1
SUPPORTING
STATEMENT
FOR
STANDARD
FORM
83­
I
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
TITLE
AND
NUMBER
OF
THE
INFORMATION
COLLECTION
Modifications
to
Standards
and
Requirements
for
Reformulated
and
Conventional
Gasoline
Including
Butane
Blenders
and
Attest
Engagements.
Current
OMB
control
number
is
2060­
0277.
The
EPA
number
for
these
modifications
is
1591.16.

(
b)
SHORT
CHARACTERIZATION/
ABSTRACT
Section
211(
k)
of
the
Clean
Air
Act
("
Act")
mandates
a
complex
reformulated
gasoline
program
requiring
that
reformulated
gasoline
(
RFG)
which
meets
various
requirements
be
exclusively
sold
in
nine
statutory
control
areas
and
in
other
ozone
nonattainment
areas
that
"
optin
to
the
reformulated
gasoline
program.
The
Act
also
requires
EPA
to
regulate
the
production
and
sale
of
conventional
gasoline
(
non­
RFG)
throughout
the
rest
of
the
country.
Refiners
and
importers
of
gasoline
are
required
to
demonstrate
compliance
by
conducting
sampling
and
testing
of
the
gasoline
and
reporting
the
results
to
EPA's
Office
of
Mobile
Sources.
The
burden
and
cost
estimates
in
this
ICR
are
those
costs
associated
with
modifications
to
the
final
rule
establishing
standards
and
requirements
for
reformulated
and
conventional
gasoline
pursuant
to
§
211(
k)
of
the
Act.
Previous
ICRs
have
covered
start
up
costs
and
other
record
keeping,
reporting,
and
testing
requirements
associated
with
the
final
rule.

This
direct
final
and
associated
proposed
rule
make
minor
revisions
to
the
RFG
and
conventional
gasoline
regulations
and
provides
regulated
parties
with
additional
flexibility
to
comply
with
the
regulations.
Most
of
the
revisions
will
not
result
in
any
additional
reporting,
recordkeeping
or
testing
burdens.
Some
of
the
provisions
that
provide
additional
flexibility
for
regulated
parties
necessitate
modest
recordkeeping
and
reporting
requirements.
One
of
these
revisions,
regarding
gasoline
treated
as
blendstock
(
GTAB),
provides
industry
with
greater
flexibility
regarding
certain
gasoline
processing
activities,
but
necessitates
some
additional
information
collection
requirements
for
parties
who
avail
themselves
of
this
flexibility.
Another
revision
allows
parties
to
blend
butane
into
finished
gasoline
without
performing
the
sampling
and
testing
normally
required
for
refiners
if
certain
requirements
are
met.
This
flexibility
for
butane
blenders
also
requires
some
additional
information
collection
requirements.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
(
a)
NEED/
AUTHORITY
FOR
THE
COLLECTION
The
basic
need
and
authority
for
the
collection
of
information
have
been
established
in
the
2
ICR
for
the
RFG
final
rule.
The
Act
specifically
provides
that
record
keeping
and
sampling
and
testing
requirements
are
among
the
tools
EPA
may
use
in
enforcement
of
the
provisions
of
§
211(
k)
and
also
provides
that
EPA
must
develop
an
enforceable
scheme.
Sections
114
and
208
of
the
Act
authorize
EPA
to
require
record
keeping
and
reporting
regarding
enforcement
of
the
provisions
of
Title
II
of
the
Act.
The
additional
information
collection
required
in
these
revisions
to
the
RFG
final
rule
is
necessary
to
ensure
that
sources
comply
with
the
standards
and
limitations
of
the
rules
for
RFG
and
conventional
gasoline.

(
b)
PRACTICAL
UTILITY/
USERS
OF
THE
DATA
The
practical
utility
and
use
of
the
collection
of
information
under
the
RFG
rule
generally
has
been
established
in
the
ICR
for
the
RFG
final
rule.

