Environmental Protection Agency, Office of Air Quality
and Planning Standards, Health and Environmental Impacts Division, February 28, 2013. EPA452/R-12-005. See: http://www.epa.gov/ttn/naaqs/standards/pm/s_pm_2007_ria.html.
3

15

- Light-Duty Vehicle Tier 2 Rule (1999)
– Heavy Duty Diesel Rule (2000)
– Clean Air Nonroad Diesel Rule (2004)
– Regional Haze Regulations and Guidelines for Best Available Retrofit Technology
Determinations (2005)
– NOx Emission Standard for New Commercial Aircraft Engines (2005)
– Emissions Standards for Locomotives and Marine Compression-Ignition Engines
(2008)
– Control of Emissions for Nonroad Spark Ignition Engines and Equipment (2008)
– C3 Oceangoing Vessels (2010)
– Boiler MACT (2011)
– Hospital/Medical/Infectious Waste Incinerators: New Source Performance Standards
and Emission Guidelines: Final Rule Amendments (2009)
– Reciprocating Internal Combustion Engines (RICE) NESHAPs (2010)
– Mercury and Air Toxics Standards (2011)
– Cross-State Air Pollution Rule (2011)
The RIA analysis projected that all areas expected to be designated as nonattainment for
the 2012 PM2.5 NAAQS except those areas located in California would be expected to attain
the standard in 2020, based only on emission reductions from the federal regulations
identified above. Thus, it could be concluded from this analysis that existing federal emission
reduction programs will help reduce administrative burden for many air agencies required to
develop SIPs for newly designated nonattainment areas.
As a starting point for developing burden estimates for this analysis, the Agency looked
at the total hours expended in related EPA level of effort work assignments for meeting the
1997 ozone NAAQS, exclusive of the air quality modeling. The total estimate for ozone
areas classified as Marginal was about 2,000 hours in level of technical effort.4 The
estimated burden for a Subpart 4 PM2.5 SIP revision was considered similar to the burden
for ozone areas classified as Moderate, and estimated at 9,000 hours. The estimated burden
for a Subpart 4 PM2.5 SIP revision after an area was reclassified to Serious was considered
similar to ozone areas with higher classifications and estimated at 18,000 hours.
Most of the estimated burden would be expected to be incurred in the first year because
the air agency would be expected to be expending resources developing the PM2.5 SIPs that
would be due 18 months after designation. For the purposes of this analysis, the assumed
allocation of total incremental burden across the three years is 50% in year 1, 25% in year 2,
and 25% in year 3.

4

EPA Contract No. 68-D-00-283; Work Assignments 3-53 and 4-66.

16
Table 3. Initial Areas Designated Nonattainment for 2012 PM2.5 NAAQS:
Estimated Incremental Burden Hours by State and Year

State

California
Idaho
Indiana
Kentucky
Ohio
Pennsylvania

EPA
Region

No. of
Areas or
Parts of
Areas

9
10
5
4
5
3

4
1
1
2
3
5

Additional
hours
Year 1

18,000
4,500
2,250
4,500
11,250
22,500

Additional
hours
Year 2

Additional
hours
Year 3

9,000
2,250
1,125
2,250
5,625
11,250

9,000
2,250
1,125
2,250
5,625
11,250

Remaining Subpart 4 Nonattainment Areas for 1997 and 2006 PM2.5 NAAQS
Table 2 provides the list of areas and states still implementing the 1997 and 2006 PM2.5
NAAQS requirements that potentially could be responsible for developing Serious area SIP
revisions or redesignation requests during the ICR period. For the purpose of this analysis, it
is assumed that one of the original 39 nonattainment areas for the 1997 PM2.5 standard (San
Joaquin Valley, CA) will still need to develop a Serious area plan during the ICR period.
Thus, the bulk of the remaining work for the 1997 nonattainment areas consists of
developing Maintenance SIPs, and this work was included in the estimates for a prior PM25
ICR. The estimated burden hours for development of the remaining Serious area SIP is
18,000 hours.
Of the 32 areas designated as nonattainment for the 2006 PM2.5 standard, Table 2
identifies seven areas that potentially could be reclassified from Moderate to Serious during
the ICR period, and that could have a Serious area SIP (or portions thereof) due within 18
months (also within the period for this ICR). For the purposes of this analysis, the estimated
burden for development of the SIP revisions to address the Serious area requirements is
18,000 hours.
Table 2 also includes 6 nonattainment areas that have attained the 2006 PM25 NAAQS
and have a final Clean Data Determination. (See
http://www.epa.gov/oar/oaqps/greenbk/rfr2rpt5.html). The estimated burden hours for
development of a redesignation request and maintenance plan is 300 hours. The presumed
allocation of total incremental burden across the three years is 50% in year 1, 25% in year 2,
and 25% in year 3.
Using the information in table 2, table 4 below provides a 3-year breakdown of expected
burden hours by state and by year.

