Burden Calculation Tables

1601t11.xlsx

Air Pollution Regulations for Outer Continental Shelf Activities (Renewal)

Burden Calculation Tables

OMB: 2060-0249

Document [xlsx]

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Overview

README
Appendix A-1
Appendix A-2
Ex1 (Exp)
Ex2 (AE)
Ex3 (Prod)
Ex4 (Exp)
Ex5 (AE)
Ex6 (Prod)
Ex7 (Exp)
Ex8 (AE)
Ex9 (Prod)
Respondent Summary
Ex10 (Exp)
Ex11 (AE)
Ex12 (Prod)
Ex13
Ex14

Sheet 1: README

README File for EPA Information Collection Request Number 1601.10 for Outer Continental Shelf (OCS) Activities
Burden Estimates for 3-year period: June 1, 2024 - May 31, 2027

Exhibit (Ex) tabs are color-coded to represent annual burden to industry (in orange), State/Local Agencies (in green), and the EPA (in blue).
	Exhibit	Annual Burden To:
	Ex1 to Ex6	Industry
	Ex7 to Ex9	State/Local Agencies
	Ex10 to Ex13	EPA
	Note: Ex14 provides a summary of the combined annual burden and costs for industry, State/Local agencies, and the EPA.

Exhibits are organized by four types of OCS activities: oil and gas phases (Exp, Cons, or Prod) or alternative energy (AE).
	Exp	Oil and Gas Exploration (Phase 1)
	Cons	Oil and Gas Construction (Phase 2)
	Prod	Oil and Gas Development/Production (Phase 3)
	AE	Alternative Energy

OCS activities are authorized under the EPA or State/Local Agencies.
	Exhibits	Permitting Authority
	Ex1 (Exp)	Industry Permit Burden to EPA
	Ex2 (AE)	Industry Permit Burden to EPA
	Ex3 (Prod)	Industry Permit Burden to EPA
	Ex4 (Exp)	Industry Permit Burden to State/Local
	Ex5 (AE)	Industry Permit Burden to State/Local
	Ex6 (Prod)	Industry Permit Burden to State/Local
	Ex7 (Exp)	State/Local Permit Review Burden
	Ex8 (AE)	State/Local Permit Review Burden
	Ex9 (Prod)	State/Local Permit Review Burden
	Ex10 (Exp)	EPA Permit Review Burden
	Ex11 (AE)	EPA Permit Review Burden
	Ex12 (Prod)	EPA Permit Review Burden
	Ex13	EPA Annual Burden related to consistency updates and overseeing State/Local Activities

NOTE: This entire excel file is a draft document for public review and comment - do not quote or cite

Sheet 2: Appendix A-1

		Appendix A-1
		LABOR RATES

Contractor Rates [1]
	*2023 Hourly*	Hourly Wage Rate	Benefits, Overhead & Profit	Total
	*$108.00*	$48.88	2.2	$107.54

Respondent Rates [2]
	*2023 Hourly*	Hourly Wage Rate	Benefits & Overhead	Total
	*$101.00*	$50.43	2	$100.86

State/Local Agency Rates [3]
	*2023 Hourly*	Hourly Wage Rate	Benefits & Overhead	Total
	*$92.00*	$46.19	2	$92.38

EPA Rates [4]
	*2023 Hourly*	Hourly Wage Rate	Benefits	Total
	*$62.00*	$38.61	1.6	$61.78

[1] Industry contractor rate based on mean hourly wages for Environmental Engineers obtained from "Occupational Employment and Wages, May 2022; 17-2081 Environmental Engineers" U.S. Deaprtment of Labor, Bureau of Labor Statistics. (http://www.bls.gov/oes/current/oes172081.htm accessed in November 2023) Benfits and overhead assumed to total 100% of wages; profit margin assumed to be 10% on top of "loaded" total. See wage escalation calculations below.


[2] Respondent in-house rate based on mean hourly wages for Environmental Engineers obtained from "Occupational Employment and Wages, May 2022; 17-2081 Environmental Engineers" U.S. Deaprtment of Labor, Bureau of Labor Statistics. (http://www.bls.gov/oes/current/oes172081.htm accessed in November 2023) Benfits and overhead assumed to total 100% of wages. See wage escalation calculations below.


[3] State/Local rates based on 25th percentile hourly wages for Environmental Engineers obtained from "Occupational Employment and Wages, May 2022; 17-2081 Environmental Engineers" U.S. Deaprtment of Labor, Bureau of Labor Statistics. (http://www.bls.gov/oes/current/oes172081.htm accessed in November 2023) Benfits and overhead assumed to total 100% of wages. See wage escalation calculations below.


[4] Federal Labor Cost obtained from U.S. Office of Personnel Management 2023 General Schedule Table 2023-GS. Hourly labor rate assumed is GS-12, Step 5 (Technical Labor). 60% benefits assumed. See https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2023/GS_h.pdf. Accessed November 2023.




WAGE ESCALATION CALCULATIONS

Industry contractor and in-house hourly wage rate
48.88	May 2022	http://www.bls.gov/oes/current/oes172081.htm				Mean hourly wage for Environmental Engineers = $48.88/hr
	Escalating to June 2023 using the Employment Cost Index (ECI) for wages and salaries for Private Industry Workers - All Workers found at https://www.bls.gov/eci/home.htm#data. accessed November 13, 2023
	ECI Sept 2022 =		154.1
	ECI June 2023 =		159.0		(Note that September 2023 was the most recent ECI available the when website accessed 11/13/23)
50.43	June 2023 wages in $/hr		hourly wage May 2022 x (ECI Sept 2022/ECI June 2023)

State/Local hourly wage rate
45.1	May-22	http://www.bls.gov/oes/current/oes172081.htm				25th percentile hourly wage for Environmental Engineers = $36.32/hr
	Escalating to June 2023 using the Employment Cost Index (ECI) for wages and salaries for State and Local Government Workers - Public Administration found at https://www.bls.gov/eci/home.htm#data. accessed November 13, 2023
	ECI Sept 2022 =		157.4
	ECI June 2023 =		161.2		(Note that September 2023 was the most recent ECI available the when website accessed 11/13/23)
46.19	June 2023 wages in $/hr		hourly wage May 2022 x (ECI Sept 2022/ECI June 2023)

