Burden Calculation Tables

2773t01.xlsx

Greenhouse Gas Reporting Program: Revisions and Confidentiality Determinations for Data Elements for the Greenhouse Gas Reporting Rule; Supplemental Notice of Proposed Rulemaking

Burden Calculation Tables

OMB: 2060-0748

⚠️ Notice: This form may be outdated. More recent filings and information on OMB 2060-0748 can be found here:

2024-11-04 - New collection (Request for a new OMB Control Number)

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Overview

Table of Contents
Cost Summary
2.1 Updates to GWPs
Subpart V (Applicability)
Subpart W (Applicability)
Subpart DD (Applicability)
Subpart HH (Applicability)
Subpart II (Applicability)
Subpart OO (Applicability)
Subpart TT (Applicability)
2.2 New Subparts
B (New Subpart)
WW (New subpart)
XX (New subpart)
YY (New subpart)
ZZ (New Subpart)
2.3 Other Applicability
Subpart P (Applicability)
Subpart Y (Applicability)
2.4 Monitoring and Calculations
Subpart AA (Calculations)
Subpart HH (Calculations)
2.5 Recordkeeping and Reporting
Reporting Cost Summary
A (Data Elements)
C (Data Elements)
F (Data Elements)
G (Data Elements)
N (Data Elements)
P (Data Elements)
Y (Data Elements)
AA (Data Elements)
HH (Data Elements)
OO (Data Elements)
PP (Data Elements)
QQ (Data Elements)

Sheet 1: Table of Contents

Table of Contents for this Workbook	Content Notes

Cost Summary	Summary of Initial, Subsequent Year, and Capital/O&M Costs for All Changes, by Subpart
2.1 Updates to GWPs	Links to spreadsheets containing burden for updates to GWPs, by Subpart, as discussed in Section 2.1 of the impacts assessment
2.2 New Subparts	Links to spreadsheets containing burden for new subparts, by Subpart, as discussed in Section 2.2 of the impacts assessment
2.3 Other Applicability	Links to spreadsheets containing burden for subparts with other applicability changes, by Subpart, as discussed in Section 2.3 of the impacts assessment
2.4 Monitoring and Calculations	Links to spreadsheets containing burden for subparts with changes to monitoring and calculations, by Subpart, as discussed in Section 2.4 of the impacts assessment
2.5 Recordkeeping and Reporting	Links to spreadsheets containing burden for subparts with changes to recordkeeping or reporting requirements, including total and by Subpart, as discussed in Section 2.5 of the impacts assessment

Sheet 2: Cost Summary

Table 4-1. Incremental Implementation Costs by Subpart (2021$)
Subpart	Number of Affected Facilities	Labor Costs		Capital and O&M	Total Initial Year Costs (Labor + Non Labor)	Total Subsequent Year Costs (Labor + Non-Labor)
		Initial Year	Subsequent Years
		Initial Year	Subsequent Years
A – General Provisions	7,840	$64,133	$64,133	$-	$64,133	$64,133
B – Energy Consumption	7,840	$8,771,243	$4,700,877	$489,050	$9,260,294	$5,189,927
C – General Stationary Fuel Combustion Sources	346	$9,906	$9,906		$9,906	$9,906
F – Aluminum Production	7	$57	$57		$57	$57
G – Ammonia Manufacturing	29	$119	$119		$119	$119
I – Electronics Manufacturing	46	$-	$-	$-	$-	$-
N – Glass Production	100	$1,227	$1,227		$1,227	$1,227
P – Hydrogen Production	116	$7,179	$7,179	$4,481	$11,660	$11,660
V – Nitric Acid Production	1	$(2,680)	$(2,680)	$(11,085)	$(13,765)	$(13,765)
W – Petroleum and Natural Gas Systems	188	$2,620,418	$2,620,418	$2,717,864	$5,338,282	$5,338,282
Y – Petroleum Refineries	6	$(6,881)	$(6,881)	$(3,930)	$(10,810)	$(10,810)
AA – Pulp and Paper Manufacturing	1	$104	$104		$104	$104
DD – Electrical Transmission	2	$6,200	$6,200	$3,119	$9,319	$9,319
HH – Municipal Solid Waste Landfills	1,126	$130,188	$127,330	$374	$130,563	$127,704
II – Industrial Wastewater Treatment	2	$5,288	$4,713	$3,077	$8,364	$7,789
OO – Suppliers of Industrial Greenhouse Gases	104	$6,680	$6,680	$62	$6,742	$6,742
PP – Suppliers of Carbon Dioxide	11	$135	$135		$135	$135
QQ – Importers and Exporters of Fluorinated Greenhouse Gases Contained in Pre-Charged Equipment or Closed-Cell Foams	33	$384	$384		$384	$384
RR – Geologic Sequestration of Carbon Dioxide	9	$-	$-	$-	$-	$-
TT – Industrial Waste Landfills	1	$4,853	$3,934	$62	$4,915	$3,996
UU – Injection of Carbon Dioxide
VV – Geologic Sequestration of Carbon Dioxide with Enhanced Oil Recovery Using ISO 27916	2	$-	$-	$-	$-	$-
WW – Coke Calciners	15	$37,847	$34,525	$19,649	$57,497	$54,175
XX – Calcium Carbide Production	1	$2,849	$2,627	$62	$2,911	$2,690
YY – Caprolactam, Glyoxyl, and Glyoxylic Acid Production	6	$12,285	$11,089	$374	$12,660	$11,464
ZZ – Ceramics Production	34	$77,083	$72,062	$2,121	$79,203	$74,183
Total	7,990	$11,748,619	$7,664,140	$3,225,282	$14,973,900	$10,889,422

Sheet 3: 2.1 Updates to GWPs

Burden for Subparts in Section 2.1 of Impacts Assessment

Subpart V (Applicability)	Total Costs Section 2.1
Subpart W (Applicability)			Initial Year	Subsequent Years
Subpart DD (Applicability)		Total Labor costs:	$2,671,132	$2,666,780
Subpart HH (Applicability)		Total Non-Labor costs:	$2,713,473	$2,713,473
Subpart II (Applicability)		Total Section 2.1:	$5,384,605	$5,380,253
Subpart OO (Applicability)
Subpart TT (Applicability)

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Sheet 4: Subpart V (Applicability)

Quantitative Burden and Costs for Revisions to Applicability (implemented during RY2025) (Section 2.1)
Applicability is affected by changes to the globabl warming potential values.											Assumes the cost impacts would be for a facility using the annual performance test option (without abatement); if they need abatement, they would be less likely to be able to cease reporting.
Table V-1. Labor Costs – Subpart V (hours from Appendix H to the 2019 ICR)											Hours for first year are from Table 4-26 of the 2009 Final Impacts Analsysis
Activity	Labor Rates (per hour)								Total Labor Cost per Year per Facility
	Lawyer		Industrial Manager		Industrial Engineer/ Technician		Administrative Support		(2021$)		Assumptions:
	$114.80		$91.33		$73.83		$34.09
	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year	Subseq. Year
Planning	1	1	8	2	16	19.5	0	1	$2,027	$1,771	*planning is related to the required annual performance test: preparing for equipment shutdown prior to testing, contacting the test company, setting up the testing, attending the performance test
QA/QC	0	0	0	0	0	0	0	0	$0	$0	*QA/QC activities include review of calculations, testing, and reports; QA/QC hours are not expected because the annual performance test (and related QA/QC) is performed by a contractor; as such both costs are represented as O&M costs
Recordkeeping	0	0	0	0.5	0	2	0	0.5	$0	$210	*Recordkeeping burden accounts for the time needed to create paper copies, backup to the cloud, or utilize another recordkeeping method
Sampling and Analysis (Calculations)	0	0	38	0.3	50	3.3	0	0.2	$7,162	$278	*Sampling and analysis costs for the annual performance test option (without abatement) include time to calculate the N2O emission factor (according to Equation V-1) using the information gathered during the performance test and to calculate total N2O emissions from the nitric acid trains. Confirmed affected facility has no abatement.
Reporting	0	0	12	1	12	4	12	1	$2,391	$421	*Represents time required to enter the data into EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT) (for new facilities, set-up of account and first-time use of e-GGRT system.
Total	1	1	58	3.8	78	28.8	12	2.7	$11,579	$2,680

Total labor, 1 facility:	1	1	58	3.8	78	28.8	12	2.7	$11,579	$2,680

Table V-2. Capital and O&M Costs – Subpart V – All facilities (from Appendix H to the 2019 ICR)
Activity	Cost Categories				Total Capital and O&M Cost per Year per Facility (2021$)
Activity	Capital Cost (2021$)	Equipment Lifetime	Annualized Capital Cost (2021$/year)	O&M Costs (2021$/year)	Initial Year	Subseq. Years
Equipment (selection, purchase, installation)	$-		$-	$-	$-	$-
Performance testing	$-		$-	$11,022	$-	$11,022	*Costs of performance testing, assumes 1.63 nitric acid trains per facility.
Recordkeeping	$-		$-	$62	$-	$62	*covers cost to store records, such as a flash drive, paper file or cloud storage
Travel	$-		$-	$-	$-	$-
Sampling and Analysis Costs	$-		$-	$-	$-	$-
Total	$-	$-	$-	$11,085	$-	$11,085

Total Capital and O&M, 1 facility:					$0	$11,085

Total Costs of Proposed Revisions, 1 facility:					$11,579	$13,765
Calculation Methodology: Total costs for 1 facility = Labor Cost per facility + Capital and O&M Costs.

Labor Costs of Proposed Revisions				O&M Cost Per Year
# of Facilities	Initial Year	Subseq. Years		Initial Year	Subseq. Years
-1	($2,680)	($2,680)		($11,085)	($11,085)
Calculation Methodology:							Assumes one facility may potentially meet the offramp provisions of 40 CFR 98.2(b) and stop reporting
Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility							Assumed the initial year savings are the same as the subsequent year savings because the facility is going to off-ramp and does not have any initial year costs.

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Sheet 5: Subpart W (Applicability)

				Quantitative Burden and Costs for Revisions to Applicability (implemented during RY2025) (Section 2.1)
				Applicability is affected by changes to the globabl warming potential values.

