SUPPORTING
STATEMENT
FOR
INFORMATION
COLLECTION
REQUEST
RENEWAL:

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

EPA
ICR
No.
1774.03
2
September
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
approval
of
substitutes
for
ozonedepleting
chemicals
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
2
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.

Terms
of
Clearance.
The
previous
ICR
was
approved
with
the
following
terms
of
clearance:
"
Prior
to
resubmitting
this
collection
to
OMB
for
approval,
EPA
should
be
careful
to
re­
evaluate
the
number
of
vehicle
air
conditioners
likely
to
be
retrofitted
during
the
requested
approval
period
for
that
ICR.
At
that
time,
EPA
should
also
ensure
that
the
collection
uses
applicable
and
properly
loaded
wage
rates
to
estimate
the
labor
costs
associated
with
the
collection."

EPA
has
revised
its
previous
estimate
as
to
the
number
of
motor
vehicle
air
conditioners
likely
to
be
retrofitted.
Section
6(
a)
below
gives
a
detailed
explanation
of
how
this
number
was
generated.
EPA
has
also
used
applicable,
loaded
wage
rates
as
described
in
item
6(
b)
below.

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
3
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
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
label
provides
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
required
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
4
A
Federal
Register
Notice
(
68
FR
38322)
making
this
supporting
statement
available
for
public
comment
was
submitted
and
published.
Two
public
comments
were
uploaded
to
the
EDOCKET
site;
one
was
an
exact
duplicate
of
the
other.
This
comment
requested
the
five
following
clarifications:

1.
All
vehicle
types
including
trucks
and
buses
should
be
accounted
to
determine
the
number
of
mobile
air
conditioners
currently
using
CFC­
12.
Response:
Ward's
2001
sales
data
were
used
to
calculate
the
number
of
motor
vehicles
with
CFC­
12
air
conditioners.
The
language
in
item
6(
a)
below
has
been
refined
to
explain
that
the
data
used
includes
trucks
and
buses
as
well
as
cars.

2.
Actual
current
registration
data
and
a
remaining
useful
life
versus
a
useful
life
calculation
applied
to
sales
data
should
be
used
to
calculate
the
number
of
mobile
air
conditioners
currently
on
the
road.
Response:
EPA
looked
for
registration
data.
The
number
of
motor
vehicles
registered
in
the
United
States
was
given
on
the
U.
S.
Department
of
Transportation,
Federal
Highway
Administration,
Office
of
Highway
Policy
Information
website.
Because
this
data
did
not
provide
an
indication
of
the
age
of
the
vehicles
registered,
it
was
not
useful
in
determining
the
number
of
motor
vehicles
with
air
conditioners
originally
designed
to
use
CFC­
12
still
in
operation.
Additional
registration
data,
available
from
the
National
Automobile
Dealers
Association,
included
vehicles
in
operation
and
some
information
on
new­
vehicle
registration
for
some
years.
Still,
this
data
was
not
sufficient
to
obtain
accurate
estimates
of
the
number
of
vehicles
currently
in
operation
by
model
year.
A
third
source
suggested
registration
data
including
age
of
vehicle
was
available,
but
that
a
charge
would
be
associated
with
obtaining
that
data.
Resources
were
not
available
to
EPA
to
pursue
this
possible
source
of
data.

3.
The
9%
future
retrofit
projection
calculation
should
be
explained.
Response:
EPA
assumed
that
9%
of
the
operating
motor
vehicle
air
conditioners
originally
designed
to
use
CFC­
12
would
be
retrofitted
during
the
term
of
this
ICR.
This
percentage
was
an
estimate
based
on
familiarity
with
the
mobile
air
conditioning
retrofit
program,
taking
into
consideration
the
other
possibilities
for
the
fate
of
these
air
conditioners,
including
the
five
items
listed
in
items
2(
a)
and
6(
a).
Upon
receipt
of
this
comment,
EPA
participated
in
a
meeting
with
several
motor
vehicle
air
conditioning
professionals.
This
group
reached
consensus
that
9%
is
likely
to
be
an
accurate
estimate.

4.
Some
number
of
retrofits
should
be
subtracted
from
the
projected
total
to
account
for
potential
noncompliance
with
the
labeling
requirement.
Response:
EPA
recognizes
that
there
may
be
noncompliance
with
the
requirement
that
a
label
be
applied
when
a
CFC­
12
mobile
air
conditioner
is
retrofitted
to
an
alternative
refrigerant.
This
comment
was
discussed
with
EPA
Office
of
Environmental
5
Information
staff
that
handle
general
issues
of
Information
Collection
Requests,
who
suggested
that
100%
compliance
be
assumed,
thereby
providing
a
conservative
estimate
of
the
burden
estimated.

