                                       

                                       
Technical Support Document
Analysis of the Economic Impact and Benefits of Proposed Revisions to the National Recycling and Emission Reduction Program

                                       
                                       

                                       
                                       
October 15, 2015
                                       
                                       

                                       

U.S. Environmental Protection Agency
Stratospheric Protection Division
Office of Atmospheric Programs
1200 Pennsylvania Avenue, NW
Washington, DC 20460




Contents
Executive Summary	vii
1.	Introduction	1
1.1.	Regulatory Context	3
1.1.1.	Profile of Regulated Community	3
1.1.2.	Current Leak Repair Requirements	3
1.1.3.	Current Recordkeeping and Reporting Requirements	4
1.2.	Proposed Regulatory Revisions	6
1.2.1.	Proposed Changes to the Leak Repair Requirements	6
1.2.2.	Proposed Changes to the Recordkeeping and Reporting Requirements	7
1.2.3.	Other Proposed Regulatory Revisions	8
1.3.	Organization of This Report	8
2.	Industry Characterization	10
2.1.	Affected Industry for Leak Inspection and Repair Requirements	10
2.1.1.	Equipment Characterization	10
2.1.2.	Industry Characterization	14
2.2.	Affected Industry for Recordkeeping and Reporting Requirements	20
2.3.	Affected Industry for Self-sealing Valves on DIY Small Cans	22
3.	Methodology	24
3.1.	Approach for Estimating Aggregate Annual Costs to the U.S. Economy	25
3.1.1.	Leak Inspection and Repair	25
3.1.2.	Recordkeeping and Reporting	35
3.1.3.	Self-sealing Valves on DIY Small Cans	40
3.1.4.	Extending Other Existing Requirements to HFCs and Other Substitutes: Implications for Costs	40
3.2.	Approach for Estimating the Economic Impact on Small Entities	43
3.2.1.	Leak Inspection and Repair Model Facility and Entity Assumptions	43
3.2.2.	Reporting and Recordkeeping	45
3.2.3.	Self-sealing Valves on DIY Small Cans	46
3.3.	Approach for Estimating Benefits	46
3.3.1.	Emission Reduction Benefits of Leak Inspection and Repair	46
3.3.2.	Emission Reductions Benefits of Installing Self-sealing Valves on Small Cans	49
3.3.3.	Extending Other Existing Requirements to HFCs and Other Substitutes: Implications for Benefits	51
4.	Aggregate Economic Impact Analysis	52
4.1.	Annual Compliance Costs	52
4.2.	Annual Refrigerant Savings	53
4.3.	Annual Emission Reduction Benefits	54
4.4.	Looking Forward: Emission Reduction Benefits in 2020 and 2025	54
4.5.	Other Benefits	55
5.	Small Entities Impact Analysis	57
5.1.	Decision Matrix for Determining Significant Economic Impact on a Substantial Number of Small Entities	57
5.2.	Aggregate Small Business Impacts of Proposed Regulatory Changes	58
6.	Statutory and Executive Order Impact Analyses	61
7.	Conclusions	62
8.	References	63
Appendix A. Sensitivity Analyses for Aggregate Economic Analysis	A-1
Appendix B. Detailed Tables for Recordkeeping and Reporting	B-1
Appendix C. Detailed Tables for SISNOSE Analysis	C-1
Appendix D. Sensitivity Analysis for SBREFA	D-1
Appendix E. NAICS Codes	E-3
Appendix F. Costs Incurred by DIYers for a Sales Restriction	F-15

Tables
Table 1. Summary of EPA's Proposed Changes to Section 608 Regulations by Rule Component	vii
Table 2. Industries Affected by the Proposed Regulatory Changes by Rule Component	x
Table 3. Existing Annual Leak Rates by Appliance Type	4
Table 4: Equipment Characterization by Sector, Type, Size, and Refrigerant Type	12
Table 5: Typical Refrigerants Used by Equipment Type	13
Table 6: Typical Charge Size Categories by Equipment Type	14
Table 7: Industry Sector, NAICS Code, and Definition	14
Table 8: Total Businesses and Facilities by Industry Category	17
Table 9: Percentage of Industry Containing Appliances with 50 or More Pounds of ODS or HFC Refrigerant, and Average Number of Systems per Facility	18
Table 10: Universe of Affected Equipment	20
Table 11. Total Number of Small Entities Affected by Industry Category and NAICS Code	21
Table 12: Industry Characterization for Small Can Manufacturers Affected by Proposed Rule	23
Table 13: Leak Repair Outcomes and Proportions	28
Table 14: Leak Rate Assumptions by Equipment Sector, Type, and Size	29
Table 15: Unit Cost Assumptions	32
Table 16. Leak Rate Comparison Based on California's RMP and EPA's Vintaging Model	34
Table 17: Affected Equipment Assumptions by Equipment Sector, Type, Size, and Refrigerant Type	34
Table 18. Appliances with Charge Sizes Between 5 and 50 Pounds Disposed in 2015	39
Table 19: Regulatory Changes Assumed to Present No Incremental Cost	41
Table 20. Potentially Affected Industries for Reporting and Recordkeeping Requirements	45
Table 21: Average GWP and ODP Assumptions by Equipment Type, Size, and Refrigerant Type	47
Table 22. Annual Compliance Costs by Rule Component (2014$)	53
Table 23. Total Annual Refrigerant Savings (2014$), Compliance Costs, and Combined Annual Compliance Costs and Refrigerant Savings	53
Table 24. Annual GHG and ODS Emissions Avoided in 2015	54
Table 25. Annual GHG Emissions Avoided in 2020 (MTCO2eq.)	54
Table 26. Annual GHG Emissions Avoided in 2025 (MTCO2eq.)	55
Table 27. Annual ODS Emissions Avoided in 2020 and 2025 (ODP-weighted MT)	55
Table 28. Decision Matrix for Certifying SISNOSE	57
Table 29. Summary of the Small Business Impact	58
Table 30. Aggregated Economic Impacts on Small Businesses	60
Table 31: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with CARB ODS and HFC Equipment Distribution	A-1
Table 32: . Annual GHG and ODS Emissions Avoided with CARB ODS and HFC Equipment Distribution	A-2
Table 33: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with 200-pound Annual Leak Inspection Threshold	A-3
Table 34: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with Higher Post-Repair Leak Rate	A-4
Table 35: . Annual GHG and ODS Emissions Avoided with Higher Post-Repair Leak Rate	A-4
Table 36: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with 3% Discount Rate	A-5
Table 37: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with 2-week Leak Repair Improvement	A-6
Table 38: . Annual GHG and ODS Emissions Avoided with 2-week Leak Repair Improvement	A-7
Table 39: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$)  with 2-month Leak Repair Improvement	A-8
Table 40: . Annual GHG and ODS Emissions Avoided with 2-month Leak Repair Improvement	A-9
Table 41: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$)  with Lower Threshold Leak Rates	A-10
Table 42: Annual GHG and ODS Emissions Avoided with Lower Threshold Leak Rates	A-11
Table 43: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with Higher Threshold Leak Rates	A-12
Table 44: Annual GHG and ODS Emissions Avoided with Higher Threshold Leak Rates	A-13
Table 45. Annual Compliance Costs for Recordkeeping and Reporting	B-1
Table 46: Estimated Number of Small Businesses Affected by NAICS Code	C-1
Table 47. Aggregated Economic Impacts on Small Businesses with 3% Discount Rate	D-1
Table 48: NAICS Codes Included in the Leak Repair Regulation Analysis	E-3
Table 49: NAICS Codes Included in the Small-can Analysis	E-13
Table 50: NAICS Codes Included in the Recordkeeping and Reporting Requirements Analysis	E-13
Table 51. Costs Incurred by DIYers to Take Vehicle to a Professional Service Shop	F-15
Table 52. Costs Incurred by DIYers to Become a 609 Certified Technician	F-15



Executive Summary
Under the National Recycling and Emission Reduction Program, found at Section 608 of the Clean Air Act (40 CFR part 82, subpart F), EPA has established standards and regulations for the use and disposal of ozone-depleting substances (ODS) during the maintenance, service, repair, or disposal of air-conditioning and refrigeration appliances. EPA is proposing to extend, as appropriate, the existing requirements in subpart F that currently apply to ozone-depleting refrigerants to non-ozone-depleting substitute refrigerants, such as hydrofluorocarbons (HFCs). Further, EPA is proposing to revise Section 608 rule components associated with leak repair; recordkeeping and reporting, and the refrigerant sales restriction. EPA's proposed changes to Section 608 are summarized in Table 1 below by rule component.
Table 1. Summary of EPA's Proposed Changes to Section 608 Regulations by Rule Component
Rule Component
Proposed Change
Leak Inspection and Repair
Extend the existing requirements to comfort cooling (CC), commercial refrigeration (CR), and industrial process refrigeration (IPR) equipment containing 50 or more pounds of HFC and other substitute refrigerant;
Lower the annual leak rates for CC, CR, and IPR equipment containing 50 or more pounds of ODS, HFC, or other substitute refrigerant; 
Require periodic leak inspections for equipment containing 50 or more pounds of ODS, HFC, or other substitute refrigerant;
Establish a leak limit where an appliance is prohibited from leaking more than 75% of its full charge in two consecutive years;
oo Require initial and follow-up verification tests for all appliances (i.e., IPR, CR, and CC equipment) when the applicable leak rate is exceeded;
oo Require a leak inspection to identify leaks upon discovering that the applicable leak rate is exceeded;
oo Require that all identified leaks are repaired when the applicable leak rate is exceeded rather than just bringing the leak rate down below the annual leak rate threshold;
oo Allow leak repair extension requests for all equipment, including non-federal CR and CC systems; and
oo Explicitly allow (and even encourage) electronic instead of paper records.
Recordkeeping and Reporting
Extend the current recordkeeping and reporting requirements to appliances containing HFCs and other non-exempt substitutes;
Allow owners/operators of all ODS, HFC, and other substitute refrigerant- containing appliances with charge sizes of 50 or more pounds to prepare and submit requests for extensions to the leak repair and retrofit/retire timeline;
Require persons servicing ODS, HFC, and other substitute refrigerant-containing appliances with charge sizes of 50 or more pounds to provide records of the following for each refrigerant addition: the identity and location of the appliance, the date and type of service performed, the quantity and type of refrigerant added, the full charge of the system, and the leak rate; 
Require owners/operators of ODS, HFC, and other substitute refrigerant-containing appliances with charge sizes of 50 or more pounds to maintain records of the following for each refrigerant addition: the identity and location of the appliance, the date and type of service performed, the quantity and type of refrigerant added, the full charge of the system, and the leak rate;
Require owners/operators of ODS, HFC, and other substitute refrigerant-containing appliances with charge sizes of 50 or more pounds to maintain reports on the results of verification tests and leak inspections any time the leak rate threshold is exceeded;
Require owners/operators of ODS, HFC, and other substitute refrigerant-containing appliances with charge sizes of 50 or more pounds to maintain records of quarterly and annual leak inspections;
Require technicians disposing of field-installed appliances with charge sizes between 5 and 50 pounds to maintain records on the quantity and types of refrigerant recovered at disposal and the quantity and type of refrigerant transferred for reclamation or destruction, as well as the company name and date;
Require approved technician certifying programs to publish online lists or databases documenting who they have certified and what type of certification each individual has received;
Require manufacturers of small cans of automotive refrigerant to keep records of test data and log forms that demonstrate compliance with the allowable leakage rate; and 
Remove the requirement for persons who maintain, service, repair, or dispose of appliances containing ODS refrigerants to submit a signed statement that they own certified recovery and recycling equipment.
Refrigerant Sales Restriction

Extend the sales restriction to HFCs and other non-exempt substitutes;
Exempt small cans of HFC refrigerant that are used for DIY aftermarket servicing of MVACs from the sales restriction; and
Require self-sealing valves on small cans of substitute refrigerant.
Other
Extend all other the regulatory requirements found at 40 CFR part 82, subpart F, including technician certification, appliance disposal, reclamation, service practices, and the requirement to recover refrigerant to HFCs and other non-exempt substitutes; and
Require substitute-containing recycling/recovery equipment to be certified.  

The purpose of this report is to present the results of a costs and benefits assessment to assist EPA in evaluating the impacts of the proposed changes to Section 608 regulations and satisfying its obligations under relevant statutes and Executive Orders (EOs), including EO 12866: Regulatory Planning and Review, the Regulatory Flexibility Act (RFA) as amended by the Small Business Regulatory Enforcement Fairness Act (SBREFA), and the Unfunded Mandates Reform Act (UMRA) of 1995. This report was developed with support from ICF International.
General Approach
Below is a summary of the general approach used to estimate the impact of the proposed regulatory changes associated with each major rule component. A list of potentially affected industry sectors by major rule component is presented in Table 2. 
Leak inspection and repair. To estimate the impact of the proposed regulatory changes associated with leak inspection and repair to the U.S. economy as a whole and individual small businesses, this analysis uses a model entity approach. The model entity approach is built up from a model facility analysis, which was developed based on assumptions about model equipment. First, the impacts were estimated for each type of affected equipment. Then, impacts were estimated for a model facility in each of the industry categories presented in Table 2. Assumptions about the number and type of equipment used per model facility varied based on the industry category. Lastly, impacts per model facility were scaled to a model entity based on the average number of facilities an entity is estimated to have in each industry category. 
Reporting and recordkeeping. To estimate the impact of the proposed regulatory changes associated with recordkeeping and reporting, the estimated burden (hours) was multiplied by the assumed average hourly administrative cost of labor plus overhead for a private firm (hourly wage rate). Additional details regarding the estimated recordkeeping and reporting burden are found in the supporting statement for the Information Collection Request accompanying this proposed rule.
Refrigerant sales restriction. To estimate the impact of requiring self-sealing valves on small cans of automotive refrigerant for MVAC servicing, the total number of small cans sold annually in the United States was multiplied by the cost per self-sealing valve.
To estimate impacts on small businesses, industries potentially affected by these regulatory options were primarily identified by North American Industry Classification System (NAICS) codes. Small businesses in each affected industry were classified as such based on size definitions established by the Small Business Administration. Economic impacts on affected small businesses were calculated using a direct compliance cost method. The "sales test" was applied by estimating annualized compliance costs for affected small businesses as a percentage of those businesses' annual sales.
Table 2. Industries Affected by the Proposed Regulatory Changes by Rule Component
Rule Component
Industry Category
NAICS Codes
NAICS Code Definition
Leak Inspection and Repair; Reporting and Recordkeeping
Agriculture and Crop Support Services
                                      115
Support Activities for Agriculture and Forestry

Arts, Entertainment, and Recreation
                                      71
Arts, Entertainment, and Recreation

Beverage and Ice Manufacturing
                                      312
Beverage Manufacturing

Durable Goods Wholesalers and Dealers
                                      423
Merchant Wholesalers - Durable Goods


                                      441
Motor Vehicle and Parts Dealers

Educational Services
                                      611
Educational Services

Food manufacturing
                                      311
Food manufacturing

General Merchandise Stores
                                      452
General Merchandise Stores


                                    453998
All Other Miscellaneous Store Retailers (except Tobacco Stores) 

Grocery and Specialty Food Stores
                                     4451
Grocery Stores


                                     4452
Specialty Food Stores


                                     72231
Food Service Contractors

Hospitals
                                      622
Hospitals

Non-durable Goods Wholesalers and Dealers
                                      424
Merchant Wholesalers  -  Non-durable Goods

Non-food Manufacturing
                                      322
Paper Manufacturing


                                      323
Printing and Related Support Activities


                                      324
Petroleum Manufacturing


                                      325
Chemical Manufacturing


                                     3254
Pharmaceutical Manufacturing


                                      326
Plastics and Rubber Manufacturing


                                      332
Metals Manufacturing


                                      333
Machinery Manufacturing


                                      334
Computer and Electronic Product Manufacturing


                                      336
Transportation Equipment Manufacturing


                                     3391
Medical Equipment and Supplies Manufacturing


                                    339999
Miscellaneous Manufacturing 

Office Buildings
                                      511
Publishing Industries (except Internet)


                                      512
Motion Picture and Video Industries


                                      515
Broadcasting


                                      517
Telecommunications


                                      518
Data Processing, Hosting, and Related Services


                                      519
Libraries and Archives


                                      522
Credit Intermediation and Related Activities


                                      524
Insurance Carriers


                                      531
Real Estate


                                      541
Professional, Scientific, and Technical Services


                                      551
Management of Companies and Enterprises


                                      561
Administrative and Support Services


                                      712
Museums, Historical Sites, and Similar Institutions


                                      721
Accommodation


                                      813
Religious, Grantmaking, Civic, Professional, and Similar Organizations

Other Warehousing, Storage, and Transportation
                                      48
Transportation and Warehousing


                                     4931
Warehousing and Storage

Refrigerated Warehousing and Storage
                                     49312
Refrigerated Warehousing and Storage

Research and Development
                                     5417
Research and Development

Utilities
                                      211
Oil and Gas Extraction


                                      221
Utilities

Warehouse Clubs and Supercenters
                                    452910
Warehouse Clubs and Supercenters 
Recordkeeping and Reporting
Reclaimers
                                    325120
Industrial Gas Manufacturing


                                    423930
Recyclable Material Merchant Wholesalers


                                    562920
Materials Recovery Facilities


                                    562212
Solid Waste Landfill


                                    424690
Other Chemical and Allied Products Merchant Wholesalers

Refrigerant Wholesalers
                                    325120
Industrial Gas Manufacturing


                                    424690
Other Chemical and Allied Products Merchant Wholesalers


                                      42
Wholesale Trade

Service Technicians
                                    238220
Plumbing, Heating, and Air-conditioning Contractors

Disposal Establishments
                                    562920
Materials Recovery Facilities


                                    562212
Solid Waste Landfill


                                    423990
Other Miscellaneous Durable Goods Merchant Wholesalers

Service Establishments
                                    811310
Commercial Industrial Machinery and Equipment (not Automotive and Electronic) Repair and Maintenance


                                    811412
Appliance Repair and Maintenance
Refrigerant Sales Restriction; Recordkeeping and Reporting
Small Can Manufacturers
                                    441310
Automotive Parts and Accessories Stores


                                    325120
Industrial Gas Manufacturing

Summary of Results: Costs and Benefits
Total annual compliance costs for EPA's proposed rulemaking are estimated to be $62 - 66 million, with a best estimate of $63 million. This estimate includes annual compliance costs associated with the proposed rulemaking, as well as avoided compliance costs associated with the proposed removal of some existing regulatory requirements and the provision of additional flexibility that are expected to reduce regulatory burden. The proposed rulemaking is also expected to result in approximately $52 million in savings associated with reduced use of ODS and HFC refrigerant. 
Total annual greenhouse gas (GHG) emissions avoided associated with the proposed regulatory changes has a best estimate of 7.5 MMTCO2eq. Total ODS emissions avoided are estimated at 116 ODP-weighted MT.
This screening analysis finds that the proposed rulemaking can be presumed not to have a significant economic impact on a substantial number of small entities (SISNOSE). In total, an estimated 950,500 small businesses may be subject to the proposed regulatory actions. About 944,000 small businesses (99%) are expected to incur compliance costs as a result of this rulemaking that are less than 1% of annual sales. Approximately 150 affected small businesses -- or less than 0.02% -- could incur costs in excess of 1% of annual sales, and fewer than 80 small businesses -- or less than 0.01% -- could incur costs in excess of 3% of annual sales. These estimates are below the thresholds for a substantial number determination under the RFA.

Introduction
Section 608 of the Clean Air Act (CAA) Amendments of 1990, also known as the National Recycling and Emission Reduction Program (the Program), provides authority for the U.S. Environmental Protection Agency's (EPA) regulations governing the use of ozone-depleting substances (ODS), including chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs), during the maintenance, service, repair, or disposal of air-conditioning and refrigeration equipment. The purpose of the Program is to: (1) prohibit any person from intentionally venting ODS refrigerants and their substitutes, such as HFCs, into the environment; (2) reduce the use and emissions of refrigerants; (3) maximize the recapture and recycling of refrigerants; and (4) ensure safe disposal of refrigerants. To this end, regulations established under 40 CFR part 82, subpart F:
Prohibit knowingly venting or otherwise releasing into the environment any refrigerant, including substitutes for ODS, while maintaining, servicing, repairing, or disposing of appliances.
Require service practices that maximize recovery and recycling of ODS (both CFCs and HCFCs and their blends) during the servicing and disposal of air-conditioning and refrigeration equipment.
Set certification requirements for refrigerant recycling and recovery equipment, technicians, and refrigerant reclaimers.
Generally restrict the sale of ODS refrigerant to certified technicians. 
Require used ODS refrigerant to be reclaimed to certain purity standards before being resold.
Require persons servicing or disposing of air-conditioning and refrigeration equipment containing an ODS to certify to EPA that they have acquired refrigerant recovery and/or recycling equipment and are complying with the requirements of the rule. 
Require the repair of significant leaks in air-conditioning and refrigeration equipment containing more than 50 pounds of an ODS refrigerant. 
Establish safe disposal requirements to ensure removal of ODS refrigerants from goods that enter the waste stream with the charge intact (e.g., motor vehicle air conditioners, home refrigerators, and room air conditioners). 
Require reporting and recordkeeping for technicians; technician certification programs; equipment testing organizations; refrigerant wholesalers and purchasers; refrigerant reclaimers; refrigeration and air-conditioning equipment owners/operators; and other establishments that perform refrigerant removal, service, or disposal.
Take enforcement actions against any violation of these regulations.
While these regulations significantly reduce emissions of refrigerants, the current requirements do not include specific requirements for substitute refrigerants other than prohibiting venting. To help minimize the harm that both ODS and substitute refrigerants have on the environment and to fully implement the prohibition on venting, EPA is considering extending the existing requirements under the Program to cover substitutes, and revising the rule components associated with leak repair, as well as recordkeeping and reporting, to reduce refrigerant emissions. Further, EPA is considering a new requirement to reduce emissions associated with Do-It-Yourself (DIY) motor vehicle air-conditioning (MVAC) re-charging where manufacturers must install a self-sealing valve on all small containers to prevent the release of refrigerant to the atmosphere. 
The purpose of this report is to document the results of a costs and benefits assessment that was conducted to help EPA evaluate the impact of the proposed revisions to Section 608 regulations. Further, this report provides information to assist EPA in satisfying its obligations under relevant statutes and Executive Orders (EOs), including: EO 12866 Regulatory Planning and Review; the Regulatory Flexibility Act (RFA); and the Unfunded Mandates Reform Act (UMRA). 
EO 12866: Regulatory Planning and Review. EO 12866 requires agencies to prepare a Regulatory Impact Analysis (RIA) for any "significant regulatory action," which includes any regulatory action that is likely to result in a rule that may:
Have an annual effect on the economy of $100 million or more or adversely affect in a material way the economy, a sector of the economy, productivity, competition, jobs, the environment, public health or safety, or State, local, or tribal governments or communities;
Create a serious inconsistency or otherwise interfere with an action taken or planned by another agency;
Materially alter the budgetary impact of entitlements, grants, user fees, or loan programs or the rights and obligations of recipients thereof; or
Raise novel legal or policy issues arising out of legal mandates, the President's priorities, or the principles set forth in EO 12866.
UMRA. Under Title II, section 202 of the UMRA, each agency is generally required to prepare a written statement for any proposed rulemaking that may result in the expenditure by State, local, and tribal governments (SLTG), in the aggregate, or by the private sector, of $100 million or more in any one year. The written statement must include an assessment of the anticipated costs and benefits of the Federal mandate, a description of the macro-economic effects, and a summary of SLTG concerns and how they were addressed. 
RFA. The RFA, as amended by the Small Business Regulatory Enforcement Fairness Act (SBREFA), requires federal agencies to consider the effects its regulations may have on small entities, and ensure that small entities have a voice in the regulatory development process. Under the RFA, small entities include:
Small businesses, which are defined by size standards established by under the North American Industry Classification System (NAICS) and are based on the number of employees or annual receipts;
Small governments, which are defined as the government of a city, county, town, township, village, school district, or special district with a population of less than 50,000; and
Small organizations, which are defined as any "not-for-profit enterprise which is independently owned and operated and is not dominant in its field."
If it is found that the rule may impose a significant economic impact on a substantial number of small entities (SISNOSE), the agency will generally be required to prepare a formal analysis of the potential adverse economic impacts on small entities, participate in a Small Business Advocacy Review Panel in the proposed rule stage, and prepare a Small Entity Compliance Guide in the final rule stage.
As required by abovementioned EOs and statutory requirements, this report provides a screening analysis to assess the potential impacts of the proposed changes to the U.S. economy as a whole, SLTGs, children, minority and low-income populations, and small entities. This analysis finds that the proposed rulemaking will result in total annual compliance costs of approximately $63 million, and therefore, is not considered an economically significant regulatory action as defined in EO 12866. Further, this analysis finds that the proposed rulemaking can be presumed to have no SISNOSE.
Regulatory Context
The following sections provide an overview of the affected industries, current regulations, and proposed changes to the current regulations.
Profile of Regulated Community
The proposed updates to the Section 608 regulations apply to a wide variety of industries across the U.S. economy.  The new leak inspection and updated repair requirements regulate equipment used for commercial refrigeration (CR), industrial process refrigeration (IPR), and comfort cooling (CC) containing 50 or more pounds of refrigerant. This regulated equipment is owned by many industries and business sectors, including grocery and specialty food stores, warehouse clubs and supercenters, agricultural and crop support services, utilities, food and non-food manufacturing, beverage and ice manufacturing, office buildings, hospitals, and others. The reporting and recordkeeping requirements affect these business sectors as well as: refrigerant reclaimers; disposal establishments; plumbing, heating, and air-conditioning contractors; service establishments; and refrigerant wholesalers. Lastly, the requirements for DIY small containers affect manufacturers of those containers, including automotive parts and accessories stores and industrial gas manufacturers.
Current Leak Repair Requirements
The current leak repair regulations require that when an owner or operator of a regulated appliance discovers that ODS refrigerant is leaking at a rate that would exceed the applicable annual leak rate during a 12-month period, the owner or operator must take corrective action to repair the leak. Table 3 below shows the current annual leak rates for each appliance type.
Table 3. Existing Annual Leak Rates by Appliance Type
Appliance Type
Annual Leak Rate
                                      CR
                                      35%
                                      IPR
                                      35%
                                      CC
                                      15%
                             All other appliances
                                      15%