	This is the list of new reporters per segment from the increase in methane GWP provided by Jennifer Bohman on November 10, 2022.*			Baseline W Monitoring Burden and Costs Per Reporter Calculated from From ICR Appendix E-4: Burden and Cost for Petroleum and Natural Gas Systems (Subpart W) June 2019 Calculated averages per reporter, scaled to 2021$				Incremental Labor Changes for New Reporters from W Data Elements After June 2022 Proposed W Amendments		Incremental Labor and O&M Cost Changes for Monitoring After June 2022 Proposed W Amendments (2021$)					Total Costs (2021$) for All New W Reporters
Segment Number	Segment	2020 Facility Count	Change in Facility Count	Burden/ Reporter (hrs)	Labor Cost/Reporter (2021$)	O&M Cost/Reporter (2021$)	Total Cost/Reporter (2021$)	Burden/ Reporter (hrs)	Labor Cost/Reporter (2021$)	Burden/ Reporter (hrs)	Labor $/ Reporter	O&M $/ Reporter	Total $/ Reporter		Burden (hrs)	Labor	O&M	Total
1	Gathering and Boosting	361	0	98	$10,848	$229	$11,077	6.84	$739	0		$-	$-		-	$-	$-	$-		Per Reporter
2	LNG Import/Export	11	0	67	$7,363	$24,421	$31,784	3.05	$329	0		$-	$-		-	$-	$-	$-		Labor	O&M
3	LNG Storage	5	1	64	$7,001	$6,897	$13,899	1.55	$168	5.75	$645.65	$-	$645.65		71.30	$7,815	$6,897	$14,712		$7,815	$6,897
4	Natural Gas Distribution	164	0	66	$7,231	$8,003	$15,234	0.69	$74	0		$-	$-		-	$-	$-	$-
5	Natural Gas Processing	462	0	69	$7,617	$26,686	$34,304	3.68	$397	10.18	$1,166.58	$-	$1,166.58		-	$-	$-	$-
6	Natural Gas Transmission Compression	644	130	70	$7,683	$18,401	$26,083	1.44	$155	5.75	$645.65	$-	$645.65		10,034.38	$1,102,879	$2,392,078	$3,494,958		$8,484	$18,401
7	Natural Gas Transmission Pipelines	49	1	63	$6,939	$62	$7,001	0.86	$93	11.5	$1,291.30	$-	$1,291.30		75.36	$8,323	$62	$8,385		$8,323	$62
8	Offshore Production	134	7	32	$3,556	$62	$3,618	0.75	$81	5.75	$645.65	$-	$645.65		269.48	$29,974	$437	$30,410		$4,282	$62
9	Onshore Production	468	40	300	$33,263	$206	$33,469	11.21	$1,210	3.18	$505.95	$-	$505.95		12,575.70	$1,399,157	$8,239	$1,407,395		$34,979	$206
10	Underground Natural Gas Storage	52	9	66	$7,217	$34,461	$41,678	1.55	$168	5.75	$645.65	$-	$645.65		659.72	$72,271	$310,150	$382,421		$8,030	$34,461

	Total	2,350	188					Avg $/reporter	$499					Totals	23,686	$2,620,418	$2,717,864	$5,338,282
																				Labor	O&M	Total
				Note to EPA: For columns G, H, I, O, P, and Q, see the calculations in hidden input sheets at back of this workbook.															Weighted Avg for Individual Reporter:	$13,938	$14,457	$28,395.12

															QA:	$13,938	$14,457		Straight Average:	$11,985	$10,015

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											$328.97	#REF!
											$813.24	#REF!
											$74.48	#REF!
											$1,563.83	#REF!
											$800.82	#REF!
											$1,384.40	#REF!
											$726.34	#REF!
											$1,716.31	#REF!
											$813.24	#REF!

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Sheet 6: Subpart DD (Applicability)

Quantitative Burden and Costs for Revisions to Applicability (implemented during RY2025) (Section 2.1)
Applicability is affected by changes to the global warming potential values.
Table DD-1. Labor Costs – Subpart DD (from Appendix H to the 2019 ICR)
Activity	Labor Rates (per hour)								Total Labor Cost per Year per Facility
	Lawyer		Industrial Manager		Industrial Engineer/ Technician		Administrative Support		(2021$)		Assumptions:
	$114.80		$91.33		$73.83		$34.09
	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year	Subseq. Year
Planning	1	1	1	1	2	2	0	0	$354	$354	*reading the rule to become familiar with any changes to the rule requirements, asking questions about applicability, reviewing any overlap in existing reporting programs
QA/QC	0	0	0	0	2	2	0	0	$148	$148	*QA/QC activities include review of calculations, testing, and reports;
Recordkeeping	0	0	0.5	0.5	5	5	0.5	0.5	$432	$432	*Recordkeeping burden accounts for the time needed to create paper copies, backup to the cloud, or utilize another recordkeeping method
Sampling and Analysis (Calculations)	0	0	2	2	12	12	4	4	$1,205	$1,205	*Specific labor costs related to sampling and analysis activities for Subpart DD include overseeing a contractor who weighs the gas cylinders and performing emission calculations
Reporting	0	0	1	1	10	10	1	1	$864	$864	*Represents time required to enter the data into EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT) (for new facilities, set-up of account and first-time use of e-GGRT system).
Total	1	1	4.5	4.5	31	31	5.5	5.5	$3,002	$3,002

Total labor, 1 facility:	1	1	4.5	4.5	31	31	5.5	5.5	$3,002	$3,002
												Adjusted hours from package 1:	$98.16
Table DD-2a. Capital and O&M Costs – Subpart DD – All facilities (from Appendix H to the 2019 ICR)
Activity	Cost Categories				Total Capital and O&M Cost per Year per Facility (2021$)
Activity	Capital Cost (2021$)	Equipment Lifetime	Annualized Capital Cost (2021$/year)	O&M Costs (2021$/year)	Initial Year	Subseq. Years
Equipment (selection, purchase, installation)	–		–	–	–	–
Performance testing	–		–	–	–	–
Recordkeeping	$-		$-	$62	$62	$62	*covers cost to store records, such as a flash drive, paper file or cloud storage
Travel	–		–	–	–	–
Sampling and Analysis Costs	–		–	$1,497	$1,497	$1,497	*Sampling O&M costs for Subpart DD are for an independent contractor to weigh gas cylinders for facilities that have a high quantity of cylinders.
Total	$-		$-	$1,559	$1,559	$1,559

Total Capital and O&M, 1 new facility:					$1,559	$1,559

Total Costs of Proposed Revisions, 1 facility:					$4,561	$4,561
Cost of Proposed Revisions from Package 1 (per facility):					$98	$98
Calculation Methodology: Total costs for 1 facility = Labor Cost per facility + Capital and O&M Costs .

Labor Costs of Proposed Revisions				O&M Cost Per Year
# of Facilities	Initial Year	Subseq. Years		Initial Year	Subseq. Years
2	$6,200	$6,200		$3,119	$3,119
Calculation Methodology:							Assumed two existing reporters would no longer qualify for the off-ramp and would be required to continue reporting.
Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility + Cost of Proposed Revision from Package 1 (Adjusted to $2021)							Because affected facilities are existing facilities that will continue reporting (instead of new reporters), the initial year and subsequent year impacts should be the same.

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Sheet 7: Subpart HH (Applicability)

Quantitative Burden and Costs for Revisions to Applicability (implemented during RY2025) (Section 2.1)
Applicability is affected by changes to the global warming potential values.
Table HH-1. Labor Costs – Subpart HH - Landfills - Facilities with gas collection systems (from Table HH-2a in Appendix H to the 2019 ICR)
Activity	Labor Rates (per hour)								Total Labor Cost per Year per Facility
	Lawyer		Industrial Manager		Industrial Engineer/ Technician		Administrative Support		(2021$)		Assumptions:
	$114.80		$91.33		$73.83		$34.09				Assumes the 6 new facilities affected by CH4 GWP change have GCS.
	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year	Subseq. Year
Planning	2	1	1	1	21	1	2	1	$1,939	$314	*New facilities in their initial year of reporting will incur additional planning hours to familiarize themselves with the rule and hours for setup of compliance activities including sampling and QA/QC. Initial year hours are based on Appendix H of the 2019 ICR.
QA/QC	0	0	1	1	13	6	1	1	$1,085	$568	*QA/QC activities include review of calculations, testing, and reports;
Recordkeeping	0	0	1	1	13	13	1	1	$1,085	$1,085	*Recordkeeping burden accounts for the time needed to create paper copies, backup to the cloud, or utilize another recordkeeping method
Sampling and Analysis (Calculations)	0	0	1	0	16	8	2	1	$1,341	$625	*Sampling and analysis (calculations) hours include completion of the measurements and calculations in (§98.346), including calculation of methane generation and emissions, estimating historical waste quantities, and determining annual waste compositions, and the composition, flow, and destruction of landfill gas through the gas collection system
Reporting	0	0	2	2	26	26	2	2	$2,170	$2,170	*Represents time required to enter the data into EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT) (for new facilities, set-up of account and first-time use of e-GGRT system).
Total	2	1	6	5	89	54	8	6	$7,621	$4,763

Total labor, 1 facility:	2	1	6	5	89	54	8	6	$7,621	$4,763
												Adjusted hours from package 1:	$4.49
Table HH-2. Capital and O&M Costs – Subpart HH – Landfills - Facilities without gas collection systems (from Table HH-3b in Appendix H to the 2019 ICR)
Activity	Cost Categories				Total Capital and O&M Cost per Year per Facility (2021$)
Activity	Capital Cost (2021$)	Equipment Lifetime	Annualized Capital Cost (2021$/year)	O&M Costs (2021$/year)	Initial Year	Subseq. Years
Equipment (selection, purchase, installation)	–		–	–	–	–
Performance testing	–		–	–	–	–
Recordkeeping	$0		$0	$62	$62	$62	*covers cost to store records, such as a flash drive, paper file or cloud storage
Travel	–		–	–	–	–
Sampling and Analysis Costs	–		–	–	–	–
Total	$0		$0	$62	$62	$62

Total Capital and O&M, 1 new facility:					$62	$62

Total Costs of Proposed Revisions, 1 facility:					$7,683	$4,825
Cost of Proposed Revisions from Package 1 (per facility):					$4	$4
Calculation Methodology: Total costs for 1 facility = Labor Cost per facility + Capital and O&M Costs .

Labor Costs of Proposed Revisions				O&M Cost Per Year
# of Facilities	Initial Year	Subseq. Years		Initial Year	Subseq. Years
6	$31,461	$28,603		$374	$374
Calculation Methodology:							Assumed 5 open landfills that have previously off-ramped from the GHGRP may have to resume reporting due to the changes to the GWP and Table HH-1, and one open landfill that is anticipated to become a new reporter due to the changes to the GWP and Table HH-1, that would otherwise not have to report.
Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility + Cost of Proposed Revision from Package 1 (Adjusted to $2021)							"Initial year" cost is based on one facility being new and 5 being earlier reporters that have only subsequent year costs.


