|
|
Appendix A-1 |
|
|
|
|
|
|
LABOR RATES |
|
|
|
|
|
|
|
|
|
|
|
Contractor Rates [1] |
|
|
|
|
|
|
|
2019 Hourly |
Hourly Wage Rate |
Benefits, Overhead & Profit |
Total |
|
|
|
$102.00 |
$46.25 |
2.2 |
$101.75 |
|
|
|
|
|
|
|
|
|
Respondent Rates [2] |
|
|
|
|
|
|
|
2019 Hourly |
Hourly Wage Rate |
Benefits & Overhead |
Total |
|
|
|
$93.00 |
$46.25 |
2 |
$92.50 |
|
|
|
|
|
|
|
|
|
State/Local Agency Rates [3] |
|
|
|
|
|
|
|
2019 Hourly |
Hourly Wage Rate |
Benefits & Overhead |
Total |
|
|
|
$66.00 |
$33.09 |
2 |
$66.17 |
|
|
|
|
|
|
|
|
|
EPA Rates [4] |
|
|
|
|
|
|
|
2019 Hourly |
Hourly Wage Rate |
Benefits |
Total |
|
|
|
$56.00 |
$35.02 |
1.6 |
$56.03 |
|
|
|
|
|
|
|
|
|
[1] Industry contractor rate based on mean hourly wages for Environmental Engineers obtained from "Occupational Employment and Wages, May 2018; 17-2081 Environmental Engineers" U.S. Deaprtment of Labor, Bureau of Labor Statistics. (http://www.bls.gov/oes/current/oes172081.htm accessed in November 2019) 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 2018; 17-2081 Environmental Engineers" U.S. Deaprtment of Labor, Bureau of Labor Statistics. (http://www.bls.gov/oes/current/oes172081.htm accessed in November 2019) 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 2018; 17-2081 Environmental Engineers" U.S. Deaprtment of Labor, Bureau of Labor Statistics. (http://www.bls.gov/oes/current/oes172081.htm accessed in November 2019) 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 2019 General Schedule Table 2019-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 |
|
|
|
|
|
|
44.54 |
May 2018 |
http://www.bls.gov/oes/current/oes172081.htm |
|
|
|
Mean hourly wage for Environmental Engineers = $44.54/hr |
|
Escalating to Sept 2019 using the Employment Cost Index (ECI) for wages and salaries for Private Industry Workers - All Workers on page 32 of http://www.bls.gov/web/eci/echistrynaics.pdf |
|
|
|
|
|
|
ECI June 2018 = |
|
132.8 |
|
|
|
|
ECI Sept 2019 = |
|
137.9 |
|
(Note that Sept 2019 was the most recent ECI available the when website accessed 11/15/19) |
|
46.25 |
Sept 2019 wages in $/hr |
|
hourly wage May 2018 x (ECI June 2018/ECI Sept 2019) |
|
|
|
|
|
|
|
|
|
|
State/Local hourly wage rate |
|
|
|
|
|
|
32.02 |
May-18 |
http://www.bls.gov/oes/current/oes172081.htm |
|
|
|
25th percentile hourly wage for Environmental Engineers = $32.02/hr |
|
Escalating to Sept 2019 using the Employment Cost Index (ECI) for wages and salaries for State and Local Government Workers - Public Administration on page 51 of http://www.bls.gov/web/eci/echistrynaics.pdf |
|
|
|
|
|
|
ECI June 2018 = |
|
129 |
|
|
|
|
ECI Sept 2019 = |
|
133.3 |
|
(Note that Sept 2019 was the most recent ECI available the when website accessed 11/15/19) |
|
33.09 |
Sept 2019 wages in $/hr |
|
hourly wage May 2018 x (ECI June 2018/ECI Sept 2019) |
|
|
|
|
Appendix A-2 |
|
|
|
|
|
|
|
Universe of Respondents |
|
|
Universe Estimates |
|
|
|
Sources under EPA authority |
|
|
|
# New exploration sources |
0 |
see below - 0 represents the number of expected primary permits to be issued during ICR period |
|
# Existing exploration sources |
1 |
see below - 1 represents the number of existing permits at the start of the ICR period |
|
# Exploration wells to be drilled |
5 |
see below - the 1 existing source above is likely to drill 5 exploratory wells during ICR period |
|
# New development/production sources |
0 |
|
|
# Existing sources |
0 |
this refers to existing development/production sources |
|
# New alternative energy sources |
3 |
3 major source permits |
|
# Existing alternative energy sources |
4 |
|
|
|
|
|
|
Sources under state/local authority |
|
|
|
# New exploration sources |
0 |
|
|
# New development/production sources |
0 |
|
|
# Existing sources |
15 |
include two sources making minor permit mods |
|
# Construction mod to existing sources |
2 |
