SUPPORTING
STATEMENT
FOR
INFORMATION
COLLECTION
REQUEST
RENEWAL:

"
INFORMATION
COLLECTION
ACTIVITIES
ASSOCIATED
WITH
EPA'S
MOBILE
AIR
CONDITIONER
RETROFITTING
PROGRAM"

EPA
ICR
No.
1774.03
24
June
2003
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
and
Number
of
the
Information
Collection
This
ICR
is
entitled
"
Information
Collection
Activities
Associated
with
EPA's
Mobile
Air
Conditioner
Retrofitting
Program,"
EPA
ICR
Number
1774.03,
and
OMB
Number
2060­
0350.

1(
b)
Short
Characterization
In
1994,
the
Significant
New
Alternatives
Policy
(
SNAP)
Program
was
enacted,
enabling
the
Agency
to
review
available
substitutes
for
ozone
depleting
substances
(
ODSs)
and
determine
their
acceptability.
The
Global
Programs
Division
(
GPD)
is
responsible
for
enacting
regulations
to
phase
out
chemicals
which
damage
the
stratospheric
ozone
layer
and
therefore
pose
a
threat
to
human
health
and
the
environment.
Depletion
of
stratospheric
ozone
can
result
in
sharp
increases
in
melanoma
and
non­
melanoma
cancers
due
to
increased
exposure
to
ultraviolet­
A
(
UVA)
and
ultraviolet­
B
(
UVB)
radiation,
and
a
higher
incidence
of
cataracts
(
a
leading
cause
of
blindness).
Under
the
SNAP
program,
companies
submit
applications
for
review
by
the
GPD.
After
all
necessary
information
is
received,
GPD
has
90
days
to
review
the
product
data
submitted,
and
determine
if
the
substitute
is
acceptable,
unacceptable,
or
if
its
use
must
be
restricted.
GPD
is
reviewing
these
substitutes
for
their
impact
on
human
health
and
the
environment,
looking
at
factors
including
ozone
depleting
potential,
atmospheric
lifetime,
global
warming
potential,
and
flammability.
Many
substitutes
are
produced
for
multiple
uses,
and
GPD
must
determine
what
uses
are
appropriate,
and
under
what
conditions.
EPA
does
not
evaluate
the
efficacy
of
the
product
to
achieve
the
results
the
manufacturer
intended.
When
GPD
makes
a
decision
that
substitutes
are
acceptable,
a
Notice
is
published
in
the
Federal
Register
listing
them.
If
the
substitute
is
found
unacceptable
or
use
restrictions
are
necessary,
a
notice­
and­
comment
rulemaking
is
necessary
to
impose
those
restrictions.
The
list
of
substitutes
is
cumulative,
with
revisions
to
the
list
made
periodically.
A
comprehensive
list
of
substitutes,
their
uses,
and
any
relevant
restrictions
is
maintained
for
distribution
to
interested
parties.

GPD
is
requiring
those
retrofitting
motor
vehicle
air
conditioners
to
use
a
substitute
refrigerant
to
provide
some
basic
information
on
a
label
to
be
affixed
to
the
air
conditioner.
The
label
will
include
information
as
to
the
substitute
refrigerant,
when
and
by
whom
the
retrofit
was
performed,
environmental
and
safety
information
about
the
substitute
refrigerant,
and
other
information.
This
information
is
needed
so
that
other
technicians
will
be
able
to
service
the
equipment
properly,
decreasing
the
likelihood
of
significant
refrigerant
cross­
contamination
and
potential
failure
of
both
air
conditioning
systems
and
recovery/
recycling
equipment.

