  SEQ CHAPTER \h \r 1 SUPPORTING STATEMENT FOR 

INFORMATION COLLECTION REQUEST RENEWAL:

"INFORMATION COLLECTION ACTIVITIES 

ASSOCIATED WITH EPA'S MOBILE 

AIR CONDITIONER RETROFITTING PROGRAM"

EPA ICR No. 1774.03

December 2006

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

The Significant New Alternatives Policy (SNAP) Program enables the
Agency to review available substitutes for ozone depleting substances
(ODSs) and determine their acceptability.  The Stratospheric Protection
Division (SPD) 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 (UV-A)
and ultraviolet-B (UV-B) radiation, and a higher incidence of cataracts
(a leading cause of blindness).  Under the SNAP program, companies
submit applications for approval of substitutes for ozone-depleting
chemicals for review by the SPD.  After all necessary information is
received, SPD has 90 days to review the product data submitted, and
determine if the substitute is acceptable, unacceptable, or if its use
must be restricted.  SPD reviews 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 SPD
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 SPD makes a decision that substitutes
are acceptable, a Notice is published in the Federal Register listing
acceptable substitutes.  If the substitute is found unacceptable or use
restrictions are necessary, a notice-and-comment rulemaking is necessary
to impose use 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. 

SPD requires those retrofitting mobile air conditioners (MAC) to use a
substitute refrigerant to provide some basic information on a label to
be affixed to the air conditioner.  The label includes the name of 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 subsequent
technicians working on the MAC system will be able to service the
equipment properly, decreasing the likelihood of significant refrigerant
cross-contamination and potential failure of air conditioning systems
and refrigerant 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 $5,933,333.

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, SPD faces the challenge of identifying acceptable alternative
refrigerants to allow consumers the choice to retrofit CFC-12 mobile air
conditioners to those alternatives.  EPA notes that in the U.S., prior
to the 1993 model year, most all mobile 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 mobile air conditioners, originally designed to
use CFC-12, operating in the U.S.  Of these, EPA estimates 1 million, or
about 9%, will be retrofitted to use alternative refrigerants between
April 1, 2007 and March 31, 2010 (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 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) Practical Utility/Users of the Data

The purpose of the label is to alert service technicians and motor
vehicle owners that the mobile 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.  Technicians need this information to avoid 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. NON DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a) Non duplication

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

A Federal Register Notice (71 FR 34604) making this supporting statement
available for public comment was submitted and published.  No public
comments were received.

3(c) Consultations

EPA consulted with the following individuals in preparing this ICR
renewal:



Ward Atkinson, Chairman of the Interior Climate Control Committee of
Society of Automotive Engineers (SAE), (602) 956-9313, regarding the
number of air conditioners likely to be retrofitted and the cost burden.

Elvis Hoffpauir, President of Mobile Air Conditioning Society Worldwide,
(215) 631-7020, 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

This ICR asks for information to be collected just once per mobile 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 mobile 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.

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 March 31, 2010,
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 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 12 million mobile
air conditioners, originally designed to use CFC-12, operating in the
U.S.  Of these, EPA estimates 1 million, or about 9%, will be
retrofitted to use alternative refrigerants between April 1, 2006 and
March 31, 2010 (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 mobile 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
mobile 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 1,000,000 mobile air
conditioners over the three-year term of this ICR.

EPA estimates the time to complete and apply the label at 5 minutes per
mobile air conditioner, making the total burden 83,333 hours (27,777
hours and 40 minutes per year).  At an estimated average labor rate of
$70 per hour, the overall cost associated with the burden hours is
$5,833,333 ($1,944,444 per year).  The cost for designing, typesetting,
printing and distributing 1,000,000 labels is estimated at $0.10 per
label to be $100,000 ($33,333 per year).  Adding the labor and capital
costs together yields a total cost burden of $5,933,333 ($1,977,778 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:			27,777 hours and 40 minutes per year

burden costs:	direct:		$33,333 per year

		labor:		$1,977,778 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 3,000,000
responses per year was given for a total annual burden of 83,333 hours
and $2,011,111.  The decrease is because of the aging CFC-12 car
population.  After 1994, new cars in the US were no longer sold with
CFC-12 air conditioning systems.   The number of operating CFC-12 cars
(ie, pre-1994 cars) has decreased since this last ICR renewal.  With
less CFC-12 cars, there are fewer cars that will be retrofit to a new
refrigerant and subject to this ICR.  

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.  Submit your comments,
referencing Docket ID No. EPA-HQ-OAR-2006-0482 to (1) EPA online using
www.regulations.gov (our preferred method), by email to
a-and-r-docket@epa.gov or by mail to: EPA Docket Center, Environmental
Protection Agency, the Air and Radiation Docket, Mail Code 6102T, 1200
Pennsylvania Ave., NW, Washington, DC 20460,  under Docket ID No.
EPA-HQ-OAR-2006-0482.  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.    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. (EPA-HQ-OAR-2006-0482) and OMB
control number (2060-0350) in any correspondence. 

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