17
Table 4. Nonattainment Areas for 1997 and 2006 PM2.5 NAAQS:
Estimated Incremental Burden Hours by State and Year
State
AK
AZ
CA
ID
PA
TN
UT

6(b)

EPA
Additional
Region hours Year 1
10
9
9
10
3
4
8

9,000
300
27,450
4,500
9,000
150
22,500

Additional
hours Year 2
4,500
150
13,725
2,250
4,500
75
11,250

Additional
hours Year 3
4,500
150
13,725
2,250
4,500
75
11,250

Estimating Respondent Cost
Labor costs are estimated for State governments using the total of projected
additional hours for the areas. These estimates do not reflect staff experience and
economies of scale. The hourly rates are the result of estimated directed and indirect cost
per employee. The main source of the information is
http://www.opm.gov/oca/payrates/index.htm
The estimated weighted direct salary cost per employee is $35.88 per hour. This
results from a summation of the professional, managerial, and support staff components.





Hourly equivalent 2010 Salary of Permanent Professional Staff at GS 11, Step 3 is
$33.34. This is the average of hourly equivalent rates for the San Francisco, CA and
Washington, D.C. areas.
To account for permanent managerial staff, 1/11 or 9% of the hourly rate for GS 13,
Step 3 is added to the professional staff hourly rates. The average hourly equivalent
rate for GS-13 using rates for San Francisco, CA and Washington, D.C. is $47.51.
Nine percent of that is $4.32.
To account for permanent support staff at GS-6, Step 6, 1/8 or 16% of the hourly rate
is added to the professional staff hourly rates. The average hourly equivalent rate for
GS-6, Step 6 using rates for San Francisco, CA and Washington, D.C. is $22.17.
Sixteen percent of that is $3.55.

The estimated hourly indirect cost per employee is $23.90. This amount is the sum of the
following:



Benefits at 16% of the weighted direct hourly equivalent salary cost per employee or
$6.59.
Sick and annual leave at 10% of the weighted direct hourly equivalent salary cost per
employee or $4.12.

18


General overhead at 32% of the weighed direct hourly equivalent salary cost per
employee or $13.18.

.
The estimated total weighted direct and indirect hourly equivalent salary cost per
employee is $65.10. The estimated total incremental respondent burden for the state
respondents to meet the new 2012 PM25 SIP requirements and complete the remaining
1997 and 2006 SIP requirements is provided in Table 5.
Table 5. Estimated Total Incremental Cost and Hour Burden for the States (Respondents) to Fulfill
the new 2012 PM25 SIP requirements and complete the remaining 1997 and 2006 SIP Submittal
Requirements.

6(c)

NAAQS

Additional Cost
for Year 1

Additional Cost
for Year 2

Additional Cost
for Year 3

Burden for the 3-year
ICR period (hrs)

2012

$4.1 million

$1.8 million

$1.7 million

126,000

1997/2006

$4.7 million

$2.0 million

$1.9 million

145,800

Total

$8.83 million

$3.8 million

$3.6 million

271,800

Estimating Agency Burden and Cost
The estimated agency burden is derived from the same estimates used for estimating
respondent costs in section 6(b). Draft estimates were developed by the headquarters staff
with review by regional office staff and subsequent refinement of the Agency burden and
cost estimates.
The respondent burden was summed by the EPA regional offices and a percentage
was applied to the yearly burden estimate to reflect the actions taken on the part of the
regional offices. Once yearly burdens were estimated for the Agency’s Regional Offices,
a percentage of those amounts are specified to derive estimates for the Agency’s
Headquarters Office Burdens. Discussions were held with Regional Office and
Headquarters staff regarding the percentages and resulting burden estimates.
Agency Regional Office Burden. Table 6 summarizes total incremental respondent
burden by Regional Office and provides estimates of total incremental Agency Regional
Office burden. The summary of total incremental respondent burden comes from Tables
1 and 2. The Agency Regional Office burden is presumed to be 10% of the estimated
total incremental burden for respondent by the EPA Regional Office. The total
incremental burden allocation for the Agency Regional Offices is 50% in year 1, 25% in
year 2, and 25% in year 3.
Agency Headquarters Burden. Table 6 also summarizes total incremental respondent
burden Agency headquarter burden. The Regional Office burden estimates for years 1, 2,

19
and 3 are multiplied by 10% to arrive at an estimate for Headquarters burden for the same
3 years.
Total Incremental Burden for the Agency. The regional and headquarters office
burden estimate for year 1 for the 2012 NAAQS is 6,930 hours. The estimates for years
2 and 3 are 3,460 hours each year. The regional and headquarters office burden estimate
for year 1 for the 1997 and 2006 NAAQS is 8,000 hours. The estimates for years 2 and 3
are 4,000 hours each year.
Total Cost for the Agency. Using the weighted direct and indirect salary equivalent hour
rate derived in section 6(b), the total incremental burden hours are multiplied by that rate.
The result is the total cost estimate for the Agency provided in Table 6.

Table 6. Estimated Total Incremental Cost and Hour Burden for the EPA Regions and Headquarter
to Fulfill the new 2012 PM25 SIP requirements and complete the remaining 1997 and 2006 SIP
Submittal Requirements.