Appliances classified as CR or IPR with a charge size greater than 50 pounds of ODS refrigerant must be repaired within 30 days of discovering a leak that would result in the release of 35% or more of the charge over a 12-month period. All other appliances with a charge size greater than 50 pounds of ODS refrigerant must be repaired within 30 days of discovering a leak that would result in the release of 15% or more of the charge over a 12-month period. Alternatively, owners or operators of appliances that exceed the annual leak rate may opt to develop a retrofit/retirement plan within 30 days of leak discovery and complete actions under that plan within 12 months. The deadlines for repair and retrofit/retirement may be extended in some cases such as when the necessary repair parts are unavailable, other applicable regulations make a repair within the required timeframe impossible, or an industrial process shutdown is required to make necessary repairs. 
IPR equipment owners or operators are also required to verify the success of repairs. Specifically, an initial verification test must be completed after any repairs and before the replacement of the refrigerant in the system. A follow-up verification test must be conducted within 30 days after the initial verification test or of bringing the system back to normal operation. If the initial or follow-up verification indicates that the repair was unsuccessful, the owner or operator is required to notify EPA and develop a retrofit or retirement plan within 30 days of the failed test. The requirement to retire or retrofit the leaking equipment may be avoided if the leak is successfully repaired within the allotted time period, as demonstrated by an initial and follow-up verification tests. If the repair requires an industrial process shutdown, a 120-day repair period is allowed.
Current Recordkeeping and Reporting Requirements
To facilitate compliance with and enforcement of Section 608 regulations, EPA requires reporting and recordkeeping of relevant entities such as owners/operators of regulated equipment and service technicians. The recordkeeping requirements and periodic submission of reports occur on an annual, biannual, one-time, or occasional basis depending on the nature of the reporting entity and the length of time that the entity has been in service.  Specific recordkeeping requirements for affected entities only cover appliances with ODS refrigerants and include the following: 
Programs certifying technicians must maintain records on each technician certified through their programs and display a copy of EPA's approval letter at their place of business.
oo Anyone selling or distributing or offering to sell or distribute previously-used or virgin refrigerant must retain invoices that indicate the name of the purchaser, the date of sale, the quantity, and that the purchaser is a certified technician (as applicable).
oo Approved refrigerant recovery/recycling equipment testing organizations must maintain records of refrigerant recovery/recycling equipment testing and performance and refrigerant recovery/recycling equipment that meets EPA standards.
Approved technician certifying programs must maintain records that include, but are not limited to, the names and addresses of all individuals taking the tests, the scores of all certification tests administered, and the dates and locations of all testing administered.
oo Technicians must maintain proof that they are certified.
oo Refrigerant reclaimers must maintain records on the quantity of material sent to them for reclamation, the amount reclaimed, waste products from the reclamation process, and customer and sales records.
oo Disposers of refrigeration and air-conditioning equipment must maintain copies of signed statements attesting that the refrigerant has been removed prior to final disposal of each appliance. 
oo Anyone servicing appliances normally containing 50 or more pounds of refrigerant must provide service invoices to the owner or operator.
oo Owners or operators of appliances normally containing 50 or more pounds of refrigerant must keep records of the amounts of refrigerant purchased and added to their appliances, as well as service records provided by technicians and other reports related to the leak repair requirements (e.g., retrofit/retirement plans, full charge calculation).
oo Owners or operators of appliances normally containing 50 or more pounds of refrigerant must maintain information on purged and destroyed refrigerant. 
Owners of refrigerant recovery equipment must certify that they have acquired and will properly use such equipment.
Periodic reports include the following: 
oo Approved technician certification programs must submit biannual reports on their pass/fail rates and the next year's testing schedule.
Approved equipment testing organizations must submit to EPA within 30 days of the certification of a new model line of recycling or recovery equipment the name of the manufacturer and the name and/or serial number of the model line.
Approved technician certification programs that stop providing the certification test must forward all records to another program currently approved by EPA, who then must inform EPA of the transferred records.
Approved technician certification programs that have had their certification revoked must forward all records to EPA.
oo Approved refrigerant recovery/recycling equipment testing organizations must submit an annual list of refrigerant recovery/recycling equipment that meet EPA standards and must notify EPA whenever a model of refrigerant recovery/recycling equipment fails a three-year recertification test.
oo Refrigerant reclaimers must submit annual reports noting the mass of refrigerant reclaimed by refrigerant type and the mass of waste products produced.
oo Owners of IPR equipment whose appliances fail a verification test and owners of IPR appliances and federally-owned CR and CC appliances who wish to receive an extension or exclusion under the leak repair requirement are subject to additional reporting and recordkeeping requirements.
Proposed Regulatory Revisions
EPA is proposing to revise select components of the current regulatory requirements under Section 608, including leak repair and recordkeeping and reporting. These changes are further described in the sub-sections below.
Proposed Changes to the Leak Repair Requirements
EPA is proposing to change the leak repair requirements for CC, CR, and IPR appliances normally containing 50 or more pounds of ODS refrigerant. Specifically, EPA is proposing to:
oo Extend the existing requirements to CC, CR, and IPR appliances containing 50 or more pounds of HFC and other substitute refrigerant, excluding those that are exempt from the venting prohibition (e.g., CO2, ammonia).
oo Lower the annual leak rates from 35% to 20% for IPR and CR appliances containing 50 or more pounds of ODS, HFC, or other non-exempt substitute refrigerant.
oo Lower the annual leak rates from 15% to 10% for CC appliances containing 50 or more pounds of ODS, HFC, or other non-exempt substitute refrigerant.
oo Require quarterly leak inspections for CR and IPR appliances containing 500 or more pounds of ODS, HFC, or other non-exempt substitute refrigerant (unless automatic leak detection equipment is installed and certified every year).
oo Require annual leak inspections for all CC appliances, plus CR and IPR appliances containing between 50-500 pounds of ODS, HFC, or other substitute refrigerant (unless automatic leak detection equipment is installed and certified every year).
oo Establish a leak limit where an appliance is prohibited from leaking more than 75% of its full charge in two consecutive years (e.g., a facility leaks 80% in one year, and 76% the following year). 
oo Require initial and follow-up verification tests for all appliances (i.e., IPR, CR, and CC equipment) when the applicable leak rate is exceeded.
oo Require a leak inspection to identify leaks upon discovering that the applicable leak rate is exceeded;
oo Require that all identified leaks are repaired when the applicable leak rate is exceeded rather than just bringing the leak rate down below the annual leak rate threshold.
oo Allow leak repair extension requests for all appliances, including non-federal CR and CC systems. 
oo Explicitly allowing (and even encouraging) electronic instead of paper records.
Proposed Changes to the Recordkeeping and Reporting Requirements
EPA is proposing to change the recordkeeping and reporting requirements for technicians, technician certification programs, refrigerant recovery/recycling equipment testing organizations, refrigerant wholesalers and purchasers, refrigerant reclaimers, refrigeration and air-conditioning equipment owners, and other establishments that perform refrigerant removal, service, or disposal. Specifically, EPA is proposing to: 
oo Extend the current recordkeeping and reporting requirements to appliances containing HFCs and other non-exempt substitutes.
oo Allow owners/operators of all CC and CR appliances containing 50 or more pounds of ODS refrigerant to prepare and submit requests for extensions to the leak repair and retrofit/retire timeline (currently limited to IPR and federally-owned CC and CR appliances).
oo Allow owners/operators of all CC, CR, and IPR appliances containing 50 or more pounds of HFC or other substitute equipment to prepare and submit requests for extensions to the leak repair and retrofit/retire timeline.
oo Require persons servicing ODS, HFC, and other non-exempt substitute refrigerant-containing appliances with charge sizes of 50 or more pounds to provide records of the following for each refrigerant addition: the identity and location of the appliance, the date and type of service performed, the quantity and type of refrigerant added, the full charge of the system, and the leak rate. 
oo Require owners/operators of ODS, HFC, and other non-exempt substitute refrigerant-containing appliances with charge sizes of 50 or more pounds to maintain records of the following for each refrigerant addition: the identity and location of the appliance, the date and type of service performed, the quantity and type of refrigerant added, the full charge of the system, and the leak rate.
oo Require owners/operators of ODS, HFC, and other non-exempt substitute refrigerant-containing appliances with charge sizes of 50 or more pounds to maintain reports on the results of verification tests and leak inspections any time the leak rate threshold is exceeded.
oo Require owners/operators of ODS, HFC, and other non-exempt substitute refrigerant-containing appliances with charge sizes of 50 or more pounds to maintain records of quarterly and annual inspections.
oo Require technicians disposing of field-installed appliances with charge sizes between 5 and 50 pounds of ODS, HFC, and other non-exempt substitute refrigerant to maintain records on the quantity and type of refrigerant recovered at disposal and the quantity and type of refrigerant transferred for reclamation or destruction, as well as the company name and date.
Require approved technician certifying programs to publish online lists or databases documenting who they have certified and what type of certification each individual has received. The regulation would only require prospective lists of who is certified, not a compilation of everyone who was certified previously.
Require manufacturers of small cans of automotive refrigerant to keep records of test data and log forms that demonstrate compliance with the allowable leakage rate.
EPA is also proposing to remove the requirement for persons who maintain, service, repair, or dispose of appliances containing ODS refrigerants to submit a signed statement that they own certified recovery and recycling equipment.
Other Proposed Regulatory Revisions
EPA is also proposing to change other regulatory requirements. Specifically, EPA is proposing to: 
Extend the sales restriction to HFCs and other non-exempt substitutes to ensure proper handling of ODS substitutes.
Exempt small cans of HFC refrigerant that are typically used for DIY aftermarket servicing of MVACs from the sales restriction.
Require self-sealing valves on small cans of substitute (currently HFC-134a) refrigerant to minimize emissions from DIY servicing.
Extend all other the regulatory requirements found at 40 CFR part 82, subpart F, including technician certification, appliance disposal, refrigerant reclamation, service practices, and the requirement to recover refrigerant to HFCs and other non-exempt substitutes.
Require substitute-containing recycling/recovery equipment to be certified.  
Organization of This Report
The remainder of this report is organized as follows: 
oo Section 2 characterizes the equipment regulated under Section 608 and identifies affected businesses within each sector.
oo Section 3 presents the general approach and assumptions used to estimate aggregate annual costs to the U.S. economy, economic impacts on small entities, and benefits associated with the proposed changes.
oo Section 4 summarizes the results of the aggregate economic impact analysis.
oo Section 5 summarizes the economic impact on small entities, including the SISNOSE determination.
oo Section 6 discusses the relevant statutes and EOs that EPA must satisfy.
oo Section 7 summarizes the results of the analysis.


Industry Characterization
The Agency's proposed changes to the Section 608 regulations -- including requirements for leak inspection and repair, recordkeeping and reporting, and self-sealing valves for small cans -- will affect a range of businesses and industries. This section identifies the industries that may be affected using North American Industry Classification System (NAICS) codes. NAICS codes are industry classifications that the U.S. Census Bureau uses to track the number of businesses and relevant information about those businesses, including their distribution by employment size and sales receipts.  
Affected Industry for Leak Inspection and Repair Requirements
Equipment Characterization
The proposed changes to the requirements for leak inspection and repair will generally affect owners and operators of CR, IPR, and CC appliances with a full charge size of 50 pounds or more of ODS or HFC refrigerant. These equipment types include:
Commercial refrigeration systems are the refrigeration appliances used in the retail food and cold storage warehouse sectors. Retail food includes the refrigeration equipment found in supermarkets, convenience stores, restaurants, and other food service establishments. All cold storage systems generally have charge sizes over 50 pounds and include the equipment used to store meat, produce, dairy products, and other perishable goods.  
Industrial Process Refrigeration systems are complex, customized systems used in the chemical, pharmaceutical, petrochemical, and manufacturing industries. These systems are directly linked to the industrial process. This sector also includes industrial ice machines, appliances used directly in the generation of electricity, and ice rinks.
Comfort Cooling includes stationary refrigeration equipment that provides cooling in order to control heat and/or humidity in facilities, such as office buildings and light commercial buildings. Comfort cooling appliances include building chillers and roof-top self-contained units. They may be used for the comfort of occupants or for climate control to protect equipment within a facility, such as in computer rooms. 
Table 4 presents the characterization of equipment by sector, type, size, and refrigerant used (ODS or HFC). Assumptions are derived from data and analysis based on EPA's Vintaging Model (see Box 2; EPA 2014) and on facility-level reporting from California's High-Global Warming Potential Stationary Source Refrigerant Management Program (RMP) (see Box 1), as described below. 
Box 1: EPA's Vintaging Model
EPA's Vintaging Model estimates the annual chemical emissions from industry sectors that have historically used ODS, including AC, refrigeration, foams, solvents, aerosols, and fire protection. Within these industry sectors, there are over 60 independently modeled end-uses. The model uses information on the market size and growth for each end-use, as well as a history and projections of the market transition from ODS to alternatives. As ODS are phased out, a percentage of the market share originally filled by the ODS is allocated to each of its substitutes, including HFCs. The model tracks emissions of annual "vintages" of new equipment that enter into operation by incorporating information on estimates of the quantity of equipment or products sold, serviced, and retired or retrofitted each year, and the quantity of the compound required to manufacture, charge, and/or maintain the equipment. EPA's Vintaging Model uses this market information to build an annual inventory of in-use stocks of equipment and the ODS and non-ODS substitutes in each end-use. The model is updated on a regular basis to reflect changes in the market and new industry information.
Box 1: EPA's Vintaging Model
EPA's Vintaging Model estimates the annual chemical emissions from industry sectors that have historically used ODS, including AC, refrigeration, foams, solvents, aerosols, and fire protection. Within these industry sectors, there are over 60 independently modeled end-uses. The model uses information on the market size and growth for each end-use, as well as a history and projections of the market transition from ODS to alternatives. As ODS are phased out, a percentage of the market share originally filled by the ODS is allocated to each of its substitutes, including HFCs. The model tracks emissions of annual "vintages" of new equipment that enter into operation by incorporating information on estimates of the quantity of equipment or products sold, serviced, and retired or retrofitted each year, and the quantity of the compound required to manufacture, charge, and/or maintain the equipment. EPA's Vintaging Model uses this market information to build an annual inventory of in-use stocks of equipment and the ODS and non-ODS substitutes in each end-use. The model is updated on a regular basis to reflect changes in the market and new industry information.
Box 2: California's Refrigerant Management Program (RMP)
CARB adopted the RMP in 2009 as a part of the state's Global Warming Solutions Act of 2006 (AB 32). The purpose of the RMP is to reduce emissions of high-GWP refrigerants from stationary, non-residential refrigeration equipment and from the installation and servicing of stationary refrigeration and air-conditioning appliances using high-GWP refrigerants. Effective January 1, 2011, facilities with refrigeration systems containing more than 50 pounds of refrigerant must conduct periodic leak inspections, promptly repair leaks, and keep onsite records.  Beginning January 1, 2012, facilities with systems containing more than or equal to 200 pounds must report annually through CARB's online reporting tool on leak inspections, repairs, and purchases of high-GWP refrigerants (CARB 2010a).

This analysis uses data reported to CARB under the RMP for the 2013 calendar year. The data include annual reports for facilities with refrigeration systems containing a full charge greater than or equal to 200 pounds. Although reporting is not required for refrigeration systems containing a full charge between 50 and 200 pounds, some facilities have chosen to track leak inspections and maintenance records for these systems through CARB's online reporting tool as well. For the 2013 calendar year, approximately 600, 42,000, and 4,600 leak event records were reported for small, medium, and large refrigeration systems, respectively (CARB 2014). 

While this analysis largely relies on 2013 RMP data, these data have been reviewed against other sources, including information from California's South Coast Air Quality Management District (SCAQMD) Rule 1415 and EPA's Vintaging Model, to ensure that assumptions made are representative of the United States as a whole. 
Box 2: California's Refrigerant Management Program (RMP)
CARB adopted the RMP in 2009 as a part of the state's Global Warming Solutions Act of 2006 (AB 32). The purpose of the RMP is to reduce emissions of high-GWP refrigerants from stationary, non-residential refrigeration equipment and from the installation and servicing of stationary refrigeration and air-conditioning appliances using high-GWP refrigerants. Effective January 1, 2011, facilities with refrigeration systems containing more than 50 pounds of refrigerant must conduct periodic leak inspections, promptly repair leaks, and keep onsite records.  Beginning January 1, 2012, facilities with systems containing more than or equal to 200 pounds must report annually through CARB's online reporting tool on leak inspections, repairs, and purchases of high-GWP refrigerants (CARB 2010a).

This analysis uses data reported to CARB under the RMP for the 2013 calendar year. The data include annual reports for facilities with refrigeration systems containing a full charge greater than or equal to 200 pounds. Although reporting is not required for refrigeration systems containing a full charge between 50 and 200 pounds, some facilities have chosen to track leak inspections and maintenance records for these systems through CARB's online reporting tool as well. For the 2013 calendar year, approximately 600, 42,000, and 4,600 leak event records were reported for small, medium, and large refrigeration systems, respectively (CARB 2014). 

While this analysis largely relies on 2013 RMP data, these data have been reviewed against other sources, including information from California's South Coast Air Quality Management District (SCAQMD) Rule 1415 and EPA's Vintaging Model, to ensure that assumptions made are representative of the United States as a whole. 
Equipment type and size. This analysis classifies equipment into four size categories based on refrigerant charges: small (containing between 50 and 199 pounds of refrigerant), medium <500 pounds (containing between 200 and 499 pounds of refrigerant), medium >=500 pounds (containing between 500 and 2,000 pounds of refrigerant), and large (containing greater than 2,000 pounds of refrigerant). These size categories are similar to those used by the California Air Resources Board (CARB) in their 2009 analysis of the RMP (CARB 2009a; see also Box 1) but adjusted to correspond with distinctions in the Agency's proposed regulatory changes. For example, quarterly reporting is proposed for CR and IPR equipment with refrigerant charges of >=500 pounds, thus, a distinction is made between medium-sized equipment with charge sizes above and below the 500 pounds threshold. Assumptions about the average charge size by equipment sector and type and the percentage of systems by type and sector were developed based on analysis of facility-level reporting under California's RMP.Equipment type is not a reporting requirement of California's RMP. Therefore, although this analysis relies on facility-level data reported under the California RMP, additional analysis and assumptions were applied to these data regarding refrigerant use, size, and industry characterizations (outlined in Section 2.1.2). The additional analysis was used to group reported equipment into the equipment sectors, types, and industries affected by the proposed regulatory changes and to determine the universe of affected equipment by the proposed regulatory changes.  Box 3 in Section 2.1.2 farther below illustrates this approach.
Refrigerant distribution. EPA's Vintaging Model is the basis for assumptions on the distribution of refrigerant (i.e., ODS and HFC) by equipment sector and type[.] 
Table 4: Equipment Characterization by Sector, Type, Size, and Refrigerant Type 
Equipment Sector
Equipment Type
Equipment Size
Refrigerant Type
Typical Charge Sizes (lbs)
Percentage of Systems in Sector
Distribution of Refrigerants by Type[a]
CC
Unitary AC
Small
                                      ODS
                                     114 
                                      28%
                                      59%



                                      HFC
                                     115 
                                      2%
                                      41%

Chiller
Medium
                                      ODS
                                     780 
                                      60%
                                      62%



                                      HFC
                                     651 
                                      8%
                                      38%

Chiller
Large
                                      ODS
                                    7,659 
                                      1%
                                      62%



                                      HFC
                                    5,118 
                                      2%
                                      38%
CR

Condensing Unit
Small
                                      ODS
                                     110 
                                      1%
                                      41%



                                      HFC
                                      97 
                                      9%
                                      59%

Rack
Medium <500 lbs
                                      ODS
                                     335 
                                      8%
                                      51%



                                      HFC
                                     370 
                                      19%
                                      49%

Rack
Medium >=500 lbs
                                      ODS
                                     961 
                                      20%
                                      51%



                                      HFC
                                     930 
                                      33%
                                      49%

Rack
Large
                                      ODS
                                    2,501 
                                      1%
                                      51%



                                      HFC
                                    2,486 
                                      1%
                                      49%

Cold Storage
Medium <500 lbs
                                      ODS
                                     320 
                                      2%
                                      57%



                                      HFC
                                     315 
                                      1%
                                      43%

Cold Storage
Medium >=500 lbs
                                      ODS
                                    1,110 
                                      2%
                                      57%



                                      HFC
                                    1,061 
                                      1%
                                      43%

Cold Storage
Large
                                      ODS
                                    7,368 
                                      2%
                                      57%



                                      HFC
                                    5,882 
                                      0%
                                      43%
IPR
IPR

Small
                                      ODS
                                      70 
                                      5%
                                      47%



                                      HFC
                                      86 
                                      22%
                                      53%


Medium <500 lbs
                                      ODS
                                     322 
                                      16%
                                      47%



                                      HFC
                                     306 
                                      8%
                                      53%


Medium >=500 lbs
                                      ODS
                                    1,049 
                                      25%
                                      47%



                                      HFC
                                    1,038 
                                      3%
                                      53%


Large
                                      ODS
                                    5,592 
                                      13%
                                      47%



                                      HFC
                                    5,062 
                                      8%
                                      53%
Totals may not sum due to independent rounding.
Source: EPA 2014; CARB 2009a
a EPA's Vintaging Model does not disaggregate all equipment types by size. Therefore, the same ODS/HFC distributions are applied across all size categories for some equipment types.