Sheet 3: Appendix A-2

	Appendix A-2
	Universe of Respondents

Estimates
*Sources under EPA authority*
*# New exploration sources*	1	represents the number of expected oil and gas exploration permits to be issued during ICR period
*# Existing exploration sources*	1	represents the number of existing oil and gas exploration permits at the start of the ICR period
*# Exploration wells to be drilled*	1	projected exploration well in this ICR period
*# New development/production sources*	1
*# Existing development/production sources*	9
*# Decommissioning sources*	0
*# Construction mod to existing sources*	0
*# New alternative energy sources*	24	projected number of wind farms to be permitted for this ICR period
*# Existing alternative energy sources*	9	existing wind farms already permitted

*Sources under state/local authority*
*# New exploration sources*	0
*# Existing exploration sources*	0
*# Exploration wells to be drilled*	0
*# New development/production sources*	0
*# Existing development/production sources*	24
*# Decommissioning sources*	3
*# Construction mod to existing sources*	2
*# New alternative energy sources*	3
*# Existing alternative energy sources*	2
*Total Number of Sources*	74	does not include # exploration wells (row 8) or modified existing sources (row 18) as this would be double counting

*State/local agencies overseeing sources*	7	Three (3) states (Delaware,Maryland, and Virginia) and the four (4) California local agencies (South Coast Air Quality Management District CA, Ventura County Air Pollution Control District CA, Santa Barbara Air Pollution Control District CA, San Luis Obispo Air Pollution Control District) CA

*Total Number of Respondents*	81

Most activity for OCS has been with the development of alternative energy sources (windfarms mainly along the eastern seaboard)

Sheet 4: Ex1 (Exp)

EXHIBIT 1. NEW AND PREVIOUSLY PERMITTED EXPLORATION SOURCES UNDER EPA AUTHORITY
RESPONDENTS' ANNUAL BURDEN
				Respondent Labor				O&M
Collection Activities	Number of Respondents	Frequency of Action in 3 Year Period	Occurrences per year	Industry Hours per Occurrence1	Industry Labor Hours Per Year	Industry Labor Cost per Occurrence	Industry Labor Costs Per Year	Contractors Hours per Occurrence	Contractor Labor Hours Per Year	Contractors Dollars per Occurrence	Contractor Labor Costs Per Year	Non-Labor Contractor O&M Costs per Occurrence	Non-Labor Contractor O&M Costs per Year	TOTAL O&M Cost Per Occurance	Total O&M Costs per Year	Capital Costs per Occurrence	Total Capital Costs per Year	Total Non-Labor Costs Per Year	Total Costs Per Year
Labor Rates						*$101.00*				*$108.00*
Read regulations2	1	1	0.33	5.00	1.67	$505.00	$168.33	0.00	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$168.33
Consult with EPA2	1	1	0.33	5.00	1.67	$505.00	$168.33	0.00	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$168.33
Prepare a NOI to construct2	1	1	0.33	30.00	10.00	$3,030.00	$1,010.00	0.00	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$1,010.00
Prepare major source permit application3	1	1	0.33	50.00	16.67	$5,050.00	$1,683.33	293.00	97.67	$31,644.00	$10,548.00	$0.00	$0.00	$31,644.00	$10,548.00	$0.00	$0.00	$10,548.00	$12,231.33
Prepare minor source permit application3	0	1	0.00	25.00	0.00	$2,525.00	$0.00	146.00	0.00	$15,768.00	$0.00	$0.00	$0.00	$15,768.00	$0.00	$0.00	$0.00	$0.00	$0.00
Perform initial compliance test4	1	1	0.33	100.00	33.33	$10,100.00	$3,366.67	764.00	254.67	$82,512.00	$27,504.00	$0.00	$0.00	$82,512.00	$27,504.00	$0.00	$0.00	$27,504.00	$30,870.67
Prepare operating permit application5	1	1	0.33	42.00	14.00	$4,242.00	$1,414.00	0.00	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$1,414.00
Conduct record keeping and report data to EPA4	1	3	1.00	32.00	32.00	$3,232.00	$3,232.00	0.00	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$3,232.00
Total		Responses per Year**	3.00		109		$11,043		352		$38,052		$0		$38,052		$0	$38,052	$49,095

1. Assumes hours per occurrence is the same as that in the 1998 ICR, except hours added for preparing permit applications
2. Assumes all new permittees must perform these tasks
3. Assumes all new permits are major sources permits
4. Assumes that testing, monitoring, recordkeeping and reporting are required only when an exploratory well is actually drilled
5. Assumes that all new major source permittees also incorporate operating permit requirements at the same time

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

Sheet 5: Ex2 (AE)

EXHIBIT 2. NEW AND PREVIOUSLY PERMITTED ALTERNATIVE ENERGY SOURCES UNDER EPA AUTHORITY
RESPONDENTS' ANNUAL BURDEN
				Respondent Labor				O&M
Collection Activities	Number of Respondents	Frequency of Action in 3 Year Period	Occurrences per year	Industry Hours per Occurrence1	Industry Labor Hours Per Year	Industry Labor Cost per Occurrence	Industry Labor Costs Per Year	Contractors Hours per Occurrence	Contractor Labor Hours Per Year	Contractors Dollars per Occurrence	Contractor Labor Costs Per Year	Non-Labor Contractor O&M Costs per Occurrence	Non-Labor Contractor O&M Costs per Year	TOTAL O&M Cost Per Occurance	Total O&M Costs per Year	Capital Costs per Occurrence	Total Capital Costs per Year	Total Non-Labor Costs Per Year	Total Costs Per Year
Labor Rates						*$101.00*				*$108.00*
Read regulations2	24	1	8.00	5	40.00	$505.00	$4,040.00	0	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$4,040.00
Consult with EPA2	24	1	8.00	5	40.00	$505.00	$4,040.00	0	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$4,040.00
Prepare a NOI to construct2	24	1	8.00	30	240.00	$3,030.00	$24,240.00	0	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$24,240.00
Prepare major source permit application3	24	1	8.00	50	400.00	$5,050.00	$40,400.00	293	2344.00	$31,644.00	$253,152.00	$0.00	$0.00	$31,644.00	$253,152.00	$0.00	$0.00	$253,152.00	$293,552.00
Prepare minor source permit application3	0	1	0.00	25	0.00	$2,525.00	$0.00	146	0.00	$15,768.00	$0.00	$0.00	$0.00	$15,768.00	$0.00	$0.00	$0.00	$0.00	$0.00
Perform initial and annual performance testing4	24	1	8.00	100	800.00	$10,100.00	$80,800.00	40	320.00	$4,320.00	$34,560.00	$0.00	$0.00	$4,320.00	$34,560.00	$0.00	$0.00	$34,560.00	$115,360.00
Prepare operating permit application4	28	1	9.33	42	392.00	$4,242.00	$39,592.00	0	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$39,592.00
Conduct record keeping and report data to EPA5	33	3	33.00	32	1,056.00	$3,232.00	$106,656.00	0	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$106,656.00
Total		Responses per Year**	82.33		2,968		$299,768		2,664		$287,712		$0		$287,712		$0	$287,712	$587,480