NAAQS

Total State
Respondents'
burden (hrs)

Additional
Cost for Year 1

Additional
Cost for Year 2

Additional
Cost for Year 3

Regions and HQ
Burden for the 3year ICR period

2012

126,000

$0.4 million

$0.2 million

$0.2 million

13,900

$0.5 million

$0.2 million

$0.2 million

16,000

$0.9 million

$0.4 million

$0.4 million

1997/2006
Total

6(d)

145,800

271,800

29,900

Estimating the Respondent Universe and Total Additional Burden and Costs
The total incremental respondent universe burden and cost estimates are presented
in Tables 7 and 8.
Table 7. 2012 PM2.5 NAAQS Total Incremental Respondent & Agency Universe Burden and Cost
Estimates

Entity
States
Agency
Total

Average Yearly
Burden (hours)
42,000
4,620
46,620

3-Year
Burden (hrs)
126,000
13,860
139,860

Present Value of Costs
for 3-Year Burden
$7.6 million
$0.8 million
$8.4 million

20
Table 8. 1997 PM2.5 and 2006 PM2.5 NAAQS Total Incremental Respondent & Agency Universe
Burden and Cost Estimates

Entity
States
Agency
Total

Average Yearly
3-Year
Burden (hours)
Burden (hrs)
48,600
145,800
5,346
16,038
53,946
161,838

Present Value of
Costs for 3-Year
Burden
$8.8 million
$0.96 million
$9.7 million

*The estimates are in current year (2012) dollars. Costs for years 2 and 3 are calculated using the equation Present Value = Future
Value/ (1 + interest rate)t ,where “t” is the number of years hence (i.e., 0 for year 1, 1 for year 2, 2 for year 3). The adjusted values for
years 1, 2, and 3 are then summed.

6(e)

Reason for Change in Burden

We are requesting an increase in burden of 302,000 hours due to implementation of this new
regulation and the implementation of the remaining requirements for the 1997 PM25 and 2006
PM25 NAAQS. This burden estimate is lower than the estimate for the previous PM2.5
Implementation ICR renewal primarily because the number of designated nonattainment areas
covered by this ICR is lower. The estimates have been calculated using 2012 dollars and some
assumptions regarding overhead, O&M costs, and capital costs have been adjusted to meet
current guidelines and common procedures for preparing ICRs.

6(f)

Burden Statement

The annual public reporting and recordkeeping burden for this collection of information
for the 2012 PM25 NAAQS is estimated to average 2,625 hours per state respondent for this
reporting period. This estimate is derived by taking 42,000 hours, the average yearly burden for
the states identified in Table 1, and dividing by 16, the number of affected state responses.
Similarly, the annual public reporting and recordkeeping burden for this collection of
information for the 1997 and 2006 NAAQS is estimated to average 3,240 hours, which is the
48,600 hours average yearly burden for the states identified in Table 1, and dividing by 15, the
number of affected state responses.
Burden means the total time, effort, or financial resources expended by persons to
generate, maintain, retain, disclose, or provide information or for a Federal agency other than the
EPA to do so. This estimate includes the time and burden needed to conduct the tasks associated
each state submitting the PM2.5 SIP required for each PM2.5 nonattainment area. The PM2.5 SIPs
due during this ICR reporting period will need to include several elements, including the
attainment demonstration, RFP plan, RACT and RACM. In meeting these milestones, such
incremental efforts may include reviewing instructions as well as verifying, processing,
maintaining, and disclosing information. Such efforts may require incremental development,
acquisition, installation, and/or utilization of technological systems for several purposes. These

21
purposes include collecting, verifying, validating, processing, maintaining and disclosing
information associated with the each milestone. The incremental efforts may result from
adjusting the ways to comply with the previously applicable instructions associated with other
National Ambient Air Quality Standards such as 8-hr ozone and PM10. Consequently, in meeting
the milestones, there could be some incremental burden associated with learning/training,
searching data sources, and transmitting the deliverables.
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 the EPA’s regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.
When this ICR is approved by OMB, the Agency will publish a technical amendment to 40 CFR
part 9 in the Federal Register to display the OMB control number for the approved information
collection requirements contained in the final implementation rule. However, as was stated in the
April 2007 Federal Register Notice for the PM2.5 Implementation Rule, “.. the failure to have an
approved ICR for this rule does not affect the statutory obligation for the states to submit SIPs as
required under part D of the CAA.”
The Agency established a docket for the PM2.5 National Ambient Air Quality Standards State
Implementation Requirements Rule under Docket ID No.OAR-2013-0691. All documents in the
docket are listed in the EDOCKET index at http://www.epa.gov/epahome/dockets.htm or
http://www.regulations.gov. Although listed in the index, some information such as Confidential
Business Information is not publicly available. Other information such as copyrighted materials
are not placed on the internet, but are available in hard copy form at the EPA Docket Center (Air
Docket), EPA/DC, EPA West, Room B102, 1301 Constitution Ave., NW., Washington, DC. The
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 Public Reading Room is (202) 566-1744. The
telephone number for the Office of Air and Radiation Docket and Information Center is (202)
566-1742.