Table 5 and Table 6 below present the specific ODS and HFC refrigerants and charge size categories, respectively, that are most commonly used in the equipment types and sectors affected by this proposed rulemaking. Typical refrigerants used by each equipment type were identified using CARB (2009) and EPA's Vintaging Model. 
Table 5: Typical Refrigerants Used by Equipment Type 
Equipment Sector
Equipment Type
ODS
HFC


123
22
402A
408A
134a
404A
407A
507
CC
Centrifugal Chillers
X
X


X




Packaged Chillers
X
X


X




Unitary AC

X






CR
Centralized Systems (DX, parallel rack)

X
X
X

X
X
X

Condensing Units

X


X
X



Cold Storage

X
X
X

X
X
X
IPR
Process Cooling
X
X


X



Source: EPA 2014; CARB 2009a

Table 6: Typical Charge Size Categories by Equipment Type
Sector
CARB Equipment Characterization
                                     Small
                                 (50-200 lbs)
                                    Medium
                                (200-2,000 lbs)
                                     Large
                             (2,000 lbs and above)
CC
Chillers
                                       
                                       X
                                       X

Unitary AC
                                       X
                                       
                                       
CR
Condensing Units
                                       X
                                       
                                       

Rack
                                       
                                       X
                                       X

Cold Storage
                                       
                                       X
                                       X
IPR
Process Cooling
                                       X
                                       X
                                       X
Source: EPA 2014; CARB 2009a

Only equipment that experience leaks that exceed the proposed leak thresholds will be subject to repair requirements; however, all equipment containing 50 or more pounds of ODS or non-exempt substitute refrigerant will be subject to the leak inspection requirements and thus incur compliance costs. These assumptions are further elaborated in Section 3.1.1. 
Industry Characterization
The affected businesses (by NAICS code) were identified from an analysis conducted by CARB (2009) on California's RMP, a similar analysis of proposed leak repair requirements (Stratus 2009), an earlier RIA on this issue (ICF 1997), an analysis of data reported under California's RMP for 2013 (which includes self-assigned NAICS codes from 3,565 facilities), the Program's 2015 supporting ICR (EPA ICR Number: 1626.13, OMB Control Number:  2060-0256) (EPA 2015b), and expert judgment.  
The affected businesses were grouped into 17 broader industry categories based on industry similarities (e.g., different types of non-food manufacturing, or different types of businesses that may have office buildings), as well as expert judgment on grouping the affected businesses by the types of equipment they are likely to use per facility. Table 7 below presents the list of affected industry sectors, NAICS codes, and NAICS code definitions. 
Table 7: Industry Sector, NAICS Code, and Definition
Industry Sector Category
NAICS Codes[a][,][b]
NAICS Code Definition



Agriculture and Crop Support Services
                                      115
Support Activities for Agriculture and Forestry
Arts, Entertainment, and Recreation
                                      71
Arts, Entertainment, and Recreation
Beverage and Ice Manufacturing
                                      312
Beverage Manufacturing
Durable Goods Wholesalers and Dealers
                                      423
Merchant Wholesalers - Durable Goods

                                      441
Motor Vehicle and Parts Dealers
Educational Services
                                      611
Educational Services
Food Manufacturing
                                      311
Food Manufacturing
General Merchandise Stores
                                      452
General Merchandise Stores

                                    453998
All Other Miscellaneous Store Retailers (except Tobacco Stores) 
Grocery and Specialty Food Stores
                                     4451
Grocery Stores

                                     4452
Specialty Food Stores

                                     72231
Food Service Contractors
Hospitals
                                      622
Hospitals
Non-durable Goods Wholesalers and Dealers
                                      424
Merchant Wholesalers  -  Non-durable Goods
Non-food Manufacturing
                                      322
Paper Manufacturing

                                      323
Printing and Related Support Activities

                                      324
Petroleum Manufacturing

                                      325
Chemical Manufacturing

                                     3254
Pharmaceutical Manufacturing

                                      326
Plastics and Rubber Manufacturing

                                      332
Metals Manufacturing

                                      333
Machinery Manufacturing

                                      334
Computer and Electronic Product Manufacturing

                                      336
Transportation Equipment Manufacturing

                                     3391
Medical Equipment and Supplies Manufacturing

                                    339999
Miscellaneous Manufacturing 
Office Buildings
                                      511
Publishing Industries (except Internet)

                                      512
Motion Picture and Video Industries

                                      515
Broadcasting

                                      517
Telecommunications

                                      518
Data Processing, Hosting, and Related Services

                                      519
Libraries and Archives

                                      522
Credit Intermediation and Related Activities

                                      524
Insurance Carriers

                                      531
Real Estate

                                      541
Professional, Scientific, and Technical Services

                                      551
Management of Companies and Enterprises

                                      561
Administrative and Support Services

                                      712
Museums, Historical Sites, and Similar Institutions

                                      721
Accommodation

                                      813
Religious, Grantmaking, Civic, Professional, and Similar Organizations
Other Warehousing, Storage, and Transportation
                                      48
Transportation and Warehousing

                                     4931
Warehousing and Storage
Refrigerated Warehousing and Storage
                                     49312
Refrigerated Warehousing and Storage
Research and Development
                                     5417
Research and Development
Utilities
                                      211
Oil and Gas Extraction

                                      221
Utilities
Warehouse Clubs and Supercenters
                                    452910
Warehouse Clubs and Supercenters 
Source: U.S. Census Bureau 2012
[a]The NAICS codes range from the broadest classification, the two digit NAICS code, to the most narrow, six digit level NAICS code, with each progressive digit specifying a further level of detail. The first two digits distinguish the economic sector, the third digit distinguishes the subsector, the fourth digit distinguishes the industry group, the fifth digit distinguishes the NAICS industry, and the sixth digit distinguishes the national industry (U.S. Census Bureau 2015). 
[b]In several cases where a broader NAICS designation is listed (e.g., two digit code), not all national industries (i.e., six digit codes) were considered applicable to this analysis. A full list of NAICS codes, disaggregated to the degree of detail used in the analysis is available in Appendix E.1.

Economic data for each affected industry -- including number of firms and establishments by employment or receipts size -- was obtained from the U.S. Census Bureau's Industry Statistics Portal (http://www.census.gov/econ/isp/) and includes the latest employment and receipt data from the U.S. Census Bureau 2012 County Business Patterns and the 2007 Economic Census, respectively (U.S. Census Bureau 2012; U.S. Census Bureau 2007).  The economic census profiles U.S. national and local economies every five years, and the 2007 data is the latest available at the time of this writing.
Table 8 below presents the total number of establishments (facilities) and firms (businesses), as well as small businesses and associated facilities, by industry category. Small businesses were identified using the U.S. Small Business Administration's table of small business size standards matched to affected NAICS codes. The version employed for this analysis became effective July 14, 2014 (U.S. Small Business Administration 2014). 
         Table 8: Total Businesses and Facilities by Industry Category
Industry Category
All Businesses
Small Businesses

                                  Facilities
                                  Businesses
                                  Facilities
                                  Businesses
Agriculture & Crop Support Services
                                                                         3,588 
                                                                         3,296 
                                                                         3,189 
                                                                         3,151 
Arts, Entertainment, and Recreation
                                                                         32,288
                                                                         27,322
                                                                         28,897
                                                                         26,891
Beverage & Ice Manufacturing
                                                                          4,712
                                                                          4,135
                                                                          4,134
                                                                          4,052
Durable Goods
                                                                        128,858
                                                                         92,362
                                                                         99,926
                                                                         90,802
Educational Services
                                                                         26,641
                                                                         21,691
                                                                         21,315
                                                                         19,888
Food Manufacturing
                                                                         25,798
                                                                         22,293
                                                                         22,533
                                                                         21,319
General Merchandise Stores
                                                                         55,428
                                                                         20,412
                                                                         24,839
                                                                         20,044
Grocery & Specialty Food Stores
                                                                        105,342
                                                                         56,740
                                                                         60,013
                                                                         55,807
Hospitals
                                                                          5,281
                                                                          2,904
                                                                          1,533
                                                                          1,363
Non-durable Goods
                                                                         52,363
                                                                         40,256
                                                                         39,061
                                                                         37,576
Non-food Manufacturing
                                                                         58,313
                                                                         51,923
                                                                         54,713
                                                                         50,815
Office Buildings
                                                                      2,258,830
                                                                      1,910,880
                                                                      1,998,350
                                                                      1,874,025
Other Warehousing, Storage, and Transportation
                                                                         67,627
                                                                         53,145
                                                                         53,582
                                                                         50,312
Refrigerated Warehousing & Storage
                                                                          1,158
                                                                            628
                                                                            638
                                                                            503
Research and Development
                                                                         15,501
                                                                         12,359
                                                                         12,426
                                                                         11,660
Utilities
                                                                         25,553
                                                                         12,781
                                                                         21,036
                                                                         12,433
Warehouse Clubs & Supercenters
                                                                          5,164
                                                                             32
                                                                             84
                                                                             26
Total 
                                                                     2,872,445 
                                                                     2,333,159 
                                                                     2,446,270 
                                                                     2,280,667 
Sources: U.S. Small Business Administration 2014; U.S. Census Bureau 2012; U.S. Census Bureau 2007

CR and IPR appliances in facilities located in California are already subject to similar leak inspection and repair requirements under the California RMP. Thus, California facilities using those equipment types were removed from the total facilities and businesses considered when model facility assumptions were scaled up to determine total affected equipment for this analysis. California facilities using CC appliances with refrigerant charges of 50 or more pounds were still included, as those systems are not already subject to similar requirements. 
To estimate aggregate costs and benefits across the entire U.S. economy, as well as costs per small business for the RFA/SBREFA screening analysis, assumptions were needed about the percentage of each industry category affected by the proposed regulatory changes (i.e., the proportion of facilities that would have appliances with refrigerant charges 50 or more pounds) and the type and number of equipment per affected facility and business.
Table 9 summarizes the assumptions made regarding the average number of systems in each sector per facility, for each industry category. These assumptions were based on analysis of 2013 data reported under California's RMP, cross-walked with assumptions made by similar analyses (CARB 2009a; Stratus 2009) about equipment use by industry, and reconciled with expert judgment. Table 9 also presents assumptions about the percentage of each industry that is assumed to use equipment containing 50 or more pounds of ODS or HFC refrigerant, and thus be affected by leak inspection and repair provisions of the proposed rulemaking. 
Comfort Cooling -- approximately 6% of commercial buildings (including offices, hospitals, and schools) are estimated to contain AC systems with a charge size of 50 or more pounds, based on data reported under the Commercial Building Energy Consumption Survey (as reviewed in Stratus 2009).
Commercial Refrigeration -- all industries assumed to use commercial refrigeration equipment use equipment that contains 50 or more pounds of refrigerant. Industries that only use smaller commercial refrigeration equipment (e.g., stand-alone systems, beverage coolers, vending machines) are not considered in the commercial refrigeration equipment categorization. 
Industrial Process Refrigeration -- IPR are very large systems that contain 50 or more pounds of refrigerant. 
Table 9: Percentage of Industry Containing Appliances with 50 or More Pounds of ODS or HFC Refrigerant, and Average Number of Systems per Facility
Industry Category
Percentage of Industry Affected
Average Systems per Facility
                                       
                                       
                                      CC
                                      CR
                                      IPR
Agriculture and Crop Support Services
100%
1
2
-
Arts, Entertainment, and Recreation

1
-
-
     Non-ice Rinks
6%
1
-
-
     Ice Rinks
2%
1
-
2
Beverage and Ice Manufacturing
100%
1
-
1
Durable Goods Wholesalers and Dealers
100%
2
-
-
Educational Services
6%
4
1
-
Food Manufacturing
100%
1
2
-
General Merchandise Stores




     Department Stores, Etc.
6%
1
-
-
     Stores with Grocery Departments
10%
1
2
-
Grocery and Specialty Food Stores
100%
1
2
-
Hospitals
6%
2
-
-
Non-durable Goods Wholesalers and Dealers
100%
1
2
-
Non-food Manufacturing
100%
2
-
3
Office Buildings
6%
3
-
-
Other Warehousing, Storage, and Transportation
6%
4
-
-
Refrigerated Warehousing and Storage
100%
1
2
-
Research and Development
6%
2
-
-
Utilities
6%
2
-
-
Warehouse Clubs and Supercenters
100%
1
3
-

In Box 3 below, the Agricultural and Crop Support Services industry is used to illustrate how the assumptions described in Sections 2.1.1 and 2.1.2 were applied to characterize the industries and equipment affected by the proposed leak inspection and repair regulatory changes.  
Box 3: Industry and Equipment Characterization Approach for the Agricultural and Crop Support Services Industry
Information regarding refrigerant use (Table 5), typical sizes per equipment type (Table 6), and equipment sectors used per industry (Table 9) were triangulated to define model equipment and facilities for the purposes of this analysis. For example, the Agriculture and Crop Support Services industry is assumed to use both CC and CR appliances. Facility reports under the RMP show equipment in this industry containing R-123, R-22, R-134a, R-404A, R-407A, and R-507. It can be reasonably assumed that all systems using R-404A, R-407A, and R-507 are commercial refrigeration systems, as these refrigerants are typically used only in the commercial refrigeration sector, regardless of equipment size. The Agriculture and Crop industry is also assumed to use cold storage equipment in the commercial refrigeration sector, which falls in the medium and large size categories and typically uses R-22, but not R-123 or R-134a. Therefore the reported medium and large R-22 systems are assumed to be commercial refrigeration systems, and the remaining R-123, R-134a, and small R-22 systems are assumed to be for comfort cooling, with small systems likely being unitary AC and medium and large systems likely being chillers. This type of reasoning process was applied for each of the broad industry categories to define the distribution of equipment types per industry, as shown in the table below.
Industry
               Average Systems and Equipment Types per Facility

                                      CC
                                  Unitary AC
                                  Chiller (M)
                                  Chiller (L)
                                      CR
                                  Cond. Unit
                                   Rack (M)
                                   Rack (L)
                               Cold Storage (M)
                               Cold Storage (M)
                                      IPR
Ag. and Crop Support Services
                                       1
                                      74%
                                      22%
                                      4%
                                       2
                                      5%
                                      0%
                                      0%
                                      78%
                                      17%
                                       -

Box 3: Industry and Equipment Characterization Approach for the Agricultural and Crop Support Services Industry
Information regarding refrigerant use (Table 5), typical sizes per equipment type (Table 6), and equipment sectors used per industry (Table 9) were triangulated to define model equipment and facilities for the purposes of this analysis. For example, the Agriculture and Crop Support Services industry is assumed to use both CC and CR appliances. Facility reports under the RMP show equipment in this industry containing R-123, R-22, R-134a, R-404A, R-407A, and R-507. It can be reasonably assumed that all systems using R-404A, R-407A, and R-507 are commercial refrigeration systems, as these refrigerants are typically used only in the commercial refrigeration sector, regardless of equipment size. The Agriculture and Crop industry is also assumed to use cold storage equipment in the commercial refrigeration sector, which falls in the medium and large size categories and typically uses R-22, but not R-123 or R-134a. Therefore the reported medium and large R-22 systems are assumed to be commercial refrigeration systems, and the remaining R-123, R-134a, and small R-22 systems are assumed to be for comfort cooling, with small systems likely being unitary AC and medium and large systems likely being chillers. This type of reasoning process was applied for each of the broad industry categories to define the distribution of equipment types per industry, as shown in the table below.
Industry
               Average Systems and Equipment Types per Facility

                                      CC
                                  Unitary AC
                                  Chiller (M)
                                  Chiller (L)
                                      CR
                                  Cond. Unit
                                   Rack (M)
                                   Rack (L)
                               Cold Storage (M)
                               Cold Storage (M)
                                      IPR
Ag. and Crop Support Services
                                       1
                                      74%
                                      22%
                                      4%
                                       2
                                      5%
                                      0%
                                      0%
                                      78%
                                      17%
                                       -

To estimate the universe of potentially affected equipment by sector, the number of facilities per industry in the United States (shown in Table 8) was multiplied by the percentage of affected industries and the assumed pieces of equipment per facilities (as shown in Table 9). Total equipment per sector was then disaggregated by equipment type, size, and refrigerant based on the assumptions shown in Table 4 (Section 2.1.1).
As shown in Table 10, there are approximately 1.5 million CC, CR, and IPR systems potentially affected by the proposed regulatory changes. 53% of these appliances contain ODS refrigerants, and 47% contain HFCs. These systems contain over 900 million pounds of refrigerant, with a GWP-weighted value of over 850 MMTCO2eq.
Table 10: Universe of Affected Equipment
Refrigerant Type
Affected Equipment
                                       
                                      CC
                                      CR
                                      IPR
                                     Total
ODS
578,181
156,981
79,961
815,123
HFC
440,511
211,584
75,276
727,371
Total
1,018,692
368,565
155,237
1,542,494

Affected Industry for Recordkeeping and Reporting Requirements
In addition to owners and operators of CC, CR, and IPR equipment (described in the previous section), there are six main industries expected to be affected by the changes to the recordkeeping and reporting requirements: (1) refrigerant reclaimers; (2) refrigerant wholesalers; (3) service technicians; (4) small can manufacturers; (5) disposal establishments; and (6) service establishments. The NAICS codes for these industry categories were identified using the Program's 2015 supporting ICR (EPA ICR Number: 1626.13, OMB Control Number:  2060-0256), as well as company research and expert judgment. Sales and employment data for all affected industries was collected from U.S. Census Bureau's Economic Census and ReferenceUSA Online Database (U.S. Census Bureau 2007; U.S. Census Bureau 2012; Infogroup Inc n.d.). The small business thresholds for the NAICS codes were used in determining the number of small businesses affected by the proposed recordkeeping and reporting requirements.
The number of affected businesses in the following industry categories was assumed to be equivalent to those in the Program's 2015 ICR Supporting Statement: reclaimers, refrigerant wholesalers, service technicians, disposal establishments, and service establishments (EPA 2015b). The total number of affected businesses in each of these industries was proportioned across: 1) the affected NAICS codes within that industry and 2) business size category (based on either enterprise receipt or employment size, depending on the specific SBA threshold for each NAICS code). This proportioning yielded the estimated number of affected small businesses, by NAICS code and business size.[,] 
Table 11 below shows the total number of entities and small entities affected by industry category and NAICS code. 	
Table 11. Total Number of Small Entities Affected by Industry Category and NAICS Code
Industry Category
NAICS Code
NAICS Code Definition
Total Entities (Affected)[a]
Small Entities (Affected)
               Industries Experiencing Annual Compliance Costs 
Reclaimers
                                    325120
Industrial Gas Manufacturing
                                                                              4
                                                                              1

                                    423930
Recyclable Material Merchant Wholesalers
                                                                             27
                                                                             26

                                    562920
Materials Recovery Facilities
                                                                              4
                                                                              3

                                    562212
Solid Waste Landfill
                                                                              3
                                                                              2

                                    424690
Other Chemical and Allied Products Merchant Wholesalers
                                                                             23
                                                                             22
Refrigerant Wholesalers
                                    325120
Industrial Gas Manufacturing
                                                                            52 
                                                                            52 

                                    424690
Other Chemical and Allied Products Merchant Wholesalers
                                                                         3,930 
                                                                         3,700 

                                      42
Wholesale Trade
                                                                       196,018 
                                                                       189,364 
Service Technicians
                                    238220
Plumbing, Heating, and Air-conditioning Contractors
                                                                       300,000 
                                                                       295,592 
Small Can Manufacturers
                                    441310
Automotive Parts and Accessories Stores
                                                                              5
                                                                              2

                                    325120
Industrial Gas Manufacturing
                                                                              5
                                                                              3
Sub-Total
                                                                       500,071 
                                                                       488,767 
               Industries Experiencing Avoided Compliance Costs
Disposal Establishments
                                    562920
Materials Recovery Facilities
                                                                             35
                                                                             32

                                    562212
Solid Waste Landfill
                                                                             25
                                                                             24

                                    423990
Other Miscellaneous Durable Goods Merchant Wholesalers
                                                                            315
                                                                            289
Service Establishments
                                    811310
Commercial Industrial Machinery and Equipment (not Automotive and Electronic) Repair and Maintenance
                                                                         1,872 
                                                                         1,800 

                                    811412
Appliance Repair and Maintenance
                                                                            378
                                                                            376
Sub-Total
                                                                         2,625 
                                                                         2,521 
Total
                                                                       502,696 
                                                                       491,288 
a The estimated number of firms in each industry category (i.e., reclaimers, refrigerant wholesalers, and service technicians) were distributed on a weighted basis across the affected NAICS codes, where the weighting was based on the number of firms in each NAICS code. This approach was slightly modified for EPA certified reclaimers and small can manufacturers, since the NAICs codes of some specific entities were known. 
Affected Industry for Self-sealing Valves on DIY Small Cans
To identify small can manufacturers potentially affected by the DIY self-sealing valve requirements, an internet search was combined with industry input from the Auto Care Association and the Automotive Refrigerant Products Institute (ARPI). Ten manufacturers were identified. This analysis assumes that all small can manufacturers can be categorized into the following NAICS codes: 441310 Automotive Parts and Accessories Stores and 325120 Industrial Gas Manufacturing. 
Information on number of employees and annual sales volume was collected for each of the affected entities from ReferenceUSA Online Database (Infogroup Inc n.d.). Then, based on company research and expert judgement, each entity was assigned a NAICS code (i.e., either 441310 or 325120). Small business standards established by the SBA were then used to assess whether an entity is considered small. For NAICS code 441310, small entities are determined based on annual sales volume, where entities with an annual sales volume of less than $15 million are categorized as small (SBA 2014). For NAICS code 325120, small entities are determined based on total number of employees, where entities with less than 1,000 employees are categorized as small (SBA 2014). Using the SBA size standards, it was estimated that five of the affected entities are small businesses. 
Table 12 below outlines the number of entities and small businesses by industry category. 
Table 12: Industry Characterization for Small Can Manufacturers Affected by Proposed Rule
Industry Category
NAICS Code
NAICS Code Definition
Total Entities Affected
Total Small Entities
Small Can Manufacturers
                                    441310
Automotive Parts and Accessories Stores
                                       5
                                       2

                                    325120
Industrial Gas Manufacturing
                                       5
                                       3
 
Methodology
This section presents the methodology used to estimate the incremental impact of the proposed regulatory changes on the U.S. economy as a whole and on small businesses individually (for the RFA/SBREFA screening analysis). The impact of EPA's proposed changes includes compliance costs (including avoided compliance costs because of the proposed removal of regulatory requirements and provision of additional flexibility measures), refrigerant savings (associated with reduced refrigerant use), and emission reduction benefits.
The analysis uses a model entity approach to estimate these impacts. The model entity approach is built up from a model facility analysis, which was developed based on assumptions about model equipment.
Model equipment. First, the compliance costs, avoided compliance costs (i.e., compliance costs no longer incurred), refrigerant savings, and benefits associated with the proposed regulatory requirements (i.e., leak inspection and repair, and recordkeeping and reporting) were estimated for each type of affected equipment.
Model facility. Next, based on the compliance costs and benefits per affected equipment, costs and benefits were estimated for a model facility in each of the industry categories described in Section 2. Assumptions about the number and type of equipment used per model facility varied based on the industry category. Assumptions about the proportion of equipment affected per industry were incorporated, based on equipment type and size, refrigerant type, and leak rate distributions.
    For the analysis of the aggregate impact on the U.S. economy, the model entity step was bypassed by multiplying the costs and benefits per model facility by the number of affected facilities. These scaling assumptions varied based on the industry category. Because CR and IPR equipment in facilities located in California are already subject to requirements that are generally more stringent than those in the proposed rule, costs and benefits were not included for these equipment/facilities. 
Model entity. For the RFA/SBREFA screening analysis, costs per model facility were scaled to a model entity on both an industry-specific and size-specific basis. Therefore, each model entity reflected information about the average number of facilities an entity has in a given industry category and size (i.e., smaller entities typically have fewer facilities per entity than larger businesses).
All costs and benefits were estimated on an annual basis, based on assumptions about the current distribution of affected ODS- and substitute-containing equipment. An analysis of future benefits in 2020 and 2025 was also conducted, as described in 3.3.1.2. All costs are shown in 2014 dollars. 
As noted previously, the proposed rule updates and extends the existing requirements to non-ozone-depleting substitute refrigerants. The main class of refrigerant affected by this proposed extension is HFCs since many other refrigerants currently in use are exempted from the venting prohibition. As such, this analysis estimates the incremental costs and benefits associated with the application of the proposed regulatory changes to ODS and HFC equipment.
The remainder of this chapter is organized as follows:
Section 3.1 describes the approach for estimating the aggregate cost to the U.S. economy.
Section 3.2 presents the methodology for estimating the impact on small businesses.
Section 3.3 provides the benefits estimation approach.
Approach for Estimating Aggregate Annual Costs to the U.S. Economy
The sections below describe the method and assumptions used to estimate aggregate incremental costs associated with the Agency's proposed regulatory changes related to: leak inspection and repair, reporting and recordkeeping, and self-sealing valves on DIY small cans. The final section provides rationale for assuming no incremental compliance costs associated with other proposed regulatory changes.
Leak Inspection and Repair
Proposed regulatory changes associated with leak inspection and repair are expected to result in:
Compliance costs associated with conducting leak inspections and repairs.
Avoided compliance costs associated with changes in the leak repair requirements that relieve regulatory burden. Specifically, EPA proposes to grant the same flexibility to owners or operators of ODS CC and CR appliances as is currently offered to owners or operators of ODS IPR appliances to request additional time to make repairs due to the unavailability of components. This additional flexibility is expected to result in fewer ODS appliances being retired prematurely.
Refrigerant savings associated with repairing leaks earlier.
As noted above, costs and savings were estimated using a model equipment, facility, and entity approach.  Costs were then scaled up industry-wide based on the proportion of businesses that could be affected by the regulation in order to determine the full impact of each of the proposed changes.
Leak Inspection
The proposed regulatory changes result in compliance costs to equipment owners and operators in order to meet new requirements to conduct annual leak inspections for CC, CR, and IPR systems with charge sizes between 50 and 500 pounds and quarterly leak inspections for CR and IPR systems with charge sizes of 500 or more pounds. As a baseline, the analysis conservatively assumes that neither annual nor quarterly leak inspections are currently performed. This assumption may overestimate compliance costs since, in practice, some owners and operators have indicated they conduct regular leak inspections to ensure that systems continue to function properly and to avoid recurring refrigerant top-off costs. Automatic leak monitoring equipment is also becoming more common, which would further reduce actual compliance costs.
Leak Repair
The proposed regulatory changes result in compliance costs to owners and operators when leaks are identified in equipment containing 50 or more pounds of ODS or HFC refrigerant that exceeds the leak rate of 10% for CC or 20% for CR and IPR equipment. Equipment owners and operators must repair all identified leaks within 30 days, or, under certain circumstances, request an extension to conduct the repair; if leaks cannot be repaired, the appliance must be retrofitted or retired. These proposed requirements are incremental for owners and operators of equipment containing 50 or more pounds of:
HFC refrigerant that exceeds the leak rate of 10% for CC or 20% for CR and IPR; and
ODS refrigerant that exceeds the leak rate of 10% for CC or 20% for CR and IPR.
When leaks are repaired, all appliances must also conduct initial and follow-up verification tests; this requirement currently only applies to federally-owned and IPR appliances.
Leak repair outcomes. Lower applicable leak rates, in combination with the proposed regulatory requirement for leak inspections for all eligible equipment, should lead to leaks being identified and repaired sooner than under the current approach. As such, this analysis assumes that leaks will be detected and repaired earlier across all CC, CR, and IPR equipment containing 50 pounds or more of ODS or HFC refrigerant. Specifically, the analysis assumed that ODS and HFC equipment that experiences a leak event requiring repair realizes one of three outcomes: 
The standard repair outcome conservatively assumes that repairs are conducted three weeks earlier as a result of the proposed leak repair and leak inspection requirements (see Box 4).
Box 4: Assuming Three-week Earlier Repair
The assumption that repairs are conducted three weeks earlier as a result of the proposed rulemaking was based on analysis of facility-level reporting on leak repair under California's RMP. Individual system-level leak rates were estimated using the amount of refrigerant reported as added during each leak event and the number of days between the refrigerant addition and the previous record for each system. This data set (i.e., individual system leak rates) was then grouped into leak rate bins (e.g., 0-10%, 10-20%, 20-30%, and so on). 