EPA
estimates
that
87,000
technicians
will
be
responsible
for
providing
this
information
over
the
next
3
years,
at
a
total
cost
(
labor
plus
materials)
of
$
17,800,000.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need
and
Authority
for
the
Collection
The
SNAP
program
includes
review
of
potential
alternatives
to
ozone­
depleting
refrigerants
used
for
air
conditioning
motor
vehicles.
With
the
phase
out
of
chlorofluorocarbons
(
CFCs),
and
specifically
CFC­
12,
GPD
faces
the
challenge
of
identifying
acceptable
alternative
refrigerants
to
allow
consumers
the
choice
to
retrofit
CFC­
12
motor
vehicle
air
conditioners
to
those
alternatives.
EPA
notes
that
in
the
U.
S.,
prior
to
the
1993
model
year,
most
all
motor
vehicle
air
conditioners
used
CFC­
12,
and
that
after
the
1995
model
year,
all
new
motor
vehicles
with
air
conditioners
used
HFC­
134a.
EPA
estimates
that
there
are
currently
approximately
33
million
motor
vehicle
air
conditioners,
originally
designed
to
use
CFC­
12,
operating
in
the
U.
S.
Of
these,
EPA
estimates
3
million,
or
about
9%,
will
be
retrofitted
to
use
alternative
refrigerants
between
October
1,
2003
and
September
30,
2006
(
the
term
of
this
ICR).
The
remaining
air
conditioners
either
(
1)
will
continue
to
operate
without
service,
(
2)
will
continue
to
operate
with
minor
service
including
refilling
with
available
supplies
of
CFC­
12,
(
3)
will
be
disposed
of
along
with
the
entire
motor
vehicle,
(
4)
will
cease
to
function
but
will
not
be
retrofitted
due
to
economic
reasons,
or
(
5)
have
already
been
retrofitted
to
an
alternative
refrigerant
and
will
not
be
retrofitted
again.

The
purpose
of
this
Information
Collection
Request
(
ICR)
is
to
estimate
the
burden
associated
with
the
40
Code
of
Federal
Regulations
(
CFR)
Part
82
requirement
that
service
technicians
label
mobile
air
conditioners
with
information
about
new
refrigerants
when
they
retrofit
a
system.
It
is
necessary
to
assess
the
time
it
will
take
for
the
service
technician
to
fill
out,
sign,
date,
and
place
the
label
on
the
retrofitted
air
conditioner.
This
label
will
acknowledge
that
the
retrofitting
has
been
completed,
and
that
the
mobile
air
conditioner
should
no
longer
use
CFC
refrigerant.
In
addition,
the
labels
provide
essential
information
to
technicians
about
the
specific
refrigerant
used
in
the
air
conditioning
system.

Section
612
of
the
Clean
Air
Act
(
CAA)
requires
EPA
to
promulgate
rules
making
it
unlawful
to
replace
any
ozone­
depleting
substance
with
any
substitute
that
the
Administrator
determines
may
present
adverse
effects
to
human
health
or
the
environment
where
the
Administrator
has
identified
an
alternative
that
(
1)
reduces
the
overall
risk
to
human
health
and
the
environment,
and
(
2)
is
currently
or
potentially
available.
EPA
is
concerned
that
the
existence
of
several
substitutes
in
this
end­
use
may
increase
the
likelihood
of
significant
refrigerant
cross­
contamination
and
potential
failure
of
both
air
conditioning
systems
and
recovery/
recycling
equipment.
In
addition,
continuing
the
smooth
transition
to
the
use
of
substitutes
strongly
depends
on
the
continued
purity
of
the
recovered,
recycled
and/
or
reclaimed
R­
12
supply.

2(
b)
Use
and
Users
of
the
Data
The
purpose
of
the
label
is
to
alert
service
technicians
and
motor
vehicle
owners
that
the
motor
vehicle
air
conditioner
has
been
retrofitted
to
use
non­
CFC
refrigerant.
The
label
will
provide
essential
information
to
technicians
about
the
specific
refrigerant
used
in
the
air
conditioning
system.
This
information
will
assist
the
technician
in
avoiding
service
practices
that
might
result
in
refrigerant
cross­
contamination
and
system
failure.
As
the
stores
of
CFC
refrigerant
are
depleted,
vehicles
are
being
retrofitted
to
use
alternative
refrigerants.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
The
required
label
is
put
on
CFC­
12
air
conditioners
that
are
being
retrofitted
with
an
acceptable
substitute.
The
label
will
be
the
only
mechanism
to
indicate
the
use
of
a
substitute,
and
therefore
will
not
be
duplicative.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
A
Federal
Register
Notice
making
this
supporting
statement
available
for
public
comment
was
submitted
for
publication.