1. Assumes hours per occurrence is the same as that in the 1998 ICR, except hours added for preparing permit applications
2. Assumes all new permittees must perform these tasks
3. Assumes all new permits are major source permits because all permitting at this time is for construction/operation.
4. Assumes that all new major source permittees also incorporate operating permit requirements at the same time.
5. Assumes that all new and existing permittees must conduct recordkeeping and reporting during each year of the ICR period


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

Sheet 6: Ex3 (Prod)

EXHIBIT 3. NEW AND PREVIOUSLY PERMITTED DEVELOPMENT/PRODUCTION SOURCES UNDER EPA AUTHORITY
RESPONDENTS' ANNUAL BURDEN
				Respondent Labor				O&M
Collection Activities	Number of Respondents	Frequency of Action in 3 Year Period	Occurrences per year	Industry Hours per Occurrence1	Industry Labor Hours Per Year	Industry Labor Cost per Occurrence	Industry Labor Costs Per Year	Contractors Hours per Occurrence	Contractor Labor Hours Per Year	Contractors Dollars per Occurrence	Contractor Labor Costs Per Year	Non-Labor Contractor O&M Costs per Occurrence	Non-Labor Contractor O&M Costs per Year	TOTAL O&M Cost Per Occurance	Total O&M Costs per Year	Capital Costs per Occurrence	Total Capital Costs per Year	Total Non-Labor Costs Per Year	Total Costs Per Year
Labor Rates						*$101.00*				*$108.00*
Read regulations2	$	1	0.33	5.00	1.67	$505.00	$168.33	0.00	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$168.33
Consult with EPA2	1	1	0.33	5.00	1.67	$505.00	$168.33	0.00	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$168.33
Prepare a NOI to construct	1	1	0.33	30.00	10.00	$3,030.00	$1,010.00	0.00	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$1,010.00
Prepare preconstruction permit application	1	1	0.33	100.00	33.33	$10,100.00	$3,366.67	585.00	195.00	$63,180.00	$21,060.00	$0.00	$0.00	$63,180.00	$21,060.00	$0.00	$0.00	$21,060.00	$24,426.67
Prepare minor modification permit application5	0	1	0.00	50.00	0.00	$5,050.00	$0.00	293.00	0.00	$31,644.00	$0.00	$0.00	$0.00	$31,644.00	$0.00	$0.00	$0.00	$0.00	$0.00
Prepare major modification permit application	0	1	0.00	100.00	0.00	$10,100.00	$0.00	585.00	0.00	$63,180.00	$0.00	$0.00	$0.00	$63,180.00	$0.00	$0.00	$0.00	$0.00	$0.00
Perform initial and annual compliance test	1	3	1.00	100.00	100.00	$10,100.00	$10,100.00	764.00	764.00	$82,512.00	$82,512.00	$0.00	$0.00	$82,512.00	$82,512.00	$0.00	$0.00	$82,512.00	$92,612.00
Prepare operating permit application	5	1	1.80	42.00	75.60	$4,242.00	$7,635.60	0.00	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$7,635.60
Conduct record keeping and report data to EPA4	10	3	10.00	64.00	640.00	$6,464.00	$64,640.00	0.00	0.00	$0.00	$0.00	$1,625.52	$16,255.20	$1,625.52	$16,255.20	$32,510.40	$325,104.04	$341,359.24	$405,999.24
Decommissioning6	0	1	0.00	174.00	0.00	$17,574.00	$0.00	0.00	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00
Total		Responses per Year**	14.13		862		$87,089		959		$103,572		$16,255		$119,827		$325,104	$444,931	$532,020

1. Assumes hours per occurrence is the same as that in the 1998 ICR
2. Assumes O&M is 5 percent of capital costs
3. Capital costs calculated using the June 2019 final CEPCI index cost of $28,662.00 to 2022 dollars by the following: (2019 value)*(DEFLATOR2022/ DEFLATOR1998) Table 1.1.9. Implicit Price Deflators for Gross Product [Index numbers, 2012=100], frequency = annual Source: Bureau of Economic Analysis, https://fred.stlouisfed.org. Last Updated on: September 28, 2023 (annual deflators: https://fred.stlouisfed.org/series/A191RD3A086NBEA)
4. Assumes that all permittees must conduct recordkeeping and reporting during each year of the ICR period
5. Assumes 2 of the existing sources will undergo minor NSR preconstruction permitting for changes at their facilities.
6. Decommissioning is guestimated to result in 174 hrs of burden per occurrence which would involve reading regulations (5 hrs), consulting with EPA (5 hrs), preparing permit application (100 hrs), and conducting record keeping and reporting data to EPA (64 hrs).

