Tables and Exhibits

1601t09.xlsx

Air Pollution Regulations for Outer Continental Shelf Activities (Renewal)

Tables and Exhibits

OMB: 2060-0249

⚠️ Notice: This form may be outdated. More recent filings and information on OMB 2060-0249 can be found here:

Document [xlsx]

Download: xlsx | pdf

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

Sheet 1: RATES

		Appendix A-1
		LABOR RATES

Contractor Rates [1]
	*2016 Hourly*	Hourly Wage Rate	Benefits, Overhead & Profit	Total
	*$96.00*	$43.43	2.2	$95.55

Respondent Rates [2]
	*2016 Hourly*	Hourly Wage Rate	Benefits & Overhead	Total
	*$87.00*	$43.43	2	$86.87

State/Local Agency Rates [3]
	*2016 Hourly*	Hourly Wage Rate	Benefits & Overhead	Total
	*$63.00*	$31.65	2	$63.30

EPA Rates [4]
	*2016 Hourly*	Hourly Wage Rate	Benefits	Total
	*$54.00*	$33.72	1.6	$53.95

[1] Industry contractor rate based on mean hourly wages for Environmental Engineers obtained from "Occupational Employment and Wages, May 2015; 17-2081 Environmental Engineers" U.S. Deaprtment of Labor, Bureau of Labor Statistics. (http://www.bls.gov/oes/current/oes172081.htm accessed in October 2016) Benfits and overhead assumed to total 100% of wages; profit margin assumed to be 10% on top of "loaded" total. See wage escalation calculations below.


[2] Respondent in-house rate based on mean hourly wages for Environmental Engineers obtained from "Occupational Employment and Wages, May 2015; 17-2081 Environmental Engineers" U.S. Deaprtment of Labor, Bureau of Labor Statistics. (http://www.bls.gov/oes/current/oes172081.htm accessed in October 2016) Benfits and overhead assumed to total 100% of wages. See wage escalation calculations below.


[3] State/Local rates based on 25th percentile hourly wages for Environmental Engineers obtained from "Occupational Employment and Wages, May 2015; 17-2081 Environmental Engineers" U.S. Deaprtment of Labor, Bureau of Labor Statistics. (http://www.bls.gov/oes/current/oes172081.htm accessed in October 2016) Benfits and overhead assumed to total 100% of wages. See wage escalation calculations below.


[4] Federal Labor Cost obtained from U.S. Office of Personnel Management 2016 General Schedule Table 2016-GS. Hourly labor rate assumed is GS-12, Step 5 (Technical Labor). 60% benefits assumed.




WAGE ESCALATION CALCULATIONS

Industry contractor and in-house hourly wage rate
42.33	May 2015	http://www.bls.gov/oes/current/oes172081.htm				Mean hourly wage for Environmental Engineers = $42.33/hr
	Escalating to June 2016 using the Employment Cost Index (ECI) for wages and salaries for Private Industry Workers - All Workers on page 29 of http://www.bls.gov/web/eci/echistrynaics.pdf
	ECI June 2015 =		122.8
	ECI June 2016 =		126.0		(Note that June 2016 was the most recent ECI available the when website accessed 10/18/16)
43.43	June 2016 wages in $/hr		hourly wage May 2015 x (ECI June 2016/ECI June 2015)

State/Local hourly wage rate
31.06	May 2015	http://www.bls.gov/oes/current/oes172081.htm				25th percentile hourly wage for Environmental Engineers = $31.06/hr
	Escalating to June 2016 using the Employment Cost Index (ECI) for wages and salaries for State and Local Government Workers - Public Administration on page 45 of http://www.bls.gov/web/eci/echistrynaics.pdf
	ECI June 2015 =		121.3
	ECI June 2016 =		123.6		(Note that June 2016 was the most recent ECI available the when website accessed 10/18/16)
31.65	June 2016 wages in $/hr		hourly wage May 2015 x (ECI June 2016/ECI June 2015)