The average leak rate for each bin was used to calculate the number of weeks before the system would lose 40% of its charge. It was assumed that systems below 60% of their full charge would require servicing -- regardless of the proposed requirements for mandatory inspection and repair (Kim and Braun 2010).

Leak events were assumed to be spread evenly over a 13 week period to simulate the time between proposed quarterly inspections. The average number of weeks early that a leak would be detected for each bin was calculated based on this spread. For example, if a system is leaking at a rate that would cause it to lose 40% of its charge in eight weeks, and the leak inspection occurs in week four, the leak is assumed to be caught four weeks early. 

The average number of weeks early for each bin was then weighted based on (a) the number of systems in each bin and (b) the emissions value of catching a leak early in each bin. The emissions weighting accounts for the fact that catastrophic leaks would likely be found very quickly due to performance degradation, regardless of mandatory leak inspections, whereas slower, smaller leaks would benefit proportionately more from early detection through leak inspection.

This approach yielded a weighted average of approximately three weeks early that a leak would be detected. More and less conservative assumptions were also modeled, assuming repairs are conducted two weeks earlier and two months earlier as a result of the proposed leak repair and leak inspection requirements. These alternate results are shown in Appendices 0 and 0, respectively.
Box 4: Assuming Three-week Earlier Repair
The assumption that repairs are conducted three weeks earlier as a result of the proposed rulemaking was based on analysis of facility-level reporting on leak repair under California's RMP. Individual system-level leak rates were estimated using the amount of refrigerant reported as added during each leak event and the number of days between the refrigerant addition and the previous record for each system. This data set (i.e., individual system leak rates) was then grouped into leak rate bins (e.g., 0-10%, 10-20%, 20-30%, and so on). 

The average leak rate for each bin was used to calculate the number of weeks before the system would lose 40% of its charge. It was assumed that systems below 60% of their full charge would require servicing -- regardless of the proposed requirements for mandatory inspection and repair (Kim and Braun 2010).

Leak events were assumed to be spread evenly over a 13 week period to simulate the time between proposed quarterly inspections. The average number of weeks early that a leak would be detected for each bin was calculated based on this spread. For example, if a system is leaking at a rate that would cause it to lose 40% of its charge in eight weeks, and the leak inspection occurs in week four, the leak is assumed to be caught four weeks early. 

The average number of weeks early for each bin was then weighted based on (a) the number of systems in each bin and (b) the emissions value of catching a leak early in each bin. The emissions weighting accounts for the fact that catastrophic leaks would likely be found very quickly due to performance degradation, regardless of mandatory leak inspections, whereas slower, smaller leaks would benefit proportionately more from early detection through leak inspection.

This approach yielded a weighted average of approximately three weeks early that a leak would be detected. More and less conservative assumptions were also modeled, assuming repairs are conducted two weeks earlier and two months earlier as a result of the proposed leak repair and leak inspection requirements. These alternate results are shown in Appendices 0 and 0, respectively.
Under the extension repair outcome, owners/operators request an extension for conducting the repair. The analysis conservatively assumes that repairs are also conducted three weeks earlier as a result of the proposed leak repair and leak inspection requirements. As mentioned above, the proposed extension would allow owners/operators of non-federally-owned CC and CR appliances additional time to repair an appliance if components cannot be delivered within the necessary time. As a result, some ODS CC and CR systems that would have been prematurely retired under the current approach are now expected to request extensions.   The retrofit/retirement outcome assumes that systems that require retrofitting/ retirement are retrofitted/retired 5 years earlier than they would have been in the absence of the proposed regulatory changes (i.e., 5 years were assumed to be remaining before normal end-of-life). ODS systems were assumed to be retired as they are generally older systems, and HFC systems were assumed to be retrofitted. As previously noted, some owners or operators would have prematurely retired their ODS CC and CR equipment if a component could not be delivered in time, but now would apply for an extension. These avoided system retirements will result in avoided compliance costs for these equipment owners. 
Table 13 below shows the proportion of affected equipment assumed to experience each outcome. The percentage of ODS systems reaching the retrofit/retirement outcome is shown as zero because no ODS systems are assumed to experience incremental incidence of retrofit or retirement.  However, approximately 2,300 premature retirements of ODS CC and CR appliances are expected to be avoided as a result of the proposed consistent set of extensions for all appliance types. These avoided retirements result in reduced regulatory burden and avoided compliance costs.
Table 13: Leak Repair Outcomes and Proportions
Outcome
HFC Systems
ODS Systems
Standard Repair
97%
98%
Extension Repair
2%
2%*
Retrofit/Retirement
1%
0%
* Only includes CC and CR appliances.

Frequency of repair. Data reported under California's RMP was reviewed to determine an appropriate assumption for the annual frequency of repair for systems that use advanced leak detection monitoring systems or are inspected annually or quarterly and are leaking above the proposed leak rates. These data suggest that most systems are repaired once per year, with the exception of larger (>500 lbs.) cold storage systems, which are repaired about twice per year on average. This analysis assumes that there would be a similar relationship between quarterly or annual leak inspections and leak detection and subsequent repair for equipment that is subject to Section 608 as there is for the equipment subject to California's RMP.
Repair effectiveness and baseline leak rates. For all equipment types and sizes, post-repair leak rates reflect CARB (2009) estimates, which were based on EPA's Vintaging Model and Intergovernmental Panel on Climate Change (IPCC)/Technology and Economic Assessment Panel (TEAP) (2005) recommendations. While EPA is requiring repair of all identified leaks if the applicable leak rate is exceeded, EPA recognizes that a post-repair leak rate of zero is not always the case. Therefore, the modeled post-repair rates may be more conservative than what may be achieved if this rule is finalized as proposed. To explore the sensitivity of costs and benefits to higher post-repair leak rates, the analysis was also run using post-repair rates set at 90% of the threshold leak rate (i.e., if the threshold rate is 20%, it is assumed that the system is repaired and has a resulting leak rate of 18%). Appendix A.3 shows the results of this sensitivity analysis.
To develop assumptions for the baseline leak rates, multiple sources of leak rate information were reviewed and compared. First, average annual leak rates for equipment reported under California's RMP were determined, and leak rates and number of affected equipment within and outside of the leak rate thresholds were examined at different levels of aggregation (e.g., sector, type, size, and refrigerant). This examination suggested that the economic analysis should develop separate leak rates for different equipment types and sizes. 
To ensure that this analysis used leak rates that were representative of equipment throughout the United States, average annual leak rates reported under the RMP that were above the leak rate thresholds for each sector were averaged and compared with equipment leak rates modeled in EPA's nationwide Vintaging Model. This comparison of leak rates suggested that the RMP data set is likely a strong indicator of average leak rates for equipment above the leak rate thresholds throughout the United States and is discussed further in Section 3.1.1.4.
Table 14 below presents the final leak rate assumptions by equipment sector, type, and size for equipment that is affected by the leak repair requirements (i.e., is expected to leak above the leak rate thresholds).  The percentage of each equipment type that is experiencing a qualifying leak is discussed in Table 17. For example, although only 23% of condensing unit systems have an annual average leak rate exceeding 20%, the average annual leak rate of those systems is 66% according to the RMP data. 
Table 14: Leak Rate Assumptions by Equipment Sector, Type, and Size
Leak Rate Threshold
Equipment Sector
Equipment Type
Equipment Size
Baseline Annual Leak Rate (for Equipment Requiring Repair)
Annual Post-repair Leak Rate
10%
CC

Unitary AC
Small
60%
5%


Chiller
Medium
49%
2%


Chiller
Large
47%
2%
20%
CR
Condensing Unit
Small
66%
5%


Rack
Medium >=500 lbs.
49%
10%


Rack
Medium <500 lbs.
70%
10%


Rack
Large
47%
10%


Cold Storage
Medium >=500 lbs.
55%
10%


Cold Storage
Medium <500 lbs.
79%
10%


Cold Storage
Large
62%
10%

IPR
IPR
Small
97%
7%


IPR
Medium >=500 lbs.
59%
7%


IPR
Medium <500 lbs
76%
7%


IPR
Large
58%
7%

Assumptions about equipment charge sizes were made by equipment type and size category, as well as by refrigerant type (HFC and ODS), based on data reported under the California RMP. These disaggregated assumptions are shown in Section 2.1.1.
Unit Cost and Savings Assumptions
Leak inspection. Leak inspections were assumed to require one hour per system per inspection for commercial refrigeration and IPR, and 30 minutes for comfort cooling systems.
An hourly labor rate of $45.07 was assumed for leak inspection and repair, based on the median hourly earnings of $21.46 for heating, air-conditioning, and refrigeration mechanics and installers from the Bureau of Labor Statistics, plus 110% to account for overhead ($23.61). 
Leak repair. Repair costs are calculated as the base cost of making the repair or retrofit, including labor, parts, refrigerant recovery, and verification tests. These costs are assumed to vary by system size, where leak repairs on a smaller system are assumed to be relatively simpler and less costly than repairs on medium and large systems. The base costs associated with each outcome were estimated as described below. All costs were adjusted to 2014 dollars.
Standard repair. Leak repair costs for a "standard repair" are based on assumptions in CARB (2009). CARB (2009) surveyed refrigeration and AC service contractors and technicians to validate these cost assumptions. 
Extension repair. An "extension repair" is assumed to involve the repair of a major component such as a compressor, and is based on costs presented in Stratus (2009). 
Retrofit. Retrofit costs were also based on Stratus (2009); this analysis assumed that the cost to retrofit an entire piece of equipment was between two to three times the cost of the compressor. As noted above, HFC systems were assumed to be retrofitted, while ODS systems were assumed to be retired as they are generally older systems.
Retirement. The base cost of retirement is assumed to be the installed cost of new, replacement equipment. The installed cost of CC, CR, and IPR equipment varies significantly across and within equipment types and capacities. For the purposes of this analysis, a reasonable average cost by equipment size was estimated through review of available literature (Stanford University 2011; Tait Consulting Ltd 2012; ACEEE 2013), including economic analyses conducted for other federal agencies (DOE 2009; DOE 2013), and industry calls.  
As noted above, lower leak rate thresholds, combined with new requirements for leak inspections, will result in leaks being repaired sooner than under the current approach. The analysis assumes that repairs are conducted three weeks earlier as a result of these proposed requirements. Thus, the repair costs attributable to the rule are based on the time cost of conducting those repairs three weeks earlier. The interest cost (at 7% per year) of the base repair cost is attributed to the rule; this cost is referred to below as the "effective cost of repair." CARB used a similar approach -- i.e., estimating the effective cost of repair -- in developing its economic impact estimates for its High-Global Warming Potential Stationary Source Refrigerant Management Program (CARB 2009a). A sensitivity analysis exploring the impact of assuming repairs are conducted two months earlier -- which results in higher effective costs of repair -- is shown in Appendix A.4.
An "effective cost" approach was also taken for the cost of retrofitting and retirement. Systems that are retrofitted as a result of the proposed regulatory changes are assumed to be retrofitted five years earlier than they would have been under current practices. Thus, the effective cost of retrofitting attributable to the rule is the cost of borrowing the funds for retrofitting for five years at 7% per year. Similarly, the avoided effective cost for premature retirement of ODS CC and CR appliances is the cost of borrowing the funds for purchasing a new system for five years at 7% per year. 
Table 15 below presents the base and effective cost assumptions by repair and system size. For retrofit and retirement outcomes, the costs presented do not include the additional cost of replacing the entire refrigerant charge with virgin refrigerant or charging a new system. With charge sizes exceeding 7,000 pounds in some very large systems, these costs can be sizeable. For the standard and extension repair outcomes, the cost of refrigerant recharge is not included, since it is assumed that the owner or operator would have topped off the system in the absence of the proposed requirements.
Table 15: Unit Cost Assumptions
System Size
Labor Hours
Parts
Refrigerant Recovery
Total Base Cost for Labor, Parts, and Recovery
Effective Cost of Early Repair / Retrofit
Standard Repair
Small
8
$109
$218
$682
$3
Medium
12
$327
$382
$1,241
$5
Large
16
$655
$709
$2,073
$9
Extension Repair
Small
20.25
$2,836
$218
$3,967 
$17
Medium
20.25
$10,345
$382
$11,639 
$51
Large
20.25
$10,345
$709
$11,966 
$52
Retrofit (HFC Equipment)
Small
20.25
$8,343
$218
$9,473 
             Varies based on charge size of equipment retrofitted
Medium
20.25
$22,247
$382
$23,541 
                                                                               
Large
20.25
$22,247
$709
$23,869 
                                                                               
Retirement (ODS Equipment)
Small

$20,000
               Varies based on charge size of equipment replaced
Medium

$100,000
                                                                               
Large

$250,000
                                                                               
Sources: for Standard Repair Labor Hours, Parts, and Recovery Costs: CARB 2009a; for Extension Repair and Retrofit: Status 2009; for Retirement: Stanford University 2011; Tait Consulting Ltd 2012; ACEEE 2013; DOE 2009; DOE 2013.
 
Refrigerant savings. By causing leaks to be repaired earlier, the proposed regulatory changes would result in refrigerant cost savings for system operators. Refrigerant cost savings are calculated based on the difference between the baseline and post-repair leak rates, multiplied by the charge size, over the three weeks earlier that each repair was conducted. An average price of $6 per pound was assumed for all refrigerants. 
On a per system basis, effective refrigerant savings range from $20 for small systems up to $1,300 for large cold storage and IPR systems.
Leak repair expected costs and savings. Expected costs and savings per model equipment were estimated on a weighted basis, taking into account the proportion of equipment assumed to reach each leak repair outcome and the unit costs and savings associated with each outcome. Expected costs and savings were estimated in the model in a disaggregated manner, distinguishing between equipment sectors, types, sizes, and refrigerant type.
Model Facility Assumptions
The following calculation steps yielded aggregate costs/savings for the U.S. economy as a whole. 
Leak repair expected costs/savings per model equipment type (as described above) were multiplied by the number of each type of equipment per facility (see below) and the percentage of each type of equipment assumed to experience leaks above the proposed rule's threshold rates (see below).
Leak inspection costs per model equipment type were multiplied by the number of each type of equipment per facility (see below), taking into account equipment size to determine required frequency of inspection.
The sum of expected leak repair costs/savings and leak inspection costs per model facility was then multiplied by the total number of facilities in each industry category (see below) and the percentage of each industry assumed to be affected (see Section 2.1.2). Because CR and IPR appliances in facilities located in California are already subject to similar leak inspection and repair requirements under the California RMP, these appliances are removed from the analysis of costs and benefits.
The assumptions made are summarized below. In the model developed for this analysis, calculations were performed in a disaggregated manner, distinguishing between industry sectors, equipment sectors, types, sizes, and refrigerant type. Many of these assumptions were based on confidential business information reported under California's RMP. To preserve the confidentiality of those data, assumptions are summarized on an industry- or equipment type-specific basis.
Section 2.1 summarizes the assumptions made regarding the average number of systems in each sector per model facility, for each industry category and the assumptions about the percentage of each industry that is assumed to use equipment containing 50 or more pounds of ODS or HFC refrigerant, and thus be affected by the proposed rulemaking.
Only equipment that experiences leaks that exceed the proposed leak threshold will be subject to repair requirements and thus incur compliance costs to repair those leaks. To determine this proportion of equipment, data submitted for CR and IPR under California's RMP was reviewed. For CC, although facilities are not required to report data on CC systems under California's RMP, some do, so while RMP data was reviewed to establish preliminary assumptions for CC systems, additional sources, such as data reported under California's South Coast Air Quality Management District (as analyzed in Stratus 2009), EPA's Vintaging Model, and expert judgement were also used to estimate the proportion of affected systems. 
Table 16 below presents a comparison of leak rate distributions by equipment sector and refrigerant type, based on analysis of California's RMP and EPA's Vintaging Model.
Table 16. Leak Rate Comparison Based on California's RMP and EPA's Vintaging Model
Equipment Sector
Ref. Type
Leak Rate Distribution
Percent of Equipment within Leak Rate Distribution



                                   CARB RMP
                                      VM
CC
ODS
>10%
                                      23%
                                      4%

HFC
>10%
                                      20%
                                    <1%
CR
ODS
>20%
                                      19%
                                     100%

HFC
>20%
                                      17%
                                      63%
IPR
ODS
>20%
                                      15%
                                      0%

HFC
>20%
                                      14%
                                      0%
              Note: The Vintaging Model assumes that 100% of ODS and HFC IPR systems have a leak rate below 20%.
Within each sector, the CARB RMP data suggest that the leak rate distributions for ODS and HFC systems are similar. Differences between the leak rate distributions from California's RMP and those from the Vintaging Model can be attributed to how annual leak rates are developed (i.e., reported leak rate data and average leak rates across equipment types, respectively). Section 2.1.1 discusses these differences further. 
Based on the information above, ODS and HFC equipment were assumed to have the same leak rate distributions, disaggregated by equipment type and size. Table 17 presents the assumptions made for this analysis regarding the proportion of affected equipment experiencing leaks above the threshold.
Table 17: Affected Equipment Assumptions by Equipment Sector, Type, Size, and Refrigerant Type
Equipment Sector
Equipment Type
Equipment Size
Percentage of Equipment Experiencing Leaks Above the Proposed Threshold Rate
CC
Unitary AC
Small
20%

Chiller
Medium
23%


Large
16%
CR
Condensing Unit
Small
23%

Rack
Medium <500
6%


Medium >=500
13%


Large
26%

Cold Storage
Medium <500
13%


Medium >=500
17%


Large
33%
IPR
IPR

Small
6%


Medium <500
12%


Medium >=500
10%


Large
10%
Recordkeeping and Reporting
Proposed regulatory changes associated with recordkeeping and reporting are expected to result in:
Compliance costs associated with incremental requirements for recordkeeping and reporting for ODS-containing appliances, extending the requirements for recordkeeping and reporting to appliances containing substitute refrigerants, and adding new recordkeeping and reporting requirements.
Avoided compliance costs associated with the removal of some recordkeeping and reporting requirements.
The sections below describe the assumptions and methodology used to estimate recordkeeping and reporting costs and avoided costs associated with the proposed regulatory changes. All recordkeeping and reporting costs are calculated by multiplying the estimated burden (hours) times the average annual respondent hourly cost (labor plus overhead). For all recordkeeping and reporting requirements, except the new recordkeeping requirement for small can manufacturers, the analysis uses the median hourly earnings of $21.46 for heating, air-conditioning, and refrigeration mechanics and installers from the Bureau of Labor Statistics (BLS 2014a). This number was multiplied by 110% for overhead (i.e., $21.46 x 1.10 = $23.61). The resulting cost of $45.07 ($21.46 + $23.61) is the average hourly administrative cost of labor plus overhead for a private firm.
Recordkeeping and Reporting Associated with Leak Inspection and Repair
The sections below describe how the incremental annual burden time was estimated for each recordkeeping and reporting requirement associated with leak inspection and repair. To generate costs, the annual burden time was multiplied by the hourly wage rate.
Requests for extensions to the leak repair and retrofit/retire timelines. Owners or operators of IPR appliances and federally-owned CR and CC appliances normally containing 50 or more pounds of ODS refrigerant may apply to EPA for an extension to the leak repair and appliance retrofit/retire timeframe. EPA is proposing to extend this requirement to: 1) all equipment types, including CC and CR appliances that are not federally-owned; and 2) appliances normally containing 50 or more pounds of HFC refrigerant. 
First, the incremental burden associated with submitting extension requests for CC and CR equipment containing ODS refrigerants was estimated. The total number of extension requests for IPR equipment under the current requirements was identified using the Program's supporting ICR (EPA ICR Number: 1626.13, OMB Control Number:  2060-0256), and this number was then scaled based on the expanded pool of affected equipment (i.e., CC and CR) using the model facility assumptions described in Section 3.1.1.4 above. In addition, some ODS-containing CC and CR equipment that would have been prematurely retired under the current approach are now expected to request extensions, as described in Section 3.1.1.2. As a result, the number of extension requests for ODS-containing CC and CR is expected to increase, while the number of plans developed to retire/replace or retrofit ODS-containing CC and CR equipment is expected to decrease. Because the burden time per response is greater for developing retirement/retrofit plans than for preparing and submitting an extension request (8 hours versus 30 minutes), some owners and operators of ODS-containing CC and CR equipment are expected to experience avoided reporting and recordkeeping costs.
To estimate the incremental burden associated with submitting extension requests for IPR, CC, and CR equipment containing HFC refrigerants, the number of requests was estimated by scaling based on the ratio of affected ODS equipment to HFC equipment. 
Invoices provided by service technicians. Under current regulations, persons servicing appliances normally containing 50 or more pounds of ODS refrigerant are required to provide invoices to appliance owners or operators indicating the amount of refrigerant added to the appliance. EPA is proposing to: 1) extend this requirement to appliances normally containing 50 or more pounds of HFC refrigerant, and 2) add new recordkeeping requirements associated with each refrigerant addition (see Section 1.2.2 for details). 
The analysis assumed that service technicians would need to provide invoices to appliance owners/operators four times per year for IPR and CR equipment with charge sizes 500 pounds or greater and one time per year for all CC equipment and IPR and CR equipment with charge sizes between 50 and 500 pounds. Multiplying this invoice frequency by the number of affected equipment yields an annual estimate of approximately 1.3 million invoices for affected ODS equipment and approximately 1.1 million invoices for affected HFC equipment. Since technicians are already required to provide invoices when servicing ODS equipment, the only incremental burden for ODS equipment was assumed to be the time associated with providing documentation for the new recordkeeping requirements (i.e., 0.5 minutes). For servicing HFC equipment, the same burden time per invoice as the ICR was assumed (i.e., 1.5 minutes), plus 0.5 minutes to account for the new recordkeeping requirements associated with refrigerant additions. 
Purchase and service records. Under current regulations, owners or operators of IPR, CC, and CR appliances normally containing 50 or more pounds of ODS refrigerant must maintain purchase and service records. EPA is proposing to: 1) extend this requirement to equipment containing HFCs and other non-exempt substitutes; and 2) require equipment owners to maintain records of the information provided by service technicians associated with each refrigerant addition (see Section 1.2.2 for further details). 
This analysis assumes that there is no incremental burden on owners of affected equipment to maintain the new information from service technicians associated with each refrigerant addition. However, owners or operators of affected HFC equipment are assumed to incur costs associated with the time burden for maintaining purchase and service records. Consistent with the ICR, 1.5 minutes of burden time is assumed each time an HFC appliance is serviced. The total number of servicing events is assumed to be equal to the number of times that service technicians provide invoices (i.e., four times per year for IPR and CR equipment with charge sizes 500 pounds or greater and one time per year for all CC equipment and IPR and CR equipment with charge sizes between 50 and 500 pounds).
Plans to retire/replace or retrofit equipment. Under current regulations, owners or operators of IPR, CC, and CR appliances normally containing 50 or more pounds of ODS refrigerant must develop and maintain a plan to retire/replace or retrofit equipment after a failed follow-up verification test. EPA is proposing to extend this requirement to IPR, CC, and CR appliances normally containing 50 or more pounds of HFC refrigerant. To calculate the incremental recordkeeping costs associated with developing a plan to retire/replace or retrofit HFC equipment, the assumptions in the ICR for ODS equipment were scaled proportionately based on the ratio of affected ODS and HFC equipment.  
Results of verification tests. Section 608 regulations currently require initial and follow-up verification tests each time the leak rate threshold is breached for both IPR appliances and federally-owned CC and CR appliances normally containing 50 or more pounds of ODS refrigerant. EPA is proposing to extend this requirement to: 1) all equipment types, including CC and CR appliances that are not federally-owned; and 2) appliances normally containing 50 or more pounds of HFC refrigerant. The model facility assumptions described in Section 3.1.1.4 were used to identify the pool of newly affected equipment (i.e., CC and CR ODS equipment and all HFC equipment) and the expected number of times that the newly affected equipment would exceed the leak rate threshold on an annual basis. For every occurrence of an appliance exceeding the leak rate threshold, 1.5 minutes of burden time was assumed to maintain reports on the results of verification tests. 
Leak inspections. Leak inspections are currently not required under the Section 608 regulations. EPA is proposing to require: 1) quarterly inspections for all IPR and CR equipment containing a refrigerant charge of 500 or more pounds; and 2) annual inspections for all IPR and CR equipment with a refrigerant charge between 50 and 500 pounds, plus all CC equipment with a refrigerant charge greater than 50 pounds. This analysis assumes that the recordkeeping time associated with quarterly and annual inspections is one minute. The model facility assumptions (see section 3.1.1.4) were used to identify the affected pool of equipment. 
Other Recordkeeping and Reporting Requirements
As also described in Section 1.2.2, EPA is proposing to extend the following recordkeeping and reporting requirements to HFC refrigerants and other substitutes: 
Reclaimer annual activity reports. Refrigerant reclaimers must submit annual reports noting the mass of refrigerant reclaimed by refrigerant type and the mass of waste products produced.
Reclaimer recordkeeping. Reclaimers must maintain records of refrigerant sales transactions, including the quantity of material sent to them for reclamation.
Disposal establishments' refrigerant recovery recordkeeping. Persons disposing of air-conditioning or refrigeration equipment must maintain a copy of a signed statement for each piece of disposed equipment that demonstrates all remaining refrigerant was recovered from the equipment before final disposal.
Refrigerant wholesalers' recordkeeping.  Wholesalers of refrigerants must maintain sales records and technician certification cards from purchasers showing that they employ at least one certified technician.
Purged refrigerant recordkeeping. Owners/operators of appliances with charge sizes greater than 50 pounds must maintain information on purged/destroyed refrigerant.
To estimate the incremental costs for an extension to HFCs and other non-exempt substitutes for each of the abovementioned requirements, the burden estimates from the Program's supporting ICR (EPA ICR Number: 1626.13, OMB Control Number:  2060-0256) were scaled based on the ratio of ODS to HFC equipment stock. For recordkeeping and reporting requirements that pertain to reclamation, it was conservatively assumed that HFC reclamation would occur at the same rate as ODS reclamation.
Other proposed recordkeeping and reporting provisions also include: 
Certified technician database. EPA is proposing to require certification programs to create and maintain a publicly-available database or list of currently certified technicians. This analysis assumes negligible cost associated with this requirement, since it is anticipated to be fulfilled by maintaining and publishing a PDF list of certified technicians online.
Small can self-sealing valve recordkeeping. EPA is proposing to add a new recordkeeping requirement for manufacturers of small cans of automotive refrigerant to keep records of test data and log forms that demonstrate compliance with the allowable leakage rate. To estimate the costs for the new small can recordkeeping requirement, it was assumed that filing test data and log forms would take approximately 1.5 minutes per test batch. Since the test procedure takes on average 30 days per batch, filing test data and log forms is assumed to occur on a monthly basis. 
Recovery and recycling equipment certification of ownership. EPA is proposing to remove the requirement for persons who maintain, service, repair, or dispose of appliances containing ODS refrigerants to submit a signed statement that they own certified recovery and recycling equipment. The removal of this requirement would result in a burden reduction for more than 2,600 affected service and disposal establishments.
Disposal of appliances with charge sizes between 5 and 50 pounds. EPA is proposing to require a new recordkeeping requirement where technicians disposing of appliances with charge sizes between 5 and 50 pounds must document how much refrigerant was recovered from the appliance at disposal and how much refrigerant is transferred for reclamation or destruction. To estimate the incremental burden associated with this new requirement, the total number of ODS and HFC appliances disposed of annually with charge sizes between 5 and 50 pounds from EPA's Vintaging Model was multiplied by the per-appliance burden time associated with maintaining these records (assumed to be two minutes). Table 18 below shows the total number of ODS and HFC appliances containing between 5 and 50 pounds of refrigerant that are estimated to be disposed of annually.
Table 18. Appliances with Charge Sizes Between 5 and 50 Pounds Disposed in 2015
Equipment Type
Estimated Units Disposed in 2015