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

Sheet 7: Ex4 (Exp)

EXHIBIT 4. NEW AND PREVIOUSLY PERMITTED EXPLORATION SOURCES UNDER STATE/LOCAL AUTHORITY
RESPONDENTS' ANNUAL BURDEN
				Respondent Labor				O&M
Collection Activities	Number of Respondents	Frequency of Action in 3 Year Period	Occurrences per year	Industry Hours per Occurrence1	Industry Labor Hours Per Year	Industry Labor Cost per Occurrence	Industry Labor Costs Per Year	Contractors Hours per Occurrence	Contractor Labor Hours Per Year	Contractors Dollars per Occurrence	Contractor Labor Costs Per Year	Non-Labor Contractor O&M Costs per Occurrence	Non-Labor Contractor O&M Costs per Year	TOTAL O&M Cost Per Occurance	Total O&M Costs per Year	Capital Costs per Occurrence	Total Capital Costs per Year	Total Non-Labor Costs Per Year	Total Costs Per Year
Labor Rates						*$101.00*				*$108.00*
Read regulations2	0	1	0.00	5.00	0.00	$505.00	$0.00	0.00	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00
Consult with EPA2	0	1	0.00	5.00	0.00	$505.00	$0.00	0.00	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00
Prepare a NOI to construct2	0	1	0.00	30.00	0.00	$3,030.00	$0.00	0.00	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00
Prepare major source permit application3	0	1	0.00	50.00	0.00	$5,050.00	$0.00	293.00	0.00	$31,644.00	$0.00	$0.00	$0.00	$31,644.00	$0.00	$0.00	$0.00	$0.00	$0.00
Prepare minor source permit application3	0	1	0.00	25.00	0.00	$2,525.00	$0.00	146.00	0.00	$15,768.00	$0.00	$0.00	$0.00	$15,768.00	$0.00	$0.00	$0.00	$0.00	$0.00
Perform initial compliance test4	0	1	0.00	100.00	0.00	$10,100.00	$0.00	764.00	0.00	$82,512.00	$0.00	$0.00	$0.00	$82,512.00	$0.00	$0.00	$0.00	$0.00	$0.00
Prepare operating permit application5	0	1	0.00	42.00	0.00	$4,242.00	$0.00	0.00	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00
Conduct record keeping and report data to EPA4	0	3	0.00	32.00	0.00	$3,232.00	$0.00	0.00	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00
Total		Responses per Year**	0.00		0		$0		0		$0		$0		$0		$0	$0	$0

1. Assumes hours per occurrence is the same as that in the 1998 ICR
2. Assumes all new permittees must perform these tasks
3. Assumes all new permits are major sources permits
4. Assumes that testing, monitoring, recordkeeping and reporting are required only when an exploratory well is actually drilled
5. Assumes that all new major source permittees also incorporate operating permit requirements at the same time


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

Sheet 8: Ex5 (AE)

EXHIBIT 5. NEW AND PREVIOUSLY PERMITTED ALTERNATIVE ENERGY SOURCES UNDER STATE/LOCAL AUTHORITY
RESPONDENTS' ANNUAL BURDEN
				Respondent Labor				O&M
Collection Activities	Number of Respondents	Frequency of Action in 3 Year Period	Occurrences per year	Industry Hours per Occurrence1	Industry Labor Hours Per Year	Industry Labor Cost per Occurrence	Industry Labor Costs Per Year	Contractors Hours per Occurrence	Contractor Labor Hours Per Year	Contractors Dollars per Occurrence	Contractor Labor Costs Per Year	Non-Labor Contractor O&M Costs per Occurrence	Non-Labor Contractor O&M Costs per Year	TOTAL O&M Cost Per Occurance	Total O&M Costs per Year	Capital Costs per Occurrence	Total Capital Costs per Year	Total Non-Labor Costs Per Year	Total Costs Per Year
Labor Rates						*$101.00*				*$108.00*
Read regulations2	3	1	1.00	5.00	5.00	$505.00	$505.00	0	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$505.00
Consult with EPA2	3	1	1.00	5.00	5.00	$505.00	$505.00	0	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$505.00
Prepare a NOI to construct2	3	1	1.00	30.00	30.00	$3,030.00	$3,030.00	0	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$3,030.00
Prepare major source permit application3	3	1	1.00	50.00	50.00	$5,050.00	$5,050.00	293	293.00	$31,644.00	$31,644.00	$0.00	$0.00	$31,644.00	$31,644.00	$0.00	$0.00	$31,644.00	$36,694.00
Prepare minor source permit application3	0	1	0.00	25.00	0.00	$2,525.00	$0.00	146	0.00	$15,768.00	$0.00	$0.00	$0.00	$15,768.00	$0.00	$0.00	$0.00	$0.00	$0.00
Perform initial and annual performance testing4	3	1	1.00	100.00	100.00	$10,100.00	$10,100.00	40	40.00	$4,320.00	$4,320.00	$0.00	$0.00	$4,320.00	$4,320.00	$0.00	$0.00	$4,320.00	$14,420.00
Prepare operating permit application4	3	1	1.00	42.00	42.00	$4,242.00	$4,242.00	0	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$4,242.00
Conduct record keeping and report data to EPA5	5	3	5.00	32.00	160.00	$3,232.00	$16,160.00	0	0.00	$0.00	$0.00	$1,625.52	$8,127.60	$1,625.52	$8,127.60	$32,510.40	$162,552.00	$170,679.60	$186,839.60
Total		Responses per Year**	11.00		392		$39,592		333		$35,964		$8,128		$44,092		$162,552	$206,644	$246,236

1. Assumes hours per occurrence is the same as that in the 1998 ICR, except hours added for preparing permit applications
2. Assumes all new permittees must perform these tasks
3. Assumes all new permits are major source permits because all permitting at this time is for construction/operation.
4. Assumes that all new major source permittees also incorporate operating permit requirements at the same time
5. Assumes that all new and existing permittees must conduct recordkeeping and reporting during each year of the ICR period
6. Assumes O&M is 5 percent of capital costs
7. Capital costs calculated using the June 2019 final CEPCI index cost of $28,662.00 to 2022 dollars by the following: (2019 value)*(DEFLATOR2022/ DEFLATOR1998) Table 1.1.9. Implicit Price Deflators for Gross Product [Index numbers, 2012=100], frequency = annual Source: Bureau of Economic Analysis, https://fred.stlouisfed.org. Last Updated on: September 28, 2023 (annual deflators: https://fred.stlouisfed.org/series/A191RD3A086NBEA)
**This number is used in the summary (Exhibit 14)

