  SEQ CHAPTER \h \r 1 SUPPORTING STATEMENT FOR 

INFORMATION COLLECTION REQUEST RENEWAL:

MOBILE AIR CONDITIONER RETROFITTING PROGRAM

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection

This ICR is entitled " Mobile Air Conditioner Retrofitting Program
(Renewal)," EPA ICR Number 1774.05, and OMB Number 2060-0350.

1(b) Short Characterization

The Significant New Alternatives Policy (SNAP) Program, under Section
612 of the Clean Air Act (CAA), 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 that damage
the stratospheric ozone layer; 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 of substitutes for ODSs.
 After all necessary information is received, SPD has 90 days to review
the data submitted, and determine if the substitute is acceptable,
unacceptable, or if its use must be restricted.  For every submission,
SPD reviews factors such as impact on human health and the environment,
ozone depleting potential, atmospheric lifetime, global warming
potential, and flammability.  Because many substitutes are produced for
multiple uses, SPD must determine what uses are appropriate based on the
factors mentioned. Once SPD makes a decision of acceptability of a
substitute, a Notice is published in the Federal Register listing
acceptable substitutes under SNAP.  If the substitute is found
unacceptable or use restrictions are required, a notice-and-comment
rulemaking is necessary.   A comprehensive list of substitutes, their
uses, and any relevant restrictions is maintained for distribution to
interested parties. 

SPD requires technicians retrofitting motor vehicle air conditioners
(MVACs) containing ODS such as CFC-12 to use an approved SNAP substitute
and to provide basic information on a label to be affixed to a visible
section of the MVAC.  The label must include 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 MVAC system will be able to service the system properly,
decreasing the likelihood of significant refrigerant emissions,
cross-contamination and potential failure of air conditioning systems
and refrigerant recovery/recycling equipment. EPA requires that when
retrofitting CFC-12 MVAC systems with an approved SNAP refrigerant, the
technician must first extract the CFC-12, and must install new fittings
unique to that refrigerant.

EPA estimates that 6,500 technicians will be responsible for providing
this information over the next 3 years, at a total cost (labor plus
materials) of $205,000.

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need and Authority for the Collection

The SNAP program reviews potential alternatives to ozone-depleting
refrigerants used in various sectors, including MVACs.  When
chlorofluorocarbons (CFCs), and specifically CFC-12, were phased out SPD
faced the challenge of identifying acceptable alternative refrigerants
that allowed consumers choice to retrofit CFC-12 MVAC systems to use
alternatives.  EPA notes that in the U.S., prior to the 1993 model year,
MVACs used CFC-12 and that after 1995, original equipment manufacturers
(OEMs) produced MVACs with HFC-134a.  EPA estimates that there are
currently approximately 3.3 million automobiles, originally designed to
use CFC-12 in their MVACs, operating in the U.S.  Of these, EPA
estimates 7,000 (about 0.2%) or less will be retrofitted to use
alternative refrigerants accepted for retrofitting between April 1, 2010
and March 31, 2013 (the term of this ICR).  The remaining MVAC systems
will either (1) continue to operate without service, (2) continue to
operate with minor service including repairs and refilling with
available supplies of CFC-12, (3) will be recycled or disposed of along
with the entire motor vehicle, (4) will cease to function but will not
be retrofitted, or (5) have already been retrofitted to an acceptable
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 CFR part, 82 subpart G requirements
that service technicians label MVAC systems 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 MVAC no longer
uses CFC-12.  In addition, the label provides essential information to
technicians about the specific refrigerant used in the air conditioning
system.

Section 612 of the CAA requires EPA to promulgate rules making it
unlawful to replace any ODS  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 air conditioning systems and recovery/recycling equipment. 
In addition, continuing the smooth transition to substitutes strongly
depends on the continued purity of the recovered, recycled and/or
reclaimed CFC-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 MVAC has been retrofitted to use an acceptable
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.

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 (75 FR 7584) 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.

Paul DeGuiseppi, Mobile Air Conditioning Society Worldwide, (215)
631-7020, 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 MVAC
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 MVAC 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.

SIC code:        Type of Industry and NAICS code: 

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 works with refrigerant
developers to eliminate the risk of duplication.  The person conducting
the retrofit must apply to the MVAC 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 has not developed a format for the label and does 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 has not developed a standard label, but rather the manufacturers
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 due to several alternative refrigerant
products on the market.  EPA works closely with industry in carrying out
these labeling requirements.  Proper labeling results in considerable
savings to industry and the public, since it greatly reduces the chance
of refrigerant contamination.  There are now 16 alternative refrigerants
on the market listed under the SNAP program as acceptable replacements
for CFC-12 for MVAC. However, only 13 of these alternative refrigerants
are acceptable for retrofitting MVACs.  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 July 31, 2010, the
date this ICR will expire, the Agency analyzed publicly available data
from the U.S. Department of Transportation, Bureau of Transportation
Statistics, regarding vehicle sales per year.  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 MVACs 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 3 million MVACs, originally designed
to use CFC-12, operating in the U.S.  Of these, EPA estimates 7000, or
about 0.2%, will be retrofitted to use alternative refrigerants between
May 1, 2010 and April 31, 2013 (the term after this ICR).  The remaining
MVACs 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 or recycled 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 MVAC.

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
MVAC.  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 650,000
automotive service technicians and mechanics (SOC Code Number 49-3023)
in the U.S.  EPA estimates that 6,500 of them, or approximately 1% of
the total, will be responsible for retrofitting the estimated 55,000
MVAC systems over the three-year term of this ICR.

EPA estimates the time to complete and apply the label at 5 minutes per
MVAC, making the total burden 4,500 hours (1,500 hours per year).  At an
estimated average labor rate of $70 per hour, the overall cost
associated with the burden hours is $315,000 ($105,000 per year).  The
cost for designing, typesetting, printing and distributing 55,000 labels
is estimated at $0.10 per label to be $5,500 ($1,833.33 per year). 
Adding the labor and capital costs together yields a total cost burden
of $320,500 ($106,833.33 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:			1,500 hours per year

burden costs:	direct:		$1,833 per year

		labor:		$105,000 per year

6(f) Reasons for Change in Burden

Based on the decline of CFC-12 MVACs in service today EPA estimates a
continued reduction in the number of CFC-12 MVACs retrofits that will
occur during the next three years. After 1994, new cars in the US were
no longer sold with CFC-12 MVACs.  Thus, the number of operating cars
with CFC-12 cars MVACs has decreased since the last ICR renewal. With
fewer cars with CFC-12 MVACs, there will be fewer retrofits with
substitute refrigerants 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 5 minutes per
response.  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-2009-0911 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 28221T, 1200
Pennsylvania Ave., NW, Washington, DC 20460,  under Docket ID No.
EPA-HQ-OAR-2009-0911.  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-2009-0911 and OMB
control number 2060-0350 in any correspondence. 

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