Sheet 2: UNIVERSE

Appendix A-2

Universe of Respondents

Universe Estimates

Sources under EPA authority

# New exploration sources

see below - 4 represents the number of expected primary permits to be issued during ICR period

# Existing exploration sources

see below - 4 represents the number of existing permits at the start of the ICR period

# Exploration wells to be drilled

see below - only 2 exploratory well are likely to be drilled during ICR period

# New development/production sources

# Existing sources

this refers to existing development/production sources

# New alternative energy sources

3 minor source permits

# Existing alternative energy sources

Cape Wind project which has been permitted (NA NSR major source) but not yet built

Sources under state/local authority

# New exploration sources

# New development/production sources

# Existing sources

include two sources making minor permit mods

# Construction mod to existing sources

the two minor mods above require minor NSR permits as well

# New alternative energy sources

2 minor source permits

# Existing alternative energy sources

Total Number of Sources

does not include # exploration wells (row 8) or modified existing sources (row 18) as this would be double counting

State/local agencies overseeing sources

see below

Total Number of Respondents

New and existing exploration sources under EPA authority - 2017 renewal

Alaska

None.

Eastern Gulf

2 existing exploratory permits currently in effect; held by the same permittee.

3 major source exploratory permits currently in house at Region 4. Two are virtually complete - consider these as permitted sources. One still requires additional processing - consider it as a new source to be permitted.

3 new major source exploratory permits projected for the ICR period.

2 exploratory wells will actually be drilled during the ICR period, across all the permits above. The testing, monitoring, recordkeeping and reporting requirements of the permits only apply during the period when they are actually drilling.

New and existing alternative energy sources

Under EPA authority

1 existing permit, for the Cape Wind project, which has not yet been constructed. Assume that it will be constructed during this ICR period.

Leases have been issued in MA (2 leases) and MA/RI (1 lease), with further action from lessees related to the Site Assessment Plans (SAPs). Assume that 3 minor source permits will be issued, each to install a meteorological tower or buoy; no operating permit required (below title V thresholds).

Leases have been issued off other states, but does not appear that permitting will occur during the ICR period.

Under state/local authority

Maryland Dept. of Environment has 1 application in house; a Virginia lessee has submitted a SAP. Assume that 2 minor source permits will be issued, each to install a meteorological tower or buoy; no operating permit required (below title V thresholds).

Leases have been issued off other delegated states, but does not appear that permitting will occur during the ICR period.

State and local agencies projected to have authority over sources

Santa Barbara County Air Pollution Control District

South Coast Air Quality Management District

Ventura County Air Pollution Control District

Maryland Department of Environment

Virginia Department of Environmental Quality

Sheet 3: Exhibit 1

EXHIBIT 1. NEW AND PREVIOUSLY PERMITTED EXPLORATION SOURCES UNDER EPA AUTHORITY
RESPONDENTS' ANNUAL BURDEN

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					*$87.00*		*$96.00*
Read regulations2	4	1	1.33	5	$435.00	0	$0.00	7	$580.00	$0.00	$0.00	$0.00	$0.00
Consult with EPA2	4	1	1.33	5	$435.00	0	$0.00	7	$580.00	$0.00	$0.00	$0.00	$0.00
Prepare a NOI to construct2	4	1	1.33	30	$2,610.00	0	$0.00	40	$3,480.00	$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	4	1	1.33	50	$4,350.00	293	$28,128.00	457	$43,304.00	$0.00	$0.00	$0.00	$0.00
Prepare minor source permit application3	0	1	0.00	25	$2,175.00	146	$14,016.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
Perform initial compliance test4	2	1	0.67	100	$8,700.00	764	$73,344.00	576	$54,696.00	$0.00	$0.00	$0.00	$0.00
Prepare operating permit application5	4	1	1.33	42	$3,654.00	0	$0.00	56	$4,872.00	$0.00	$0.00	$0.00	$0.00
Conduct record keeping and report data to EPA4, 6	2	1	0.67	32	$2,784.00	0	$0.00	21	$1,856.00	$0.00	$0.00	$0.00	$0.00
		Responses per Year**	8.00				Burden	1,164	$109,368.00			$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 all new permits are major sources permits
4. Assumes that testing, monitoring, recordkeeping and reporting are required only when an exploratory well is actually drilled
5. Assumes that all new major source permittees also incorporate operating permit requirements at the same time
6. Assumes that each exploration source is in actual operation for 1 year only (to drill one well) and must conduct recordkeeping and reporting during that year