Sheet 9: Ex6 (Prod)

EXHIBIT 6. EXISTING DEVELOPMENT/PRODUCTION SOURCES UNDER STATE/LOCAL AUTHORITY
RESPONDENTS' ANNUAL BURDEN
				Respondent Labor				O&M
Collection Activities	Number of Respondents	Frequency of Action in 3 Year Period	Occurrences per year	Industry Hours per Occurrence1	Industry Labor Hours Per Year	Industry Labor Cost per Occurrence	Industry Labor Costs Per Year	Contractors Hours per Occurrence	Contractor Labor Hours Per Year	Contractors Dollars per Occurrence	Contractor Labor Costs Per Year	Non-Labor Contractor O&M Costs per Occurrence	Non-Labor Contractor O&M Costs per Year	TOTAL O&M Cost Per Occurance	Total O&M Costs per Year	Capital Costs per Occurrence	Total Capital Costs per Year	Total Non-Labor Costs Per Year	Total Costs Per Year
Labor Rates						*$101.00*				*$108.00*
Read regulations2	0.0	1	0.00	5.00	0.00	$505.00	$0.00	0.00	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00
Consult with EPA2	0.0	1	0.00	5.00	0.00	$505.00	$0.00	0.00	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00
Prepare a NOI to construct	14.4	1	4.80	42.00	201.60	$4,242.00	$20,361.60	0.00	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$20,361.60
Prepare preconstruction permit application	24.0	3	24.00	100.00	2,400.00	$10,100.00	$242,400.00	764.00	18336.00	$82,512.00	$1,980,288.00	$0.00	$0.00	$82,512.00	$1,980,288.00	$0.00	$0.00	$1,980,288.00	$2,222,688.00
Prepare minor modification permit application5	24.0	3	24.00	64.00	1,536.00	$6,464.00	$155,136.00	0.00	0.00	$0.00	$0.00	$1,625.52	$39,012.49	$1,625.52	$39,012.49	$0.00	$0.00	$39,012.49	$194,148.49
Prepare major modification permit application	2.0	1	0.67	30.00	20.00	$3,030.00	$2,020.00	0.00	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$2,020.00
Perform initial and annual compliance test	0.0	1	0.00	100.00	0.00	$10,100.00	$0.00	585.00	0.00	$63,180.00	$0.00	$0.00	$0.00	$63,180.00	$0.00	$0.00	$0.00	$0.00	$0.00
Prepare operating permit application	2.0	1	0.67	50.00	33.33	$5,050.00	$3,366.67	293.00	195.33	$31,644.00	$21,096.00	$0.00	$0.00	$31,644.00	$21,096.00	$0.00	$0.00	$21,096.00	$24,462.67
Conduct record keeping and report data to EPA4	0.0	1	0.00	100.00	0.00	$10,100.00	$0.00	585.00	0.00	$63,180.00	$0.00	$0.00	$0.00	$63,180.00	$0.00	$0.00	$0.00	$0.00	$0.00
Decommissioning6	3.0	1	1.00	174.00	174.00	$17,574.00	$17,574.00	0.00	0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$0.00	$17,574.00
Total		Responses per Year**	55.13		4,365		$440,858		18,531		$2,001,384		$39,012		$2,040,396		$0	$2,040,396	$2,481,255

1. Assumes hours per occurrence is the same as that in the 1998 ICR, except that hours for minor preconstruction permit are half the major source level
2. Assumes O&M is 5 percent of capital costs
3. Because these are 5-year permits, assumes that 60 percent of existing sources will renew their operating permits during the 3 years of the ICR period
4. Assumes that all permittees must conduct recordkeeping and reporting during each year of the ICR period
5. Assumes 2 of the existing sources will undergo minor NSR preconstruction permitting for changes at their facilities.
6. Decommissioning is guestimated to result in 174 hrs of burden per occurrence which would involve reading regulations (5 hrs), consulting with State/Local authority (5 hrs), preparing permit application (100 hrs), and conducting record keeping and reporting data to State/Local Authority (64 hrs).

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

Sheet 10: Ex7 (Exp)

EXHIBIT 7. NEW AND PREVIOUSLY PERMITTED EXPLORATION SOURCES UNDER STATE/LOCAL AUTHORITY
STATE/LOCAL AGENCIES' ANNUAL BURDEN

Collection Activities	Number of Respondents	Number of Occurrences for 3 years	Occurrences per year	Hours per Occurrence1	Cost per Occurrence	Total Hours per Year	Total Cost per Year
Labor Rate					*$92.00*
Consult with sources2	0	1	0.00	5	$460.00	0	$0.00
Review NOI to construct and minor permit application3	0	1	0.00	131	$12,052.00	0	$0.00
Review NOI to construct and major permit application3	0	1	0.00	263	$24,196.00	0	$0.00
Review operating permit application4	0	1	0.00	40	$3,680.00	0	$0.00
Oversee initial compliance test5	0	1	0.00	67	$6,164.00	0	$0.00
Conduct inspections	0	2	0.00	16	$1,472.00	0	$0.00
Review data reports5	0	1	0.00	8	$736.00	0	$0.00
		Responses per year**	0.00		Burden	0	$0.00

1. Assumes hours per occurrence is the same as that in the 1998 ICR.
2. Assumes these activities required with all new permittees
3. Assumes all new permits are major sources permits
4. Assumes that all new major source permittees also incorporate operating permit requirements at the same time
5. Assumes that testing, monitoring, recordkeeping and reporting are required only when an exploratory well is actually drilled

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

Sheet 11: Ex8 (AE)

EXHIBIT 8. NEW AND PREVIOUSLY PERMITTED ALTERNATIVE ENERGY SOURCES UNDER STATE/LOCAL AUTHORITY
STATE/LOCAL AGENCIES' ANNUAL BURDEN