3(
c)
Consultations
EPA
consulted
with
the
following
individuals
in
preparing
this
ICR
renewal:

°
Ward
Atkinson,
Sun
Test
Engineering,
480­
994­
9299,
regarding
the
number
of
air
conditioners
likely
to
be
retrofitted,
the
number
of
technicians
likely
to
be
affected,
and
the
cost
burden.
°
Tony
Molla,
National
Institute
for
Automotive
Service
Excellence,
703­
669­
6600,
regarding
the
number
of
technicians
likely
to
be
affected.
°
Marian
Martin
Van
Pelt
and
Katrin
Peterson,
ICF
Consulting,
202­
862­
1200,
regarding
the
number
of
air
conditioners
likely
to
be
retrofitted.

3(
d)
Effects
Of
Less
Frequent
Collection
This
ICR
asks
for
information
to
be
collected
just
once
per
motor
vehicle
air
conditioner
retrofit.

3(
e)
General
Guidelines
This
ICR
follows
all
of
OMB's
general
guidelines
for
information
collections.

3(
f)
Confidentiality
This
ICR
does
not
ask
for
any
information
that
would
be
considered
confidential.

3(
g)
Sensitive
Questions
This
ICR
does
not
ask
any
questions
concerning
sexuality,
religious
beliefs,
or
other
matters
usually
considered
private.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents
and
SIC
Codes
The
following
is
a
list
of
Standard
Industrial
Classification
(
SIC)
codes
and
associated
industries
that
may
retrofit
a
motor
vehicle
air
conditioner
and
therefore
may
be
affected
by
information
collection
requirements
covered
under
this
ICR:

551
New
and
used
car
dealers
554
Gas
service
stations
7532PT
Top
and
body
repair
shops
7538
General
automotive
repair
shops
7539
Automotive
repair
shops
not
elsewhere
classified,
including
air
conditioning
and
radiator
specialty
shops
4(
b)
Information
Requested
The
Agency
will
not
standardize
the
label,
but
rather
allow
the
industry
to
devise
a
format
that
accommodates
information
about
the
refrigerants
on
the
market.
Unique
fittings
are
necessary
for
different
refrigerants
in
order
to
avoid
cross
contamination,
as
is
the
use
of
different
colored
labels
for
each
refrigerant.
EPA
will
work
closely
with
refrigerant
developers
to
eliminate
the
risk
of
duplication.
The
person
conducting
the
retrofit
must
apply
to
the
air
conditioning
system
in
the
engine
compartment
a
label
that
contains
the
following
information:

°
The
name
and
address
of
the
technician
and
the
company
performing
the
retrofit.
°
The
date
of
the
retrofit.
°
The
trade
name,
charge
amount,
and,
when
applicable,
the
numerical
designation
of
the
refrigerant
as
determined
under
the
latest
version
of
Standard
34
of
the
American
Society
of
Heating,
Refrigerating,
and
Air­
conditioning
Engineers
(
ASHRAE),
Inc..
°
The
type,
manufacturer,
and
amount
of
lubricant
used.
°
If
the
refrigerant
is
or
contains
an
ozone­
depleting
substance,
the
phrase
"
ozone
depleter".
°
If
the
refrigerant
displays
flammability
limits
as
measured
according
to
latest
version
of
Standard
E681
of
the
American
Society
for
Testing
and
Materials
(
ASTM)
International,
the
statement
"
This
refrigerant
is
FLAMMABLE.
Take
appropriate
precautions."

5.
THE
INFORMATION
COLLECTED
 
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
The
Agency
will
not
develop
a
format
for
the
label
and
will
not
collect
and
compile
the
information
provided
on
the
label.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
EPA
will
not
develop
a
standard
label,
but
rather
the
manufacturers
will
have
the
opportunity
to
produce
unique
labels
to
accompany
their
refrigerant.
Much
of
the
information
required
on
the
labels
can
be
printed
with
the
labels,
thereby
lessening
the
burden
on
the
individual
service
shops,
many
of
which
are
small
businesses.
These
labels
may
also
contain
information
about
the
specific
fittings
the
service
technician
should
use,
with
the
subject
refrigerant,
to
minimize
the
potential
for
cross­
contamination
when
the
system
is
serviced
at
a
later
date.
We
will
work
closely
with
industry
in
carrying
out
these
labeling
requirements,
because
there
are
several
manufacturers
who
have
alternative
refrigerant
products
on
the
market.
Proper
labeling
will
result
in
considerable
savings
to
industry
and
the
public,
since
it
will
greatly
reduce
the
chance
of
refrigerant
contamination.
There
are
now
15
alternative
refrigerants
on
the
market
listed
under
the
SNAP
program
as
acceptable
replacements
for
CFC­
12
for
mobile
air
conditioning.
Considerable
costs
would
accrue
if
refrigerants
were
contaminated
(
mixed),
including
the
costs
to
repair
systems
which
failed
as
a
result
and
the
costs
to
recover,
separate,
reclaim
and/
or
dispose
of
contaminated
refrigerant.