the two minor mods above require minor NSR permits as well (carried this number over from 2017 renewal) |
|
# New alternative energy sources |
5 |
5 major source permits |
|
# Existing alternative energy sources |
1 |
|
|
Total Number of Sources |
29 |
does not include # exploration wells (row 8) or modified existing sources (row 18) as this would be double counting |
|
|
|
|
|
State/local agencies overseeing sources |
7 |
see below |
|
|
|
|
|
Total Number of Respondents |
36 |
|
|
|
|
|
|
New and existing oil/gas exploration sources - 2020 renewal |
|
|
|
Under EPA authority |
|
|
|
Alaska: |
|
|
|
1 permit application for an exploration source will be submitted, and the permit will be issued prior to 10/1/2020; this is considered an existing source for this ICR. The permit will allow up to five exploratory wells over 2 years. |
Eastern Gulf: |
|
|
|
None |
|
|
|
Other areas: |
|
|
|
None |
|
|
|
|
|
|
|
Under state/local authority |
|
|
|
None |
|
|
|
|
|
|
|
New and existing oil/gas development/production sources - 2020 renewal |
|
|
|
Under EPA authority |
|
|
|
None |
|
|
|
|
|
|
|
Under state/local authority |
|
|
|
South Coast Air Quality Management District: |
|
|
|
There are 4 existing platforms that are expected to continue operating |
|
|
|
Ventura County Air Pollution Control District: |
|
|
|
Of the 4 existing platforms in Ventura County, 2 are in the process of shutting down and 2 are expected to continue operating |
|
|
|
Santa Barbara County Air Pollution Control District: |
|
|
|
Of the 15 platforms formerly in Santa Barbara County, 3 have shut down, 3 are in the process of shutting down, 3 that were "shut in" are expected to resume production, and 6 are expected to continue operating. These are treated as 9 existing sources for this ICR |
|
|
|
|
New and existing alternative energy sources - 2020 renewal |
|
|
|
Under EPA authority |
|
|
|
Region 1: |
|
|
|
3 offshore wind projects will have submitted their NOIs and major source construction/operation permit applications prior to 10/1/2020; these are considered existing sources for this ICR |
3 additional offshore wind projects will submit their NOIs and major source construction/operation permit applications during the period covered by this ICR; these are considered new sources for this ICR |
Region 2: |
|
|
|
1 offshore wind project will submit its NOI and major source construction/operation permit application prior to 10/1/2020; this is considered an existing source for this ICR |
|
|
|
Region 3: |
|
|
|
None; Virginia, Maryland, and Delaware have received delegation of the OCS program |
|
|
|
Regions 4, 9, and 10: |
|
|
|
No permitting activity anticipated. Region 4 expects a meteorological buoy to be deployed in 2022/2023, but it will not require an OCS permit. |
|
|
|
|
|
|
|
Under state/local authority |
|
|
|
Maryland: |
1 offshore wind project has been issued a minor source permit for a meteorological tower. It will submit its NOI and major source construction/operation permit applications during the period covered by this ICR; this is considered a new source for this ICR |
Virginia: |
|
|
|
1 offshore wind demonstration project (two turbines) will complete minor source permitting and construction before the period covered by this ICR; this is considered an existing source for this ICR |
1 offshore wind project will submit its NOI and major source construction/operation permit application during the period covered by this ICR; this is considered a new source for this ICR |
Delaware |
|
|
|
1 offshore wind project has been issued a minor source permit for a meteorological buoy. It will submit its NOI and major source construction/operation permit applications during the period covered by this ICR; this is considered a new source for this ICR |
New Jersey: |
|
|
|
2 offshore wind projects will submit their NOIs and major source construction/operation permit applications during the period covered by this ICR; these are considered new sources for this ICR |