Collection Activities	Number of Respondents	Number of Occurrences for 3 years	Occurrences per year	Hours per Occurrence1	Cost per Occurrence	Total Hours per Year	Total Cost per Year
Labor Rate					*$92.00*
Consult with sources2	3	1	1.00	40	$3,680.00	40	$3,680.00
Review NOI to construct and minor source permit application3	0	1	0.00	265	$24,380.00	0	$0.00
Review NOI to construct and major source permit application3, 6	3	1	1.00	530	$48,760.00	530	$48,760.00
Review operating permit application4	3	1	1.00	80	$7,360.00	80	$7,360.00
Conduct inspections5	5	3	5.00	16	$1,472.00	80	$7,360.00
Review data reports5	5	3	5.00	8	$736.00	40	$3,680.00
		Responses per year**	13.00		Burden	770	$70,840.00

1. Assumes hours per occurrence is the same as that in the 1998 ICR for consultations, inspections and report reviews; hours for permit application reviews developed consistent with other exhibits
2. Assumes these activities required with all new permittees
3. Assumes all new permits are major source permits because all permitting at this time is for construction/operation.
4. Assumes that all new major source permittees also incorporate operating permit requirements at the same time
5. Assumes these activities required with all new and existing permittees
6. This step includes the time required for developing the draft permit, the statement of basis, and responding to comments received from a public notice.

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

Sheet 12: Ex9 (Prod)

EXHIBIT 9. EXISTING DEVELOPMENT/PRODUCTION SOURCES UNDER STATE/LOCAL AUTHORITY
STATE/LOCAL AGENCIES' ANNUAL BURDEN

Collection Activities	Number of Respondents	Number of Occurrences for 3 years	Occurrences per year	Hours per Occurrence1	Cost per Occurrence	Total Hours per Year	Total Cost per Year
Labor Rate					*$92.00*
Consult with sources	2	1	0.67	5	$460.00	3	$306.67
Oversee intial and annual compliance test	24	3	24.00	67	$6,164.00	1,608	$147,936.00
Conduct inspections	24	12	96.00	16	$1,472.00	1,536	$141,312.00
Review operating permit application2	14	1	4.80	40	$3,680.00	192	$17,664.00
Review data reports	24	3	24.00	8	$736.00	192	$17,664.00
Review NOI to construct and permit application3	2	1	0.67	131	$12,052.00	87	$8,034.67
Decomissioning4	3	1	1.00	76	$6,992.00	76	$6,992.00
		Responses per year**	151.13		Burden	3,695	$339,909.33

1. Assumes hours per occurrence is the same as that in the 1998 ICR.
2. Because these are 5-year permits, assumes that 60 percent of existing sources will renew their operating permits during the 3 years of the ICR period
3. Assumes 2 of the existing sources will undergo minor NSR preconstruction permitting for changes at their facilities.
4. Decommissioning is guestimated to result in 76 hrs of burden per occurrence which would involve consulting with sources (5 hrs), reviewing permit application (55 hrs) and conducting inspections (16 hrs).

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

Sheet 13: Respondent Summary

Industry Under EPA Authority Summary (As calculated using old, incorrect, methodology)
	Responses	165.59

	Industry Labor Hours Per Year	8,697
	Industry Labor Costs Per Year	$878,350

	Contractor Labor Hours Per Year	22,840
	Contractor Labor Costs Per Year	$2,466,684

	Total Hours Per Year (including Contractor)	31,536
	Total Labor Costs Per Year (including Contractor)	$3,345,034

	Total O&M Costs per Year	$63,395
	Total Capital Costs per Year	$487,656

	Total Non-Labor Costs Per Year ( no contractor)	$551,051


	Total Costs Per Year	$3,896,085.20

INDUSTRY BURDEN (Corrected)
	Responses	165.59				2.2377027027027
			Reporting	Recordkeeping
	Industry Labor Hours Per Year	8,697	6,809	1,888
	Industry Labor Costs Per Year	$878,350	$687,661.87	$190,688.00

	Contractor Labor Costs	$2,466,684

	Total O&M Costs per Year	$2,530,079
	Total Capital Costs per Year	$487,656

	Total Non-Labor Costs Per Year	$3,017,735

	Total Costs Per Year	$3,896,085



STATE/LOCAL AGENCIES' ANNUAL BURDEN
	Responses	164.13			23.447619047619
			Reporting	Recordkeeping
	Labor Hours Per Year	4,465	4,465	0
	Labor Costs Per Year	$410,749.33


	Total O&M Costs per Year	0
	Total Capital Costs per Year	0

	Total Non-Labor Costs Per Year	0

	Total Costs Per Year	$410,749.33

Total Respondent
		Correct Methodology	Incorrect Methodology	Change Due to correction in methodology
	Responses	329.72	329.72	0.00

	Labor Hours Per Year	13,161.20	36,000.87	-22,839.67
	Labor Costs Per Year	$1,289,099.20	$3,755,783.20	$(2,466,684.00)


	Total O&M Costs per Year	$2,530,079.29	$63,395.29	$2,466,684.00
	Total Capital Costs per Year	$487,656.04	$487,656.04	$0.00

	Total Non-Labor Costs Per Year	$3,017,735.33	$551,051.33	$2,466,684.00

	Total Costs Per Year	$4,306,834.53	$4,306,834.53	$0.00

Sheet 14: Ex10 (Exp)

EXHIBIT 10. NEW AND PREVIOUSLY PERMITTED EXPLORATION SOURCES UNDER EPA AUTHORITY
EPA'S ANNUAL BURDEN

Collection Activities	Number of Respondents	Number of Occurrences for 3 years	Occurrences per year	Hours per Occurrence1	Cost per Occurrence	Total Hours per Year	Total Cost per Year
Labor Rate					*$62.00*
Consult with sources2	1	1	0.33	5	$310.00	2	$103.33
Review NOI to construct and minor permit application3	0	1	0.00	131	$8,122.00	0	$0.00
Review NOI to construct and major permit application3	1	1	0.33	263	$16,306.00	88	$5,435.33
Review operating permit application4	1	1	0.33	40	$2,480.00	13	$826.67
Oversee initial compliance test5	1	1	0.33	67	$4,154.00	22	$1,384.67
Conduct inspections	1	2	0.67	16	$992.00	11	$661.33
Review data reports5	1	1	0.33	8	$496.00	3	$165.33
					Burden	138	$8,576.67