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Sheet 8: Subpart II (Applicability)

Quantitative Burden and Costs for Revisions to Applicability (implemented during RY2025) (Section 2.1)
Applicability is affected by changes to the global warming potential values.
Table II-1. Labor Costs – Subpart II (from Appendix H to the 2019 ICR)
Activity	Labor Rates (per hour)								Total Labor Cost per Year per Facility
	Lawyer		Industrial Manager		Industrial Engineer/ Technician		Administrative Support		(2021$)		Assumptions:
	$114.80		$91.33		$73.83		$34.09
	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year	Subseq. Year	Initial year hours are also from Appendix H to the 2019 ICR
Planning	2	1	0.2	0.1	2.0	1.0	0.2	0.1	$402	$201	*New facilities in their initial year of reporting will incur additional planning hours to familiarize themselves with the rule and hours for setup of compliance activities, including QA/QC
QA/QC	0	0	0.2	0.1	2.0	1.0	0.2	0.1	$173	$86	*QA/QC activities include review of calculations, testing, and reports;
Recordkeeping	0	0	0.5	0.5	5.0	5.0	0.5	0.5	$432	$432	*Recordkeeping burden accounts for the time needed to create paper copies, backup to the cloud, or utilize another recordkeeping method
Sampling and Analysis (Calculations)	0	0	2.0	2.0	8.0	8.0	0	0	$773	$773	*Sampling and analysis (calculations) hours include completion of the measurements and calculations in §98.356, including calculation of any methane generation, emissions, and biogas collection and recovery amounts and gas characterization if applicable
Reporting	0	0	1.0	1.0	10.0	10.0	1.0	1.0	$864	$864	*Represents time required to enter the data into EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT).
Total	2	1	3.9	3.7	27	25	1.9	1.7	$2,644	$2,356

Total labor, 1 facility:	2	1	3.9	3.7	27	25	1.9	1.7	$2,644	$2,356

Table II-2. Capital and O&M Costs – Subpart II – All facilities (from Appendix H to the 2019 ICR)
Activity	Cost Categories				Total Capital and O&M Cost per Year per Facility (2021$)
Activity	Capital Cost (2021$)	Equipment Lifetime	Annualized Capital Cost (2021$/year)	O&M Costs (2021$/year)	Initial Year	Subseq. Years
Equipment (selection, purchase, installation)	–		–	–	–	–
Performance testing	–		–	–	–	–
Recordkeeping	$0		$0	$62	$62	$62	*covers cost to store records, such as a flash drive, paper file or cloud storage
Travel	–		–	–	–	–
Sampling and Analysis Costs	$0		$0	$1,476	$1,476	$1,476	*Costs for the calibration of the flow meter at a Subpart II facility. The O&M cost of $3,550 only occurs once every three years under Subpart II. Therefore, each facility (both new facilities and existing facilities) will be expected to incur a cost of $1,183 each year over a three-year period
Total	$0		$0	$1,538	$1,538	$1,538

Total Capital and O&M, 1 new facility:					$1,538	$1,538

Total Costs of Proposed Revisions, 1 facility:					$4,182	$3,895
Calculation Methodology: Total costs for 1 facility = Labor Cost per facility + Capital and O&M Costs.

Labor Costs of Proposed Revisions				O&M Cost Per Year
# of Facilities	Initial Year	Subseq. Years		Initial Year	Subseq. Years
2	$5,288	$4,713		$3,077	$3,077
Calculation Methodology:							Assumed two new reporters would be expected to start reporting to the GHGRP
Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility

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Sheet 9: Subpart OO (Applicability)

Quantitative Burden and Costs for Revisions to Applicability (implemented during RY2025) (Section 2.1)

Applicability is affected by changes to the global warming potential values.

Table OO-1. Labor Costs – Subpart OO - F-GHG Importers (from Table OO-1b in Appendix H to the 2019 ICR)

Activity

Labor Rates (per hour)

Total Labor Cost per Year per Facility

Note: Package 1 includes costs for new data elements for subpart OO that do not overlap with new data elements added in this package that may need to be considered for new reporters.

Lawyer

Industrial Manager

Industrial Engineer/ Technician

Administrative Support

(2021$)

Assumptions:

$114.80

$91.33

$73.83

$34.09

Assumed the new reporter would be an importer (all producers are already required to report).

Initial Year Hours

Subseq. Year Hours

Initial Year Hours

Subseq. Year Hours

Initial Year Hours

Subseq. Year Hours

Initial Year Hours

Subseq. Year Hours

Initial Year

Subseq. Year

Planning

2.0

1.0

$395

*New facilities in their initial year of reporting will incur similar planning hours.

QA/QC

5.0

$457

*QA/QC activities include review of calculations, testing, and reports;

Recordkeeping

1.0

13.0

1.0

$1,085

*Recordkeeping burden accounts for the time needed to create paper copies, backup to the cloud, or utilize another recordkeeping method

Sampling and Analysis (Calculations)

0.9

18.0

1.8

$1,472

*Importers develop an annual report that summarizes imports at the corporate level

Reporting

2.0

26.0

2.0

$2,170

*Represents time required to enter the data into EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT).

Total

2.0

9.9

4.8

$5,579

Total labor, 1 facility:

2.0

9.9

4.8

$5,579

Adjusted hours from package 1:

$12.67

Table OO-2. Capital and O&M Costs – Subpart OO – F-GHG Producers (from Appendix H to the 2019 ICR)

Activity

Cost Categories

Total Capital and O&M Cost per Year per Facility (2021$)

Capital Cost (2021$)

Equipment Lifetime

Annualized Capital Cost (2021$/year)

O&M Costs (2021$/year)

Initial Year

Subseq. Years

Equipment (selection, purchase, installation)

–

Performance testing

–

Recordkeeping

$62

*covers cost to store records, such as a flash drive, paper file or cloud storage

Travel

–

Sampling and Analysis Costs

–

Total

$62

Total Capital and O&M, 1 new facility:

$62

Total Costs of Proposed Revisions, 1 new facility:

$5,642

Cost of Proposed Revisions from Package 1 (per facility, labor):

$13

Calculation Methodology: Total costs for 1 new facility = Labor Cost per facility + Capital and O&M Costs.

Labor Costs of Proposed Revisions

O&M Cost Per Year

# of Facilities

Initial Year

Subseq. Years

Initial Year

Subseq. Years

$5,592

$62

Calculation Methodology:

Assumed to be one new reporter who would be expected to start reporting to the GHGRP

Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility + Cost of Proposed Revision from Package 1 (Adjusted to $2021)

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Sheet 10: Subpart TT (Applicability)

Quantitative Burden and Costs for Revisions to Applicability (implemented during RY2025) (Section 2.1)
Applicability is affected by changes to the global warming potential values.
Table TT-1. Labor Costs – Subpart TT (from Appendix H to the 2019 ICR)
Activity	Labor Rates (per hour)								Total Labor Cost per Year per Facility		Assumptions:
	Lawyer		Industrial Manager		Industrial Engineer/ Technician		Administrative Support		(2021$)
	$114.80		$91.33		$73.83		$34.09
	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year	Subseq. Year
Planning	3	1	3	1	3	1	3	1	$942	$314	*New facilities in their initial year of reporting will incur additional planning time to familiarize themselves with the rule. Initial year labor costs also include time for setup of compliance activities.
QA/QC	0	0	2	1	1	1	2	1	$325	$199	*QA/QC activities include review of calculations, testing, and reports;
Recordkeeping	0	0	1	1	13	13	1	1	$1,085	$1,085	*Recordkeeping burden accounts for the time needed to create paper copies, backup to the cloud, or utilize another recordkeeping method
Sampling and Analysis (Calculations)	0	0	2	1	2	1	0	0	$330	$165	*Sampling and analysis (calculations) hours include completion of the measurements and calculations in (§98.276), including calculation of emissions, and volatile solids testing for the initial year of reporting, where applicable.
Reporting	0	0	2	2	26	26	2	2	$2,170	$2,170	*Represents time required to enter the data into EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT).
Total	3	1	10	6	45	42	8	5	$4,853	$3,934

Total labor, 1 new facility:	3	1	10	6	45	42	8	5	$4,853	$3,934

Table TT-2. Capital and O&M Costs – Subpart TT – All facilities (from Appendix H to the 2019 ICR)
Activity	Cost Categories				Total Capital and O&M Cost per Year per Facility (2021$)
Activity	Capital Cost (2021$)	Equipment Lifetime	Annualized Capital Cost (2021$/year)	O&M Costs (2021$/year)	Initial Year	Subseq. Years
Equipment (selection, purchase, installation)	–		–	–	–	–
Performance testing	–		–	–	–	–
Recordkeeping	$0		$0	$62	$62	$62	*covers cost to store records, such as a flash drive, paper file or cloud storage
Travel	–		–	–	–	–
Sampling and Analysis Costs	–		–	–	–	–
Total	$0		$0	$62	$62	$62

Total Capital and O&M, 1 new facility:					$62	$62

Total Costs of Proposed Revisions, 1 new facility:					$4,915	$3,996
Calculation Methodology: Total costs for 1 new facility = Labor Cost per facility (Table I-I) + Capital and O&M Costs (Table I-2a).

Labor Costs of Proposed Revisions				O&M Cost Per Year
# of Facilities	Initial Year	Subseq. Years		Initial Year	Subseq. Years
1	$4,853	$3,934		$62	$62
Calculation Methodology:							Assumed to be one new reporter who would be expected to start reporting to the GHGRP.
Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility

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Sheet 11: 2.2 New Subparts

Burden for Subparts in Section 2.2 of Impacts Assessment
B (New Subpart)	Total Costs Section 2.2
WW (New subpart)			Initial Year	Subsequent Years
XX (New subpart)		Total Labor costs:	$8,901,308	$4,821,181
YY (New subpart)		Total Non-Labor costs:	$511,257	$511,257
ZZ (New Subpart)		Total Section 2.2:	$9,412,565	$5,332,438

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Sheet 12: B (New Subpart)

Quantitative Burden and Costs for New Subparts (implemented during RY2025) (Section 2.2)

Table B-1. Labor Costs – Subpart B – Energy Consumption

Activity

Labor Rates (per hour)

Total Labor Cost per Year per Facility

Assumptions:

Lawyer

Industrial Manager

Industrial Engineer/ Technician

Administrative Support

(2021$)

$114.80

$91.33

$73.83

$34.09

Initial Year Hours

Subseq. Year Hours

Initial Year Hours

Subseq. Year Hours

Initial Year Hours

Subseq. Year Hours

Initial Year Hours

Subseq. Year Hours

Initial Year

Subseq. Year

Planning

0.5

0.1

0.4

0.1

6.0

2.0

0.8

0.2

$564

$175

Planning: sources are required to develop an Metered Energy Monitoring Plan (MEMP). Assumed time to develop the initial plan and update it annually. Note that an energy audit would be required once every 5 years.

QA/QC

0.1

2.0

0.5

0.2

0.1

$164

$49

QA/QC: Meters must comply with specified standards for electric metering. Assumed time to confirm that meters comply initially and periodically thereafter.

Recordkeeping

0.4

0.3

2.0

0.8

0.6

$211

$196

Recordkeeping: the rule has provisions for accounting for missing billing statements. Assumed 0.26 hours per month (3.2 hours per year) for recordkeeping in the initial year and 0.21 hours/month in subsequent years.

Sampling and Analysis (Calculations)

0.1

1.0

0.3

$93

Sampling and calculations: The rule does not have any calculations, but if a facility is subject to multiple DE subparts, they need to estimate the fraction attributable to each subpart. Assume 1.4 hours per year for reporters to split energy consumption among subparts.

Reporting

0.1

1.0

0.1

$86

Estimated Reporting Costs (represents time required to enter the data into EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT)):

Total

0.5

0.1

1.1

0.7

6.5

2.2

1.3

$1,119

$600

12 data items (b) though (m) must be reported

Assume that all reporters have to report data items for both electricity and thermal energy (e.g., natural gas).

Total labor, 1 new facility:

0.5

0.1

1.1

0.7

6.5

2.2

1.3

$1,119

$600

Data items (f) and (l) apply only to electricity and not thermal energy, so the total for a facility using both electricity and thermal energy is 20 data elements.

20 data elements x 0.05 hours per element = 1 hour of reporting.