The
information
collection
requirements
associated
with
the
provisions
for
GTAB
and
butane
blenders
are
necessary
enforcement
mechanisms
to
ensure
that
the
increased
flexibility
allowed
by
these
provisions
will
not
result
in
any
environmental
degradation.

The
EPA's
Office
of
Enforcement
and
Compliance
Assurance
and
EPA's
Office
of
Air
and
Radiation,
Office
of
Transportation
and
Air
Quality,
will
be
the
governmental
users
of
the
information
contained
in
the
information
collection.
In
addition,
the
required
information
collection
is
necessary
for
parties
to
track
their
own
compliance
with
applicable
standards.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
(
a)
NONDUPLICATION
The
information
collection
is
not
unnecessarily
duplicative
of
information
otherwise
reasonably
accessible
to
the
Agency
and
is
not
available
from
other
sources.
The
collection
activities
associated
with
these
revisions
are
approved
under
the
ICR
for
the
final
RFG
rule.

(
b)
PUBLIC
NOTICE
REQUIRED
PRIOR
TO
ICR
SUBMISSION
TO
OMB
Notice
of
most
of
the
information
collection
changes
to
the
reformulated
gasoline
regulations
resulting
from
this
rulemaking
were
published
in
the
preamble
to
the
proposed
rule
at
62
FR
37338,
at
37374
(
July
11,
1997).
EPA
received
no
comments
on
the
proposed
information
collection
changes.
A
few
additional
modest
information
collection
requirements
are
included
in
this
rulemaking.

(
b)
CONSULTATIONS
Representatives
from
the
affected
industry
participated
in
the
development
of
the
provisions
in
this
rule.
The
primary
industry
contacts
were
representative
from
the
American
Petroleum
Institute
and
the
National
Petroleum
Refiners
Association.
3
Public
comments
on
this
action
are
addressed
in
the
final
rulemaking
package.

(
c)
EFFECTS
OF
LESS
FREQUENT
COLLECTION
If
the
relevant
information
were
collected
less
frequently,
EPA
would
not
be
reasonably
assured
that
the
refiner
or
importer
is
in
compliance
with
the
standards
for
RFG
and
conventional
gasoline.

(
d)
GENERAL
GUIDELINES
The
general
guidelines
for
the
collection
of
information
pursuant
to
the
RFG
rule
are
approved
in
the
ICR
for
the
final
RFG
rule.

(
e)
CONFIDENTIALITY
AND
SENSITIVE
QUESTIONS
(
i)
Confidentiality
Any
information
submitted
to
EPA
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
EPA
regulations
at
40
C.
F.
R.
2.201
et.
seq.

(
ii)
Sensitive
Questions
This
section
is
not
applicable
as
this
ICR
does
not
involve
matters
of
a
sensitive
nature.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
(
a)
RESPONDENTS/
SIC
CODES
Respondents
are
refiners
(
2911)
and
importers
(
5172)
of
RFG
and
conventional
gasoline.
Some
of
the
required
information
collection
is
generated
and
currently
maintained
in
the
normal
course
of
business.
Without
the
required
information,
EPA
will
be
unable
to
ensure
compliance
with
the
RFG
and
conventional
gasoline
standards.

(
b)
INFORMATION
REQUESTED
(
i)
Data
Items,
Including
Record
keeping
Requirements
(
1)
The
provisions
providing
flexibility
for
blending
GTAB
require
importers
to
maintain
documents
that
reflect
the
physical
movement
of
the
gasoline
to
the
point
of
blending
to
produce
RFG
and
identify
GTAB
as
such
on
batch
reports
to
EPA.
The
GTAB
option
requires
the
GTAB
to
be
tested
initially
as
an
imported
product
and
then
tested
after
blending.