                                     HCFC
                                      HFC
                                     Total
Water and ground source heat pumps
                                    68,240
                                       0
                                    68,240
Ice Makers
                                       0
                                    142,240
                                    142,240
Small condensing units
                                    72,970
                                     7,790
                                    80,760
Refrigerated transport
                                     3,160
                                    315,280
                                    318,440
Residential unitary AC
                                   6,302,760
                                    99,080
                                   6,401,840
Small commercial unitary AC
                                    260,150
                                     8,050
                                    268,200
Large commercial unitary AC
                                    15,440
                                       0
                                    15,440
                                     Total
                                   6,722,720
                                    572,440
                                   7,295,160
     Source: EPA 2014.

The following recordkeeping and reporting requirements were assumed to have no incremental burden costs associated with an extension to HFCs and other substitutes: 
Maintenance of copies of signed statements of previous refrigerant recovery by disposal establishments.
Refrigerant recovery and recycling equipment testing organizations submitting reports on approved equipment and maintaining records of equipment tested.
Certification by refrigerant reclaimers that change ownership or enter the market.
Technician certification programs applying for approval.
Recordkeeping and biannual reporting by existing technician certification programs.
Technicians acquiring and maintaining certification cards.
Self-sealing Valves on DIY Small Cans 
Consistent with CARB's Staff Analysis on Emissions and Economic Impact of Proposed Regulation for Small Containers of Automotive Refrigerant, this analysis assumes that the extra cost to install a self-sealing valve on DIY small cans would be approximately $0.25 per can (CARB 2009b). Using data from the NPD Automotive Aftermarket Industry Monitor, the total number of small cans sold annually in the United States was multiplied by the cost per valve to arrive at the total annual incremental cost estimated to be incurred by small can manufacturers (NPD 2008; CARB 2009b). Small cans that are sold in the state of California were excluded from this analysis due to CARB's existing requirement for all small can manufacturers to install self-sealing valves, which became effective October 1, 2009.
EPA also considered what the costs would be of extending the sales restriction to HFCs and other substitutes without an exemption for small cans of refrigerant for MVAC servicing. If EPA had extended the sales restriction without the exemption, DIYers would be required to either seek certification under section 609 or take their car to a technician to be serviced. As shown in Appendix F, extending the sales restriction to small cans would be significantly more burdensome than the requirement to equip all small cans with a self-sealing valve.
Extending Other Existing Requirements to HFCs and Other Substitutes: Implications for Costs
While EPA is requiring specific practices to prevent release of refrigerant, including but not limited to requiring refrigerant be recovered from small appliances, MVACs, and MVAC-like appliances before disposal, evacuation of refrigerant before opening an appliance for servicing, and reclamation of used refrigerant to industry standards before sale, EPA has not assumed any additional cost to industry for this extension other than those discussed in Section 3.1. Likewise, EPA has not calculated any of the benefits that would accrue if compliance were to increase as a result of this rulemaking (see Section 3.3). 
This assumption is reasonable and appropriate because anyone handling HFC and other substitute refrigerants already must comply with the venting prohibition, which effectively necessitates similar practices to ensure refrigerant is not released into the environment. This assumption is supported by feedback from numerous regulated entities both in the public and private sector that most in industry treat HFCs and ODS refrigerants the same way to comply with the venting prohibition.
Thus, some of the regulatory changes that EPA is proposing are not expected to result in compliance costs. Table 19 summarizes these regulatory changes and the rationales for assuming no incremental costs.
Table 19: Regulatory Changes Assumed to Present No Incremental Cost
 
Recommended Regulatory Changes
Rationale for Assuming No Incremental Costs
                          Leak Repair and Prevention
 + Require all appliances to conduct initial and follow-up verification tests (currently only applies to federal and IPR appliances)

Industry input suggested that verification tests are already conducted as standard practice during servicing events. Moreover, because initial and follow-up verification tests can both be conducted during the same service appointment, this requirement is not expected to result in a longer servicing event (and thus not expected to result in incremental labor costs).

 + Require a leak inspection to identify leaks upon discovering that the applicable leak rate is exceeded
This analysis assumes that equipment owners or operators are currently inspecting their equipment as part of a service call to identify what must be repaired upon discovering that the appliance exceeds the applicable leak rate. 

 + Create an annual leak limit of 75% for 2 consecutive years

This regulatory change is expected to improve compliance and enforcement. However, because the economic analysis presented in this document already assumes full compliance with the regulatory changes, it is assumed that qualifying leak events are identified and repaired within a one-year period, such that equipment would not leak more than 75% of its total charge within two consecutive 12-month periods. 
                     Preventing Emissions During Servicing
 + Extend the sales restriction to non-exempt substitutes, thereby requiring technician certification and proper handling for HFCs
This analysis assumes that all technicians currently servicing ODS equipment also service HFC equipment, and therefore, extending the sales restriction to HFCs would not result in any technicians needing to become newly certified.
                              Venting Prohibition
 + Extend the de minimis exemption to HFCs and other substitute refrigerants
This analysis assumes no costs associated with this extension because most stakeholders are already properly recovering substitute refrigerants during maintenance, servicing, repair, or disposal of appliances as required under the venting prohibition. This requirement would likely mean minimal, if any, change in business practices other than the recordkeeping provisions discussed previously.
                            Evacuation Requirements
 + Extend evacuation requirements to HFCs and other substitute refrigerants
This analysis assumes no costs associated with this extension because most technicians are already properly evacuating substitute refrigerants during maintenance, servicing, repair, or disposal of appliances as required under the venting prohibition. This requirement would likely mean minimal, if any, change in business practices.
                       Recovery Equipment Certification
 + Extend the requirement to use certified recovery equipment during the maintenance, service, repair, or disposal of appliances, other than MVACs and MVAC-like appliances, that contain HFCs or other substitute refrigerants
This analysis assumes no costs associated with this extension since the existing pool of recycling and recovery equipment are already expected to meet certification requirements and can be used to recover both ODS refrigerants and fluorocarbon substitutes. Additionally, EPA assumes full compliance with the venting prohibition, which would necessitate recovery of all non-exempt refrigerants. 
                                 Safe Disposal
 + Extend requirements for the safe disposal of appliances to HFCs or other substitute refrigerants
This analysis assumes no costs associated with this extension because most technicians are already properly evacuating substitute refrigerants during maintenance, servicing, repair, or disposal of appliances as required under the venting prohibition. This requirement would likely mean minimal, if any, change in business practices other than the recordkeeping provisions discussed previously.
                                  Reclamation
 + Extend reclamation standards in Appendix A (currently based on ARI Standard 700-1995, Specification for Fluorocarbons and Other Refrigerants) to HFCs and other substitutes
This analysis assumes no costs associated with this extension because refrigerant recovered and reclaimed from disposed appliances must be of a certain purity to effectively be used in the appliance service sectors. Additionally, feedback from industry indicates that reclaimers use the same processes and practices when they reclaim HFCs as they do for ODS.
                           Technician Certification
 + Extend certification requirements to technicians who work with HFCs and other substitute refrigerants
This analysis assumes no costs associated with this extension because the pool of currently certified technicians is assumed to work with both ODS and substitute refrigerants. Many companies already require certification of their technicians regardless of the type of refrigerant being used. Further, EPA is not requiring currently certified technicians to recertify under this provision.
                                       
 + Require technician certification programs to offer tests to technicians who work with HFCs and other substitute refrigerants 
This analysis assumes no costs associated with this extension because certification programs will not need to change current practices to offer tests for these technicians. Further, EPA is not proposing to require certification programs to recertify.
                           Grandfathering Provisions
 + Remove provisions related to voluntary certification programs
This analysis assumes no costs associated with removing provisions related to voluntary certification programs since the provisions are deemed no longer necessary.
                              Certification Cards
 + Change the required text that is printed on certification cards
This analysis assumes the costs associated with this change are negligible and may actually ease burden on refrigerant wholesalers who must inspect the cards to verify the certification of technicians.
Approach for Estimating the Economic Impact on Small Entities
The sections below describe the method and assumptions used to estimate the economic impact on small entities associated with proposed regulatory changes related to: leak inspection and repair, reporting and recordkeeping, and self-sealing valves on DIY small cans. 
Leak Inspection and Repair Model Facility and Entity Assumptions
The RFA/SBREFA screening analysis uses most of the assumptions and methodological steps presented above for the aggregate economic analysis, in Section 3.1.1.
Different model facility scenarios were developed, however, to more accurately reflect the range of compliance costs that a given small business owner or operator could experience. For each facility, there are many potential configurations of equipment types, refrigerant, leak rates, and repair outcomes. For example, a food manufacturer with one comfort cooling system and two commercial refrigeration systems could have the comfort cooling system exceed the leak rate threshold and conduct a standard repair, while the two commercial refrigeration systems do not exceed the leak rate threshold. Or, the comfort cooling system could exceed the leak rate threshold and require a retrofit, while the commercial refrigeration systems are maintained below the threshold. Or, alternatively, the two commercial refrigeration systems could exceed the leak rate threshold and require an extension repair, while the comfort cooling system does not exceed the threshold. Multiple other configurations are possible within this single example and across all of the other industry categories.
Considering these multiple possibilities, "worst case" model facility assumptions were adopted. The "worst case" reflects the possibility that equipment with leak rates above the proposed threshold are clustered in individual facilities, such that all of the eligible equipment in a single model facility might trigger repair requirements. Within each facility, it is assumed that multiple units of the same equipment type are maintained in the same way (e.g., if a facility has two commercial refrigeration systems, both pieces of equipment are assumed to have similar leak rates), and thus experience the same leak repair outcomes. Model facility scenarios were developed for each industry category based on how many different types of equipment the industry is assumed to use and the expected number of extension requests and retrofits. Each scenario features a different combination of equipment and leak repair outcomes.
In Box 5 below, the Agricultural and Crop Support Services industry (Ag/Crop) is used to illustrate how this method was applied. 

Box 5: Model Facility Approach for the Agricultural and Crop Support Services Industry
In the Ag/Crop industry, a total of about 1,140 commercial refrigeration systems and 728 comfort cooling systems are estimated to be affected by the proposed rule. Each Ag/Crop facility is assumed to have two commercial refrigeration systems and one comfort cooling system. Therefore, 570 facilities (1,1,40 / 2) are assumed to have two commercial refrigeration systems and one comfort cooling system with leak rates above the proposed threshold. The remaining 158 facilities (728  -  570) have one comfort cooling system with leak rates that exceed the proposed threshold. 

The 570 facilities with all three pieces of affected equipment were further broken down by the potential repair outcomes for the affected equipment. Because the extension requests and retrofits result in the highest compliance costs incurred, these leak repair outcomes drove the model facility scenarios. The number of extension requests and retrofit requests were apportioned to each industry by multiplying the percentage of affected equipment (by sector and industry) by the total number of extension requests and retrofits expected across all industries.

For the Ag/Crop industry, 8 pieces of commercial refrigeration equipment are estimated to undergo retrofit in a given year. Assuming that both pieces of commercial refrigeration equipment at a facility will experience the same leak repair outcome, 4 facilities are assumed to have two pieces of commercial refrigeration equipment retrofitted. The comfort cooling systems at those 4 facilities are assumed to undergo a standard repair. Similarly, 18 pieces of commercial refrigeration equipment are assumed to request an extension repair, so 9 facilities are assumed to have two commercial refrigeration units with extension repairs and one comfort cooling system with a standard repair. This matrix approach is applied until all equipment outcomes are distributed among facilities, as shown in the table below.

Number of Facilities
Comfort Cooling Units
Commercial Refrigeration Units
                                       
                                   Standard
                                   Extension
                                   Retrofit
                                   Standard
                                   Extension
                                   Retrofit
Facilities with only 1 CC Affected
                                      158
                                       1
                                       
                                       
                                       
                                       
                                       
Facilities with 1 CC and 2 CR Affected
                                       4
                                       1
                                       
                                       
                                       
                                       
                                       2
                                       9
                                       1
                                       
                                       
                                       
                                       2
                                       
                                       5
                                       
                                       
                                       1
                                       2
                                       
                                       
                                      12
                                       
                                       1
                                       
                                       2
                                       
                                       
                                      540
                                       1
                                       
                                       
                                       2
                                       
                                       

Box 5: Model Facility Approach for the Agricultural and Crop Support Services Industry
In the Ag/Crop industry, a total of about 1,140 commercial refrigeration systems and 728 comfort cooling systems are estimated to be affected by the proposed rule. Each Ag/Crop facility is assumed to have two commercial refrigeration systems and one comfort cooling system. Therefore, 570 facilities (1,1,40 / 2) are assumed to have two commercial refrigeration systems and one comfort cooling system with leak rates above the proposed threshold. The remaining 158 facilities (728  -  570) have one comfort cooling system with leak rates that exceed the proposed threshold. 

The 570 facilities with all three pieces of affected equipment were further broken down by the potential repair outcomes for the affected equipment. Because the extension requests and retrofits result in the highest compliance costs incurred, these leak repair outcomes drove the model facility scenarios. The number of extension requests and retrofit requests were apportioned to each industry by multiplying the percentage of affected equipment (by sector and industry) by the total number of extension requests and retrofits expected across all industries.

For the Ag/Crop industry, 8 pieces of commercial refrigeration equipment are estimated to undergo retrofit in a given year. Assuming that both pieces of commercial refrigeration equipment at a facility will experience the same leak repair outcome, 4 facilities are assumed to have two pieces of commercial refrigeration equipment retrofitted. The comfort cooling systems at those 4 facilities are assumed to undergo a standard repair. Similarly, 18 pieces of commercial refrigeration equipment are assumed to request an extension repair, so 9 facilities are assumed to have two commercial refrigeration units with extension repairs and one comfort cooling system with a standard repair. This matrix approach is applied until all equipment outcomes are distributed among facilities, as shown in the table below.

Number of Facilities
Comfort Cooling Units
Commercial Refrigeration Units
                                       
                                   Standard
                                   Extension
                                   Retrofit
                                   Standard
                                   Extension
                                   Retrofit
Facilities with only 1 CC Affected
                                      158
                                       1
                                       
                                       
                                       
                                       
                                       
Facilities with 1 CC and 2 CR Affected
                                       4
                                       1
                                       
                                       
                                       
                                       
                                       2
                                       9
                                       1
                                       
                                       
                                       
                                       2
                                       
                                       5
                                       
                                       
                                       1
                                       2
                                       
                                       
                                      12
                                       
                                       1
                                       
                                       2
                                       
                                       
                                      540
                                       1
                                       
                                       
                                       2
                                       
                                       

Expected compliance costs per model facility were estimated by multiplying the unit cost assumptions described in Section 3.1.1.3 plus the expected reporting and recordkeeping costs per facility, by the model facility configurations for each industry sector. Costs to small businesses were then scaled based on the proportion of facilities-to-entities for small businesses in each NAICS code in each industry category.To be conservative, this analysis does not include the avoided compliance costs associated with the proposed flexibility for owners or operators of ODS CC and CR appliances to request additional time to make repairs due to the unavailability of components. While this flexibility is expected to result in fewer ODS appliances being retired prematurely, these avoided costs are not reflected in the small business impacts analysis. 
Reporting and Recordkeeping 
The compliance costs associated with reporting and recordkeeping that are incurred by affected equipment owners and operators are included in the model facility calculations described above. This section addresses the costs to other small entities subject to reporting and recordkeeping requirements, including reclaimers, disposal establishments, service establishments, refrigerant wholesalers, small can manufacturers, and service technicians. 
Table 20 below shows potentially affected industries by reporting and recordkeeping requirement (see also Section 2.2).
Table 20. Potentially Affected Industries for Reporting and Recordkeeping Requirements
Reporting and Recordkeeping Requirement
Industry 
NAICS Code and Definition
Reclaimer annual activity reports and recordkeeping
Reclaimers
325120
Industrial Gas Manufacturing


423930
Recyclable Material Merchant Wholesalers


562920
Materials Recovery Facilities


562212
Solid Waste Landfill


424690
Other Chemical and Allied Products Merchant Wholesalers
Refrigerant wholesalers recordkeeping for refrigerant sales, including maintenance of technician certification cards from purchasers employing at least one certified technician
Refrigerant Wholesalers
325120
Industrial Gas Manufacturing


424690
Other Chemical and Allied Products Merchant Wholesalers


42
Wholesale Trade
New recordkeeping requirement to document how much refrigerant was recovered from 5-50 lb. appliances at disposal and the fate of that refrigerant
Service Technicians
238220
Plumbing, Heating, and Air-conditioning Contractors
New recordkeeping requirement to keep records of self-sealing valve test data and log forms
Small Can Manufacturers

441310
Automotive Parts and Accessories Stores


325120
Industrial Gas Manufacturing
Removal of certification requirement for disposal establishments that change ownership or enter the market

Disposal Establishments

562920
Materials Recovery Facilities


562212
Solid Waste Landfill


423990
Other Miscellaneous Durable Goods Merchant Wholesalers
Removal of certification requirement for owners of refrigerant recovery/ recycling equipment that change ownership or enter the market 
Service Establishments

811310
Commercial Industrial Machinery and Equipment (not Automotive and Electronic) Repair and Maintenance


811412
Appliance Repair and Maintenance

To determine the incremental cost per firm to comply with the proposed changes to recordkeeping and reporting requirements, the total aggregate incremental costs were divided by the total number of affected businesses in each industry. For example, the aggregate incremental costs for reclaimers represents the sum of the incremental costs associated with: 1) reclaimer annual activity reports; and 2) reclaimer recordkeeping (i.e., $12,011 + $15,014= $27,025). This number was then divided by 61, representing the number of certified refrigerant reclaimers affected by the proposed changes (i.e., $27,025/61 = $443/per certified refrigerant reclaimer).  This conservative approach likely overestimates costs for small businesses by assuming equal burden regardless of business size. 
Self-sealing Valves on DIY Small Cans
To estimate the cost per entity to install self-sealing valves, total annual sales of DIY small cans were distributed across the manufacturers using a weighted average of total small can Stock Keeping Units (SKUs) and share of total sales volume. For small businesses, this number was then multiplied by the cost to install a self-sealing valve, which is assumed to be $0.25 per can.
Approach for Estimating Benefits
The sections below describe the method and assumptions used to estimate aggregate benefits associated with proposed regulatory changes related to leak inspection and repair and self-sealing valves on DIY small cans. In addition, the methodology for estimating future benefits in 2020 and 2025 of the leak inspection and repair proposed regulatory changes is presented. The environmental benefits are the annual GHG emissions avoided (MTCO2eq) and annual ODS emissions avoided (ODP-weighted MT) as a result of the proposed regulatory changes.  
Emission Reduction Benefits of Leak Inspection and Repair
Annual Benefits of Leak Inspection and Repair
Similar to the methodology for estimating costs and savings, benefits were estimated using a model equipment, facility, and entity approach.  Benefits were then scaled up industry-wide based on the proportion of businesses that could be affected by the regulation in order to determine the full impact of each of the proposed changes.
Benefits are calculated as the refrigerant emissions prevented by repairing or retrofitting a leaking system earlier. Avoided refrigerant emissions are calculated based on the difference between the baseline and post-repair leak rates (shown in Section 3.1.1.2 above), multiplied by the charge size, over the three weeks earlier that each repair was conducted. The amount of avoided refrigerant emissions is weighted by an average ODP (for ODS systems) and GWP (for ODS and HFC systems). ODP and GWP values were estimated as a weighted average of the refrigerant GWP or ODP (using IPCC AR4 values) and charge size for each equipment type and size, based on 2013 data reported under California's RMP.
Table 21: Average GWP and ODP Assumptions by Equipment Type, Size, and Refrigerant Type
Sector
Equipment Type
Equipment Size
Refrigerant Type
Weighted-Average ODP
Weighted-Average GWP
CC
Unitary AC
Small
ODS
0.05
1,816