Table B-2. Capital and O&M Costs – Subpart B

Assumed manager hours are 5% of technical (rounded up to a minimum of 0.1 hour) and administrative support are 10% of technical

Activity

Cost Categories

Total Capital and O&M Cost per Year per Facility (2021$)

Capital Cost (2021$)

Equipment Lifetime

Annualized Capital Cost (2021$/year)

O&M Costs (2021$/year)

Initial Year

Subseq. Years

Equipment (selection, purchase, installation)

–

Performance testing

–

Recordkeeping

$62

*covers cost to store records, such as a flash drive, paper file or cloud storage

Travel

–

Sampling and Analysis Costs

–

Total

$62

Total Capital and O&M, 1 new facility:

$62

Total Costs of Proposed Revisions, 1 new facility:

$1,181

$662

Calculation Methodology: Total costs for 1 new facility = Labor Cost per facility + Capital and O&M Costs.

Labor Costs of Proposed Revisions

O&M Cost Per Year

$9,260,294

# of Facilities

Initial Year

Subseq. Years

Initial Year

Subseq. Years

7,840

$8,771,243

$4,700,877

$489,050

Assume 7,582 existing reporters per year, based on 2021 RY reporters in S3 data subject to direct emitter subparts , + 5 RR reporters, + 200 new reporters from GWP changes + 53 reporters from new subparts WW, XX, YY, and ZZ.

Calculation Methodology:

Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility

7582

Direct Emitters, from file: https://easternresearchgroup.sharepoint.com/:x:/r/sites/GHGRP/Shared%20Documents/General/Rulemaking/Supplemental%20Notice/Impacts/Data%20Pulls/GHGRP_Rulemaking_DataAggregations_220824_FINAL.xlsx?d=w8e531e632f6c455591c93fbeb406e4a7&csf=1&web=1&e=bUnx5E

RR facilities

7,840

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200

GWP new reporters

New subpart reporters

Sheet 13: WW (New subpart)

Quantitative Burden and Costs for New Subparts (implemented during RY2025) (Section 2.2)											Assumptions:
Table WW-1. Labor Costs – Subpart WW – Coke Calciners											For Subpart Y, EPA previously used model plants to estimate costs that assume a variety of refinery emission units and a set amount of units for each model. For these reasons, these estimates instead assume the same labor hours and O&M costs as used for subpart Q - Iron and Steel Production (carbon mass balance option with sampling, see Table Q-1a(1) in Appendix H) - because both rules rely on a carbon mass balance approach with carbon content sampling.
Activity	Labor Rates (per hour)								Total Labor Cost per Year per Facility (2021$)		Because these facilities are already reporting under subpart Y or C, we asumed that the initial and subsequent year costs are similar, though additional planning hours were added for the initial year.
	Lawyer		Industrial Manager		Industrial Engineer/ Technician		Administrative Support				Only 1 of the 15 facilities currently reporting under subparts Y or C are Calciner Units with/ CEMs. For this facility, we assume the same burden for reporting and recordkeeping, no burden for planning or QA/QC, and a burden of 2.0 hours for industrial technician, 0.2 hours for industrial manager, and 0.1 hours for administrative support for sampling and analysis/calculations. This would result in a total labor cost of $1,030/facility ($2021) in initial and subsequent years.
	$114.80		$91.33		$73.83		$34.09
	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year	Subseq. Year
Planning	1	1	0.3	0.3	6	3	0.2	0.2	$592	$370	*Planning activities include familiarizing with the rule and hours for setup of compliance activities including sampling and QA/QC
QA/QC	1	1	0.2	0.2	2	2	0.1	0.1	$284	$284	*QA/QC activities include review of calculations, testing, and reports;
Recordkeeping	0	0	0.5	0.5	2	2	0.5	0.5	$210	$210	*Recordkeeping burden accounts for the time needed to create paper copies, backup to the cloud, or utilize another recordkeeping method
Sampling and Analysis (Calculations)	0	0	1.2	1.2	12	12	0.6	0.6	$1,016	$1,016	*Sampling and analysis (calculations) hours include completion of the measurements and calculations, including entering mass of materials used in the process into equations Eq. AAA-1 to estimate CO2 emissions and use of emission factors in Eq. AAA-2 and AAA-3 to estimate N2O and CH4 emissions.
Reporting	0	0	1	1	4	4	1	1	$421	$421	*Reporting: Represents time required to enter the data into EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT), including set-up of account and first-time use of e-GGRT system).
Total	2	2	3.2	3.2	26	23	2.4	2.4	$2,523	$2,302

Total labor, 1 new facility:	2	2	3.2	3.2	26	23	2.4	2.4

Table WW-2. Capital and O&M Costs – Subpart WW – Coke Calciners
Activity	Cost Categories				Total Capital and O&M Cost per Year per Facility (2021$)
Activity	Capital Cost (2021$)	Equipment Lifetime	Annualized Capital Cost (2021$/year)	O&M Costs (2021$/year)	Initial Year	Subseq. Years
Equipment (selection, purchase, installation)	–		–	–	–	–
Performance testing	–		–	–	–	–
Recordkeeping	$0		$0	$62	$62	$62	*covers cost to store records, such as a flash drive, paper file or cloud storage
Travel	–		–	–	–	–
Sampling and Analysis Costs	$0		$0	$1,248	$1,248	$1,248	*Cost to collect and analyze samples to determine carbon content.
Total	$0		$0	$1,310	$1,310	$1,310

Total Capital and O&M, 1 new facility:					$1,310	$1,310

Total Costs of Proposed Revisions, 1 new facility:					$3,833	$3,612
Calculation Methodology: Total costs for 1 new facility = Labor Cost per facility + Capital and O&M Costs.

Labor Costs of Proposed Revisions				O&M Cost Per Year
# of Facilities	Initial Year	Subseq. Years		Initial Year	Subseq. Years
15	$37,847	$34,525		$19,649	$19,649
Calculation Methodology:
Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility

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Sheet 14: XX (New subpart)

Quantitative Burden and Costs for New Subparts (implemented during RY2025) (Section 2.2)											Assumptions:
											From the draft preamble: There is currently one producer of calcium carbide in the U.S., Carbide Industries, LLC, located in Louisville, KY. Carbide Industries LLC, currently reports their process greenhouse gas (GHG) emissions under the GHG Reporting Program (GHGRP; 40 CFR part 98), subpart K – Ferroalloy Production (GHGRP Facility ID 528303). Their reporting under subpart K is voluntary as the subpart does not cover the production of calcium carbide.
Table XX-1. Labor Costs – Subpart XX – Calcium Carbide Production											Subpart K requires that analysis of the C-content of 6 input and output materials in the mass balance equation; Subpart XX requires the analysis of 4 materials and does not require calculating CH4 emissions.
Activity	Labor Rates (per hour)								Total Labor Cost per Year per Facility		The existing carbide facility does not currently report under subpart C or K using CEMS. Based on this information, assume the same hour and O&M burden as for subpart K, Tables K-1 and K-2 of Appendix H to the 2019 ICR, except assume that hours for sampling and analysis (calculations) for subpart XX are 2/3 of what they are for subpart K (e.g., 8 hours of engineer/technician instead of 12 hours).
	Lawyer		Industrial Manager		Industrial Engineer/ Technician		Administrative Support		(2021$)		Assumed additional planning hours for the initial year.
	$114.80		$91.33		$73.83		$34.09
	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year	Subseq. Year
Planning	1	1	0.3	0.3	6	3	0.2	0.2	$592	$370	*Planning activities include familiarizing with the rule and hours for setup of compliance activities including sampling and QA/QC
QA/QC	1	1	0.2	0.2	2	2	0.1	0.1	$284	$284	*QA/QC activities include review of calculations, testing, and reports;
Recordkeeping	0	0	0.5	0.5	5	5	0.5	0.5	$432	$432	*Recordkeeping burden accounts for the time needed to create paper copies, backup to the cloud, or utilize another recordkeeping method
Sampling and Analysis (Calculations)	0	0	0.8	0.8	8	8	0.4	0.4	$677	$677	*Sampling and analysis (calculations) hours include completion of the measurements and calculations, including collecting carbon content and calculating CO2 emissions from each calcium carbide process unit
Reporting	0	0	1	1	10	10	1	1	$864	$864	*Reporting: Represents time required to enter the data into EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT), including set-up of account and first-time use of e-GGRT system).
Total	2	2	2.8	2.8	31	28	2.2	2.2	$2,849	$2,627

Total labor, 1 new facility:	2	2	2.8	2.8	31	28	2.2	2.2	$2,849	$2,627

Table XX-2a. Capital and O&M Costs – Subpart XX
Activity	Cost Categories				Total Capital and O&M Cost per Year per Facility (2021$)
Activity	Capital Cost (2021$)	Equipment Lifetime	Annualized Capital Cost (2021$/year)	O&M Costs (2021$/year)	Initial Year	Subseq. Years
Equipment (selection, purchase, installation)	–		–	–	–	–
Performance testing	–		–	–	–	–
Recordkeeping	$0		$0	$62	$62	$62	*covers cost to store records, such as a flash drive, paper file or cloud storage
Travel	–		–	–	–	–
Sampling and Analysis Costs	–		–	–	–	–
Total	$0		$0	$62	$62	$62

Total Capital and O&M, 1 new facility:					$62	$62

Total Costs of Proposed Revisions, 1 new facility:					$2,911	$2,690
Calculation Methodology: Total costs for 1 new facility = Labor Cost per facility + Capital and O&M Costs.

Labor Costs of Proposed Revisions				O&M Cost Per Year
# of Facilities	Initial Year	Subseq. Years		Initial Year	Subseq. Years
1	$2,849	$2,627		$62	$62
Calculation Methodology:
Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility

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Sheet 15: YY (New subpart)

Quantitative Burden and Costs for New Subparts (implemented during RY2025) (Section 2.2)

Assumptions:

Table YY-1. Labor Costs – Subpart YY - Caprolactam, Glyoxal, and Glyoxylic Acid Production

Activity

Labor Rates (per hour)

Total Labor Cost per Year per Facility

Assumed similar labor hours and O&M as for subpart V - Nitirc Acid Production for the Alternative Monitoring Method Option. These are both subparts dealing with sources of N2O that include the use of emission factors and accounting for abatement DRE.

Lawyer

Industrial Manager

Industrial Engineer/ Technician

Administrative Support

(2021$)

Assumed additional planning hours for the initial year.

$114.80

$91.33

$73.83

$34.09

Initial Year Hours

Subseq. Year Hours

Initial Year Hours

Subseq. Year Hours

Initial Year Hours

Subseq. Year Hours

Initial Year Hours

Subseq. Year Hours

Initial Year

Subseq. Year

Planning

0.3

3.3

0.2

$592

$393

*Planning activities include familiarizing with the rule and hours for setup of compliance activities including sampling and QA/QC

QA/QC

0.8

8.1

0.4

$685

*QA/QC hours related to maintaining the equipment used to comply with the alternative monitoring method option, along with review of all measurements and calculations used to determine emissions

Recordkeeping

0.5

$210

*Recordkeeping burden accounts for the time needed to create paper copies, backup to the cloud, or utilize another recordkeeping method

Sampling and Analysis (Calculations)

0.2

1.6

0.1

$140

*Sampling and analysis (calculations) hours include completion of the measurements and calculations, including estimating N2O base on the use of emission factors and accounting for abatement DRE.

Reporting

$421

*Reporting: Represents time required to enter the data into EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT), including set-up of account and first-time use of e-GGRT system).

