1
INFORMATION
COLLECTION
REQUEST
(
ICR)

OMB­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STRATOSPHERIC
OZONE
PROTECTION
A.
JUSTIFICATION
1.
Identification
of
the
Information
Collection
a)
Title:
Request
for
Information
on
Existing
and
Available
Stocks
of
Methyl
Bromide
EPA
Number:
2157.01
b)
Short
Characterization:

This
is
an
emergency,
one
time
request
to
collect
data.

With
this
Information
Collection
Request
(
ICR),
the
Office
of
Air
and
Radiation
(
OAR)
is
seeking
permission
to
solicit
data
from
regulated
industries
on
amounts
of
methyl
bromide,
an
ozone
depleting
chemical,
held
in
inventories.
OAR
is
requesting
this
data
in
order
to
establish
company
level
baselines
of
methyl
bromide
stocks
and
to
subsequently
issue
allowances
that
would
permit
the
company
to
sell
such
stocks
to
critical
uses
of
methyl
bromide.
This
data
is
required
so
that
OAR
may
finalize
allowance
allocations
to
companies
in
a
notice
and
comment
rulemaking
creating
the
critical
use
exemption.
Without
this
data,
companies
that
hold
methyl
bromide
will
not
be
allowed
to
sell
their
inventory
to
critical
uses
and
farmers
who
have
critical
uses
may
face
a
shortage
of
supplies
as
a
result.
The
critical
use
exemption
is
allowed
under
the
Montreal
Protocol
on
Substances
that
Deplete
the
Ozone
Layer
(
Protocol)
and
the
Clean
Air
Act.

2.
Need
For,
and
Use
Of,
the
Collection
a)
Authority
for
the
Collection
This
information
collection
is
authorized
under
section
114
of
the
Clean
Air
Act
Amendments
of
1990,
which
allows
the
Agency
to
collect
data
needed
to
implement
the
statute.
Further,
this
collection
which
is
needed
to
implement
the
critical
use
exemption
is
authorized
under
section
604
(
d)(
6)
of
the
Act
added
by
Section
764
of
the
1999
Omnibus
Consolidated
and
Emergency
Supplemental
Appropriations
Act
(
Public
Law
No.
105­
277;
October
21,
1998)
which
created
the
critical
use
exemption.

b)
Practical
Utility/
Users
of
the
Data
2
The
reported
data
will
enable
EPA
to:

1)
Establish
baselines
for
companies
so
that
they
may
receive
allowances
to
sell
existing
stocks
of
methyl
bromide
to
critical
uses.
2)
Ensure
that
critical
use
exemptions
comply
with
Section
604(
d)(
6)
as
amended
in
1998;
3)
Maintain
compliance
with
the
Protocol
requirements
which
compel
the
U.
S.
to
manage
stocks
under
the
critical
use
exemption.

3.
Nonduplication,
Consultation,
and
Other
Collection
Criteria
a)
Nonduplication
All
the
information
requested
from
respondents
under
this
ICR
is
authorized
by
statute
(
CAA
Section
114
and
604
(
d)(
6))
and
is
not
available
from
other
sources
because
it
is
proprietary
or
sensitive
information.

b)
Public
Notice
This
is
an
emergency
ICR.
EPA
will
provide
public
notice
and
comment
regarding
this
ICR
concurrent
to
publication
of
the
section
114
notice
soliciting
the
data.

c)
Consultations
EPA
has
held
several
consultations,
in
the
form
of
stakeholder
meetings,
on
the
options
for
the
proposed
rulemaking
as
well
as
the
options
for
reporting
and
recordkeeping
requirements.
Copies
of
transcripts
from
two
of
the
six
sessions
held
during
the
summer
of
2003
are
available
at
EPA's
website
at
www.
epa.
gov/
ozone.
EPA
anticipates
receiving
comments
from
stakeholders
through
the
notice
and
comment
process
as
well.

d)
Effects
of
Less
Frequent
Collection
This
is
a
one
time
collection
of
data.

e)
General
Guidelines
This
rule
does
not
exceed
any
of
the
OMB
guidelines
f)
Confidentiality
EPA
informs
respondents
that
they
may
assert
claims
of
business
confidentiality
for
any
of
the
information
they
submit.
Information
claimed
confidential
will
be
treated
in
accordance
with
the
procedures
for
handling
information
claimed
as
confidential
under
40
CFR
Part
2,
Subpart
b,
and
will
be
disclosed
only
if
EPA
determines
that
the
information
is
not
entitled
to
confidential
3
treatment.
If
no
claim
of
confidentiality
is
asserted
when
the
information
is
received
by
EPA,
it
may
be
made
available
to
the
public
without
further
notice
to
the
respondents
(
40
CFR
2.203).

g)
Sensitive
Information
Individual
reporting
data
may
be
claimed
as
sensitive
and
will
be
treated
as
confidential
information
in
accordance
with
procedures
outlined
in
40
CFR
Part
2.