(
2)
The
provisions
providing
sampling
and
testing
flexibility
for
parties
who
blend
butane
4
into
RFG
and
conventional
gasoline
require
such
parties
to
maintain
documents
that
reflect
the
volume
and
quality
of
the
butane
and
compliance
with
requirements
for
assuring
that
the
minimum
level
of
oxygen
content
in
RFG
is
maintained.
Parties
who
blend
butane
under
this
flexibility
are
required
to
report
the
volume
and
quality
of
the
butane
and
the
blended
gasoline,
and
the
weight
percent
oxygen
differential
between
the
RFG
prior
to
and
subsequent
to
the
butane
blending
on
batch
reports
to
EPA.
Annual
reports
currently
are
required
under
the
RFG
regulations.
Under
this
rulemaking,
parties
who
blend
butane
are
required
to
include
in
their
annual
reports
the
total
volume
of
butane
used,
the
total
volume
of
gasoline
produced
using
butane,
and
for
butane
blended
into
RFG,
information
regarding
oxygen
content
of
the
RFG.

(
ii)
Respondent
Activities
The
information
collection
activities
for
record
keeping
and
reporting
are
as
described
in
the
approved
ICR
for
the
RFG
final
rule.

5.
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY
AND
INFORMATION
MANAGEMENT
(
a)
AGENCY
ACTIVITIES
The
burden
on
the
Agency
is
not
expected
to
increase
as
a
result
of
this
rule.

(
b)
COLLECTION
METHODOLOGY
AND
MANAGEMENT
There
are
no
significant
changes
to
the
collection
methodologies
in
the
ICR
for
the
RFG
final
rule
anticipated
as
a
result
of
these
revisions
to
the
rule.

(
c)
SMALL
BUSINESS
FLEXIBILITY
This
action
provides
flexibility
for
certain
refiners
and
importers,
including
small
business
refiners
and
importers.
The
flexibility
regarding
GTAB
will
allow
importers
to
treat
finished
gasoline
as
blendstock
to
provide
flexibility
to
correct
off­
spec
imported
gasoline.
The
provisions
regarding
butane
blending
simplify
the
sampling
and
testing
requirements
for
refiners
who
produce
gasoline
by
blending
butane.
This
action
also
eliminates
the
requirement
for
refiners
of
conventional
gasoline
who
also
import
gasoline
to
calculate
a
special
baseline
for
their
imported
gasoline,
and
modifies
the
requirements
for
every­
batch
testing
of
gasoline
imported
by
truck.
In
addition,
this
action
makes
the
attest
engagement
procedures
more
efficient.
Other
provisions
will
aid
refiners
and
importers
by
clarifying
and
providing
additional
guidance
with
regard
to
existing
requirements.
Any
increase
in
the
information
collection
requirements
necessitated
by
the
increased
flexibility
associated
with
the
use
of
GTAB
and
butane
blending
will
be
more
than
offset
by
the
savings
to
refiners
and
importers
resulting
from
this
additional
flexibility.

(
d)
COLLECTION
SCHEDULE
5
The
collection
schedule
contained
in
the
ICR
for
the
RFG
final
rule
would
apply
to
the
information
collection
in
these
proposed
revisions.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
(
a)
ESTIMATING
RESPONDENT
BURDEN
Three
labor
categories
are
involved
with
this
rulemaking:
managerial
(
includes
legal
and
professional
review),
technical,
and
clerical.
The
labor
mix
for
each
hour
for
each
of
the
activities
in
this
ICR
is
assumed
to
be
about
0.1
hour
managerial,
0.7
hour
technical,
and
0.2
hour
clerical.