Total

2.8

21.7

2.2

$2,048

$1,848

Total labor, 1 new facility:

2.8

21.7

2.2

$2,048

$1,848

Table YY-2. Capital and O&M Costs – Subpart YY - Caprolactam, Glyoxal, and Glyoxylic Acid Production

Activity

Cost Categories

Total Capital and O&M Cost per Year per Facility (2021$)

Capital Cost (2021$)

Equipment Lifetime

Annualized Capital Cost (2021$/year)

O&M Costs (2021$/year)

Initial Year

Subseq. Years

Equipment (selection, purchase, installation)

–

Performance testing

–

Recordkeeping

$62

*covers cost to store records, such as a flash drive, paper file or cloud storage

Travel

–

Sampling and Analysis Costs

–

Total

$62

Total Capital and O&M, 1 new facility:

$62

Total Costs of Proposed Revisions, 1 new facility:

$2,110

$1,911

Calculation Methodology: Total costs for 1 new facility = Labor Cost per facility + Capital and O&M Costs.

Labor Costs of Proposed Revisions

O&M Cost Per Year

# of Facilities

Initial Year

Subseq. Years

Initial Year

Subseq. Years

$12,285

$11,089

$374

There are approximately four to six facilities, which is the known universe of facilities that produce caprolactam, glyoxal, and glyoxylic acid in the United States.

Calculation Methodology:

Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility

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Sheet 16: ZZ (New Subpart)

Quantitative Burden and Costs for New Subparts (implemented during RY2025) (Section 2.2)											Assumptions:
Table ZZ-1. Labor Costs – Subpart ZZ - Ceramics Production											Because the emissions from ceramics occur from the calcination of the materials, the labor and O&M burden was assumed to be the same as for the non-CEMS option for lime manufacturing, which is also a calcination process. Subsequent year hours and O&M are from Tables S-1b and S-2 in Appendix H of the 2019 ICR. Assumed additional planning hours for the initial year.
Activity	Labor Rates (per hour)								Total Labor Cost per Year per Facility		Threshold analysis assumes 34 facilities would exceed the 25,000 mtCO2e threshold. Of the 16 facilities identified currently reporting under subpart C of Part 98, none appear to use CEMS. Additionally, other air quality regulations for ceramics manufacturers (NESHAP 5K and 6R) do not appear to require CEMS. Therefore, we assume most ceramics manufacturers would not have CEMs unless required by state or other regulation. However, we estimate that the recordkeeping and reporting burden from facilities using CEMS would be similar to costs for non-CEMS facilities; these sources would not have burden associated with planning, QA/QC, or sampling and analysis.
	Lawyer		Industrial Manager		Industrial Engineer/ Technician		Administrative Support		(2021$)
	$114.80		$91.33		$73.83		$34.09
	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year	Subseq. Year
Planning	1	1	0.4	0.4	6	4	0.2	0.2	$601	$453	*Planning activities include familiarizing with the rule and hours for setup of compliance activities including sampling and QA/QC
QA/QC	1	1	0.2	0.2	2	2	0.1	0.1	$284	$284	*QA/QC activities include review of calculations, testing, and reports;
Recordkeeping	0	0	0.5	0.5	5	5	0.5	0.5	$432	$432	*Recordkeeping burden accounts for the time needed to create paper copies, backup to the cloud, or utilize another recordkeeping method
Sampling and Analysis (Calculations)	0	0	0.1	0.1	1	1	0.1	0.1	$86	$86	*Sampling and analysis (calculations) hours include completion of the measurements and calculations. Calculations include inputting the amounts of carbonate-based mineral into the equations to calculate CO2 emissions.
Reporting	0	0	1	1	10	10	1	1	$864	$864	*Reporting: Represents time required to enter the data into EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT), including set-up of account and first-time use of e-GGRT system).
Total	2	2	2.2	2.2	24	22	1.9	1.9	$2,267	$2,119

Total labor, 1 new facility:	2	2	2.2	2.2	24	22	1.9	1.9	$2,267	$2,119

Table ZZ-2a. Capital and O&M Costs – Subpart ZZ
Activity	Cost Categories				Total Capital and O&M Cost per Year per Facility (2021$)
Activity	Capital Cost (2021$)	Equipment Lifetime	Annualized Capital Cost (2021$/year)	O&M Costs (2021$/year)	Initial Year	Subseq. Years
Equipment (selection, purchase, installation)	–		–	–	–	–
Performance testing	–		–	–	–	–
Recordkeeping	$0		$0	$62	$62	$62	*covers cost to store records, such as a flash drive, paper file or cloud storage
Travel	–		–	–	–	–
Sampling and Analysis Costs	–		–	–	–	–
Total	$0		$0	$62	$62	$62

Total Capital and O&M, 1 new facility:					$62	$62

Total Costs of Proposed Revisions, 1 new facility:					$2,330	$2,182
Calculation Methodology: Total costs for 1 new facility = Labor Cost per facility + Capital and O&M Costs.

Labor Costs of Proposed Revisions				O&M Cost Per Year
# of Facilities	Initial Year	Subseq. Years		Initial Year	Subseq. Years
34	$77,083	$72,062		$2,121	$2,121
Calculation Methodology:
Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility

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Sheet 17: 2.3 Other Applicability

Burden for Subparts in Section 2.3 of Impacts Assessment
Subpart P (Applicability)	Total Costs Section 2.3
Subpart Y (Applicability)			Initial Year	Subsequent Years
		Total Labor costs:	($3,072)	($3,072)
Back to Table of Contents		Total Non-Labor costs:	($1,689)	$551
		Total Section 2.3:	($4,761)	($2,521)

Sheet 18: Subpart P (Applicability)

Quantitative Burden and Costs for Revisions to Applicability (implemented during RY2025) (Section 2.3)
Applicability is affected by rule changes that increase the number of hydrogen plants reporting.
Table P-1. Labor Costs – Subpart P - Hydrogen Production - Mass Balance Option; Natural Gas and Liquid/Solid Fuels (from Table P-1e of Appendix H to the 2019 ICR)
Activity	Labor Rates (per hour)								Total Labor Cost per Year per Facility
	Lawyer		Industrial Manager		Industrial Engineer/ Technician		Administrative Support		(2021$)		Assumptions:
	$114.80		$91.33		$73.83		$34.09
	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year	Subseq. Year
Planning	0	0	0.4	0.4	4	4	0.4	0.4	$345	$345	*reading the rule to become familiar with any changes to the rule requirements, asking questions about applicability, reviewing any overlap in existing reporting programs
QA/QC	0	0	0.2	0.2	2	2	0.2	0.2	$173	$173	*QA/QC activities include review of calculations, testing, and reports;
Recordkeeping	0	0	0.5	0.5	5	5	0.5	0.5	$432	$432	*Recordkeeping burden accounts for the time needed to create paper copies, backup to the cloud, or utilize another recordkeeping method
Sampling and Analysis (Calculations)	0	0	0.1	0.1	1	1	0.1	0.1	$86	$86	*Sampling and analysis to determine the molecular weight and carbon content of the natural gas is performed annually
Reporting	0	0	1	1	10	10	1	1	$864	$864	*Represents time required to enter the data into EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT) (for new facilities, set-up of account and first-time use of e-GGRT system).
Total	0	0	2.2	2.2	22	22	2.2	2.2	$1,900	$1,900
												Adjusted hours from Package 1:	$16.36
Total labor, 1 new facility:	0	0	2.2	2.2	22	22	2.2	2.2	$1,900	$1,900

Table P-2. Capital and O&M Costs – Subpart P - Hydrogen Production – Mass Balance Option; Natural Gas and Liquid/Solid Fuels (from Table P-2e in Appendix H to the 2019 ICR)
Activity	Cost Categories				Total Capital and O&M Cost per Year per Facility (2021$)
Activity	Capital Cost (2021$)	Equipment Lifetime	Annualized Capital Cost (2021$/year)	O&M Costs (2021$/year)	Initial Year	Subseq. Years
Equipment (selection, purchase, installation)	–		–	–	–	–
Performance testing	–		–	–	–	–
Recordkeeping				$62	$62	$62	*covers cost to store records, such as a flash drive, paper file or cloud storage
Travel	–		–	–	–	–
Sampling and Analysis Costs	–		–	$2,178	$2,178	$2,178	*For sampling and analysis of carbon content of natural gas
Total	$0	$0	$0	$2,241	$2,241	$2,241

Total Capital and O&M, 1 new facility:					$2,241	$2,241

Total Costs of Proposed Revisions, 1 new facility:					$4,141	$4,141
Cost of Proposed Revisions from Package 1 (per facility):					$16	$16
Calculation Methodology: Total costs for 1 new facility = Labor Cost per facility + Capital and O&M Costs.

Labor Costs of Proposed Revisions				O&M Cost Per Year
# of Facilities	Initial Year	Subseq. Years		Initial Year	Subseq. Years
2	$3,833	$3,833		$2,241	$4,481
Calculation Methodology:
Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility + Cost of Proposed Revision from Package 1 (Adjusted to $2021)

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Sheet 19: Subpart Y (Applicability)

Quantitative Burden and Costs for Revisions to Applicability (implemented during RY2025) (Section 2.3)
Applicability is affected by rule changes that shift certain operations to a new subpart for coke calciners.
Table Y-1. Labor Costs – Subpart Y - Petroleum Refineries
Activity	Labor Rates (per hour)								Total Labor Cost per Year per Facility
	Lawyer		Industrial Manager		Industrial Engineer/ Technician		Administrative Support		(2021$)		Assumptions:
	$114.80		$91.33		$73.83		$34.09				Subpart Y uses model plants to estimate costs that assume a variety of refinery emission units and a set amount of units for each model. For these reasons, these estimates instead assume a reduced number of labor hours that apply only for coke calcining units. Estimates are based on similar labor hours and O&M costs as used for subpart Q - Iron and Steel Production (carbon mass balance option with sampling, see Table Q-1a(1) in Appendix H) - because both rules rely on a carbon mass balance approach with carbon content sampling.
	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year	Subseq. Year
Planning	1	1	0.3	0.3	3	3	0.2	0.2	$370	$370	*reading the rule to become familiar with any changes to the rule requirements, asking questions about applicability, reviewing any overlap in existing reporting programs
QA/QC	1	1	0.2	0.2	2	2	0.1	0.1	$284	$284	*QA/QC activities include review of calculations, testing, and reports;
Recordkeeping	0	0	0.5	0.5	2	2	0.5	0.5	$210	$210	*Recordkeeping burden accounts for the time needed to create paper copies, backup to the cloud, or utilize another recordkeeping method
Sampling and Analysis (Calculations)	0	0	1.2	1.2	12	12	0.6	0.6	$1,016	$1,016	*Sampling and analysis to determine the carbon content of input materials is performed monthly.
Reporting	0	0	1	1	4	4	1	1	$421	$421	*Represents time required to enter the data into EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT) (for new facilities, set-up of account and first-time use of e-GGRT system).
Total	2	2	3.2	3.2	23	23	2.4	2.4	$2,302	$2,302

Total labor, 1 new facility:	2	2	3.2	3.2	23	23	2.4	2.4	$2,302	$2,302

Table Y-2. Capital and O&M Costs – Subpart Y – All facilities (from Appendix H to the 2019 ICR)
Activity	Cost Categories				Total Capital and O&M Cost per Year per Facility (2021$)
Activity	Capital Cost (2021$)	Equipment Lifetime	Annualized Capital Cost (2021$/year)	O&M Costs (2021$/year)	Initial Year	Subseq. Years
Equipment (selection, purchase, installation)	–		–	–	–	–
Performance testing	–		–	–	–	–
Recordkeeping	$0		$0	$62	$62	$62	*covers cost to store records, such as a flash drive, paper file or cloud storage
Travel	–		–	–	–	–
Sampling and Analysis Costs	–		–	$1,248	$1,248	$1,248	*Cost to collect and analyze samples to determine carbon content.
Total	$0	$0	$0	$1,310	$1,310	$1,310

Total Capital and O&M, 1 new facility:					$1,310	$1,310

Total Costs of Proposed Revisions, 1 new facility:					$3,612	$3,612
Calculation Methodology: Total costs for 1 new facility = Labor Cost per facility + Capital and O&M Costs.