1. Assumes hours per occurrence is the same as that in the 1998 ICR
2. Assumes these activities required with all new permittees
3. Assumes all new permits are major sources permits
4. Assumes that all new major source permittees also incorporate operating permit requirements at the same time
5. Assumes that testing, monitoring, recordkeeping and reporting are required only when an exploratory well is actually drilled

Sheet 15: Ex11 (AE)

EXHIBIT 11. NEW AND PREVIOUSLY PERMITTED ALTERNATIVE ENERGY SOURCES UNDER EPA AUTHORITY
EPA'S ANNUAL BURDEN

Collection Activities	Number of Respondents	Number of Occurrences for 3 years	Occurrences per year	Hours per Occurrence1	Cost per Occurrence	Total Hours per Year	Total Cost per Year
Labor Rate					*$62.00*
Consult with sources2	24	1	8.00	40	$2,480.00	320	$19,840.00
Review NOI to construct and minor source permit application3	0	1	0.00	265	$16,430.00	0	$0.00
Review NOI to construct and major source permit application3, 6	24	1	8.00	530	$32,860.00	4,240	$262,880.00
Review operating permit application4	28	1	9.33	80	$4,960.00	747	$46,293.33
Conduct inspections5	33	3	33.00	16	$992.00	528	$32,736.00
Review data reports5	33	3	33.00	8	$496.00	264	$16,368.00
					Burden	6,099	$378,117.33

1. Assumes hours per occurrence is the same as that in the 1998 ICR, except burden for review of a minor source revised to be consistent with other exhibits
2. Assumes these activities required with all new permittees
3. Assumes all new permits are major source permits because all permitting at this time is for construction/operation. Note this step includes drafting permits, fact sheets, public notice, hearing, and response to comments.
4. Assumes that all new major source permittees also incorporate operating permit requirements at the same time
5. Assumes these activities required with all new and existing permittees
6. This step includes the time required for developing the draft permit, the statement of basis, and responding to comments received from a public notice.

Sheet 16: Ex12 (Prod)

EXHIBIT 12. NEW AND PREVIOUSLY PERMITTED DEVELOPMENT/PRODUCTION SOURCES UNDER EPA AUTHORITY
EPA'S ANNUAL BURDEN

Collection Activities	Number of Respondents	Number of Occurrences for 3 years	Occurrences per year	Hours per Occurrence*	Costs per Occurrence	Total Hours per Year	Total Cost per Year
Labor Rate					*$62.00*
Consult with sources	1.0	1	0.33	5	$310.00	2	$103.33
Conduct inspections	1.0	12	4.00	16	$992.00	64	$3,968.00
Review NOI to construct and permit application	1.0	1	0.33	263	$16,306.00	88	$5,435.33
Oversee intial and annual compliance test	1.0	3	1.00	67	$4,154.00	67	$4,154.00
Review operating permit application	5.4	1	1.80	40	$2,480.00	72	$4,464.00
Review data reports	1.0	3	1.00	8	$496.00	8	$496.00
Decomissioning1	0.0	1	0.00	76	$4,712.00	0	$0.00
					Burden	300	$18,620.67

1. Decommissioning is guestimated to result in 59 hrs of burden per occurrence which would involve reviewing request for decommissioning (8hrs), reviewing permit application (35 hrs) and conducting inspections (16 hrs).

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

Sheet 17: Ex13

EXHIBIT 13. CONSISTENCY UPDATES AND OVERSEEING STATE/LOCAL ACTIVITIES
EPA'S ANNUAL BURDEN

Collection Activities	Number of Respondents	Number of Occurrences for 3 years	Occurrences per year	Hours per Occurrence*	Cost per Occurrence	Total Hours per Year	Total Cost per Year
Labor Rate					*$62.00*
Annual Consistency Reviews	14	3	14.00	40	2,480.00	560	$34,720.00
Major NOI/Regulatory Changes Review	2	1	0.67	150	9,300.00	100	$6,200.00
Minor NOI/Regulatory Changes Review	7	1	2.33	40	2,480.00	93	$5,786.67
					Burden	753	$46,706.67

* Assumes hours per occurrence is the same as that in the 1998 ICR, except we have added concept of "minor" review
See supporting statement for explanation of Number of Respondents