**This number is used in the summary (Exhibit 14)

Sheet 4: Exhibit 2

EXHIBIT 2. NEW AND PREVIOUSLY PERMITTED ALTERNATIVE ENERGY SOURCES UNDER EPA AUTHORITY
RESPONDENTS' ANNUAL BURDEN

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					*$87.00*		*$96.00*
Read regulations2	3	1	1.00	5	$435.00	0	$0.00	5	$435.00	$0.00	$0.00	$0.00	$0.00
Consult with EPA2	3	1	1.00	5	$435.00	0	$0.00	5	$435.00	$0.00	$0.00	$0.00	$0.00
Prepare a NOI to construct2	3	1	1.00	30	$2,610.00	0	$0.00	30	$2,610.00	$0.00	$0.00	$0.00	$0.00
Prepare major source permit application3	0	1	0.00	50	$4,350.00	293	$28,128.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
Prepare minor source permit application3	3	1	1.00	25	$2,175.00	146	$14,016.00	171	$16,191.00	$0.00	$0.00	$0.00	$0.00
Prepare operating permit application4	0	1	0.00	42	$3,654.00	0	$0.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
Conduct record keeping and report data to EPA5	4	3	4.00	32	$2,784.00	0	$0.00	128	$11,136.00	$0.00	$0.00	$0.00	$0.00
		Responses per Year**	8.00				Burden	339	$30,807.00			$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 all new permits are minor source permits at this time because they are all in the Site Assessment phase (i.e., only placing a tower or buoy to take meteorological readings).
4. Assumes that all new major source permittees also incorporate operating permit requirements at the same time; for the 2016 ICR renewal we project 0 new major sources
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)

Sheet 5: Exhibit 3

EXHIBIT 3. NEW DEVELOPMENT/PRODUCTION SOURCES UNDER EPA AUTHORITY
RESPONDENTS' ANNUAL BURDEN

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
Labor Rates					*$87.00*		*$96.00*
Read regulations	0	1	0.00	5	$435.00	0	$0.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
Consult with EPA	0	1	0.00	5	$435.00	0	$0.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
Prepare a NOI to construct	0	1	0.00	30	$2,610.00	0	$0.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
Prepare preconstruction permit application	0	1	0.00	100	$8,700.00	585	$56,160.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
Perform initial compliance test	0	1	0.00	100	$8,700.00	764	$73,344.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
Prepare operating permit application	0	1	0.00	42	$3,654.00	0	$0.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
Conduct record keeping and report data to EPA4	0	3	0.00	64	$5,568.00	0	$0.00	0	$0.00	$1,339.83	$26,796.53	$0.00	$0.00
		Responses per Year**	0.00				Burden	0	$0.00	$1,339.83	$26,796.53	$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 July 2016 (preliminary) CEPCI index for process instruments (389.3) compared to the final December 1998 index (363.2) and applied to the 1998 estimate of $25,000
4. Assumes that all permittees must conduct recordkeeping and reporting during each year of the ICR period

**This number is used in the summary (Exhibit 14)

Sheet 6: Exhibit 4

EXHIBIT 4. NEW EXPLORATION SOURCES UNDER STATE/LOCAL AUTHORITY
RESPONDENTS' ANNUAL BURDEN

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					*$87.00*		*$96.00*
Read regulations	0	1	0.00	5	$435.00	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	$435.00	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	$6,090.00	0	$0.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
Perform initial compliance test	0	1	0.00	100	$8,700.00	748	$71,808.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
Conduct record keeping and report data to local agency	0	3	0.00	64	$5,568.00	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