|
|
|
|
|
|
|
|
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 |
|
|
|
New Jersey Department of Environmental Protection |
|
|
|
Delaware Department of Natural Resources and Environmental Control |
|
|
|
|
|
|
|
San Luis Obispo Air Pollution Control District has received delegation of the OCS permit program, but is not anticipated to have any OCS sources |
|
|
|
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 |
|
|
|
|
$93.00 |
|
$102.00 |
|
|
|
|
|
|
|
|
|
|
|
Read regulations2 |
0 |
1 |
0.00 |
5 |
$465.00 |
0 |
$0.00 |
0 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
|
|
|
|
Consult with EPA2 |
0 |
1 |
0.00 |
5 |
$465.00 |
0 |
$0.00 |
0 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
|
|
|
|
Prepare a NOI to construct2 |
0 |
1 |
0.00 |
30 |
$2,790.00 |
0 |
$0.00 |
0 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
|
|
|
|
Prepare major source permit application3 |
0 |
1 |
0.00 |
50 |
$4,650.00 |
293 |
$29,886.00 |
0 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
|
|
|
|
Prepare minor source permit application3 |
0 |
1 |
0.00 |
25 |
$2,325.00 |
146 |
$14,892.00 |
0 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
|
|
|
|
Perform initial compliance test4 |
5 |
1 |
1.67 |
100 |
$9,300.00 |
764 |
$77,928.00 |
1,440 |
$145,380.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
|
|
|
|
Prepare operating permit application5 |
0 |
1 |
0.00 |
42 |
$3,906.00 |
0 |
$0.00 |
0 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
|
|
|
|
Conduct record keeping and report data to EPA4 |
5 |
1 |
1.67 |
32 |
$2,976.00 |
0 |
$0.00 |
53 |
$4,960.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
|
|
|
|
|
|
Responses per Year** |
3.33 |
|
|
|
Burden |
1,493 |
$150,340.00 |
|
|
$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 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
**This number is used in the summary (Exhibit 14) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
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 |
|
|
|
|
$93.00 |
|
$102.00 |
|
|
|
|
|
|
|
|
|
|
|
Read regulations2 |
3 |
1 |
1.00 |
5 |
$465.00 |
0 |
$0.00 |
5 |
$465.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
|
|
|
|
Consult with EPA2 |
3 |
1 |
1.00 |
5 |
$465.00 |
0 |
$0.00 |
5 |
$465.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
|
|
|
|
Prepare a NOI to construct2 |
3 |
1 |
1.00 |
30 |
$2,790.00 |
0 |
$0.00 |
30 |
$2,790.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
|
|
|
|
Prepare major source permit application3 |
3 |
1 |
1.00 |
50 |
$4,650.00 |
293 |
$29,886.00 |
343 |
$34,536.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
|
|
|
|
Prepare minor source permit application3 |
0 |
1 |
0.00 |
25 |
$2,325.00 |
146 |
$14,892.00 |
0 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
|
|
|
|
Prepare operating permit application4 |
3 |
1 |
1.00 |
42 |
$3,906.00 |
0 |
$0.00 |
42 |
$3,906.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
|
|
|
|
Conduct record keeping and report data to EPA5 |
7 |
3 |
7.00 |
32 |
$2,976.00 |
0 |
$0.00 |
224 |
$20,832.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
|
|
|
|
|
|
Responses per Year** |
12.00 |
|
|
|
Burden |
649 |
$62,994.00 |
|
|
$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 source permits because all permitting at this time is for construction/operation. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
4. Assumes that all new major source permittees also incorporate operating permit requirements at the same time. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
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) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
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 |
|
|
|
|
$93.00 |
|
$102.00 |
|
|
|
|
|
|
|
Read regulations |
0 |
1 |
0.00 |
5 |
$465.00 |
0 |
$0.00 |
0 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
