Air Emissions Reporting Requirements (AERR) (Renewal)
Extension without change of a currently approved collection
No
Regular
Approved with change
01/31/2022
10/29/2021
Upon resubmission, the program must use the standard 18 question Supporting Statement format. In addition, the program should reexamine the burden and costs associated with state and local governments reporting systems.
table that charts list comparision
Inventory as of this Action
Requested
Previously Approved
01/31/2025
36 Months From Approved
01/31/2022
85
0
75
48,702
0
47,248
255,000
0
225,000
The EPA promulgated the Air Emissions Reporting Requirements (AERR) (40 CFR part 51 subpart A) to coordinate emissions inventory reporting requirements with existing requirements of the Clean Air Act and 1990 Amendments. Under this reporting, 54 State and Territorial air quality agencies, including the District of Columbia, as well as an estimated 31 local and tribal air quality agencies submit emissions data (including mobile model inputs) every 3 years for all point, non-point, on-road mobile, and non-road mobile sources of volatile organic compounds, oxides of nitrogen, carbon monoxide, sulfur dioxide, particulate matter less than or equal to 10 micrometers in diameter, particulate matter less than or equal to 2.5 micrometers in diameter, ammonia, and lead.
In addition, the air quality agencies must submit annually emission data for point sources emitting at greater than specified levels of those pollutants. The data supplied to the emission reporting requirement is needed so that the EPA can compile and make available a national inventory of air pollutant emissions. A comprehensive inventory updated at regular intervals is essential to allow the EPA to fulfill its mandate to monitor and plan for the attainment and maintenance of the national ambient air quality standards established for criteria pollutants. The EPA makes the inventory available to states for air quality planning and to the public at large.
This information is collected under 23 U.S.C. 101; 42 U.S.C 7401-7671q, and the authority of the AERR. This information is mandatory and, as specified, cannot be treated as confidential by the EPA. The number and frequency of data collection and submittal is expected to remain the same for 20222024.
These changes show an average annual increase in the number of responses from 75 to 80 and an associated hour increase of about 1,454 and cost increase of about $447,518 including the changes in labor rates noted. This increase does not reflect a change in burden for each respondent, but rather reflects the latest counts of local agencies that report their emissions. The previous ICR assumed 20 local agencies would report on average, but the highest number of local agencies reporting in the last three reporting years has been 31 agencies with a weighted average of 26 for a triennial period. The total number of state and territorial agencies reporting is 54, bringing the total revised number of annual average respondents to 80.
Based on an assumption of 12 state and local agencies adopting CAERS over 3 years as described above, these estimates reflect an annual average decrease of 800 hours of burden representing an annual $77,500 decrease in labor costs for those agencies. Because this ICR does not include the cost burden of state emissions data collection systems, the burden reduction associated with states that no longer need those systems is not included either. In some cases, the burden reduction for states using CAERS would be compared to using paper forms, and additional benefits are achieved by allowing states to convert to electronic collection. Although such effects are not included in this ICR, the EPA believes that a significant burden reduction is achieved and efficiencies gained for states using CAERS.
Additionally, increased labor rates are included in this ICR as compared with the existing approved ICR. Labor rates have been updated to the 2020 labor rates from U.S. Department of Labor, Bureau of Labor Statistics for managers and technical staff.
EPA costs included in this ICR reflect an update to the number of staff working to support the NEI program and to create the CAERS. We have revisited the number of EPA FTE involved in data collection for the NEI to include training, support, and the emissions factor program. Additionally, the CAERS program adds 3 FTE to the total. This has resulting in an increased number of EPA FTE from 10 to 18, which contributes to a $1,184,000 increase in the cost using current labor rates. In addition, the CAERS annual capital, operation and maintenance costs are included, which adds an additional $1,200,000 to the annual costs.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
2170ss08.docx
Air Emissions Reporting Requirements (AERR)