**This number is used in the summary (Exhibit 14)

Sheet 7: Exhibit 5

EXHIBIT 5. NEW ALTERNATIVE ENERGY SOURCES UNDER STATE/LOCAL AUTHORITY
RESPONDENTS' ANNUAL BURDEN

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					*$87.00*		*$96.00*
Read regulations2	2	1	0.67	5	$435.00	0	$0.00	3	$290.00	$0.00	$0.00	$0.00	$0.00
Consult with state/local agency2	2	1	0.67	5	$435.00	0	$0.00	3	$290.00	$0.00	$0.00	$0.00	$0.00
Prepare a NOI to construct2	2	1	0.67	30	$2,610.00	0	$0.00	20	$1,740.00	$0.00	$0.00	$0.00	$0.00
Prepare major source permit application3	0	1	0.00	50	$4,350.00	293	$28,128.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
Prepare minor source permit application3	2	1	0.67	25	$2,175.00	146	$14,016.00	114	$10,794.00	$0.00	$0.00	$0.00	$0.00
Prepare operating permit application4	0	1	0.00	42	$3,654.00	0	$0.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
Conduct record keeping and report data to state/local agency5	2	3	2.00	32	$2,784.00	0	$0.00	64	$5,568.00	$0.00	$0.00	$0.00	$0.00
		Responses per Year**	4.67				Burden	205	$18,682.00			$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 all new permits are minor source permits at this time because they are all in the Site Assessment phase (i.e., only placing a tower or buoy to take meteorological readings)
4. Assumes that all new major source permittees also incorporate operating permit requirements at the same time; for the 2016 ICR renewal we project 0 new major sources
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)

Sheet 8: Exhibit 6

EXHIBIT 6. EXISTING DEVELOPMENT/PRODUCTION SOURCES UNDER STATE/LOCAL AUTHORITY
RESPONDENTS' ANNUAL BURDEN

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
Labor Rates					*$87.00*		*$96.00*
Prepare permit to operate application3	15	1	5.00	42	$3,654.00	0	$0.00	210	$18,270.00	$0.00	$0.00	$0.00	$0.00
Perform annual compliance test	23	3	23.00	100	$8,700.00	764	$73,344.00	19,872	$1,887,012.00	$0.00	$0.00	$0.00	$0.00
Conduct record keeping and report data to EPA4	23	3	23.00	64	$1,131.00	0	$0.00	1,472	$26,013.00	$1,339.83	$0.00	$30,816.01	$0.00
Prepare a NOI to construct5	2	1	0.67	30	$2,610.00	0	$0.00	20	$1,740.00	$0.00	$0.00	$0.00	$0.00
Prepare minor modification permit application5	2	1	0.67	50	$4,350.00	293	$28,128.00	229	$21,652.00	$0.00	$0.00	$0.00	$0.00
Prepare major modification permit application	0	1	0.00	100	$8,700.00	585	$56,160.00	0	$0.00	$0.00	$0.00	$0.00	$0.00
		Responses per Year**	52.33				Burden	21,803	$1,954,687.00	$1,339.83	$0.00	$30,816.01	$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 of the 23 sources will apply to renew their title V permits to operate each year. These are 5-year permits, so this is a conservatively high yearly average.
4. Assumes that all permittees must conduct recordkeeping and reporting during each year of the ICR period
5. Assumes 2 of the existing sources will undergo minor NSR preconstruction permitting for changes at their facilities.