HFC
-
2,349

Chiller
Medium
ODS
0.05
1,716



HFC
-
2,044

Chiller
Large
ODS
0.05
1,414



HFC
-
1,544
CR
Condensing Unit
Small
ODS
0.03
3,140



HFC
-
3,792

Rack
Medium
ODS
0.05
2,191



HFC
-
3,644

Rack
Large
ODS
0.05
1,861



HFC
-
3,860

Cold Storage
Medium
ODS
0.05
1,839



HFC
-
3,726

Cold Storage
Large
ODS
0.06
1,810



HFC
-
3,984
IPR
IPR
Small
ODS
0.02
2,788



HFC
-
3,957

IPR
Medium
ODS
0.04
1,076



HFC
-
3,234

IPR
Large
ODS
0.05
1,556



HFC
-
1,860

The benefits for the extension repair are assumed to be equivalent to the benefits of a standard repair, as this analysis does not take into account the additional 30 days that the system is leaking between filing the extension and when the actual repair takes place, which could result in overestimating the avoided emissions as a result of the extension request. However, because systems requiring an extension repair have typically more complicated or catastrophic leaks, an extension repair as a result of the proposed regulatory changes would still be taking place earlier than it would under the baseline scenario, and emissions would still be avoided. 
No emission benefits associated with retrofit and replacement are assumed, as the proposed rule does not require equipment that is repaired or retrofitted to be initially repaired. Furthermore, because this analysis only considers a one-year period, it does not include benefits from preventing a chronically leaking system from continued operation over a longer time period than one year, nor does it include the benefits of an accelerated transition to alternative refrigerants that may have lower GWPs. 
On a per system basis, effective benefits range from 3 MTCO2eq for small comfort cooling HFC systems up to more than 200 MTCO2eq for very large IPR systems.
Model Equipment Expected Benefits. Expected benefits per model equipment were estimated on a weighted basis, taking into account the proportion of equipment assumed to reach each leak repair outcome (see Table 13 above) and the avoided refrigerant emissions associated with each outcome. Expected benefits were estimated in the model in a disaggregated manner, distinguishing between equipment sectors, types, sizes, and refrigerant type.
Model Facility Assumptions. To estimate expected benefits per model facility, the expected avoided refrigerant emissions per model equipment type (as described above) were multiplied by the number of each type of equipment per facility and the percentage of each type of equipment assumed to experience leaks above the proposed rule's threshold rate (see Table 17 above). In the final step, the expected avoided refrigerant emissions per model facility were multiplied by the total number of facilities in each industry category and the percentage of each industry assumed to be affected. These calculations yield aggregate benefits for the U.S. as a whole. More detailed assumptions about model facilities are summarized above in Section 3.1.1.4.
Future Annual Benefits of Leak Inspection and Repair
The analysis described above estimates one-year benefits based on the current distribution of ODS and HFC equipment in use. However, because the use of HFCs and ODS will change over the next decade due to multiple factors, including the continued phase-out of ODS systems and EPA's rulemaking, Protection of Stratospheric Ozone: Change of Listing Status for Certain Substitutes under the Significant New Alternatives Policy Program (Status Change Rule) (80 FR 42869), benefits for the proposed regulatory changes to the Program will also change. Future benefits were estimated using a model equipment, facility, and entity approach.  Benefits were then scaled up industry-wide based on the total number of affected equipment anticipated for two points in the future: 2020 and 2025. 
In order to simplify the process of determining the number of affected equipment and the benefits of leak repair in 2020 and 2025, several assumptions were made:
Equipment used in 2020 and 2025 is assumed to have the same leak rates and charge sizes as equipment today.
The same proportion of standard repairs, extension requests, and retrofit/retirements are assumed for 2020 and 2025.
The affected ODS and HFC equipment in 2013 is assumed to grow according to the growth rate, lifetime, and transitions in EPA's Vintaging Model -- with the adjustments described below. 
Growth in stock of HFC equipment was slightly adjusted to ensure that the analysis accurately reflects other rulemakings that affect the same equipment sectors. EPA's Status Change Rule makes certain HFCs unacceptable for use in some of the equipment affected by the Program, specifically commercial refrigeration equipment (i.e., rack systems and condensing units). Benefits from the transition away from HFCs were quantified and presented in EPA's analysis Climate Benefits of the SNAP Program Status Change Rule (Docket No. EPA-HQ-OAR-2014-0198-0239). In order to avoid double-counting benefits, this analysis assumes that HFC commercial refrigeration equipment begins transitioning away from HFCs in accordance with the "most likely" transition scenario presented in the Benefits Analysis for the Status Change Rule. 
Equipment-specific average ODP and GWP values were also updated to reflect the specific mix of ODS and HFC refrigerants assumed in 2020 and 2025. Benefits on a per-equipment basis were then calculated in the same manner outlined in Section 3.3.1.1 and were multiplied by the estimated affected equipment in 2020 and 2025 described above. 
Emission Reductions Benefits of Installing Self-sealing Valves on Small Cans
Annual Benefits of Installing Self-sealing Valves on Small Cans
The following equation was used to calculate annual emissions avoided from the installation of self-sealing valves on DIY small cans:
SCUS-SCCAxCS xSL x 0.00045359 xGWP=AE
Where: 
SCUS
=
Annual sales of R-134a small cans to DIY market in United States; assumed to be approximately 14 million
SCCA
=
Annual sales of R-134a small cans to DIY market in California; assumed to be approximately 1.8 million
CS
= 
Charge size per small can (0.75 lbs.)
SL
= 
Percent of initial mass contained in the can that is directly emitted during the charging procedure (i.e., servicing loss rate); assumed to be 11%
0.00045359
= 
Factor used to convert from lbs. to MT
GWP
= 
Global warming potential of R-134a; assumed to be 1,430
AE
= 
Annual avoided emissions (MTCO2eq.)

As a first step in the calculation, the number of R-134a small cans that are sold annually to the DIY market in the United States and California were estimated based on data from NPD Automotive Aftermarket Industry Monitor (NPD 2008; CARB 2009b). Small cans sold to the DIY market in California were excluded from this analysis since they already have self-sealing valves per CARB regulations. Then, the amount of refrigerant sold annually to the DIY market (excluding sales in California) was calculated assuming that each small can contains 12 ounces of refrigerant (0.75 lbs.). 
To estimate the total mass of refrigerant that would have been directly emitted during the DIY charging procedure without a self-sealing valve, it was assumed that 11% of the total initial mass is directly emitted to the environment during the DIY charging procedure (CEP-Armines 2008). The inclusion of a self-sealing valve is expected to reduce release during service to negligible levels, and thus, for the purposes of this analysis, it was assumed that 100% of the refrigerant emitted during servicing is prevented by the valve. Emissions from the can heel are conservatively assumed to remain the same as cans without a self-sealing valve, and therefore are excluded from the benefits analysis. The heel that remains in the can may be emitted to the environment during extended storage periods or when landfilled (Zhan et al. 2014). As a last step, the total mass of refrigerant loss prevented by the self-sealing valve was converted to metric tons of carbon dioxide equivalent (MTCO2eq.) assuming a GWP of 1,430 from IPCC's fourth assessment report (AR4).  
Although this analysis conservatively assumes that self-sealing valves will only negate emissions from servicing losses, there also may be emission benefits associated with the can heel. Having a self-sealing valve would likely change the percentage and number of cans used per recharge, but no data are available to quantify this effect at this time.
Future Annual Benefits of Self-sealing Valves
The analysis described above estimates one-year benefits based on the current number of R-134a small cans that are sold annually to the DIY market. However, due to recent rulemakings, including 1) the joint rulemaking issued by EPA and the National Highway Traffic Safety Administration (NHTSA) to establish light-duty vehicle (LDV) GHG emission standards and Corporate Average Fuel Economy (CAFE) Standards and 2) EPA's Status Change Rule (80 FR 42869), the amount of R-134a refrigerant sold to the DIY market is expected to decline over the next decade.  As a result, the estimated benefits for this proposed regulatory requirement are also expected to decline. 
To estimate the future benefits, current benefits were scaled down based on the Vintaging Model's projected stock of R-134a MVAC units in years 2020 and 2025. The Vintaging Model's projected stock of R-134a MVAC units incorporates assumptions from the Technical Support Document for EPA/NHTSA's final rule, which assumes that in 2017 20% of the U.S. market will adopt alternative MVAC systems, and that in each subsequent year the market penetration will increase an additional 20%, reaching 100% by 2021 (EPA/NHTSA 2012). This analysis assumes that as the market transitions to alternative MVAC systems, DIYers are more likely to have their vehicles serviced by a certified technician. 
Extending Other Existing Requirements to HFCs and Other Substitutes: Implications for Benefits
While EPA is proposing specific practices to prevent release of HFCs and other substitute refrigerant, including but not limited to requiring refrigerant be recovered from small appliances, MVACs, and MVAC-like appliances before disposal, evacuation of refrigerant before opening an appliance for servicing, and reclamation of refrigerant to industry standards before sale for use, EPA has not calculated any of the benefits that would accrue if compliance were to increase as a result of this rulemaking.
As noted above in Section 3.1.4, this assumption seems reasonable because anyone handling HFC and other substitute refrigerants already must comply with the venting prohibition, which effectively necessitates similar practices to ensure refrigerant is not released into the environment. This assumption is supported by feedback from numerous regulated entities both in the public and private sector that most in industry treat HFCs and ODS refrigerants the same way to comply with the venting prohibition. Assuming no additional benefits also results in a conservative assessment of the benefits of this rule.
Aggregate Economic Impact Analysis
This section summarizes the estimated impacts on the entire U.S. economy associated with the Agency's proposed regulatory changes to Section 608 of the CAA. These results were generated for the industries and equipment types characterized in Section 2, using the modeling approach and methodology described in Section 3.  All costs and savings are provided in 2014 dollars.
To provide a full range of costs, savings, and benefits estimates, Appendix A presents the results of several sensitivity analyses across different assumption dimensions:
Appendix A.1: CARB distribution of ODS and HFC refrigerants by equipment type, rather than Vintaging Model.
Appendix A.2: 200 pound threshold for annual and quarterly leak inspection for CR and IPR equipment, rather than 500 pounds.
Appendix A.3: Higher post-repair leak rates set at 90% of the threshold leak rate (e.g., if the threshold rate is 20%, it is assumed that the system is repaired and has a resulting leak rate of 18%), rather than the rates in Table 14.
Appendix A.4: 3% discount rate, rather than 7%.
Appendix A.5: Leak repairs are conducted two weeks earlier, rather than three weeks.
Appendix A.6: Leak repairs are conducted two months earlier, rather than three weeks.
Appendix A.7: Lower threshold leak rates of 5% for CC and 15% for CR and IPR, rather than 10% for CC and 20% for CR and IPR.
Appendix A.8: Higher IPR threshold leak rates of 15% for CC, 25% for CR, and 30% for IPR, rather than 10% for CC and 20% for CR and IPR.
Annual Compliance Costs
EPA's proposed changes to the Section 608 regulations are expected to result in annual compliance costs of approximately $63 million, as shown in Table 22. This amount includes new compliance costs of approximately $113 million associated with the proposed rulemaking, as well as avoided compliance costs of approximately $50 million associated with the proposed removal of some existing regulatory requirements and provision of additional flexibility that are expected to reduce regulatory burden. 
Table 22. Annual Compliance Costs by Rule Component (2014$)
Rule Component
Compliance Costs

                                      HFC
                                      ODS
                                     TOTAL
Leak Inspection
                                       
                                       
                                       
  CC, CR, and IPR 50-500 lbs.
                                  $17,409,000
                                  $16,822,000
                                  $34,231,000
  CR and IPR >=500 lbs.
                                  $21,777,000
                                  $27,536,000
                                  $49,314,000
Leak Repair
                                       
                                       
                                       
  CC
                                  $5,046,000
                                 -$38,191,000
                                 -$33,145,000
  CR
                                  $1,709,000
                                 -$10,137,000
                                  -$8,428,000
  IPR
                                   $494,000
                                    $39,000
                                   $533,000
Reporting & Recordkeeping
                                  $11,304,000
                                  $5,789,000
                                  $17,093,000
Self-sealing Valves on Small Cans
                                  $3,070,000
                                       -
                                  $3,070,000
Total
                                  $60,809,000
                                  $1,858,000
                                  $62,668,000
Totals may not sum due to independent rounding.
More detailed results tables for reporting and recordkeeping can be found in Appendix B.
Annual Refrigerant Savings
Total annual operating savings associated with reduced refrigerant use are estimated to be $52 million. Table 23 below shows the annual savings by rule component. As noted in Section 3.1.1, the combination of proposed leak repair and inspection requirements is expected to result in refrigerant savings for system owners or operators due to earlier leak repair action. 
Table 23. Total Annual Refrigerant Savings (2014$), Compliance Costs, and Combined Annual Compliance Costs and Refrigerant Savings
 Rule Component
Annual Refrigerant Savings
Compliance Costs
Combined Annual Refrigerant Savings and Compliance Costs

HFC
ODS
Total


Leak Inspection
                                       
                                       
                                       
                                       
                                       
  CC, CR, and IPR 50-500 lbs.
                                       -
                                       -
                                       -
                                  $34,231,000
                                  $34,231,000
  CR and IPR >=500 lbs.
                                       -
                                       -
                                       -
                                  $49,314,000
                                  $49,314,000
Leak Repair
                                       
                                       
                                       
                                       
                                       
  CC
                                 -$15,977,000
                                 -$20,221,000
                                 -$36,198,000
                                 -$33,145,000
                                 -$69,343,000
  CR
                                  -$4,130,000
                                  -$7,514,000
                                 -$11,644,000
                                  -$8,428,000
                                 -$20,072,000
  IPR
                                  -$2,074,000
                                  -$2,240,000
                                  -$4,314,000
                                   $533,000
                                  -$3,781,000
Reporting & Recordkeeping
                                       -
                                       -
                                       -
                                  $17,093,000
                                  $17,093,000
Self-sealing Valves on Small Cans
                                       -
                                       -
                                       -
                                  $3,070,000
                                  $3,070,000
Total
                                 -$22,181,000
                                 -$29,975,000
                                 -$52,156,000
                                  $62,668,000
                                  $10,512,000
           Totals may not sum due to independent rounding.
Annual Emission Reduction Benefits
The Agency's proposed regulatory changes to Section 608 of the CAA are expected to reduce both GHG and ODS emissions. Total annual GHG emissions avoided in 2015 from the proposed regulatory changes are expected to be approximately 7.5 MMTCO2eq. Total ODS emissions avoided from the proposed regulatory changes are expected to be 116 ODP-weighted MT. 
Table 24 below shows the annual GHG and ODS emissions avoided from HFC and ODS refrigerants by rule component. 
Table 24. Annual GHG and ODS Emissions Avoided in 2015
Rule Component
GHG Emissions Avoided 
(MTCO2eq)
ODS Emissions Avoided (ODP-weighted MT)
                                       
                                      HFC
                                      ODS
                                     Total
                                      ODS
Leak Inspection and Repair
                                       
                                       
                                       
                                       
  CC
                                   1,425,000 
                                   2,487,000 
                                   3,912,000 
                                      78 
  CR
                                   1,246,000 
                                   1,077,000 
                                   2,323,000 
                                      30 
  IPR
                                    381,000 
                                    250,000 
                                    630,000 
                                       8 
Reporting & Recordkeeping
                                       -
                                       -
                                       -
                                       -
Self-sealing Valves on Small Cans
                                   657,000 
                                       -
                                   657,000 
                                       -
Total
                                   3,709,000 
                                   3,814,000 
                                   7,522,000 
                                      116 
   Totals may not sum due to independent rounding.
Looking Forward: Emission Reduction Benefits in 2020 and 2025
Leak inspection and repair. The distribution of ODS and HFC equipment in use is anticipated to change significantly over the next decade, resulting in different leak inspection and repair benefits for 2020 and 2025. 
Self-sealing valves on small cans. The number of R-134a small cans sold annually to the DIY market is also expected to change over the next decade, resulting in different benefits for 2020 and 2025. 
Table 25 and Table 26 below show the annual GHG emissions avoided from HFC and ODS refrigerants by rule component.
Table 25. Annual GHG Emissions Avoided in 2020 (MTCO2eq.)
Rule Component
2020

                                      HFC
                                      ODS
                                     Total
Leak Inspection and Repair
                                       
                                       
                                       
  CC
                                  2,382,000 
                                  1,316,000 
                                  3,698,000 
  CR
                                  1,902,000 
                                   769,000 
                                  2,671,000 
  IPR
                                   723,000 
                                   255,000 
                                   978,000 
Self-Sealing Valves on DIY Small Cans
                                    537,000
                                       0
                                   537,000 
Total
                                  5,544,000 
                                  2,340,000 
                                  7,884,000 
             Totals may not sum due to independent rounding.

Table 26. Annual GHG Emissions Avoided in 2025 (MTCO2eq.)
Rule Component
2025

                                      HFC
                                      ODS
                                     Total
Leak Inspection and Repair
                                       
                                       
                                       
  CC
                                   3,367,000 
                                    526,000 
                                   3,893,000 
  CR
                                   2,286,000 
                                    440,000 
                                   2,726,000 
  IPR
                                    927,000 
                                    224,000 
                                   1,151,000 
Self-Sealing Valves on DIY Small Cans
                                    339,000
                                       0
                                    339,000 
Total
                                   6,919,000 
                                   1,190,000 
                                   8,109,000 
             Totals may not sum due to independent rounding.

Total ODS emissions avoided from the proposed leak repair regulatory changes in 2020 are expected to be 80 ODP-weighted MT and in 2025 are expected to be 44 ODP-weighted MT. Table 27 below shows the range of annual ODS emissions avoided by rule component.
Table 27. Annual ODS Emissions Avoided in 2020 and 2025 (ODP-weighted MT)
Rule Component
2020
2025

                                      ODS
                                      ODS
Leak Inspection and Repair
                                       
                                       
  CC
                                      48
                                      23
  CR
                                      23
                                      13
  IPR
                                       8
                                       8
Total
                                      80
                                      44
             Totals may not sum due to independent rounding.
Other Benefits
The Agency's proposed changes to Section 608 of the CAA may result in other economic, health, and environmental benefits that are not quantified or monetized in this conservative analysis. Some of these potential benefits include the following: 
Energy savings from leak repair. In addition to the financial impacts associated with replacing refrigerant from leaking systems, refrigeration and air-conditioning equipment may operate poorly when the charge is too low, resulting in higher energy costs. System performance is dependent on the charge level in the system and an undercharged system can use significantly more energy than an optimally charged one (Cowan, et al. 2010). Energy savings would also take place when leaking, inefficient systems are replaced with new, more energy-efficient systems. This analysis does not quantify the benefits of improved equipment performance from leak repair and retirement/replacement, although these benefits could be significant.
Reporting and recordkeeping. Emissions benefits associated with proposed changes to reporting and recordkeeping were not estimated. However, these requirements are anticipated to result in improved compliance with the Section 608 requirements, particularly for leak inspection, leak repair, and proper refrigerant recovery upon disposal of appliances. In addition, reporting and recordkeeping may encourage better equipment management practices, which could lead to faster repairs and better maintenance, and consequently reduced expense to system owners and increased environmental benefits. 
Benefits associated with the proposed recordkeeping requirement for disposing of field-installed appliances with charge sizes between 5 and 50 pounds were also not estimated. However, it is assumed that this new requirement will address a significant portion of potential emissions during equipment disposal. Based on estimates from EPA's Vintaging Model, the stock of refrigerant contained in field-installed appliances with charge sizes between 5 and 50 pounds that are disposed of annually contain a total of 27,300 MT of refrigerant (49.5 million MTCO2eq., 960 ODP-weighted MT), representing 45% of the total amount of HCFC and HFC refrigerants charged into all appliances being disposed annually (EPA 2014).
Extending servicing practice disposal requirements to substitutes. This analysis assumes servicing and disposal practices for HFCs and other substitutes are similar to those required for ODS refrigerants in order to comply with the venting prohibition. Extending these explicit requirements to HFCs and other substitutes could result in better compliance with the existing regulations for ODS appliances. Additionally, consistent standards for all refrigerants (except those that are exempt from the venting prohibition) should increase compliance, resulting in more benefits than are estimated in this analysis.
Human health benefits. Ozone depletion, caused by the release of CFCs and HCFCs, is associated with many adverse health effects, including melanoma skin cancer, non-melanoma skin cancers (e.g., basal cell carcinoma and squamous cell carcinoma), and cataracts. Reducing ODS emissions through the proposed regulatory changes to the Program will reduce the damages associated with ozone depletion. 
Materials and crop damage and ecological benefits. Some materials, such as polymers, are susceptible to photodegradation when exposed to ultraviolet (UV)B radiation. UVB radiation has also been shown to reduce crop yields. Other ecological effects of UV radiation can include impacts on recreational fishing, forests, overall marine ecosystems, and some plant types (EPA 1999). A reduction in UV radiation would extend the life of these materials and resources and result in physical and economic benefits (EPA 2011). 
Small Entities Impact Analysis 
This screening analysis finds that the proposed rulemaking can be presumed not to have a significant economic impact on a substantial number of small entities (SISNOSE), as described below. This section describes the decision matrix used to make this determination and the aggregated small business impacts.
 Decision Matrix for Determining Significant Economic Impact on a Substantial Number of Small Entities
This analysis uses the matrix shown in Table 28 to determine whether this rulemaking would impose a SISNOSE. The economic threshold levels are set conservatively at 1% and 3% of sales, consistent with similar analyses of other Clean Air Act Title VI rules. These thresholds are set conservatively because the proposed rulemaking affects small businesses in a range of different industries, which may have significantly different profit margins and abilities to pass compliance costs along to customers. Based on this decision matrix, this screening analysis finds that the proposed rulemaking can be presumed to have no SISNOSE. 
Table 28. Decision Matrix for Certifying SISNOSE
Economic Impact
Number of Small Entities Subject to the Rule and Experiencing Given Economic Impact
Percent of All Small Entities Subject to the Rule That Are Experiencing Given Economic Impact
Certification Category
Less than 1% for all affected small entities 
                                  Any number
                                  Any percent
                             Presumed No SISNOSE 
1% or more for one or more affected small entities
                                Fewer than 100
                             Less than 20 percent
                             Presumed No SISNOSE 

                                Fewer than 100
                                  20% or more
                         Uncertain  -  No Presumption

                              Between 100 and 999
                                 Less than 20%
                              Presumed No SISNOSE

                              Between 100 and 999
                                  20% or more
                         Uncertain  -  No Presumption

                                 1000 or more
                                  Any percent
                         Uncertain  -  No Presumption 
Greater than 3% for one or more affected small entities
                                Fewer than 100
                                 Less than 20%
                              Presumed No SISNOSE

                                Fewer than 100
                                  20% or more
                         Uncertain  -  No Presumption

                              Between 100 and 999
                                 Less than 20%
                         Uncertain  -  No Presumption

                              Between 100 and 999
                                  20% or more
                     Presumed Ineligible for Certification

                                 1000 or more
                                  Any percent
                     Presumed Ineligible for Certification

 Aggregate Small Business Impacts of Proposed Regulatory Changes
As shown in Table 29, an estimated 950,500 small businesses may be subject to the proposed regulatory actions. Appendix C shows small businesses potentially affected at the NAICS code level.
Table 29. Summary of the Small Business Impact
Industry
Estimated Number of Small Businesses Affected by the Rule
Grocery and Specialty Food Stores
                                      64,220 
Warehouse Clubs and Supercenters
                                              30 
Agriculture and Crop Support Services
                                        3,780 
Utilities
                                           580 
Food manufacturing
                                      38,230 
Beverage and Ice Manufacturing
                                        4,530 
Non-food Manufacturing
                                      58,120 
General Merchandise Stores
                                        2,960 
Refrigerated Warehousing and Storage
                                           580 
Other Warehousing, Storage, and Transportation
                                        3,680 
Non-durable Goods Wholesalers and Dealers
                                      43,140 
Durable Goods Wholesalers and Dealers
                                   105,770 
Educational Services
                                        1,420 
Hospitals
                                              90 
Research and Development
                                           820 
Office Buildings
                                   128,980 
Arts, Entertainment, and Recreation
                                        2,250 
Reclaimers
                                              50 
Disposal Establishments 
                                           340 
Service Establishments
                                        2,180 
Refrigerant Wholesalers
                                   193,120 
Service Technicians
                                   295,590 
Small Can Manufacturers
                                                5 
Total
                                                     950,490 
         Totals may not sum due to independent rounding.