Labor Costs of Proposed Revisions				O&M Cost Per Year
# of Facilities	Initial Year	Subseq. Years		Initial Year	Subseq. Years
-3	($6,905)	($6,905)		($3,930)	($3,930)		Table Y-1 in Appendix H to the 2019 ICR indicates 4 facilities in the model plant for "Large Upgrading Refinery with Coke Calcining." Based on RY2021 data, this now appears to be 3 facilities. Assumed these would all move to subpart AAA.
Calculation Methodology:
Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility

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Sheet 20: 2.4 Monitoring and Calculations

Burden for Subparts in Section 2.4 of Impacts Assessment
Subpart AA (Calculations)	Total Costs Section 2.4
Subpart HH (Calculations)			Initial Year	Subsequent Years
		Total Labor costs:	$31,066	$31,066
Back to Table of Contents		Total Non-Labor costs:	$0	$0
		Total Section 2.4:	$31,066	$31,066

Sheet 21: Subpart AA (Calculations)

Quantitative Burden and Costs for Revisions to the Calculation Methodology for Subpart AA (section 2.4)

Labor Costs – Subpart AA
Activity	Labor Rates (per hour)								Total Labor Cost per Year per Facility (2021$)		Initial and subsequent year hours are based on required activities unique to the Tier 1 methodology from Appendix F to the 2019 ICR, specifically, the time to perform engineering calculations to total CO2, CH4, and N2O emissions .
	Lawyer		Industrial Manager		Industrial Engineer/ Technician		Administrative Support
	$114.80		$91.33		$73.83		$34.09
	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year	Subseq. Year
Planning	0	0	0	0	0	0	0	0	$-	$-	Additional sampling and analysis labor costs specific to each tier approach are detailed in Appendix F-1 through F-9 of the 2019 ICR. These costs are incurred only by the facilities that report using the specified tier.
QA/QC	0	0	0	0	0	0	0	0	$-	$-
Recordkeeping	0	0	0	0	0	0	0	0	$-	$-
Sampling and Analysis (Calculations)	0	0	0	0	1.3	1.3	0	0	$96	$96
Reporting	0	0	0	0	0	0	0	0	$-	$-
Total	0	0	0	0	1.3	1.3	0	0	$96	$96
Based on annual average hours per respondent for Tier 1, time to perform engineering calculation to determine CO2 emissions (0.4 hours) using Eq C-1, C-1a, or C-1b of subpart C, and CH4 and N2O emissions (0.9 hours) using Eq C-8, Eq C-8a, or Eq C-8b of subpart C using default high heat values and/or default emission factors. From Appendix F, Table F-1, of the 2019 ICR.

Labor Costs of Proposed Revisions
# of Facilities	Initial Year	Subseq. Years			Revise 40 CFR 98.273 to include methodologies to calculate CH4, N2O and biogenic CO2 emissions from the combustion of biomass fuels other than spent liquor solids, as well as the combustion of biomass other than spent liquor solids with other fuels, according to the applicable methodology from the provisions for stationary combustion sources found at 40 CFR 98.33(a), 40 CFR 98.33(c), and 40 CFR 98.33(e).
1	$96	$96
Calculation Methodology:					107 facilities are expected to report under subpart AA, based on the 2019 ICR.
Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility					EPA estimates that just one (1) facility combusts biomass (other than spent liquor solids) with other fuels.

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Sheet 22: Subpart HH (Calculations)

Quantitative Burden and Costs for Revisions to the Calculation Methodology for Subpart HH (section 2.4)

Labor Costs – Subpart HH - Facilities with Gas Collection Systems
Activity	Labor Rates (per hour)								Total Labor Cost per Year per Facility (2021$)		Initial and subsequent year hours are based on required activities for landfills with gas collection systems that conduct surface monitoring measurements under 40 CFR Part 60 or Part 62 rules or use lower default CEs, specifically, the additional time to conduct engineering calculations incorporating the count and surface measurement methane concentrations that exceed 500 parts per million above background in the reporting year. There is no burden associated with surface measurement monitoring as landfills will use data previously collected for the Part 60 and Part 62 rules, or, if not subject to Part 60 and Part 62 rules, may use default CEs.
	Lawyer		Industrial Manager		Industrial Engineer/ Technician		Administrative Support
	$114.80		$91.33		$73.83		$34.09
	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year Hours	Subseq. Year Hours	Initial Year	Subseq. Year
Planning	0	0	0	0	0	0	0	0	$-	$-
QA/QC	0	0	0	0	0	0	0	0	$-	$-
Recordkeeping	0	0	0	0	0	0	0	0	$-	$-
Sampling and Analysis (Calculations)	0	0	0	0	0.5	0.5	0	0	$37	$37
Reporting	0	0	0	0	0	0	0	0	$-	$-
Total	0	0	0	0	0.5	0.5	0	0	$37	$37


Labor Costs of Proposed Revisions
# of Facilities	Initial Year	Subseq. Years			Revise Equations HH-6, HH-7, and HH-8 to add a term to adjust the estimated methane emissions based on methane surface monitoring measurements or lower default CEs.
839	$30,970	$30,970
Calculation Methodology:					Based on crosswalk of GHGRP/NSPS reporters, 833 reporters have GCS. Of these, 70% of GHGRP landfills (792 reporters) are likely subject to NSPS, EG, or FP. It is assumed that the 6 new facilities under subpart HH would review the new calculations, however, these facilities are not likely subject to the NSPS, EG, or FP since the majority of those facilities (91%) already report to the GHGRP.
Labor Costs of Proposed Revisions = Number of Facilities x Total Labor Cost per Year per Facility

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Sheet 23: 2.5 Recordkeeping and Reporting

Burden for Subparts in Section 2.5 of Impacts Assessment

Reporting Cost Summary

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Sheet 24: Reporting Cost Summary

Quantitative Burden and Costs for New, Revised, and Deleted Data Elements - Existing Subparts (Section 2.5)

	Total Costs Section 2.5
	Subpart	# Reporters Affected	Incremental Annual Average Costs (2021$)	Annual Avg Cost/ Reporter

	A	7,840	$64,133	$8
	C	346	$9,906	$29
	F	7	$57	$8
	G	29	$119	$4
	N	100	$1,227	$12
	P	116	$3,346	$29
	Y	6	$25	$4
	AA	1	$8	$8
	HH	1,126	$67,757	$60
	OO	104	$1,088	$10
	PP	11	$135	$12
	QQ	33	$384	$12

	TotaI Industry Costs and Avg. Cost/Reporter		$148,185	$16


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Sheet 25: A (Data Elements)

Quantitative Burden and Costs for New, Revised, and Deleted Data Elements (implemented during RY2025) (Section 2.5)

Item	Subpart A Data Element Revisions
Item	Total	A (2)
Number of Reporters Affected (1, 2)	7,840	7,840
# of New Data Elements	2	2
# of Revised Data Elements	0	0
# of Removed Data Elements	0	0
Sum of Data Element Changes	2	2
Technical Respondent Hours Per Occurrence		0.05
Respondent Hours
Technical	0.10	0.10
Clerical	0.01	0.01
Managerial	0.01	0.01
Total	0.12	0.12
Reporter Costs
Technical	$7	$7
Clerical	$0	$0
Managerial	$0	$0
Total	$8	$8
Total Industry Costs and Avg. Cost/Reporter
Total	$64,133	$64,133
	$8	$/reporter
Notes:
Calculation Methodology: Total Technical Respondent Hours = Sum of Data Element Changes (Number of New + Revised - No. of Removed Data Elements) x Technical Respondent Hours per Occurance. Clerical and managerial hours are estimated as 10% and 5% of technical hours, respectively. Total Reporter Costs = (Technical Respondent Hours x $71.45/hr) + (Managerial Respondent Hours x $87.45/hr) + (Clerical Respondent Hours x $36.28/hr) Total Industry Costs = Number of Reporters Affected x Total Reporter Costs Average Cost Per Reporter = Total Industry Costs / Total Number of Reporters Affected
(1) Based on the total number of existing reporters affected, based on RY2021 data and estimated during RY2025, unless otherwise noted. Additional details may be found in Appendix A of the Impacts Memo.
(2) Per RY2021 data, 7,587 direct emitters would be required to report new data elements for electricity and thermal energy consumption at 40 CFR 98.3(c)(4)(iv), in addition to 80 new reporters from subparts W, HH, II, OO, TT and 53 new reporters from proposed subparts WW, XX, YY, and ZZ. The proposed data element requires totaling annual purchases from each meter on each electric bill, which are reported under proposed 40 CFR 98.26(k). This document assumes that the data may generally be obtained from existing company records or are readily available, and the labor is based on the time to enter the totalled purchase quantities into e-GGRT.

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Sheet 26: C (Data Elements)

Quantitative Burden and Costs for New, Revised, and Deleted Data Elements (implemented during RY2025) (Section 2.5)

Item	Subpart C Data Element Revisions
Item	Total	C (2)
Number of Reporters Affected (1, 2)	346	346
# of New Data Elements	7	7
# of Revised Data Elements	0	0
# of Removed Data Elements	0	0
Sum of Data Element Changes	7	7
Technical Respondent Hours Per Occurrence		0.05
Respondent Hours
Technical	0.35	0.35
Clerical	0.04	0.04
Managerial	0.02	0.02
Total	0.40	0.40
Reporter Costs
Technical	$26	$26
Clerical	$1	$1
Managerial	$2	$2
Total	$29	$29
Total Industry Costs and Avg. Cost/Reporter
Total	$9,906	$9,906
	$29	$/reporter
Notes:
Calculation Methodology: Total Technical Respondent Hours = Sum of Data Element Changes (Number of New + Revised - No. of Removed Data Elements) x Technical Respondent Hours per Occurance. Clerical and managerial hours are estimated as 10% and 5% of technical hours, respectively. Total Reporter Costs = (Technical Respondent Hours x $71.45/hr) + (Managerial Respondent Hours x $87.45/hr) + (Clerical Respondent Hours x $36.28/hr) Total Industry Costs = Number of Reporters Affected x Total Reporter Costs Average Cost Per Reporter = Total Industry Costs / Total Number of Reporters Affected
(1) Based on the total number of existing reporters affected, based on RY2021 data and estimated during RY2025, unless otherwise noted. Additional details may be found in Appendix A of the Impacts Memo.
(2) It is estimated that 346 respondents reporting under subpart C may have at least 1 potential EGU. The proposed requirements would require a facility to report for either the individual unit, aggregation of units, common stack, or common pipe configuration an indicator of whether the unit is an EGU. If the reporter is using the reporting alternatives of aggregation of units, common stack, or common pipe configuration, the facility must also report an estimate of the group’s total reported emissions attributable to electricity generation for each reporting alternative. The number of facilities estimated is based on a crosswalk between GHGRP facility IDs and ORIS codes for facilities not in the GHGRP Power Sector that submitted reports in RY2020. See: https://www.epa.gov/system/files/documents/2022-04/ghgrp_oris_power_plant_crosswalk_12_13_21.xlsx (accessed September 29, 2022). Additional facilities with small EGUs that are less than 1 MW electric output or that are not subject to reporting would also be required to report, however, we lack information to definitively quantify the number of facilities with these units that would be required to report these additional data elements. However, the provided estimate is a conversative estimate as reporters would only enter two data elements to identify the affected EGU Unit and the fraction of reported emissions attributable to electricity generation for the reported configuration.