**This number is used in the summary (Exhibit 14)

Sheet 9: Exhibit 7

EXHIBIT 7. NEW EXPLORATION SOURCES UNDER STATE/LOCAL AUTHORITY
STATE/LOCAL AGENCIES' 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
Labor Rate					*$63.00*
Consult with sources	0	1	0.00	5	$315.00	0	$0.00
Review NOI to construct	0	1	0.00	55	$3,465.00	0	$0.00
Review permit to operate application	0	1	0.00	40	$2,520.00	0	$0.00
Oversee initial compliance test	0	1	0.00	67	$4,221.00	0	$0.00
Conduct inspections	0	2	0.00	16	$1,008.00	0	$0.00
Review data reports	0	1	0.00	8	$504.00	0	$0.00
		Responses per year**	0.00		Burden	0	$0.00

* Assumes hours per occurrence is the same as that in the 1998 ICR.
**This number is used in the summary (Exhibit 14)

Sheet 10: Exhibit 8

EXHIBIT 8. NEW ALTERNATIVE ENERGY SOURCES UNDER STATE/LOCAL AUTHORITY
STATE/LOCAL AGENCIES' 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
Labor Rate					*$63.00*
Consult with sources2	2	1	0.67	5	$315.00	3	$210.00
Review NOI to construct and minor source permit application3	2	1	0.67	55	$3,465.00	37	$2,310.00
Review NOI to construct and major source permit application3	0	1	0.00	263	$16,569.00	0	$0.00
Review permit to operate application4	0	1	0.00	40	$2,520.00	0	$0.00
Conduct inspections5	2	3	2.00	16	$1,008.00	32	$2,016.00
Review data reports5	2	3	2.00	8	$504.00	16	$1,008.00
		Responses per year**	5.33		Burden	88	$5,544.00

1. Assumes hours per occurrence is the same as that in the 1998 ICR for consultations, inspections and report reviews; hours for permit application reviews developed consistent with other exhibits
2. Assumes these activities required with all new permittees
3. Assumes all new permits are minor source permits at this time because they are all in Site Assessment phase (i.e., only placing a tower or buoy to take meteorological readings)
4. Assumes that all new major source permittees also incorporate operating permit requirements at the same time; for the 2016 ICR renewal we project 0 new major sources
5. Assumes these activities required with all new and existing permittees

**This number is used in the summary (Exhibit 14)

Sheet 11: Exhibit 9

EXHIBIT 9. EXISTING DEVELOPMENT/PRODUCTION SOURCES UNDER STATE/LOCAL AUTHORITY
STATE/LOCAL AGENCIES' 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
Labor Rate					*$63.00*
Oversee annual compliance test	23	3	23.00	67	$4,221.00	1,541	$97,083.00
Conduct inspections	23	12	92.00	16	$1,008.00	1,472	$92,736.00
Review permit to operate application2	15	1	5.00	40	$2,520.00	200	$12,600.00
Review data reports	23	3	23.00	8	$504.00	184	$11,592.00
Review NOI to construct and permit application3	2	1	0.67	35	$2,205.00	23	$1,470.00
		Responses per year**	143.67		Burden	3,420	$215,481.00

1. Assumes hours per occurrence is the same as that in the 1998 ICR.
2. Assumes 5 of the 23 sources will apply to renew their title V permits to operate each year. These are 5-year permits, so this is a conservatively high yearly average.
3. Assumes 2 of the existing sources will undergo minor NSR preconstruction permitting for changes at their facilities.


**This number is used in the summary (Exhibit 14)

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
Labor Rate					*$54.00*
Consult with sources2	4	1	1.33	5	$270.00	7	$360.00
Review NOI to construct and minor permit application3	0	1	0.00	35	$1,890.00	0	$0.00
Review NOI to construct and major permit application3	4	1	1.33	263	$14,202.00	351	$18,936.00
Review operating permit application4	4	1	1.33	40	$2,160.00	53	$2,880.00
Oversee initial compliance test5	2	1	0.67	67	$3,618.00	45	$2,412.00
Review data reports5, 6	2	1	0.67	8	$432.00	5	$288.00
					Burden	461	$24,876.00