Consult with EPA |
0 |
1 |
0.00 |
5 |
$465.00 |
0 |
$0.00 |
0 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
Prepare a NOI to construct |
0 |
1 |
0.00 |
30 |
$2,790.00 |
0 |
$0.00 |
0 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
Prepare preconstruction permit application |
0 |
1 |
0.00 |
100 |
$9,300.00 |
585 |
$59,670.00 |
0 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
Perform initial compliance test |
0 |
1 |
0.00 |
100 |
$9,300.00 |
764 |
$77,928.00 |
0 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
Prepare operating permit application |
0 |
1 |
0.00 |
42 |
$3,906.00 |
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 |
$5,952.00 |
0 |
$0.00 |
0 |
$0.00 |
$1,433.09 |
$28,661.89 |
$0.00 |
$0.00 |
|
|
|
Responses per Year** |
0.00 |
|
|
|
Burden |
0 |
$0.00 |
$1,433.09 |
$28,661.89 |
$0.00 |
$0.00 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
1. Assumes hours per occurrence is the same as that in the 1998 ICR |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
2. Assumes O&M is 5 percent of capital costs |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
3. Capital costs calculated using the June 2019 final CEPCI index for process instruments (416.4) 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) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
EXHIBIT 5. NEW AND PREVIOUSLY PERMITTED 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 |
|
|
|
|
$93.00 |
|
$102.00 |
|
|
|
|
|
|
|
|
|
|
|
|
Read regulations2 |
5 |
1 |
1.67 |
5 |
$465.00 |
0 |
$0.00 |
8 |
$775.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
|
|
|
|
|
Consult with state/local agency2 |
5 |
1 |
1.67 |
5 |
$465.00 |
0 |
$0.00 |
8 |
$775.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
|
|
|
|
|
Prepare a NOI to construct2 |
5 |
1 |
1.67 |
30 |
$2,790.00 |
0 |
$0.00 |
50 |
$4,650.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
|
|
|
|
|
Prepare major source permit application3 |
5 |
1 |
1.67 |
50 |
$4,650.00 |
293 |
$29,886.00 |
572 |
$57,560.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
|
|
|
|
|
Prepare minor source permit application3 |
0 |
1 |
0.00 |
25 |
$2,325.00 |
146 |
$14,892.00 |
0 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
|
|
|
|
|
Prepare operating permit application4 |
5 |
1 |
1.67 |
42 |
$3,906.00 |
0 |
$0.00 |
70 |
$6,510.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
|
|
|
|
|
Conduct record keeping and report data to state/local agency5 |
6 |
3 |
6.00 |
32 |
$2,976.00 |
0 |
$0.00 |
192 |
$17,856.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
|
|
|
|
|
|
|
Responses per Year** |
14.33 |
|
|
|
Burden |
900 |
$88,126.00 |
|
|
$0.00 |
$0.00 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
1. Assumes hours per occurrence is the same as that in the 1998 ICR, except hours added for preparing permit applications |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
2. Assumes all new permittees must perform these tasks |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
3. Assumes all new permits are major source permits because all permitting at this time is for construction/operation. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
4. Assumes that all new major source permittees also incorporate operating permit requirements at the same time |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
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) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
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 |
|
|
|
|
$93.00 |
|
$102.00 |
|
|
|
|
|
|
|
Prepare permit to operate application3 |
9 |
1 |
3.00 |
42 |
$3,906.00 |
0 |
$0.00 |
126 |
$11,718.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
Perform annual compliance test |
15 |
3 |
15.00 |
100 |
$9,300.00 |
764 |
$77,928.00 |
12,960 |
$1,308,420.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