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Sheet 27: F (Data Elements)

Quantitative Burden and Costs for New, Revised, and Deleted Data Elements (implemented during RY2025) (Section 2.5)

Item	Subpart F Data Element Revisions
Item	Total	F (2)
Number of Reporters Affected (1, 2)	7	7
# of New Data Elements	2	2
# of Revised Data Elements	0	0
# of Removed Data Elements	0	0
Sum of Data Element Changes	2	2
Technical Respondent Hours Per Occurrence		0.05
Respondent Hours
Technical	0.10	0.10
Clerical	0.01	0.01
Managerial	0.01	0.01
Total	0.12	0.12
Reporter Costs
Technical	$7	$7
Clerical	$0	$0
Managerial	$0	$0
Total	$8	$8
Total Industry Costs and Avg. Cost/Reporter
Total	$57	$57
	$8	$/reporter
Notes:
Calculation Methodology: Total Technical Respondent Hours = Sum of Data Element Changes (Number of New + Revised - No. of Removed Data Elements) x Technical Respondent Hours per Occurance. Clerical and managerial hours are estimated as 10% and 5% of technical hours, respectively. Total Reporter Costs = (Technical Respondent Hours x $71.45/hr) + (Managerial Respondent Hours x $87.45/hr) + (Clerical Respondent Hours x $36.28/hr) Total Industry Costs = Number of Reporters Affected x Total Reporter Costs Average Cost Per Reporter = Total Industry Costs / Total Number of Reporters Affected
(1) Based on the total number of existing reporters affected within each segment, based on RY2021 data and estimated during RY2025, unless otherwise noted. Additional details may be found in Appendix A of the Impacts Memo.
(2) Per RY2021 data, 7 respondents report to subpart F who would be required to report new data elements at 40 CFR 98.66(a) for production capacity (tons) and at 40 CFR 98.66(g) for annual operating days per potline.

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Sheet 28: G (Data Elements)

Quantitative Burden and Costs for New, Revised, and Deleted Data Elements (implemented during RY2025) (Section 2.5)

Item	Subpart G Data Element Revisions
Item	Total	G (2)
Number of Reporters Affected (1, 2)	29	29
# of New Data Elements	1	1
# of Revised Data Elements	0	0
# of Removed Data Elements	0	0
Sum of Data Element Changes	1	1
Technical Respondent Hours Per Occurrence		0.05
Respondent Hours
Technical	0.05	0.05
Clerical	0.01	0.01
Managerial	0.00	0.00
Total	0.06	0.06
Reporter Costs
Technical	$4	$4
Clerical	$0	$0
Managerial	$0	$0
Total	$4	$4
Total Industry Costs and Avg. Cost/Reporter
Total	$119	$119
	$4	$/reporter
Notes:
Calculation Methodology: Total Technical Respondent Hours = Sum of Data Element Changes (Number of New + Revised - No. of Removed Data Elements) x Technical Respondent Hours per Occurance. Clerical and managerial hours are estimated as 10% and 5% of technical hours, respectively. Total Reporter Costs = (Technical Respondent Hours x $71.45/hr) + (Managerial Respondent Hours x $87.45/hr) + (Clerical Respondent Hours x $36.28/hr) Total Industry Costs = Number of Reporters Affected x Total Reporter Costs Average Cost Per Reporter = Total Industry Costs / Total Number of Reporters Affected
(1) Based on the total number of existing reporters affected within each segment, based on RY2021 data and estimated during RY2025, unless otherwise noted. Additional details may be found in Appendix A of the Impacts Memo.
(2) Per RY2021 data, 29 respondents reporting to subpart G who do not use CEMs to measure emissions would be required to report new data element 40 CFR 98.76(b)(16), annual quantity of excess hydrogen produced that is not consumed through the production of ammonia (metric tons).

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Sheet 29: N (Data Elements)

Quantitative Burden and Costs for New, Revised, and Deleted Data Elements (implemented during RY2025) (Section 2.5)

Item	Subpart N Data Element Revisions
Item	Total	N (2)
Number of Reporters Affected (1, 2)	100	100
# of New Data Elements	2	2
# of Revised Data Elements	1	1
# of Removed Data Elements	0	0
Sum of Data Element Changes	3	3
Technical Respondent Hours Per Occurrence		0.05
Respondent Hours
Technical	0.15	0.15
Clerical	0.02	0.02
Managerial	0.01	0.01
Total	0.17	0.17
Reporter Costs
Technical	$11	$11
Clerical	$1	$1
Managerial	$1	$1
Total	$12	$12
Total Industry Costs and Avg. Cost/Reporter
Total	$1,227	$1,227
	$12	$/reporter
Notes:
Calculation Methodology: Total Technical Respondent Hours = Sum of Data Element Changes (Number of New + Revised - No. of Removed Data Elements) x Technical Respondent Hours per Occurance. Clerical and managerial hours are estimated as 10% and 5% of technical hours, respectively. Total Reporter Costs = (Technical Respondent Hours x $71.45/hr) + (Managerial Respondent Hours x $87.45/hr) + (Clerical Respondent Hours x $36.28/hr) Total Industry Costs = Number of Reporters Affected x Total Reporter Costs Average Cost Per Reporter = Total Industry Costs / Total Number of Reporters Affected
(1) Based on the total number of existing reporters affected within each segment, based on RY2021 data and estimated during RY2025, unless otherwise noted. Additional details may be found in Appendix A of the Impacts Memo.
(2) Per RY2021 data, 100 respondents reporting to subpart N would be required to report two new data elements under 40 CFR 98.146(a)(3) (CEMS facilities) or 98.146(b)(5) (non-CEMS facilities) to report the annual quantity (tons) of recycled scrap glass (cullet) charged to each glass melting furnace and for all furnaces combined, and one revised data element under 40 CFR 98.146(b)(9) to report the number of times in the reporting year that missing data procedures are used to measure monthly quantities of recycled scrap glass (cullet).

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Sheet 30: P (Data Elements)

Quantitative Burden and Costs for New, Revised, and Deleted Data Elements (implemented during RY2025) (Section 2.5)

Item	Subpart P Data Element Revisions
Item	Total	P (1, 2)	P (3)
Number of Reporters Affected	116	116	3
# of New Data Elements	7	5	2
# of Revised Data Elements	2	2	0
# of Removed Data Elements	0	0	0
Sum of Data Element Changes	9	7	2
Technical Respondent Hours Per Occurrence		0.05	0.05
Respondent Hours
Technical	0.45	0.35	0.10
Clerical	0.05	0.04	0.01
Managerial	0.02	0.02	0.01
Total	0.52	0.40	0.12
Reporter Costs
Technical	$33	$26	$7
Clerical	$2	$1	$0
Managerial	$2	$2	$0
Total	$37	$29	$8
Total Industry Costs and Avg. Cost/Reporter
Total	$3,346	$3,321	$25
	$29	$/reporter	$/reporter
Notes:
Calculation Methodology: Total Technical Respondent Hours = Sum of Data Element Changes (Number of New + Revised - No. of Removed Data Elements) x Technical Respondent Hours per Occurance. Clerical and managerial hours are estimated as 10% and 5% of technical hours, respectively. Total Reporter Costs = (Technical Respondent Hours x $71.45/hr) + (Managerial Respondent Hours x $87.45/hr) + (Clerical Respondent Hours x $36.28/hr) Total Industry Costs = Number of Reporters Affected x Total Reporter Costs Average Cost Per Reporter = Total Industry Costs / Total Number of Reporters Affected
(1) Based on the total number of existing reporters affected within each segment, based on RY2021 data and estimated during RY2025, unless otherwise noted. Additional details may be found in Appendix A of the Impacts Memo.
(2) Per RY2021 data, 114 existing respondents reporting to subpart P, plus two new reporters, would be required to report five new data elements at 40 CFR 98.166(b)(1), (b)(2), (b)(3)(ii) and (b)(9), and two revised data elements at 40 CFR 98.166(b)(6)-(7).
(3) Per RY2021 data, 3 respondents reporting to subpart P who use CEMS to measure emissions would be required to report two new data elements at 40 CFR 98.166(b)(2)(i-ii).

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Sheet 31: Y (Data Elements)

Quantitative Burden and Costs for New, Revised, and Deleted Data Elements (implemented during RY2025) (Section 2.5)

Item	Subpart Y Data Element Revisions
Item	Total	Y(2)
Number of Reporters Affected (1)	6	6
# of New Data Elements	1	1
# of Revised Data Elements	0	0
# of Removed Data Elements	0	0
Sum of Data Element Changes	1	1
Technical Respondent Hours Per Occurrence		0.05
Respondent Hours
Technical	0.05	0.05
Clerical	0.01	0.01
Managerial	0.00	0.00
Total	0.06	0.06
Reporter Costs
Technical	$4	$4
Clerical	$0	$0
Managerial	$0	$0
Total	$4	$4
Total Industry Costs and Avg. Cost/Reporter
Total	$25	$25
	$4	$/reporter
Notes:
Calculation Methodology: Total Technical Respondent Hours = Sum of Data Element Changes (Number of New + Revised - No. of Removed Data Elements) x Technical Respondent Hours per Occurance. Clerical and managerial hours are estimated as 10% and 5% of technical hours, respectively. Total Reporter Costs = (Technical Respondent Hours x $71.45/hr) + (Managerial Respondent Hours x $87.45/hr) + (Clerical Respondent Hours x $36.28/hr) Total Industry Costs = Number of Reporters Affected x Total Reporter Costs Average Cost Per Reporter = Total Industry Costs / Total Number of Reporters Affected
(1) Based on the total number of existing reporters affected within each segment, based on RY2021 data and estimated during RY2025, unless otherwise noted. Additional details may be found in Appendix A of the Impacts Memo.
(2) Per RY2021 data, 6 respondents reporting to subpart Y with asphalt blowing units would be required to report one new data element at 40 CFR 98.256(j)(2).