Sheet 18: Ex14

EXHIBIT 14. OCS AIR REGULATIONS INFORMATION COLLECTION BURDEN
SUMMARY OF ANNUAL BURDENS AND COSTS
	Current ICR									Previously Approved (EPA ICR ID# 1601.10) Updated to Correct Methodology									Change in Burden
	Responses	Respondent Hours	Respondent Labor Costs	O&M Costs	Capital Costs	Agency Hours	Agency Costs	Total Costs		Responses	Respondent Hours	Respondent Labor Costs	O&M Costs	Capital Costs	Agency Hours	Agency Costs	Total Costs		Responses	Respondent Hours	Respondent Labor Costs	O&M Costs	Capital Costs	Agency Hours	Agency Costs	Total Costs
New and Previously Permitted Exploration Sources under EPA Authority (Exhibit 1)	3.0	109	$11,043	$38,052	$0	n/a	n/a	$49,094.67	New and Previously Permitted Exploration Sources under EPA Authority (Exhibit 1)	3.3	220	$20,460	$129,880	$0	n/a	n/a	$150,340.00	New and Previously Permitted Exploration Sources under EPA Authority (Exhibit 1)	-0.3	(111)	($9,417)	($91,828)	$0	n/a	n/a	$(101,245.33)
New and Previously Permitted Alternative Energy Sources under EPA Authority (Exhibit 2)	82.3	2,968	$299,768	$287,712	$0	n/a	n/a	$587,480.00	New and Previously Permitted Alternative Energy Sources under EPA Authority (Exhibit 2)	12.0	356	$1,151,526	$29,886	$0	n/a	n/a	$1,181,412.00	New and Previously Permitted Alternative Energy Sources under EPA Authority (Exhibit 2)	70.3	2,612	-$851,758	$257,826	$0	n/a	n/a	$(593,932.00)
New and Previously Permitted Development / Production Sources under EPA Authority (Exhibit 3)	14.1	862	$87,089	$119,827	$325,104	n/a	n/a	$532,020.18	New and Previously Permitted Development / Production Sources under EPA Authority (Exhibit 3)	0.0	0	$0	$0	$0	n/a	n/a	$-	New and Previously Permitted Development / Production Sources under EPA Authority (Exhibit 3)	14.1	862	$87,089	$119,827	$325,104	n/a	n/a	$532,020.18
New and Previously Permitted Exploration Sources under State/Local Authority (Exhibit 4)	0.0	0	$0	$0	$0	n/a	n/a	$0.00	New and Previously Permitted Exploration Sources under State/Local Authority (Exhibit 4)	0.0	0	$0	$0	$0	n/a	n/a	$-	New and Previously Permitted Exploration Sources under State/Local Authority (Exhibit 4)	0.0	0	$0	$0	$0	n/a	n/a	$-
New and Previously Permitted Alternative Energy Sources under State/Local Authority (Exhibit 5)	11.0	392	$39,592	$44,092	$162,552	n/a	n/a	$246,235.60	New and Previously Permitted Alternative Energy Sources under State/Local Authority (Exhibit 5)	14.3	412	$38,316	$49,810	$0	n/a	n/a	$88,126.00	New and Previously Permitted Alternative Energy Sources under State/Local Authority (Exhibit 5)	-3.3	(20)	$1,276	-$5,718	$162,552	n/a	n/a	$158,109.60
Existing Development / Production Sources under State/Local Authority (Exhibit 6)	55.1	4,365	$440,858	$2,040,396	$0	n/a	n/a	$2,481,254.75	Existing Development / Production Sources under State/Local Authority (Exhibit 6)	34.3	2,639	$174,313	$1,210,340	$0	n/a	n/a	$1,384,653.42	Existing Development / Production Sources under State/Local Authority (Exhibit 6)	20.8	1,726	$266,545	$830,056	$0	n/a	n/a	$1,096,601.33
Subtotal of Industry Burden (rounded)	166	8,697	$878,350	$2,530,079	$487,656	n/a	n/a	$3,896,085	Subtotal of Industry Burden (rounded)	64	3,627	$1,384,615	$1,419,916	$0	n/a	n/a	$2,804,531.00	Subtotal of Industry Burden (rounded)	102	5,069	($506,265)	$1,110,163	$487,656	n/a	n/a	$1,091,554

New and Previously Permitted Exploration Sources Under State/Local Authority (Exhibit 7)	0	0	$0	$0.00	$0.00	n/a	n/a	$0.00	New and Previously Permitted Exploration Sources Under State/Local Authority (Exhibit 7)	0.0	0	$0	$0.00	$0.00	n/a	n/a	$-	New and Previously Permitted Exploration Sources Under State/Local Authority (Exhibit 7)	0.0	0	$0	$0.00	$0.00	n/a	n/a	$-
New and Previously Permitted Alternative Energy Sources under State/Local Authority (Exhibit 8)	13	770	$70,840	$0.00	$0.00	n/a	n/a	$70,840.00	New and Previously Permitted Alternative Energy Sources under State/Local Authority (Exhibit 8)	17.0	657	$43,384	$0.00	$0.00	n/a	n/a	$43,384.00	New and Previously Permitted Alternative Energy Sources under State/Local Authority (Exhibit 8)	13.0	770	$70,840	$0.00	$0.00	n/a	n/a	$27,456.00
Existing Development/ Production Sources under State/Local Authority (Exhibit 9)	151	3,695	$339,909	$0.00	$0.00	n/a	n/a	$339,909.33	Existing Development/ Production Sources under State/Local Authority (Exhibit 9)	93.7	2,228	$147,070	$0.00	$0.00	n/a	n/a	$147,070.00	Existing Development/ Production Sources under State/Local Authority (Exhibit 9)	151.1	3,695	$0	$0.00	$0.00	n/a	n/a	$192,839.33
Subtotal of State/Local Burden (rounded)	164	4,465	$410,749	$0	$0	n/a	n/a	$410,749	Subtotal of State/Local Burden (rounded)	111	2,886	$190,454.00	$0.00	$0.00	n/a	n/a	$190,454.00	Subtotal of State/Local Burden (rounded)	164	4,465	$70,840	$0	$0	n/a	n/a	$220,295.00

New and Previously Permitted Exploration Sources under EPA Authority (Exhibit 10)	n/a	n/a	n/a	n/a	n/a	138	$8,577		New and Previously Permitted Exploration Sources under EPA Authority (Exhibit 10)	n/a	n/a	n/a	n/a	n/a	125	$7,000		New and Previously Permitted Exploration Sources under EPA Authority (Exhibit 10)	n/a	n/a	n/a	n/a	n/a	13	1,577
New and Previously Permitted Alternative Energy Sources under EPA Authority (Exhibit 11)	n/a	n/a	n/a	n/a	n/a	6,099	$378,117		New and Previously Permitted Alternative Energy Sources under EPA Authority (Exhibit 11)	n/a	n/a	n/a	n/a	n/a	364	$29,344		New and Previously Permitted Alternative Energy Sources under EPA Authority (Exhibit 11)	n/a	n/a	n/a	n/a	n/a	5,735	348,773
New and Previoulsy Permitted Development/ Production Sources under EPA Authority (Exhibit 12)	n/a	n/a	n/a	n/a	n/a	300	$18,621		New and Previoulsy Permitted Development/ Production Sources under EPA Authority (Exhibit 12)	n/a	n/a	n/a	n/a	n/a	0	$0		New and Previoulsy Permitted Development/ Production Sources under EPA Authority (Exhibit 12)	n/a	n/a	n/a	n/a	n/a	300	18,621
Consistency Updates (Exhibit 13)						753	$46,707		Consistency Updates (Exhibit 13)						0	$0		Consistency Updates (Exhibit 13)						0	$0
Subtotal of EPA Burden	n/a	n/a	n/a	n/a	n/a	7,291	$452,021		Subtotal of EPA Burden	n/a	n/a	n/a	n/a	n/a	489	$36,344		Subtotal of EPA Burden	n/a	n/a	n/a	n/a	n/a	6,048	$368,971

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