1. Assumes hours per occurrence is the same as that in the 1998 ICR
2. Assumes these activities required with all new permittees
3. Assumes all new permits are major sources permits
4. Assumes that all new major source permittees also incorporate operating permit requirements at the same time
5. Assumes that testing, monitoring, recordkeeping and reporting are required only when an exploratory well is actually drilled
6. Assumes that each exploration source is in actual operation for 1 year only and must submit semi-annual monitoring reports

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
Labor Rate					*$54.00*
Consult with sources2	3	1	1.00	5	$270.00	5	$270.00
Review NOI to construct and minor source permit application3	3	1	1.00	35	$1,890.00	35	$1,890.00
Review NOI to construct and major source permit application3	0	1	0.00	263	$14,202.00	0	$0.00
Review operating permit application4	0	1	0.00	40	$10,800.00	0	$0.00
Review data reports5	4	3	4.00	8	$432.00	32	$1,728.00
					Burden	72	$3,888.00

1. Assumes hours per occurrence is the same as that in the 1998 ICR, except burden for review of a minor source revised to be consistent with other exhibits
2. Assumes these activities required with all new permittees
3. Assumes all new permits are minor sources permits
4. Assumes that all new major source permittees also incorporate operating permit requirements at the same time
5. Assumes these activities required with all new and existing permittees

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
Labor Rate					*$54.00*
Consult with sources	0	1	0.00	5	$270.00	0	$0.00
Review NOI to construct and permit application	0	1	0.00	263	$14,202.00	0	$0.00
Review preconstruction permit application	0	1	0.00	100	$5,400.00	0	$0.00
Oversee initial compliance test	0	1	0.00	67	$3,618.00	0	$0.00
Review operating permit application	0	1	0.00	40	$10,800.00	0	$0.00
Review data reports	0	1	0.00	8	$702.00	0	$0.00
					Burden	0	$0.00

* Assumes hours per occurrence is the same as that in the 1998 ICR.

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
Labor Rate					*$54.00*
Annual Consistency Reviews	16	3	16.00	4	216.00	64	$3,456.00
Major NOI/Regulatory Changes Review	2	1	0.67	150	8,100.00	100	$5,400.00
Minor NOI/Regulatory Changes Review	4	1	1.33	40	2,160.00	53	$2,880.00
					Burden	217	$11,736.00

* 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

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)	8.0	1,164	$109,368	$0	$0
New and Previously Permitted Alternative Energy Sources under EPA Authority (Exhibit 2)	8.0	339	$30,807	$0	$0
New Development / Production Sources under EPA Authority (Exhibit 3)	0.0	0	$0	$0	$0
New Exploration Sources under State/Local Authority (Exhibit 4)	0.0	0	$0	$0	$0
New Alternative Energy Sources under State/Local Authority (Exhibit 5)	4.7	205	$18,682	$0	$0
Existing Development / Production Sources under State/Local Authority (Exhibit 6)	52.3	21,803	$1,954,687	$30,816	$0
Subtotal of Industry Burden (rounded)	73.0	23,510	$2,113,544	$30,816	$0
New Exploration Sources under State/Local Authority (Exhibit 7)	0.0	0	$0
New Alternative Energy Sources under State/Local Authority (Exhibit 8)	5.3	88	$5,544
Existing Development/ Production Sources under State/Local Authority (Exhibit 9)	143.7	3,420	$215,481
Subtotal of State/Local Burden (rounded)	149.0	3,508	$221,025
New and Previously Permitted Exploration Sources under EPA Authority (Exhibit 10)						461	$24,876
New and Previously Permitted Alternative Energy Sources under EPA Authority (Exhibit 11)						72	$3,888
New and Existing Development/ Production Sources under EPA Authority (Exhibit 12)						0	$0
Consistency Updates (Exhibit 13)						217	$11,736
Subtotal of EPA Burden						750	$40,500
Total Annual Cost /Burden for the Outer Continental Shelf Air Regulations	222	27,018	$2,334,569	$30,816	$0	750	$40,500

File Type	application/vnd.openxmlformats-officedocument.spreadsheetml.sheet
File Modified	0000-00-00
File Created	0000-00-00