4.
The
Respondents
and
the
Information
Requested
a)
Respondents/
SIC
Codes
Respondents
producers,
importers,
distributors,
and
custom
applicators
of
methyl
bromide.
The
appropriate
North
American
Industry
Classification
System
(
NAICS)
and
Standard
Industrial
Classification
(
SIC)
codes
for
these
entities
are:
4
TABLE
I:
NAICS
CLASSIFICATION
OF
REGULATED
ENTITIES
Category
NAICS
code
SIC
code
Distributors
and
Applicators
Producers
and
Importers
115112­
Soil
Preparation,
Planting
and
Cultivating
424910­
Farm
Supplies
Merchant
Wholesalers
325310­
Pesticide
and
Other
Agricultural
Chemical
Manufacturing
0721­
Crop
Planting,
Cultivation,
and
Protection
2879­
Pesticides
and
Agricultural
Chemicals,
NEC
b)
Information
Requested
i)
Data
Items
EPA
has
proposed
to
require
the
following
information
to
be
provided
to
the
Agency
(
A)
Reporting
·
Producers,
importers,
Distributors,
fumigators
and
applicators
·
One
time:
kilograms
methyl
bromide
held
for
themselves
or
for
third
parties
as
of
date
of
December
31,
2003
·
One
time:
kilograms
methyl
bromide
held
for
themselves
or
for
third
parties
as
of
date
of
notice
·
One
time:
kilograms
methyl
bromide
held
for
themselves
or
for
third
parties
that
are
restricted
for
quarantine
and
preshipment
uses
or
for
developing
countries
as
of
December
31,
2003
·
One
time:
kilograms
methyl
bromide
held
for
themselves
or
for
third
parties
that
are
restricted
for
quarantine
and
preshipment
uses
or
for
developing
countries
as
of
date
of
notice
(
B)
Recordkeeping
·
None
5.
The
Information
Collected,
Agency
Activities,
Collection
Methodology,
and
Information
Management
5
a)
Agency
Activities
·
All
reported
data
will
be
reviewed
by
EPA.

·
EPA
will
use
data
to
calculate
baselines
and
apportion
allowances
to
each
baseline
entity.

·
The
data
will
then
be
stored.

b)
Collection
and
Methodology
and
Management
Data
will
be
collected
by
industry
and
reported
to
EPA
in
the
form
of
a
letter.
Information
claimed
as
confidential
business
information
will
be
stored
in
appropriately
controlled
areas.

c)
Small
Entity
Flexibility
This
ICR
is
related
to
the
collection
of
information
for
an
exemption
program
that
will
confer
a
benefit
to
the
respondents
in
the
form
of
tradable
allowances.

d)
Collection
Schedule
The
information
is
to
be
submitted
on
a
one­
time
basis
within
20
working
days
of
publication
of
the
section
114
notice
in
the
Federal
Register.

6)
Estimating
the
Burden
and
Cost
of
Collection
a)
Estimating
the
Burden
EPA
drew
upon
experience
implementing
similar
regulations
among
the
same
entities
in
order
to
derive
estimates
of
the
burden
associated
with
this
one
time
reporting
activity.

b)
Estimating
the
Respondent
Cost
To
determine
respondent
costs,
EPA
used
an
hourly
industry
wage
rate
of
$
80
per
hour.
Some
activities,
such
as
rule
familiarization,
are
in
fact
one
time
activities
therefore
total
respondent
burden
hours
indicated
in
Table
II
(
below)
may
be
overestimated.

