Draft Annual Burdens associated with Motor Vehicle and Non-Road Diesel
Fuel

Applicable January 2008 through December 2010

EPA ICR No. 1718.08

EPA-HQ-OAR-2007-1121

We drew upon experience implementing similar regulations among the same
entities to develop estimates of the burden associated with this
collection.  We also had discussed our estimates on the expiring ICR
with industry sources.    

  SEQ CHAPTER \h \r 1 Three labor categories are involved in this draft
estimate: managerial (includes legal and professional review),
technical, and clerical.  According to the Bureau of Labor Statistics,
Employer Costs for Employee Compensation, “Table 12 - Private
industry, manufacturing, and non-manufacturing industries by
occupational group (December, 2003),”( the following wages and
benefits apply by category:

Wages and Benefits

									

Managerial	$49.30 per hour

Technical		$32.31 per hour

Clerical		$22.42 per hour

	Doubling for company overhead beyond wages and benefits, and for
convenience, rounding to the dollar, gives the following rates for this
ICR:

Total Employer Cost

Managerial	$99 per hour

Technical		$65 per hour

Clerical		$45 per hour

	The labor mix for the activities above will be about the same for each.
 It is assumed that for each hour of activity the mix will be about 0.1
hour managerial, 0.7 hour technical, and 0.2 hour clerical.  This gives
an average labor cost of about $65 per hour, which will be used in this
ICR.   The annual burden estimates given below in the table that follows
are based upon the likely respondents and estimated number of reports,
industry contact, and our knowledge of likely industry activity over the
next three years.  

	

TABLE - ESTIMATES BY COLLECTION ACTIVITY

Collection

Activity	Number of

Respondents	Responses per

Respondent/Total Responses	Hours per Report/Total Hours	Labor Costs in $

Provided for Reference Purposes

(Assumes $65/hour)      	Costs in $

(Assumes Purchased Services Rate at

$130/hour or at double hourly labor cost assumption)

Registration  (refiner, importer, other parties)1	40	1/40	1/40	  2,600	0

Temporary Hardship Applications2	2	1/2	40/80	  5,200	0

R&D Exemption Application3	8	1/8	1/8	    520	0

Refiners’ and Importers’ Annual Reporting	200	1/200	40/8,000	520,000
0

Refiners’ and Importers’ Quarterly Reporting	200	4/800	40/32,000
2,080,000	0

Annual Reporting by All Other Parties (Pipelines, Terminals)	1,000
1/1,000	40/40,000	2,600,000	0

Quarterly Reporting by All Other Parties (Pipelines, Terminals)	1,000
4/4,000	40/160,000	10,400,000	0

Voluntary QA by refiners and  importers	200

	100/20,000

	1/20,000

	1,300,000

	2,600,000

Purchased Services



Attest engagements for foreign refiners4	5	1/5	40/200	13,000	26,000

Purchased

Services

Placement of notice or codes for dyed diesel fuel5	2,000	200/400,000
.0333/222	14,430	0

Prepare and Submit Application for Performance-Based Test Method/Lab

Qualification	20	1/20	180/3,600	234,000	0

	

TOTALS:  

FROM THE TABLE:

Total Responses:  	426,075  

Total Hours:      	264,150

Total Costs: 		$2,626,000 (Non-labor costs.  All purchased services).

										



( 	 See     HYPERLINK "http://www.bls.gov/news.release/ecet.t12.htm." 
http://stats.bls.gov/news.release/ecet.t12.htm.  (Accessed April 8,
2004.)  

1 	Nearly all parties have already registered.  Number is for new
registrants or for updated registrations.  

2 	Applications of this type are only for extreme, unforseen
circumstances and are expected to be very rare.

3 	Estimate is based upon the number of R&D exemptions requested in
similar programs and upon discussion with industry sources.

4 	Only for foreign refiners who use the temporary compliance or other
flexibility option (e.g. small refiner).

5 	Capital/start up costs were incurred by regulated industry in 1993. 
The notice or codes are typically is now automatically generated by
software and represents a minimal burden.  This item is the only
reporting burden under existing ICR 1718.03, expiring 9/1/04.  

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