To
estimate
the
total
number
of
retrofits
to
occur
by
September
30,
2006,
the
date
this
ICR
will
expire,
the
Agency
analyzed
publicly
available
data
for
vehicle
sales
in
the
U.
S.
The
U.
S.
Department
of
Transportation,
Federal
Highway
Administration,
Office
of
Highway
Policy
Information
website
provided
vehicle
sales
from
1970
through
2000,
citing
Ward's
2001
as
the
source.
EPA
assumed
that
the
penetration
of
air
conditioning
in
these
cars
rose
linearly
from
70%
in
1970
to
98%
in
1998
and
remained
at
98%
thereafter.
EPA
assumed
that
100%
of
the
air
conditioners
were
designed
for
CFC­
12
for
years
1970
through
1991,
67%
for
1992,
33%
for
1993,
and
0%
thereafter.
EPA
assumed
the
lifetime
of
service
of
an
air
conditioner
follows
a
Poisson
distribution
with
an
average
lifetime
of
12
years.
Using
this
method,
EPA
estimates
that
there
are
currently
approximately
33
million
motor
vehicle
air
conditioners,
originally
designed
to
use
CFC­
12,
operating
in
the
U.
S.
Of
these,
EPA
estimates
3
million,
or
about
9%,
will
be
retrofitted
to
use
alternative
refrigerants
between
October
1,
2003
and
September
30,
2006
(
the
term
of
this
ICR).
The
remaining
air
conditioners
either
(
1)
will
continue
to
operate
without
service,
(
2)
will
continue
to
operate
with
minor
service
including
refilling
with
available
supplies
of
CFC­
12,
(
3)
will
be
disposed
of
along
with
the
entire
motor
vehicle,
(
4)
will
cease
to
function
but
will
not
be
retrofitted
due
to
economic
reasons,
or
(
5)
have
already
been
retrofitted
to
an
alternative
refrigerant
and
will
not
be
retrofitted
again.

The
U.
S.
Department
of
Labor
statistics
indicate
there
are
168,630
automotive
body
and
related
repairers
(
Standard
Occupation
Classification
[
SOC]
System
Code
Number
49­
3021)
and
701,150
automotive
service
technicians
and
mechanics
(
SOC
Code
Number
49­
3023)
in
the
U.
S.
EPA
estimates
that
87,000
of
them,
or
approximately
10%
of
the
total,
will
be
responsible
for
retrofitting
the
estimated
3,000,000
motor
vehicle
air
conditioners.
EPA
estimates
the
time
to
complete
and
apply
the
label
at
5
minutes
per
motor
vehicle
air
conditioner,
making
the
total
burden
250,000
hours.
At
an
estimated
average
labor
rate
of
$
70
per
hour,
the
overall
cost
associated
with
the
burden
hours
is
$
17,500,000.
The
cost
for
designing,
typesetting,
printing
and
distributing
3,000,000
labels
is
estimated
to
be
$
300,000
($
0.10
per
label).
Adding
the
labor
and
capital
costs
together
yields
a
total
cost
burden
of
$
17,800,000.

6(
b)
Burden
Statement
The
annual
public
reporting
and
record
keeping
burden
for
this
collection
of
information
is
estimated
to
average
0.083
hours
(
5
minutes)
per
response
(
i.
e.,
to
fill
out
the
information
required
on
the
label
and
affix
it
to
the
air
conditioner).
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.

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
No.
OAR­
2003­
0097,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
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
is
(
202)
566­
1742.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
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.
Once
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,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
OAR­
2003­
0097)
and
OMB
control
number
(
2060­
0350)
in
any
correspondence.