TABLE
II­
RESPONDENT
BURDEN
HOURS
(
One
time)
Collection
Activity
No.
of
respondents
Total
no.
of
responses
Hours
per
response
Total
hours
Report
Inventory
Data
(
one
time)
54
54
2.5
135
6
Total
Burden
Hours
2.5
135
TABLE
III­
CAPITAL
AND
OPERATING
COSTS
Activity
No
of
Entities
Affected
Estimated
Annual
Cost
per
entity
Total
Estimated
Annual
Cost
None
c)
Estimating
Agency
Burden
and
Cost
The
basis
of
this
analysis
is
the
identification
of
the
steps
involved
in
distributing
critical
use
allowances,
reviewing
reporting
data,
submitting
data
to
the
Ozone
Secretariat
on
U.
S.
compliance,
and
developing
guidance
for
regulated
entities.
Each
hour
of
extramural
(
contractor)
time
is
valued
at
$
80.00
per
hour
including
overhead
and
fringe.
Each
hour
of
Agency
time
is
valued
using
the
2003
OPM
annual
base
pay
table
divided
by
2,080
to
estimate
the
hourly
wage
and
then
multiplied
by
1.6,
the
standard
government
benefits
multiplier.
The
hourly
wage
rates
are
as
flows:
for
EPA
managerial
staff
the
rate
is
$
65.49,
for
technical
staff
(
GS­
13
level)
the
value
is
$
47.12,
and
for
clerical
staff
(
GS­
5
level)
is
$
18.03.
The
data
in
table
IV
reflects
total
annual
Agency
effort.

TABLE
IV­
AGENCY
BURDEN
HOURS
Hours
per
Response
No.
of
Responses
Managerial
Hours
per
Response
Technical
Hours
per
Response
Clerical
Hours
per
Response
Extramural
Hours
per
Response
Total
Agency
Hours/
year
Receive
data
54
0
0
.25
0
13.5
Determine
historic
baseline
54
.5
1
0
0
24
Distribute
allowances
54
1
5
0
4
40
Store
data
54
0
.25
0
0
13.5
TOTAL
1.5
6.25
.25
4
91
d)
Estimating
the
Respondent
Universe
EPA
was
able
to
estimate
the
number
of
regulated
entities
drawing
upon
experience
regulating
the
same
entities,
except
for
end
users
of
methyl
bromide,
as
we
do
under
the
phaseout
program.
EPA
believes
that
there
are
4
producers
and
importers
of
methyl
bromide
who
report
quarterly
and
up
to
50
distributors/
applicators
of
methyl
bromide
who
report
annually.
7
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
i)
The
burden
hours
portion
of
the
respondent
reporting
burden
and
operating/
capital
costs
are
estimated
in
Tables
II
and
III
respectively.
The
dollar
estimate
associated
with
this
burden
is
displayed
in
Table
V
below.

TABLE
V­
RESPONDENT
BURDEN
HOURS
AND
COSTS
Response
No
of
Responses
Hours/
Response
Cost/
Hour
Total
Cost
Reporting
54
2.5
$
80
$
10,800
Total
$
10,800
ii)
Agency
burden
is
reported
in
Table
IV.
The
dollar
value
associated
with
this
burden
is
displayed
below
in
Table
VI.

TABLE
VI­
ANNUAL
AGENCY
BURDEN
HOURS
AND
COSTS
Managerial
Hours
Annual
Total
@
$
65.49
Technical
Hours
Annual
Total
@
$
47.12
Clerical
Hours
Annual
Total
@
$
18.03
Extramural
Hours
Annual
Total
$
80.00
Total
Agency
Hours
per
Year
Total
Agency
Costs
per
Year
Hours/
Response
81
337.5
13.5
216
648
$
38,731
f)
Reasons
for
Change
in
Burden
Require
data
to
establish
baselines
for
a
new
exemption
program.

g)
Burden
Statement
Table
II
presents
the
average
annual
respondent
burden.
For
respondents
affected
by
the
methyl
bromide
critical
use
exemption,
the
annual
reporting
and
recordkeeping
burden
is
as
follows:
4
producers
and
importers
at
a
total
of
10
hours
per
year
for
this
group
of
entities
and;
50
distributors
and
applicators
at
125
hours
per
year.
The
total
industry
burden
hours
for
this
one
time
effort
are
therefore
135.
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
8
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
rule,
which
includes
this
ICR,
under
Electronic
Docket
ID
number
OAR­
2003­
0230.
Submit
any
comments
related
to
the
rule
ICR
for
this
proposed
rule
to
EPA
and
OMB.
See
"
Addresses'
section
at
the
beginning
of
this
notice
for
where
to
submit
comments
to
EPA.
Send
comments
to
OMB
at
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17
th
Street
NW,
Washington
D.
C.
20503
attn:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
(
2157.01)
in
correspondence
related
to
this
ICR.