5.
The
actual
data
used
to
determine
the
cost
for
label
design,
typesetting,
printing
and
distribution
costs
should
be
detailed.
Response:
EPA
contacted
two
companies
that
offer
refrigerants
approved
under
SNAP
for
the
retrofit
of
CFC­
12
motor
vehicle
air
conditioners.
One
company
indicated
that
the
$
0.10
per
label
was
an
accurate
estimate,
but
noted
that
additional
costs
might
be
incurred
by
a
refrigerant
packager,
for
example
if
the
label
was
placed
in
an
envelope
or
bag.
The
second
company
indicated
it
provides
several
labels
when
it
ships
the
alternative
refrigerant,
for
example
in
cases
of
cans
or
in
approximately
25
to
30­
pound
cylinders.
The
company
estimated
that
the
cost
it
pays
for
those
labels,
including
design,
typesetting,
printing
and
distribution,
was
approximately
$
0.02
per
label.
The
company
also
indicated
it
makes
available
to
those
who
may
retrofit
a
CFC­
12
motor
vehicle
air
conditioner
packages
of
additional
labels,
at
a
cost
of
approximately
$
0.225
per
label.
Thus,
EPA
feels
the
original
estimate
of
$
0.10
per
label
is
accurate.

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.
°
Paul
DeGuiseppi,
Elvis
Hoffpauir,
Amy
Kline,
Marion
Posen
and
Jim
Taylor,
Mobile
Air
Conditioning
Society
Worldwide,
215­
631­
7020,
regarding
the
percent
of
air
conditioners
likely
to
be
retrofitted.
°
John
Linden,
Midas
International
Corporation,
412­
369­
9630,
regarding
the
percent
of
air
conditioners
likely
to
be
retrofitted.
°
Peter
Coll,
Neutronics
Inc.,
610­
524­
8800,
regarding
the
percent
of
air
conditioners
likely
to
be
retrofitted.
°
Jim
Thomas,
Refrigerant
Services
Inc.,
902­
468­
4997,
regarding
the
cost
of
labels.
°
Doug
Pettigrew,
ICOR
International,
317­
826­
3200,
regarding
the
cost
of
labels.

3(
d)
Effects
Of
Less
Frequent
Collection
6
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.
Also
listed
is
the
corresponding
North
American
Industry
Classification
System
(
NAICS)
codes
available
from
http://
www.
census.
gov/
epcd/
www/
naics.
html.

551
New
and
used
car
dealers
(
NAICS
code
441110)
554
Gas
service
stations
(
NAICS
codes
447110
and
447190)
7532
Top
and
body
repair
shops
(
NAICS
code
811121)
7538
General
automotive
repair
shops
(
NAICS
code
811111)
7539
Automotive
repair
shops
not
elsewhere
classified,
including
air
conditioning
and
radiator
specialty
shops
(
NAICS
code
811198)

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.
7
°
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
if
the
system
is
serviced
at
a
later
date.
EPA
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
(
cars,
trucks
and
buses)
sales
from
1970
through
2000,
citing
Ward's
2001
as
the
source.
EPA
assumed
that
the
penetration
of
air
conditioning
in
these
vehicles
rose
linearly
from
70%
in
1970
to
98%
in
1998
and
remained
at
98%
thereafter.
EPA
8
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.

EPA
estimates
the
time
to
complete
and
apply
the
required
label
at
5
minutes
per
motor
vehicle
air
conditioner.

6(
b)
Estimating
Respondent
Costs
EPA
estimates
the
cost
per
label
to
be
$
0.10.

EPA
estimates
the
time
to
complete
and
apply
the
label
at
5
minutes
per
motor
vehicle
air
conditioner.
Based
on
recent
consultation
with
the
industry,
EPA
uses
an
estimate
of
$
70
per
hour
loaded
labor
rate
(
includes:
wages
paid
to
the
technician;
benefits
including
paid
leave,
health
insurance,
retirement
savings
and
legally
required
benefits;
and
overhead,
including
office
space,
furniture,
equipment
and
computers,
supplies
and
other
business
expenses).
Thus
the
loaded
labor
cost
per
response
is
approximately
$
5.83.

6(
c)
Estimating
Agency
Burden
And
Cost
The
data
required
on
the
label
is
not
submitted
to
the
EPA;
therefore,
the
Agency
burden
and
cost
is
zero.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
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
over
the
three­
year
term
of
this
ICR.

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
(
83,333
hours
and
20
minutes
per
year).
At
an
estimated
average
labor
rate
of
$
70
per
hour,
the
overall
cost
associated
with
the
burden
hours
9
is
$
17,500,000
($
5,833,333.33
per
year).
The
cost
for
designing,
typesetting,
printing
and
distributing
3,000,000
labels
is
estimated
at
$
0.10
per
label
to
be
$
300,000
($
100,000
per
year).
Adding
the
labor
and
capital
costs
together
yields
a
total
cost
burden
of
$
17,800,000
($
5,933,333.33
per
year).

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
As
indicated
in
6(
c),
there
is
no
burden
or
cost
to
the
Agency;
therefore,
the
bottom­
line
burden
hours
and
costs
are
equivalent
to
the
respondent
burden
hours
and
costs:
burden
hours:
83,333
hours
and
20
minutes
per
year
burden
costs:
direct:
$
100,000
per
year
labor:
$
5,833,333.33
per
year
6(
f)
Reasons
for
Change
in
Burden
This
represents
a
decrease
in
the
burden
estimated
for
the
previous
three­
year
term
of
this
ICR.
Previously,
an
estimate
of
5,000,000
responses
per
year
was
given
for
a
total
annual
burden
of
416,667
hours
and
$
500,000.
The
decrease
is
because
the
EPA
estimates
less
CFC­
12
motor
vehicle
air
conditioners
will
be
retrofitted
in
the
next
three
years
than
the
previous
three
years.

6(
g)
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
10
(
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.