To analyze the economic impacts on small businesses against the SISNOSE decision matrix, a "sales test" was applied, which calculates annualized compliance costs as a percentage of annual sales for businesses in each NAICS code by size category. For industries for which annual sales data were not available through the Economic Census, annual receipts or annual value of shipments was used as a proxy.
Table 30 aggregates the estimated economic impacts on small businesses, according to the categories set out in the SISNOSE decision matrix and using a 7% discount rate. Using the decision criteria established in Table 28, this screening analysis suggests that this rulemaking can be presumed to have no SISNOSE for the following reasons:
About 944,000 small businesses (99%) are estimated to incur compliance costs that will be less than 1% of annual sales.
Approximately 150 of the approximately 950,500 affected small businesses -- or less than 0.02% -- could incur costs in excess of 1% of annual sales and that fewer than 80 small businesses -- or less than 0.01% -- could incur costs in excess of 3% of annual sales. These estimates are below the thresholds for a substantial number determination (i.e., between 100 and 999 entities and less than 20% of affected entities).
Table 30. Aggregated Economic Impacts on Small Businesses
Economic Impact 
Industry
Number of Small Entities Subject to the Rule and Experiencing Given Economic Impact
Percent of All Small Entities Subject to the Rule That are Experiencing Given Economic Impact
Less than 1% for all affected small entities a
Agriculture and Crop Support Services 
                                                                          3,780


Grocery & Specialty Food Stores
                                                                         64,160


Warehouse Clubs & Supercenters 
                                                                             10


Utilities
                                                                            560


Food Manufacturing
                                                                         37,840


Beverage & Ice Manufacturing
                                                                          4,530


Non-food Manufacturing
                                                                         57,800


General Merchandise Stores
                                                                          <5


Refrigerated Warehousing and Storage
                                                                            520


Other Warehousing, Storage, and Transportation
                                                                          3,670


Non-durable Goods Wholesalers and Dealers
                                                                         43,140


Durable Goods Wholesalers and Dealers
                                                                        105,730


Educational Services
                                                                          1,420


Hospitals
                                                                             90


Research and Development
                                                                            820


Office Buildings
                                                                        128,510


Arts, Entertainment, and Recreation
                                                                          2,250


Reclaimers
                                                                             50


Refrigerant Wholesalers
                                                                        193,120


Service Technicians
                                                                        295,590


Small Can Manufacturers
                                                                          <5


Total
                                                                        943,610
                                                                            99%
1% or more for one or more affected small entities b
Agriculture and Crop Support Services 
                                                                          <5


Grocery & Specialty Food Stores
                                                                             40


Warehouse Clubs & Supercenters
                                                                             20


Food Manufacturing
                                                                             10


Beverage & Ice Manufacturing
                                                                          <5


Non-food Manufacturing
                                                                             10


Other Warehousing, Stor, Trans.
                                                                          <5


Non-durable Goods Wholesalers
                                                                          <5


Durable Goods Wholesalers
                                                                             30


Research and Development
                                                                          <5


Office Buildings
                                                                             20


Small Can Manufacturers
                                                                          <5


Total
                                                                            150
                                                                          0.02%
Greater than 3% for one or more affected small entities
Agriculture and Crop Support Services 
                                                                          <5


Grocery & Specialty Food Stores
                                                                             10


Warehouse Clubs & Supercenters
                                                                             20


Food Manufacturing
                                                                          <5


Non-food Manufacturing
                                                                          <5


Other Warehousing, Stor, Trans.
                                                                          <5


Durable Goods Wholesalers
                                                                             20


Office Buildings
                                                                             20


Total
                                                                             80
                                                                          0.01%
Totals may not sum due to independent rounding.
[a] Represents small entities affected with an economic impact equal to or lesser than 1% but greater than 0%.  
b This category aggregates the number of small entities that would be expected to experience an impact of 1% to 3% with the number of small entities that would be expected to experience an impact of 3% or greater.
 Statutory and Executive Order Impact Analyses
This section summarizes the screening analyses that were conducted to meet the relevant statutory and administrative requirements imposed by Congress and the Executive Office, including EOs 12866, 13132, 13045, and 12898; the RFA; and the UMRA.
EO 12866: Regulatory Planning and Review. The total annual economic impact of the proposed regulatory changes is expected to be approximately $63 million, which is below the $100 million threshold for an economically "significant regulatory action." 
UMRA. The proposed rulemaking is not expected to result in expenditures by State, local, and tribal governments, in the aggregate, or by the private sector, of $100 million or more in any one year. The estimated aggregate expenditures associated with the proposed rulemaking are approximately $63 million.
RFA. This screening analysis finds that the proposed rulemaking can be presumed to have no significant economic impact on a substantial number of small entities (SISNOSE) for the following reasons:
About 944,000 small businesses (99%) are estimated to incur compliance costs that will be less than 1% of annual sales.
Approximately 150 of the approximately 950,500 affected small businesses -- or less than 0.02% -- could incur costs in excess of 1% of annual sales, and that fewer than 80 small businesses -- or less than 0.01% -- could incur costs in excess of 3% of annual sales. These estimates are below the thresholds for a substantial number determination (i.e., between 100 and 999 entities, and less than 20% of affected entities).
Conclusions
This screening analysis found the total annual compliance costs of EPA's proposed regulatory changes to Section 608 to be approximately $63 million. These costs are below the $100 million adverse impact threshold set by EO 12866. Emission reduction benefits of the proposed rulemaking are approximately 7.5 MMTCO2eq (from both ODS and HFC refrigerants), and 116 ODP-weighted MT. 
The RFA screening analysis found that the Agency's proposed changes will impact an estimated 950,000 small businesses, with only 0.01% of the small businesses subject to the rulemaking experiencing net costs of 1% or more of annual sales.
 
References
ACEEE (American Council for an Energy-Efficient Economy). 2013. Appliance Standards: Comparing Predicted and Observed Prices. Report Number E13D. Prepared by Steven Nadel and Andrew deLaski.  
Bureau of Labor Statistics (BLS). 2014a. U.S. Department of Labor, Occupational Employment and Wages, May 2014. 49-9021 Heating, Air Conditioning, and Refrigeration Mechanics and Installers. Retrieved August 3, 2015, from http://www.bls.gov/oes/current/oes499021.htm. 
Bureau of Labor Statistics (BLS). 2014b. U.S. Department of Labor, Occupational Employment and Wages, May 2014. 43-5111 Weighers, Measurers, Checkers, and Samplers, Recordkeeping. Retrieved August 3, 2015, from http://www.bls.gov/oes/current/oes435111.htm. 
CARB. 2009a. Initial Statement of Reasons for Proposed Regulation for the Management of High Global Warming Potential Refrigerants for Stationary Sources. Retrieved July 24, 2015, from http://www.arb.ca.gov/cc/rmp/RMP_ISOR&Appendices(WithE&F).pdf.
CARB. 2009b. Appendix G. Technical Support Document: Staff Analysis on Emissions and Economic Impact of Proposed Regulation for Small Containers of Automotive Refrigerant. Retrieved June 3, 2015, from http://www.arb.ca.gov/regact/2009/hfc09/hfcappg.pdf. 
CARB. 2010a. Regulation for the Management of High Global Warming Potential Refrigerants for Stationary Sources. Final Regulation Order. Retrieved August 3, 2015, from http://www.arb.ca.gov/regact/2009/hfc09/testpro.pdf.   
CARB. 2010b. Test Procedure for Leaks from Small Containers of Automotive Refrigerant. TP-503. Retrieved June 5, 2015, from http://www.arb.ca.gov/cc/rmp/rmprule.htm.  
CARB. 2014. Data reported to California Air Resources Board under the Refrigerant Management Program for the 2013 calendar year. Provided to EPA and ICF on May 16, 2014. 
CEP-Armines. 2008. Evaluation of the Potential Impact of Emissions of HFC-134a From Non Professional Servicing of Motor Vehicle Air Conditioning Systems. Prepared for State of California Air Resources Board under CARB Agreement No. 06-341. Final Report. December 2008. Retrieved June 4, 2015, from http://www.arb.ca.gov/research/apr/past/06-341.pdf. 
Clodic et al. 2008. Evaluation of the Potential Impact of Emissions of HFC-134a from Nonprofessional Servicing of Motor Vehicle Air Conditioning Systems, ARB Research Contract Draft Final Report, July, 2008. http://www.arb.ca.gov/research/apr/past/06-341.pdf  
Cowan, D. et al. 2010. REAL Zero  -  Reducing refrigerant emissions & leakage  -  feedback from the IOR Project. The Institute of Refrigeration. Available online at: http://www.epa.gov/greenchill/downloads/IOR_ReducingRefrigerantEmissions.pdf. 
ICF International (ICF). 1997. Analysis of the Costs and Benefits of Leak Repair Requirements for the Commercial Refrigeration and Retail Food Sectors. Prepared for U.S. EPA, Office of Air and Radiation.
Infogroup, Inc. (n.d.). ReferenceUSA Online Database. Retrieved May 27, 2015, from http://www.referenceusa.com. 
Intergovernmental Panel on Climate Change (IPCC). 2007. Climate Change 2007: The Physical Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change. Solomon, S., D. Qin, M. Manning, Z. Chen, M. Marquis, K.B. Averyt, M. Tignor, and H.L. Miller (Eds.). Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA. September 2007. Available online at: http://www.ipcc.ch/publications_and_data/ar4/wg1/en/contents.html.
Intergovernmental Panel on Climate Change [IPCC] and Technology and Economic Assessment Panel [TEAP] (IPCC/TEAP). 2005. Special Report on Safeguarding the Ozone Layer and the Global Climate Systems, 2005. Available online at: https://www.ipcc.ch/pdf/special-reports/sroc/sroc_full.pdf 

Kim, Woohyn, and James E. Braun. 2010. Impacts of Refrigerant Charge on Air Conditioner and Heat Pump Performance. International Refrigeration and Air Conditioning Conference. Paper 1122. Retrieved July 28, 2015, from http://docs.lib.purdue.edu/iracc/1122.
NPD. 2008. NPD Automotive Aftermarket Industry Monitor - Total U.S. Auto Parts Chain Retailers, Refrigerant Category  -  Topline Summary #2.
Oak Ridge National Laboratory (ORNL). 2014. The Transportation Energy Data Book (TEDB). Produced by Oak Ridge National Laboratory for the U.S. Department of Energy's Office of Energy Efficiency and Renewable Energy. Edition 33 Released July 31, 2014. Retrieved July 27, 2015, from http://cta.ornl.gov/data/index.shtml. 
SBA. 2014. U.S. Small Business Administration Table of Small Business Size Standards Matched to North American Industry Classification System Codes. Retrieved June 3, 2015, from https://www.sba.gov/content/small-business-size-standards. 
Stanford University. 2011. Energy Efficiency and Climate Change Mitigation. EMF Report 25; Volume I.
Stratus Consulting (Stratus). 2009. Screening Analysis to Examine the Economic Impact of Proposed Revisions to the Refrigerant Recycling and Emissions Rule. 
Tait Consulting Ltd, 2012. Impact Assessment for Condensing Units. Retrieved March 10, 2015, from http://www.taitconsulting.co.uk/Ecodesign_Consultation_files/Impact%20assesment%20report%20Condensing%20units%20V1_3.pdf.
U.S. Census Bureau. 2007. Economic Census. Retrieved February 25, 2015 from: http://www.census.gov/econ/susb/data/susb2007.html 
U.S. Census Bureau. 2012. 2012 County Business Patterns. Number of Firms, Number of Establishments, Employment, and Annual Payroll by Enterprise Employment Size for the United States, All Industries:  2012. Retrieved February 25, 2015 from: http://www.census.gov/econ/susb/ 
U.S. Census Bureau. 2015. North American Industry Classification System Frequently Asked Questions. Accessed June 3, 2015. Available online at: https://www.census.gov/eos/www/naics/faqs/faqs.html
U.S. Department of Energy (DOE). 2009. Energy Savings Potential and R&D Opportunities for Commercial Refrigeration. Prepared by Navigant Consulting, Inc.
U.S. Department of Energy (DOE). 2013. Life-Cycle Cost Spreadsheet (NOPR). EERE-2013-BT-STD-0007-0024.
U.S. Environmental Protection Agency (EPA). 1993. Regulatory Impact Analysis:  The National Recycling Program and Emission Reduction Program (Section 608 of the Clean Air Act Amendments of 1990). U.S. Environmental Protection Agency, Office of Air and Radiation, Global Programs Division, Washington, DC. March, 1993.
U.S. Environmental Protection Agency (EPA). 1999. The Benefits and Costs of the Clean Air Act 1990 to 2010. EPA Report to Congress. EPA-410-R-99-001.
U.S. Environmental Protection Agency (EPA). 2011. Health and Welfare Benefits Analyses to Support the Second Section 812 Benefit-Cost Analysis of the Clean Air Act. Prepared by Industrial Economics, Incorporated for U.S. Environmental Protection Agency, Office of Air and Radiation. February 2011. Available online at: http://www.epa.gov/cleanairactbenefits/feb11/benefitsfullreport.pdf. 
U.S. Environmental Protection Agency (EPA). 2013. The Social Cost of Carbon. Available online at: http://www.epa.gov/climatechange/EPAactivities/economics/scc.html  
U.S. Environmental Protection Agency (EPA). 2014. EPA's Vintaging Model. "VM IO file_v4.4_10.13.14."
U.S. Environmental Protection Agency (EPA). 2015a. Updating Ozone Calculations and Emissions Profiles for use in the Atmospheric and Health Effects Framework Model. U.S. Environmental Protection Agency, Office of Air and Radiation, Stratospheric Protection Division, Washington, DC. February, 2015. Available online at: http://www.epa.gov/ozone/science/effects/AHEF_2015_Update_Report-FINAL_508.pdf  
U.S. Environmental Protection Agency (EPA). 2015b. National Refrigerant Recycling and Emissions Reduction Program, EPA ICR Number: 1626.13, OMB Control Number:  2060-0256. Available online at: http://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=201501-2060-008. 
U.S. Environmental Protection Agency (EPA) and National Highway Traffic Safety Administration (NHTSA). 2012. Joint Technical Support Document: Final Rulemaking for 2017-2025 Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards. August 2012. Available online at: http://www.epa.gov/otaq/climate/documents/420r12901.pdf.
United States Government. 2013. Technical Support Document - Technical Update of the Social Cost of Carbon for Regulatory Impact Analysis  -  Under Executive Order 12866. Interagency Working Group on Social Cost of Carbon, United States Government. Updated November 2013. Available online at: https://www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technical-update-social-cost-of-carbon-for-regulator-impact-analysis.pdf. 
Zhan, T. et al. 2014. Inventory and Mitigation Opportunities for HFC-134a Emissions from Nonprofessional Automotive Service. Atmospheric Environment 99 (2014) 17-23.

Sensitivity Analyses for Aggregate Economic Analysis
Aggregate Economic Analysis with CARB ODS and HFC Equipment Distribution

The following tables show the impact on the results of using the CARB distribution for ODS versus HFC equipment rather than the Vintaging Model.

Table 31: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with CARB ODS and HFC Equipment Distribution 
Rule Component
Annual Compliance Costs
Annual Refrigerant Savings

                                      HFC
                                      ODS
                                     Total
                                      HFC
                                      ODS
                                     Total
Leak Inspection
                                       
                                       
                                       
                                       
                                       
                                       
  CC, CR, and IPR 50-500 lbs.
                                  $17,409,000
                                  $16,822,000
                                  $34,231,000
                                       -
                                       -
                                       -
  CR and IPR >=500 lbs.
                                  $21,777,000
                                  $27,536,000
                                  $49,314,000
                                       -
                                       -
                                       -
Leak Repair
                                       
                                       
                                       
                                       
                                       
                                       
  CC
                                  $6,067,000
                                 -$36,180,000
                                 -$30,113,000
                                 -$12,091,000
                                 -$17,337,000
                                 -$29,427,000
  CR
                                  $1,683,000
                                 -$11,946,000
                                 -$10,262,000
                                  -$3,081,000
                                  -$8,806,000
                                 -$11,887,000
  IPR
                                   $379,000
                                    $49,000
                                   $428,000
                                  -$1,963,000
                                  -$2,586,000
                                  -$4,549,000
Reporting & Recordkeeping
                                  $11,320,000
                                  $5,772,000
                                  $17,092,000
                                       -
                                       -
                                       -
Self-sealing Valves on Small Cans
                                  $3,070,000
                                       -
                                  $3,070,000 
                                       -
                                       -
                                       -
Total
                                  $61,705,000
                                  $2,053,000
                                  $63,760,000
                                 -$17,135,000
                                 -$28,729,000
                                 -$45,863,000


Table 32: . Annual GHG and ODS Emissions Avoided with CARB ODS and HFC Equipment Distribution  
Rule Component
GHG Emissions Avoided 
(MTCO2eq)
ODS Emissions Avoided (ODP-weighted MT)
                                       
                                      HFC
                                      ODS
                                     Total
                                      ODS
Leak Inspection and Repair
                                       
                                       
                                       
                                       
  CC
                                   1,742,000 
                                   2,134,000 
                                   3,876,000 
                                      67
  CR
                                   1,030,000 
                                   1,238,000 
                                   2,269,000 
                                      36
  IPR
                                    306,000 
                                    276,000 
                                    582,000 
                                       9
Reporting & Recordkeeping
                                       -
                                       -
                                       -
                                       -
Self-sealing Valves on Small Cans
                                    657,000
                                       -
                                    657,000
                                       -
Total
                                   3,735,000 
                                   3,648,000 
                                   7,384,000 
                                      112


Aggregate Economic Analysis with 200-pound Annual Leak Inspection Threshold

The following table show the impact on results associated with a 200-pound threshold for annual leak inspection of CR and IPR, rather than 500 pounds (i.e., CR and IPR equipment containing less than 200 pounds receive annual leak inspections and CR and IPR equipment containing 200 or more pounds of refrigerant receive quarterly leak inspections). This sensitivity analysis did not affect the estimated annual GHG and ODS emissions avoided.
Table 33: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with 200-pound Annual Leak Inspection Threshold 
Rule Component
Annual Compliance Costs
Annual Refrigerant Savings

                                      HFC
                                      ODS
                                     Total
                                      HFC
                                      ODS
                                     Total
Leak Inspection
                                       
                                       
                                       
                                       
                                       
                                       
  CC, CR, and IPR 50-200 lbs.
                                  $14,073,000
                                  $13,578,000
                                  $27,651,000
                                       -
                                       -
                                       -
  CR and IPR >=200 lbs.
                                  $35,123,000
                                  $40,512,000
                                  $75,636,000
                                       -
                                       -
                                       -
Leak Repair
                                       
                                       
                                       
                                       
                                       
                                       
  CC
                                  $5,046,000
                                 -$38,191,000
                                 -$33,145,000
                                 -$15,977,000
                                 -$20,221,000
                                 -$36,198,000
  CR
                                  $1,709,000
                                 -$10,137,000
                                  -$8,428,000
                                  -$4,130,000
                                  -$7,514,000
                                 -$11,644,000
  IPR
                                   $494,000
                                    $39,000
                                   $533,000
                                  -$2,074,000
                                  -$2,240,000
                                  -$4,314,000
Reporting & Recordkeeping
                                  $12,055,000
                                  $6,032,000
                                  $18,087,000
                                       -
                                       -
                                       -
Self-sealing Valves on Small Cans
                                  $3,070,000
                                       -
                                  $3,070,000
                                       -
                                       -
                                       -
Total
                                  $71,570,000
                                  $11,833,000
                                  $83,404,000
                                 -$22,181,000
                                 -$29,975,000
                                 -$52,156,000

Aggregate Economic Analysis with Higher Post-Repair Leak Rate

The following tables show the impact on results associated with higher post-repair leak rates set at 90% of the threshold leak rate (i.e., if the threshold rate is 20%, it is assumed that the system is repaired and has a resulting leak rate of 18%), rather than the rates in Table 14.
Table 34: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with Higher Post-Repair Leak Rate 
Rule Component
Annual Compliance Costs
Annual Refrigerant Savings

                                      HFC
                                      ODS
                                     Total
                                      HFC
                                      ODS
                                     Total
Leak Inspection
                                       
                                       
                                       
                                       
                                       
                                       
  CC, CR, and IPR 50-500 lbs.
                                  $17,409,000
                                  $16,822,000
                                  $34,231,000
                                       -
                                       -
                                       -
  CR and IPR >=500 lbs.
                                  $21,777,000
                                  $27,536,000
                                  $49,314,000
                                       -
                                       -
                                       -
Leak Repair
                                       
                                       
                                       
                                       
                                       
                                       
  CC
                                  $5,046,000
                                 -$38,191,000
                                 -$33,145,000
                                  -$8,374,000
                                 -$10,573,000
                                 -$18,947,000
  CR
                                  $1,709,000
                                 -$10,137,000
                                  -$8,428,000
                                  -$2,942,000
                                  -$4,766,000
                                  -$7,708,000
  IPR
                                   $494,000
                                    $39,000
                                   $533,000
                                  -$1,867,000
                                  -$2,016,000
                                  -$3,883,000
Reporting & Recordkeeping
                                  $11,304,000
                                  $5,789,000
                                  $17,093,000
                                       -
                                       -
                                       -
Self-sealing Valves on Small Cans
                                  $3,070,000 
                                       -
                                  $3,070,000
                                       -
                                       -
                                       -
Total
                                  $60,809,000
                                  $1,858,000
                                  $62,668,000
                                 -$13,183,000
                                 -$17,355,000
                                 -$30,538,000
Table 35: . Annual GHG and ODS Emissions Avoided with Higher Post-Repair Leak Rate  
Rule Component
GHG Emissions Avoided 
(MTCO2eq)
ODS Emissions Avoided (ODP-weighted MT)
                                       
                                      HFC
                                      ODS
                                     Total
                                      ODS
Leak Inspection and Repair
                                       
                                       
                                       
                                       
  CC
                                   1,212,000 
                                   2,112,000 
                                   3,324,000 
                                      66
  CR
                                    842,000 
                                    859,000 
                                   1,701,000 
                                      24
  IPR
                                    310,000 
                                    203,000 
                                    513,000 
                                       7
Reporting & Recordkeeping
                                       -
                                       -
                                       -
                                       -
Self-sealing Valves on Small Cans
                                    657,000
                                       -
                                    657,000
                                       -
Total
                                   3,021,000 
                                   3,174,000 
                                   6,195,000 
                                      97
Aggregate Economic Analysis with 3% Discount Rate

The following table show the impact on results associated with a 3% discount rate, rather than a 7% discount rate. This sensitivity analysis did not affect the estimated annual GHG and ODS emissions avoided.

Table 36: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with 3% Discount Rate
Rule Component
Annual Compliance Costs
Annual Refrigerant Savings
                                       
                                      HFC
                                      ODS
                                     Total
                                      HFC
                                      ODS
                                     Total
Leak Inspection
                                       
                                       
                                       
                                       
                                       
                                       
  CC, CR, and IPR 50-500 lbs.
                                  $17,409,000
                                  $16,822,000
                                  $34,231,000
                                       -
                                       -
                                       -
  CR and IPR >=500 lbs.
                                  $21,777,000
                                  $27,536,000
                                  $49,314,000
                                       -
                                       -
                                       -
Leak Repair
                                       
                                       
                                       
                                       
                                       
                                       
  CC
                                  $2,437,000
                                 -$18,705,000
                                 -$16,268,000
                                 -$15,977,000
                                 -$20,221,000
                                 -$36,198,000
  CR
                                   $823,000
                                  -$4,963,000
                                  -$4,139,000
                                  -$4,130,000
                                  -$7,514,000
                                 -$11,644,000
  IPR
                                   $239,000
                                    $17,000
                                   $255,000
                                  -$2,074,000
                                  -$2,240,000
                                  -$4,314,000
Reporting & Recordkeeping
                                  $11,304,000
                                  $5,789,000
                                  $17,093,000
                                       -
                                       -
                                       -
Self-sealing Valves on Small Cans
                                  $3,070,000
                                       -
                                  $3,070,000
                                       -
                                       -
                                       -
Total
                                  $57,059,000
                                  $26,496,000
                                  $83,556,000
                                 -$22,181,000
                                 -$29,975,000
                                 -$52,156,000


Aggregate Economic Analysis with 2-week Leak Repair Improvement

The following tables show the impact on results associated with the assumption that leaks are detected and repaired two weeks faster as a result of the proposed rulemaking, rather than three weeks.

Table 37: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with 2-week Leak Repair Improvement
Rule Component
Annual Compliance Costs
Annual Refrigerant Savings

                                      HFC
                                      ODS
                                     Total
                                      HFC
                                      ODS
                                     Total
Leak Inspection
                                       
                                       
                                       
                                       
                                       
                                       
  CC, CR, and IPR 50-500 lbs.
                                  $17,409,000
                                  $16,822,000
                                  $34,231,000
                                       -
                                       -
                                       -
  CR and IPR >=500 lbs.
                                  $21,777,000
                                  $27,536,000
                                  $49,314,000
                                       -
                                       -
                                       -
Leak Repair
                                       
                                       
                                       
                                       
                                       
                                       
  CC
                                  $4,886,000
                                 -$38,444,000
                                 -$33,558,000
                                 -$10,651,000
                                 -$13,481,000
                                 -$24,132,000
  CR
                                  $1,645,000
                                 -$10,192,000
                                  -$8,547,000
                                  -$2,754,000
                                  -$5,009,000
                                  -$7,763,000
  IPR
                                   $479,000
                                    $26,000
                                   $505,000
                                  -$1,383,000
                                  -$1,493,000
                                  -$2,876,000
Reporting & Recordkeeping
                                  $11,304,000
                                  $5,789,000
                                  $17,093,000
                                       -
                                       -
                                       -
Self-sealing Valves on Small Cans
                                  $3,070,000
                                       -
                                  $3,070,000 
                                       -
                                       -
                                       -
Total
                                  $60,570,000
                                  $1,537,000
                                  $62,108,000
                                 -$14,788,000
                                 -$19,983,000
                                 -$34,771,000


Table 38: . Annual GHG and ODS Emissions Avoided with 2-week Leak Repair Improvement  
Rule Component
GHG Emissions Avoided 
(MTCO2eq)
ODS Emissions Avoided (ODP-weighted MT)
                                       
                                      HFC
                                      ODS
                                     Total
                                      ODS
Leak Inspection and Repair
                                       
                                       
                                       
                                       
  CC
                                    950,000 
                                   1,658,000 
                                   2,608,000 
                                      52
  CR
                                    831,000 
                                    718,000 
                                   1,549,000 
                                      20
  IPR
                                    254,000 
                                    166,000 
                                    420,000 
                                       5
Reporting & Recordkeeping
                                       -
                                       -
                                       -
                                       -
Self-sealing Valves on Small Cans
                                    657,000
                                       -
                                    657,000
                                       -
Total
                                   2,692,000 
                                   2,542,000 
                                   5,234,000 
                                      78


Aggregate Economic Analysis with 2-month Leak Repair Improvement

The following tables show the impact on results associated with the assumption that leaks are detected and repaired two months faster as a result of the proposed rulemaking, rather than three weeks.