The
increased
recordkeeping/
reporting
burden
on
importers
who
use
the
GTAB
option
is
estimated
to
be
minimal,
approximately
3
minutes
per
batch
report.
EPA
estimates
that
the
burden
would
average
one
hour
per
importer.
(
Approximately
26%,
or
1.6
billion
gallons,
of
imported
gasoline
nationwide
is
GTAB
=
800
batches
(
assuming
an
average
of
2
million
gallons
per
batch)
x
3
min/
report
=
40
hours
÷
40
importers.)
The
provision
for
GTAB
requires
the
product
to
be
sampled
and
tested
initially
as
imported
product
and
tested
again
after
it
is
blended.
This
additional
sampling
and
testing
would
require
approximately
33.4
hours
per
importer
(
1.67
hrs/
batch
x
20
batches
per
importer.)
It
should
be
noted,
however,
that
there
is
no
requirement
to
use
the
GTAB
option.
The
provision
for
GTAB
was
requested
by
industry
and
provides
industry
with
additional
flexibility
in
blending
gasoline.
Any
burdens
associated
with
using
the
GTAB
provision
are
far
outweighed
by
the
savings
to
industry
gained
from
the
additional
flexibility
provided
by
the
GTAB
option.
The
GTAB
option
has
been
allowed
under
guidance
(
Reformulated
Gasoline
and
Anti­
Dumping
Questions
and
Answers
(
February
6,
1995).
Experience
has
shown
that
this
option
is
effective
in
providing
importers
appropriate
flexibility
and
that
the
associated
requirements
have
been
effective
in
preventing
compliance
difficulties.

The
increased
recordkeeping/
reporting
burden
on
parties
who
use
the
butane
blending
flexibility
afforded
in
this
rule
is
estimated
to
be
minimal,
approximately
5
minutes
per
batch
report
and
5
minutes
per
annual
report.
EPA
estimates
that
the
burden
would
average
65
minutes
per
party,
based
on
an
estimate
of
12
batches
per
year
plus
one
annual
report
(
13
x
5
=
65
minutes).
It
should
be
noted
that
the
provision
for
butane
blending
was
requested
by
industry.
Any
burdens
associated
with
using
the
butane
blending
provision
are
greatly
outweighed
by
the
savings
to
industry
gained
from
the
additional
flexibility
to
blend
butane
without
performing
the
sampling
and
testing
which
would
otherwise
be
required
under
the
regulations.
This
approach
has
been
allowed
for
parties
who
blend
butane
into
conventional
gasoline
under
guidance
(
Reformulated
Gasoline
and
Anti­
dumping
Questions
and
Answers
(
October
3,
1994).
Experience
has
shown
that
this
approach
is
effective
in
providing
butane
blenders
appropriate
flexibility
and
that
the
associated
requirements
have
been
effective
in
preventing
compliance
difficulties.

(
b)
ESTIMATING
RESPONDENT
COST
6
According
to
the
Bureau
of
Labor
Statistics,
Employment
Cost
Trends
(
March
1996),
for
all
workers
in
manufacturing
industries,
wages
and
benefits
were:

Wages
and
Benefits
Managerial
$
37.72
per
hour
Technical
$
27.90
per
hour
Clerical
$
16.69
per
hour
Doubling
for
company
overhead
beyond
wages
and
benefits,
employing
a
3%
annual
inflation
factor
to
bring
the
rates
to
2000,
and
for
convenience,
rounding
to
the
dollar,
gives
the
following
rates
for
this
ICR:

Total
Employer
Cost
Managerial
$
86
per
hour
Technical
$
64
per
hour
Clerical
$
38
per
hour
Assuming
the
labor
mix
for
each
activity
described
above,
this
gives
an
average
labor
cost
of
about
$
60
per
hour
for
the
activities
in
this
rulemaking.

The
recordkeeping/
reporting
cost
to
importers
who
use
the
provision
for
GTAB
is
estimated
to
average
$
60
per
year
per
importer
($
60/
hr
x
1
hr.
per
importer.)
The
estimated
cost
associated
with
the
increased
sampling
and
testing
required
for
using
GTAB
is
approximately
$
2,000
per
importer
($
100/
test
(
1.67
hr/
test
x
$
60/
hr)
x
20
batches
(
tests)
per
importer.)
As
noted
in
(
a)
above,
the
GTAB
provision
was
requested
by
industry
and
there
is
no
requirement
to
use
GTAB
for
gasoline
blending.
Any
costs
associated
with
the
use
of
GTAB
are
greatly
outweighed
by
the
savings
which
industry
will
derive
from
the
additional
flexibility
afforded
by
the
GTAB
provision.