Conduct record keeping and report data to EPA4 |
15 |
3 |
15.00 |
64 |
$1,209.00 |
0 |
$0.00 |
960 |
$18,135.00 |
$1,433.09 |
$0.00 |
$21,496.42 |
$0.00 |
|
Prepare a NOI to construct5 |
2 |
1 |
0.67 |
30 |
$2,790.00 |
0 |
$0.00 |
20 |
$1,860.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
Prepare minor modification permit application5 |
2 |
1 |
0.67 |
50 |
$4,650.00 |
293 |
$29,886.00 |
229 |
$23,024.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
Prepare major modification permit application |
0 |
1 |
0.00 |
100 |
$9,300.00 |
585 |
$59,670.00 |
0 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
$0.00 |
|
|
|
Responses per Year** |
34.33 |
|
|
|
Burden |
14,295 |
$1,363,157.00 |
$1,433.09 |
$0.00 |
$21,496.42 |
$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. Because these are 5-year permits, assumes that 60 percent of existing sources will renew their operating permits during the 3 years of the ICR period |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
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) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
EXHIBIT 8. NEW AND PREVIOUSLY PERMITTED 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 |
|
|
|
|
$66.00 |
|
|
|
|
|
|
|
|
|
Consult with sources2 |
5 |
1 |
1.67 |
5 |
$330.00 |
8 |
$550.00 |
|
|
|
|
|
|
|
Review NOI to construct and minor source permit application3 |
0 |
1 |
0.00 |
55 |
$3,630.00 |
0 |
$0.00 |
|
|
|
|
|
|
|
Review NOI to construct and major source permit application3 |
5 |
1 |
1.67 |
263 |
$17,358.00 |
438 |
$28,930.00 |
|
|
|
|
|
|
|
Review permit to operate application4 |
5 |
1 |
1.67 |
40 |
$2,640.00 |
67 |
$4,400.00 |
|
|
|
|
|
|
|
Conduct inspections5 |
6 |
3 |
6.00 |
16 |
$1,056.00 |
96 |
$6,336.00 |
|
|
|
|
|
|
|
Review data reports5 |
6 |
3 |
6.00 |
8 |
$528.00 |
48 |
$3,168.00 |
|
|
|
|
|
|
|
|
|
Responses per year** |
17.00 |
|
Burden |
657 |
$43,384.00 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
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 major source permits because all permitting at this time is for construction/operation. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
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 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
**This number is used in the summary (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) |
3.3 |
1,493 |
$150,340 |
$0 |
$0 |
|
|
|
New and Previously Permitted Alternative Energy Sources under EPA Authority (Exhibit 2) |
12.0 |
649 |
$62,994 |
$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 and Previously Permitted Energy Sources under State/Local Authority (Exhibit 5) |
14.3 |
900 |
$88,126 |
$0 |
$0 |
|
|
|
Existing Development / Production Sources under State/Local Authority (Exhibit 6) |
34.3 |
14,295 |
$1,363,157 |
$21,496 |
$0 |
|
|
|
Subtotal of Industry Burden (rounded) |
64.0 |
17,337 |
$1,664,617 |
$21,496 |
$0 |
|
|
|
New Exploration Sources under State/Local Authority (Exhibit 7) |
0.0 |
0 |
$0 |
|
|
|
|
|
New and Previously Permitted Alternative Energy Sources under State/Local Authority (Exhibit 8) |
17.0 |
657 |
$43,384 |
|
|
|
|
|
Existing Development/ Production Sources under State/Local Authority (Exhibit 9) |
93.7 |
2,228 |
$147,070 |
|
|
|
|
|
Subtotal of State/Local Burden (rounded) |
111.0 |
2,886 |
$190,454 |
|
|
|
|
|
New and Previously Permitted Exploration Sources under EPA Authority (Exhibit 10) |
|
|
|
|
|
125 |
$7,000 |
|
New and Previously Permitted Alternative Energy Sources under EPA Authority (Exhibit 11) |
|
|
|
|
|
364 |
$29,344 |
|
New and Existing Development/ Production Sources under EPA Authority (Exhibit 12) |
|
|
|
|
|
0 |
$0 |
|
Consistency Updates (Exhibit 13) |
|
|
|
|
|
249 |
$13,963 |
|
Subtotal of EPA Burden |
|
|
|
|
|
738 |
$50,307 |
|
Total Annual Cost /Burden for the Outer Continental Shelf Air Regulations |
175 |
20,223 |
$1,855,071 |
$21,496 |
$0 |
738 |
$50,307 |
|