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Sheet 32: AA (Data Elements)

Quantitative Burden and Costs for New, Revised, and Deleted Data Elements (implemented during RY2025) (Section 2.5)

Item	Subpart AA Data Element Revisions
Item	Total	AA (2)
Number of Reporters Affected (1)	1	1
# of New Data Elements	2	2
# of Revised Data Elements	0	0
# of Removed Data Elements	0	0
Sum of Data Element Changes	2	2
Technical Respondent Hours Per Occurrence		0.05
Respondent Hours
Technical	0.10	0.10
Clerical	0.01	0.01
Managerial	0.01	0.01
Total	0.12	0.12
Reporter Costs
Technical	$7	$7
Clerical	$0	$0
Managerial	$0	$0
Total	$8	$8
Total Industry Costs and Avg. Cost/Reporter
Total	$8	$8
	$8	$/reporter
Notes:
Calculation Methodology: Total Technical Respondent Hours = Sum of Data Element Changes (Number of New + Revised - No. of Removed Data Elements) x Technical Respondent Hours per Occurance. Clerical and managerial hours are estimated as 10% and 5% of technical hours, respectively. Total Reporter Costs = (Technical Respondent Hours x $71.45/hr) + (Managerial Respondent Hours x $87.45/hr) + (Clerical Respondent Hours x $36.28/hr) Total Industry Costs = Number of Reporters Affected x Total Reporter Costs Average Cost Per Reporter = Total Industry Costs / Total Number of Reporters Affected
(1) Based on the total number of existing reporters affected within each segment, based on RY2021 data and estimated during RY2025, unless otherwise noted. Additional details may be found in Appendix A of the Impacts Memo.
(2) EPA identified 1 respondent reporting to subpart AA that combusts biomass (other than spent liquor solids) with other fuels would be required to report annual biogenic CO2 emissions under subpart C.
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Sheet 33: HH (Data Elements)

Quantitative Burden and Costs for New, Revised, and Deleted Data Elements (implemented during RY2025) (Section 2.5)

Item	Subpart HH Data Element Revisions
Item	Total	HH (2)	HH (3)	HH (4)	HH(5)
Number of Reporters Affected (1)	1,126	839	814	792	1,126
# of New Data Elements	17	4	4	8	1
# of Revised Data Elements	3	2	1	0	0
# of Removed Data Elements	0	0	0	0	0
Sum of Data Element Changes	20	6	5	8	1
Technical Respondent Hours Per Occurrence		0.05	0.05	0.05	0.05
Respondent Hours
Technical	1.00	0.30	0.25	0.40	0.05
Clerical	0.10	0.03	0.03	0.04	0.01
Managerial	0.05	0.02	0.01	0.02	0.00
Total	1.15	0.35	0.29	0.46	0.06
Reporter Costs
Technical	$74	$22	$18	$30	$4
Clerical	$3	$1	$1	$1	$0
Managerial	$5	$1	$1	$2	$0
Total	$82	$25	$20	$33	$4
Total Industry Costs and Avg. Cost/Reporter
Total	$67,757	$20,590	$16,647	$25,915	$4,605
	$60	$/reporter
Notes:
Calculation Methodology: Total Technical Respondent Hours = Sum of Data Element Changes (Number of New + Revised - No. of Removed Data Elements) x Technical Respondent Hours per Occurance. Clerical and managerial hours are estimated as 10% and 5% of technical hours, respectively. Total Reporter Costs = (Technical Respondent Hours x $71.45/hr) + (Managerial Respondent Hours x $87.45/hr) + (Clerical Respondent Hours x $36.28/hr) Total Industry Costs = Number of Reporters Affected x Total Reporter Costs Average Cost Per Reporter = Total Industry Costs / Total Number of Reporters Affected
(1) Based on the total number of existing reporters affected within each segment, based on RY2021 data and estimated during RY2025, unless otherwise noted. Additional details may be found in Appendix A of the Impacts Memo.
Tracy Curtis: 98.346(j)(5),(j)(6)(i), (j)(6)(iii), (j)(6)(iv), (j)(6)(v)(A), 98.346(j)(6)(v)(C), (2) Per RY2021 data, 833 facilities reporting to subpart HH report information for gas collection systems, and 6 new facilities are anticipated to have GCS. These facilities would be required to report 4 new data elements and 2 revised data elements under 98.346(j)(5) and (6).
Tracy Curtis: ,(j)(6)(v)(D)(1), (j)(6)(v)(D)(2), (j)(6)(v)(D)(4), (j)(6)(v)(D)(5),(j)(6)(v)(D)(6) (3) Per RY2021 data, 814 facilities reporting to subpart HH report information for gas collection systems with destruction devices. These facilities would be required to report 4 new data elements and 1 revised data element under proposed 98.346(j)(6)(v)(D).
Tracy Curtis: 98.346(h), 98.346(j)(7)(iv) and (v) (4) Per RY2021 data, 792 facilities reporting to subpart HH also meet the design criteria for landfills subject to 40 CFR part 60 landfill NSPS, EG, or FP rules. These facilities would be required to report 8 new data elements under proposed 98.346(h) and (j)(7) related to surface methane measurements collected under the 40 CFR part 60 landfill NSPS, EG, or FP rules.
(5) Per RY2021 data, facilities reporting to subpart HH report 1 new data element under 98.346(h).

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Sheet 34: OO (Data Elements)

Quantitative Burden and Costs for New, Revised, and Deleted Data Elements (implemented during RY2025) (Section 2.5)

Item	Subpart OO Data Element Revisions
Item	Total	OO (2)	OO (3)
Number of Reporters Affected (1)	104	58	104
# of New Data Elements	3	1	2
# of Revised Data Elements	0	0	0
# of Removed Data Elements	0	0	0
Sum of Data Element Changes	3	1	2
Technical Respondent Hours Per Occurrence		0.05	0.05
Respondent Hours
Technical	0.15	0.05	0.10
Clerical	0.02	0.01	0.01
Managerial	0.01	0.00	0.01
Total	0.17	0.06	0.12
Reporter Costs
Technical	$11	$4	$7
Clerical	$1	$0	$0
Managerial	$1	$0	$0
Total	$12	$4	$8
Total Industry Costs and Avg. Cost/Reporter
Total	$1,088	$237	$851
	$10	$/reporter	$/reporter
Notes:
Calculation Methodology: Total Technical Respondent Hours = Sum of Data Element Changes (Number of New + Revised - No. of Removed Data Elements) x Technical Respondent Hours per Occurance. Clerical and managerial hours are estimated as 10% and 5% of technical hours, respectively. Total Reporter Costs = (Technical Respondent Hours x $71.45/hr) + (Managerial Respondent Hours x $87.45/hr) + (Clerical Respondent Hours x $36.28/hr) Total Industry Costs = Number of Reporters Affected x Total Reporter Costs Average Cost Per Reporter = Total Industry Costs / Total Number of Reporters Affected
(1) Based on the total number of existing reporters affected within each segment, based on RY2021 data and estimated during RY2025, unless otherwise noted. Additional details may be found in Appendix A of the Impacts Memo.
(2) Per RY2021 data, 58 respondents reporting to subpart OO are bulk importers who would be required to report new data element 40 CFR 98.416(b)(11).
(3) Per RY2021 data, 103 respondents reporting to subpart OO are suppliers of F-HTFs who would be required to report new data elements at 40 CFR 98.416(k), and one new reporter.

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Sheet 35: PP (Data Elements)

Quantitative Burden and Costs for New, Revised, and Deleted Data Elements (implemented during RY2025) (Section 2.5)

Item	Subpart PP Data Element Revisions
Item	Total	OO (2)
Number of Reporters Affected (1)	11	11
# of New Data Elements	0	0
# of Revised Data Elements	3	3
# of Removed Data Elements	0	0
Sum of Data Element Changes	3	3
Technical Respondent Hours Per Occurrence		0.05
Respondent Hours
Technical	0.15	0.15
Clerical	0.02	0.02
Managerial	0.01	0.01
Total	0.17	0.17
Reporter Costs
Technical	$11	$11
Clerical	$1	$1
Managerial	$1	$1
Total	$12	$12
Total Industry Costs and Avg. Cost/Reporter
Total	$135	$135
	$12	$/reporter
Notes:
Calculation Methodology: Total Technical Respondent Hours = Sum of Data Element Changes (Number of New + Revised - No. of Removed Data Elements) x Technical Respondent Hours per Occurance. Clerical and managerial hours are estimated as 10% and 5% of technical hours, respectively. Total Reporter Costs = (Technical Respondent Hours x $71.45/hr) + (Managerial Respondent Hours x $87.45/hr) + (Clerical Respondent Hours x $36.28/hr) Total Industry Costs = Number of Reporters Affected x Total Reporter Costs Average Cost Per Reporter = Total Industry Costs / Total Number of Reporters Affected
(1) Based on the total number of existing reporters affected within each segment, based on RY2021 data and estimated during RY2025, unless otherwise noted. Additional details may be found in Appendix A of the Impacts Memo.
(2) It is estimated that 11 reporters subject to subpart PP would be required to implement reporting of the revised data elements under 98.426(h). Per RY2021 data, 9 respondents report to subpart RR (Geologic Sequestration of CO2). From the 2022 Data Quality Improvements Proposal (Jule 21, 2022), EPA assumes that 2 reporters will cease reporting under subpart UU and begin reporting under proposed subpart VV each year.


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Sheet 36: QQ (Data Elements)

Quantitative Burden and Costs for New, Revised, and Deleted Data Elements (implemented during RY2025) (Section 2.5)

Item	Subpart QQ Data Element Revisions
Item	Total	QQ (2)	QQ (3)
Number of Reporters Affected (1)	33	33	28
# of New Data Elements	3	2	1
# of Revised Data Elements	0	0	0
# of Removed Data Elements	0	0	0
Sum of Data Element Changes	3	2	1
Technical Respondent Hours Per Occurrence		0.05	0.05
Respondent Hours
Technical	0.15	0.10	0.05
Clerical	0.02	0.01	0.01
Managerial	0.01	0.01	0.00
Total	0.17	0.12	0.06
Reporter Costs
Technical	$11	$7	$4
Clerical	$1	$0	$0
Managerial	$1	$0	$0
Total	$12	$8	$4
Total Industry Costs and Avg. Cost/Reporter
Total	$384	$270	$115
	$12	$/reporter	$/reporter
Notes:
Calculation Methodology: Total Technical Respondent Hours = Sum of Data Element Changes (Number of New + Revised - No. of Removed Data Elements) x Technical Respondent Hours per Occurance. Clerical and managerial hours are estimated as 10% and 5% of technical hours, respectively. Total Reporter Costs = (Technical Respondent Hours x $71.45/hr) + (Managerial Respondent Hours x $87.45/hr) + (Clerical Respondent Hours x $36.28/hr) Total Industry Costs = Number of Reporters Affected x Total Reporter Costs Average Cost Per Reporter = Total Industry Costs / Total Number of Reporters Affected
(1) Based on the total number of existing reporters affected within each segment, based on RY2021 data and estimated during RY2025, unless otherwise noted. Additional details may be found in Appendix A of the Impacts Memo.
(2) Per RY2021 data, 33 respondents reporting to subpart QQ are bulk importers who would be required to report two new data elements at 40 CFR 98.436(a)(7-8).
(3) Per RY2021 data, 28 respondents reporting to subpart QQ are bulk exporters who would be required to report one new data elements at 40 CFR 98.436(b)(7).

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