The
recordkeeping/
reporting
cost
to
parties
who
use
the
provision
for
butane
blending
is
estimated
to
average
$
65
per
year
per
party
($
60/
hr
x
65
minutes
per
party).
As
noted
in
(
a)
above,
the
butane
blending
provision
was
requested
by
industry.
Any
costs
associated
with
the
use
of
the
butane
blending
provision
are
greatly
outweighed
by
the
savings
which
industry
will
derive
from
the
additional
flexibility
afforded
by
the
butane
blending
provision.

There
are
no
capital/
start­
up
costs
associated
with
this
information
collection.

(
c)
ESTIMATING
AGENCY
BURDEN
AND
COST
Insignificant
additional
Agency
costs
are
anticipated
with
regard
to
the
provisions
for
GTAB
and
butane
blending.
7
(
d)
ESTIMATING
THE
RESPONDENT
UNIVERSE
AND
TOTAL
BURDEN
AND
COSTS
The
total
annual
information
collection
burden
on
industry
associated
with
this
rule
is
estimated
to
be
1398
hours.
The
total
annual
respondent
cost
associated
with
this
rule
is
estimated
to
be
$
83,860.

(
e)
BOTTOM
LINE
BURDEN
HOURS
AND
COSTS
The
bottom
line
burden
hours
and
costs
for
the
respondents
and
the
Agency
are
as
given
in
the
tables
below:

TABLE
1.
Refiner/
Importer
Information
Collection
Information
Collection
Activity
Mgr.
Hr/
Yr
($
86/
hr)
Tech.
Hr/
Yr
($
64/
hr)
Cler.
Hr/
Yr
($
38/
hr)
Resp.
Hr/
Yr
Resp.
Cost/
Yr
Capital
Startup
Cost
O&
M
Cost
No.
of
Resp.
Total
Hr/
Yr
Total
Cost/
Yr
GTAB
Reporting
0.10
0.70
0.20
1.00
$
60
0
Negl.
40
40
$
2,400
GTAB
Testing
33.20
0.20
33.40
$
2,004
0
Negl.
40
1336
$
80,160
Butane
Blending
Reporting
0.10
0.78
0.20
1.08
$
65
0
Negl.
20
22
$
1,300
TOTAL
1398
$
83,860
(
f)
REASON
FOR
CHANGE
IN
BURDEN
These
changes
to
the
existing
ICR
for
the
RFG
final
rule
are
to
ensure
compliance
with
the
RFG
regulations
and
provide
adequate
enforcement
tools.
The
analysis
in
previous
sections
outlines
as
necessary
the
changes
from
the
current
ICR.

(
g)
BURDEN
STATEMENT
The
annual
public
reporting,
record
keeping
and
compliance
testing
burden
for
this
collection
of
information
is
estimated
to
average:

One
hour
per
response,
and
$
60
per
respondent,
for
recordkeeping/
reporting
for
importers
who
use
the
GTAB
option;
thirty­
three
hours
per
response,
and
$
2000
per
respondent,
for
testing
product
produced
using
GTAB;
sixty­
five
minutes
per
response,
and
$
65
per
respondent,
for
blending
butane
into
gasoline.
8
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
EPA­
HQ­
OAR­
2003­
0019,
which
is
available
for
online
viewing
at
www.
regulations.
gov,
or
in
person
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
NW,
Washington,
D.
C.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Air
and
Radiation
Docket
and
Information
Center
is
(
202)
566­
1742.
An
electronic
version
of
the
public
docket
is
available
at
www.
regulations.
gov.
This
site
can
be
used
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
When
in
the
system,
select
"
search,"
then
key
in
the
Docket
ID
Number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
D.
C.
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
Number
EPA­
HQOAR
2003­
0019
and
OMB
Control
Number
2060­
0277
in
any
correspondence.

B.
COLLECTION
OF
INFORMATION
EMPLOYING
STATISTICAL
METHODS
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
the
data
collection
associated
with
the
reformulated
and
anti­
dumping
regulations.