Table 39: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$)  with 2-month Leak Repair Improvement
Rule Component
Annual Compliance Costs
Annual Refrigerant Savings

                                      HFC
                                      ODS
                                     Total
                                      HFC
                                      ODS
                                     Total
Leak Inspection
                                       
                                       
                                       
                                       
                                       
                                       
  CC, CR, and IPR 50-500 lbs.
                                  $17,409,000
                                  $16,822,000
                                  $34,231,000
                                       -
                                       -
                                       -
  CR and IPR >=500 lbs.
                                  $21,777,000
                                  $27,536,000
                                  $49,314,000
                                       -
                                       -
                                       -
Leak Repair
                                       
                                       
                                       
                                       
                                       
                                       
  CC
                                  $6,552,000
                                 -$36,924,000
                                 -$30,371,000
                                 -$42,605,000
                                 -$53,922,000
                                 -$96,527,000
  CR
                                  $2,262,000
                                  -$9,864,000
                                  -$7,602,000
                                 -$11,014,000
                                 -$20,037,000
                                 -$31,051,000
  IPR
                                   $636,000
                                   $105,000
                                   $741,000
                                  -$5,531,000
                                  -$5,972,000
                                 -$11,503,000
Reporting & Recordkeeping
                                  $11,304,000
                                  $5,789,000
                                  $17,093,000
                                       -
                                       -
                                       -
Self-sealing Valves on Small Cans
                                  $3,070,000
                                       -
                                  $3,070,000
                                       -
                                       -
                                       -
Total
                                  $63,010,000
                                  $3,464,000
                                  $66,476,000
                                 -$59,150,000
                                 -$79,931,000
                                 -$139,081,000


Table 40: . Annual GHG and ODS Emissions Avoided with 2-month Leak Repair Improvement  
Rule Component
GHG Emissions Avoided 
(MTCO2eq)
ODS Emissions Avoided (ODP-weighted MT)
                                       
                                      HFC
                                      ODS
                                     Total
                                      ODS
Leak Inspection and Repair
                                       
                                       
                                       
                                       
  CC
                                   3,799,000 
                                   6,633,000 
                                  10,432,000 
                                      209
  CR
                                   3,323,000 
                                   2,872,000 
                                   6,195,000 
                                      80
  IPR
                                   1,015,000 
                                    666,000 
                                   1,681,000 
                                      21
Reporting & Recordkeeping
                                       -
                                       -
                                       -
                                       
Self-sealing Valves on Small Cans
                                    657,000
                                       -
                                    657,000
                                       
Total
                                   8,794,000 
                                  10,171,000 
                                  18,965,000 
                                      311

Aggregate Economic Analysis with Lower Threshold Leak Rates

The following tables show the impact on results associated with lower threshold leak rates of 5% for CC and 15% for CR and IPR, rather than 10% and 20% respectively.

Table 41: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$)  with Lower Threshold Leak Rates
Rule Component
Annual Compliance Costs
Annual Refrigerant Savings

                                      HFC
                                      ODS
                                     Total
                                      HFC
                                      ODS
                                     Total
Leak Inspection
                                       
                                       
                                       
                                       
                                       
                                       
  CC, CR, and IPR 50-500 lbs.
                                  $17,409,000
                                  $16,822,000
                                  $34,231,000
                                       -
                                       -
                                       -
  CR and IPR >=500 lbs.
                                  $21,777,000
                                  $27,536,000
                                  $49,314,000
                                       -
                                       -
                                       -
Leak Repair
                                       
                                       
                                       
                                       
                                       
                                       
  CC
                                  $5,463,000
                                 -$38,130,000
                                 -$32,666,000
                                 -$10,475,000
                                 -$21,581,000
                                 -$32,055,000
  CR
                                  $2,007,000
                                 -$10,109,000
                                  -$8,102,000
                                  -$3,568,000
                                  -$7,587,000
                                 -$11,155,000
  IPR
                                   $548,000
                                    $43,000
                                   $591,000 
                                  -$2,465,000
                                  -$2,410,000
                                  -$4,875,000
Reporting & Recordkeeping
                                  $11,316,000
                                  $5,805,000
                                 $17,120,000 
                                       -
                                       -
                                       -
Self-sealing Valves on Small Cans
                                  $3,070,000
                                       -
                                  $3,070,000 
                                       -
                                       -
                                       -
Total
                                  $61,590,000
                                  $1,967,000 
                                 $63,558,000 
                                 -$16,508,000
                                 -$31,578,000
                                 -$48,085,000


Table 42: Annual GHG and ODS Emissions Avoided with Lower Threshold Leak Rates  
Rule Component
GHG Emissions Avoided 
(MTCO2eq)
ODS Emissions Avoided (ODP-weighted MT)
                                       
                                      HFC
                                      ODS
                                     Total
                                      ODS
Leak Inspection and Repair
                                       
                                       
                                       
                                       
  CC
                                   1,509,000 
                                   2,648,000 
                                   4,157,000 
                                      83
  CR
                                   1,332,000 
                                   1,091,000 
                                   2,423,000 
                                      30
  IPR
                                   404,000 
                                    270,000
                                    674,000
                                       9
Reporting & Recordkeeping
                                       -
                                       -
                                       -
                                       -
Self-sealing Valves on Small Cans
                                    657,000
                                       -
                                    657,000
                                       -
Total
                                   3,902,000 
                                   4,009,000 
                                   7,911,000 
                                      122


Aggregate Economic Analysis with Higher Threshold Leak Rates

The following tables show the impact on results associated with threshold leak rates of 15% for CC, 25% for CC, and 30% for IPR, rather than 10% for CC, and 20% for CC and IPR. 

Table 43: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with Higher Threshold Leak Rates
Rule Component
Annual Compliance Costs
Annual Refrigerant Savings

                                      HFC
                                      ODS
                                     Total
                                      HFC
                                      ODS
                                     Total
Leak Inspection
                                       
                                       
                                       
                                       
                                       
                                       
  CC, CR, and IPR 50-500 lbs.
                                  $17,409,000
                                  $16,822,000
                                  $34,231,000
                                       -
                                       -
                                       -
  CR and IPR >=500 lbs.
                                  $21,777,000
                                  $27,536,000
                                  $49,314,000
                                       -
                                       -
                                       -
Leak Repair
                                       
                                       
                                       
                                       
                                       
                                       
  CC
                                  $4,030,000
                                 -$38,333,000
                                 -$34,303,000
                                  -$7,349,000
                                 -$14,092,000
                                 -$21,440,000
  CR
                                  $1,419,000
                                 -$10,164,000
                                  -$8,745,000
                                  -$3,415,000
                                  -$7,417,000
                                 -$10,833,000
  IPR
                                   $359,000
                                    $29,000
                                   $389,000
                                  -$1,915,000
                                  -$1,870,000
                                  -$3,786,000
Reporting & Recordkeeping
                                  $11,283,000
                                  $5,761,000
                                  $17,044,000
                                       -
                                       -
                                       -
Self-sealing Valves on Small Cans
                                  $3,070,000
                                       -
                                  $3,070,000
                                       -
                                       -
                                       -
Total
                                  $59,347,000
                                  $1,651,000
                                  $61,000,000
                                 -$12,679,000
                                 -$23,379,000
                                 -$36,059,000


Table 44: Annual GHG and ODS Emissions Avoided with Higher Threshold Leak Rates  
Rule Component
GHG Emissions Avoided 
(MTCO2eq)
ODS Emissions Avoided (ODP-weighted MT)
                                       
                                      HFC
                                      ODS
                                     Total
                                      ODS
Leak Inspection and Repair
                                       
                                       
                                       
                                       
  CC
                                   1,136,000 
                                   1,833,000 
                                   2,970,000 
                                      57
  CR
                                   1,513,000 
                                   1,064,000 
                                   2,578,000 
                                      30
  IPR
                                    688,000 
                                    461,000 
                                   1,149,000 
                                      15
Reporting & Recordkeeping
                                       -
                                       -
                                       -
                                       
Self-sealing Valves on Small Cans
                                    657,000
                                       -
                                    657,000
                                       
Total
                                   3,994,000 
                                   3,358,000 
                                   7,354,000 
                                      101



Detailed Tables for Recordkeeping and Reporting
Table 45. Annual Compliance Costs for Recordkeeping and Reporting
                 Recordkeeping & Reporting  Rule Component
                        Annual Direct Compliance Costs
                           Avoided Compliance Costs
                            Total Compliance Costs

                                      HFC
                                      ODS
                                     Total
                                      ODS
                                       
Reclaimer recordkeeping & reporting
                                    $27,000
                                       -
                                    $27,000
                                       -
                                    $27,000
Refrigerant wholesalers recordkeeping
                                  $6,498,000
                                       -
                                  $6,498,000
                                       -
                                  $6,498,000
Owners/operators of appliances w/charge sizes >50 lbs. maintain information on purged/destroyed refrigerant
                                   <$100
                                       -
                                   <$100
                                       -
                                   <$100
Develop/maintain plan to retire/replace or retrofit equipment
                                       -
                                       -
                                       -
                                   -$813,000
                                   -$813,000
Owners/operators of appliances w/charge sizes >50 lbs. prepare & submit requests for extensions
                                    $49,000
                                    $55,000
                                   $104,000
                                       -
                                   $104,000
Recordkeeping associated with leak inspection and repair
                                  $4,301,000
                                  $1,616,000
                                  $5,917,000
                                       -
                                  $5,917,000
New recordkeeping requirement for 5-50 lb. appliances
                                   $430,000
                                  $5,049,000
                                  $5,479,000
                                       -
                                  $5,479,000
New recordkeeping requirement for small can manufacturers
                                   <$100
                                       -
                                   <$100
                                       -
                                   <$100
Removal of requirement for certification for acquisition of recovery/recycling equipment
                                       -
                                       -
                                       -
                                   -$118,000
                                   -$118,000
Total
                                  $11,304,000
                                  $6,720,000
                                  $18,025,000
                                   -$931,000
                                  $17,093,000
Totals may not sum due to independent rounding.

Detailed Tables for SISNOSE Analysis 
Table 46: Estimated Number of Small Businesses Affected by NAICS Code
Industry
NAICS Code and Definition
           Estimated Number of Small Businesses Affected by the Rule



Agriculture and Crop Support Services
115112
Soil Preparation, Planting, and Cultivating
                                     2,491

115113
Crop Harvesting, Primarily by Machine
                                      383

115114
Postharvest Crop Activities (except Cotton Ginning)
                                      908
Utilities
221111
Hydroelectric Power Generation
                                       5

221112
Fossil fuel electric power generation
                                      15

221113
Nuclear Electric Power Generation
                                       2

221114
Solar Electric Power Generation
                                       3

221115
Wind Electric Power Generation
                                       3

221116
Geothermal Electric Power Generation
                                       0

221117
Biomass Electric Power Generation
                                       2

221118
Other Electric Power Generation
                                       5

221121
Electric Bulk Power Transmission and Control
                                       2

221122
Electric Power Distribution
                                      79

221210
Natural Gas Distribution
                                      18

221310
Water Supply and Irrigation Systems
                                      153

221320
Sewage Treatment Facilities
                                      15

221330
Steam and Air-conditioning Supply
                                       2

211111
Crude Petroleum and Natural Gas Extraction
                                      280
Food Manufacturing
311111
Dog and Cat Food Manufacturing
                                      379

311119
Other Animal Food Manufacturing
                                     1,501

311211
Flour Milling
                                      272

311212
Rice Milling
                                      74

311213
Malt Manufacturing
                                      32

311221
Wet Corn Milling
                                      60

311224
Soybean and Other Oilseed Processing
                                      161

311225
Fats and Oils Refining and Blending
                                      167

311230
Breakfast Cereal Manufacturing
                                      70

311313
Beet Sugar Manufacturing
                                      29

311314
Cane Sugar Manufacturing
                                      65

311340
Non-chocolate Confectionery Manufacturing
                                      725

311351
Chocolate and Confectionery Manufacturing from Cacao Beans
                                      266

311352
Confectionery Manufacturing from Purchased Chocolate
                                     1,961

311411
Frozen Fruit, Juice, and Vegetable Manufacturing
                                      227

311412
Frozen Specialty Food Manufacturing
                                      620

311421
Fruit and Vegetable Canning
                                      953

311422
Specialty Canning
                                      191

311423
Dried and Dehydrated Food Manufacturing
                                      263

311511
Fluid Milk Manufacturing
                                      359

311512
Creamery Butter Manufacturing
                                      41

311513
Cheese Manufacturing
                                      650

311514
Dry, Condensed, and Evaporated Dairy Product Manufacturing
                                      187

311520
Ice Cream and Frozen Dessert Manufacturing
                                      581

311611
Animal (except Poultry) Slaughtering
                                     2,467

311612
Meat Processed from Carcasses
                                     2,052

311613
Rendering and Meat Byproduct Processing
                                      183

311615
Poultry Processing
                                      441

311710
Seafood Product Preparation and Packaging
                                      854

311811
Retail Bakeries
                                    11,455

311812
Commercial Bakeries
                                     4,014

311813
Frozen Cakes, Pies, and Other Pastries Manufacturing
                                      325

311821
Cookie and Cracker Manufacturing
                                      516

311824
Dry Pasta, Dough, and Flour Mixes Manufacturing from Purchased Flour
                                      616

311830
Tortilla Manufacturing
                                      583

311911
Roasted Nuts and Peanut Butter Manufacturing
                                      342

311919
Other Snack Food Manufacturing
                                      506

311920
Coffee and Tea Manufacturing
                                      710

311930
Flavoring Syrup and Concentrate Manufacturing
                                      223

311941
Mayonnaise, Dressing, and Other Prepared Sauce Manufacturing
                                      507

311942
Spice and Extract Manufacturing
                                      566

311991
Perishable Prepared Food Manufacturing
                                     1,075

311999
All Other Miscellaneous Food Manufacturing
                                      955
Beverage and Ice Manufacturing
312111
Soft Drink Manufacturing
                                      230

312112
Bottled Water Manufacturing
                                      234

312113
Ice Manufacturing
                                      341

312120
Breweries
                                      931

312130
Wineries
                                     2,796
Non-food Manufacturing
322121
Paper (except Newsprint) Mills
                                      151

322211
Corrugated and Solid Fiber Box Manufacturing
                                      887

322220
Paper Bag and Coated and Treated Paper Manufacturing
                                      789

323111
Commercial Printing (except Screen and Books)
                                    22,310

324110
Petroleum Refineries
                                      87

325120
Industrial Gas Manufacturing
                                      141

325180
Other Basic Inorganic Chemical Manufacturing
                                      476

325211
Plastics Material and Resin Manufacturing
                                     1,045

325320
Pesticide and Other Agricultural Chemical Manufacturing
                                      174

325412
Pharmaceutical preparation manufacturing
                                     1,076

325413
In-vitro diagnostic substance manufacturing
                                      185

325414
Biological product (except diagnostic) manufacturing
                                      209

325620
Toilet preparation manufacturing
                                      901

325991
Custom compounding of purchased resins
                                      390

325998
All other miscellaneous chemical product and preparation manufacturing
                                     1,025

326122
Plastics pipe and pipe fitting manufacturing
                                      311

326140
Polystyrene foam product manufacturing
                                      316

326160
Plastics bottle manufacturing
                                      185

326199
All other plastics product manufacturing
                                     6,298

326211
Tire manufacturing (except retreading)
                                      93

332431
Metal can manufacturing
                                      80

332812
Metal coating, engraving (except jewelry and silverware), and allied services to manufacturers
                                     2,558

332813
Electroplating, plating, polishing, anodizing, and coloring
                                     2,580

333241
Food Product Machinery Manufacturing
                                      451

333242
Semiconductor Machinery Manufacturing
                                      165

333415
Air-conditioning and warm air heating equipment and commercial and industrial refrigeration equipment manufacturing
                                      839

333611
Turbine and turbine generator set units manufacturing
                                      227

334112
Computer storage device manufacturing
                                      119

334419
Other Electronic Component Manufacturing
                                     2,640

334413
Semiconductor and related device manufacturing
                                      808

334510
Electromedical and electrotherapeutic apparatus manufacturing
                                      689

334515
Instrument manufacturing for measuring and testing electricity and electrical systems
                                      856

334516
Analytical laboratory instrument manufacturing
                                      651

334613
Blank magnetic and optical recording media manufacturing
                                      87

336411
Aircraft manufacturing
                                      262

336415
Guided missile and space vehicle propulsion unit and propulsion unit parts manufacturing
                                      21

339112
Surgical and medical instrument manufacturing
                                     1,236

339999
All other miscellaneous manufacturing
                                     6,804
Grocery and Specialty Food Stores
445110
Supermarkets and other grocery (except convenience) stores
                                    47,513

445210
Meat markets
                                     5,466

445230
Fruit and vegetable markets
                                     3,027

445299
All other specialty food stores
                                     4,624

722310
Food service contractors
                                     3,593
Warehouse Clubs and Supercenters
452910
Warehouse clubs and supercenters
                                      31
General Merchandise Stores
452112
Discount department stores
                                       5

452990
All other general merchandise stores
                                     1,166

453998
All other miscellaneous store retailers (except tobacco stores)
                                     1,785
Refrigerated Warehousing and Storage
493120
Refrigerated warehousing and storage
                                      577
Other Warehousing, Storage, and Transportation
484220
Specialized freight (except used goods) trucking, local
                                     2,086

488119
Other airport operations
                                      84

488510
Freight transportation arrangement
                                     1,060

488991
Packing and crating
                                      88

493110
General warehousing and storage
                                      276

493130
Farm product warehousing and storage
                                      20

493190
Other warehousing and storage
                                      63
Non-durable Goods Wholesalers and Dealers
424210
Drugs and druggists' sundries merchant wholesalers
                                     7,084

424410
General line grocery merchant wholesalers
                                     2,414

424420
Packaged frozen food merchant wholesalers
                                     3,031

424430
Dairy product (except dried or canned) merchant wholesalers
                                     1,770

424440
Poultry and poultry product merchant wholesalers
                                      481

424460
Fish and seafood merchant wholesalers
                                     2,076

424470
Meat and meat product merchant wholesalers
                                     2,337

424480
Fresh fruit and vegetable merchant wholesalers
                                     4,772

424490
Other grocery and related products merchant wholesalers
                                    10,673

424590
Other farm product raw material merchant wholesalers
                                      653

424710
Petroleum bulk stations and terminals
                                     2,994

424810
Beer and ale merchant wholesalers
                                     1,399

424930
Flower, nursery stock, and florists' supplies merchant wholesalers
                                     3,461
Durable Goods Wholesalers and Dealers
423410
Photographic equipment and supplies merchant wholesalers
                                      811

423740
Refrigeration equipment and supplies merchant wholesalers
                                      727

423990
Other miscellaneous durable goods merchant wholesalers
                                     9,338

441110
New Car Dealers
                                    19,183

441120
Used Car Dealers
                                    27,127

441210
Recreational Vehicle Dealers  
                                     2,777

441222
Boat Dealers
                                     4,973

441228
Motorcycle, ATV, and All Other Motor Vehicle Dealers
                                     6,012

441310
Automotive Parts and Accessories Stores
                                    23,056

441320
Tire Dealers
                                    11,766
Educational Services
611110
Elementary and second schools
                                     1,281

611210
Junior Colleges
                                      27

611310
College, universities, and professional schools
                                      111
Hospitals
622110
General medical and surgical hospitals
                                      92
Research and Development
54171
Research and development in the Physical, Engineering and Life Sciences
                                      824
Office Buildings
511110
Newspaper Publishers
                                      307

511120
Periodical Publishers
                                      321

511130
Book Publishers
                                      149

511140
Directory and Mailing List Publishers
                                      48

511191
Greeting Card Publishers
                                       6

511199
All Other Publishers
                                      45

511210
Software Publishers
                                      380

512110
Motion Picture and Video Production
                                      834

512120
Motion Picture and Video Distribution
                                      26

512131
Motion Picture Theaters (except Drive-Ins)
                                      135

512132
Drive-In Motion Picture Theaters
                                      17

512191
Teleproduction and Other Postproduction Services
                                      132

512199
Other Motion Picture and Video Industries
                                      21

512210
Record Production
                                      25

512220
Integrated Record Production/Distribution
                                      22

512230
Music Publishers
                                      47

512240
Sound Recording Studios
                                      113

512290
Other Sound Recording Industries
                                      26

515111
Radio Networks
                                      38

515112
Radio Stations
                                      212

515120
Television Broadcasting
                                      61

515210
Cable and Other Subscription Programming
                                      23

517110
Wired Telecommunications Carriers
                                      471

517210
Wireless Telecommunications Carriers (except Satellite)
                                      144

517410
Satellite Telecommunications
                                      35

51791
Other Telecommunications
                                      256

518210
Data Processing, Hosting, and Related Services
                                      485

519120
Libraries and Archives
                                      143

522220
Sales Financing
                                      153

522291
Consumer Lending
                                      325

522292
Real Estate Credit
                                      691

522293
International Trade Financing
                                      16

522294
Secondary Market Financing
                                      13

522298
All Other Nondepository Credit Intermediation
                                      345

522310
Mortgage and Nonmortgage Loan Brokers
                                     1,342

522320
Financial Transactions Processing, Reserve, and Clearinghouse Activities
                                      146

522390
Other Activities Related to Credit Intermediation
                                      362

524113
Direct Life Insurance Carriers
                                      58

524114
Direct Health and Medical Insurance Carriers
                                      47

524126
Direct Property and Casualty Insurance Carriers
                                      242

524127
Direct Title Insurance Carriers
                                      155

524128
Other Direct Insurance (except Life, Health and Medical) Carriers
                                      29

524130
Reinsurance Carriers
                                      13

524210
Insurance Agencies and Brokerages
                                     7,967

524291
Claims Adjusting
                                      238

524292
Third Party Administration of Insurance and Pension Funds
                                      216

524298
All Other Insurance Related Activities
                                      148

531110
Lessors of Residential Buildings and Dwellings
                                     3,295

531120
Lessors of Nonresidential Buildings (except Miniwarehouses)
                                     1,820

531130
Lessors of Miniwarehouses and Self Storage Units
                                      628

531190
Lessors of Other Real Estate Property
                                      571

531210
Offices of Real Estate Agents and Brokers
                                     6,564

531311
Residential Property Managers
                                     1,814

531312
Nonresidential Property Managers
                                      874

531320
Offices of Real Estate Appraisers
                                     1,059

531390
Other Activities Related to Real Estate
                                     1,055

541110
Offices of Lawyers
                                    11,062

541191
Title Abstract and Settlement Offices
                                      655

541199
All Other Legal Services
                                      182

541211
Offices of Certified Public Accountants
                                     3,560

541213
Tax Preparation Services
                                     1,019

541214
Payroll Services
                                      252

541219
Other Accounting Services
                                     2,295

541310
Architectural Services
                                     1,546

541320
Landscape Architectural Services
                                      420

541330
Engineering Services
                                     2,968

541340
Drafting Services
                                      202

541350
Building Inspection Services
                                      377

541360
Geophysical Surveying and Mapping Services
                                      64

541370
Surveying and Mapping (except Geophysical) Services
                                      611

541380
Testing Laboratories
                                      317

541410
Interior Design Services
                                      893

541420
Industrial Design Services
                                      121

541430
Graphic Design Services
                                     1,095

541490
Other Specialized Design Services
                                      136

541511
Custom Computer Programming Services
                                     3,204

541512
Computer Systems Design Services
                                     2,750

541513
Computer Facilities Management Services
                                      204

541519
Other Computer Related Services
                                      662

541611
Administrative Management and General Management Consulting Services
                                     3,821

541612
Human Resources Consulting Services
                                      882

541613
Marketing Consulting Services
                                     1,628

541614
Process, Physical Distribution and Logistics Consulting Services
                                      405

541618
Other Management Consulting Services
                                      434

541620
Environmental Consulting Services
                                      537

541690
Other Scientific and Technical Consulting Services  
                                     1,615

54171
Research and Development in the Physical, Engineering, and Life Sciences
                                      775

541720
Research and Development in the Social Sciences and Humanities
                                      149

541810
Advertising Agencies
                                      852

541820
Public Relations Agencies
                                      473

541830
Media Buying Agencies
                                      52

541840
Media Representatives
                                      125

541850
Outdoor Advertising
                                      136

541860
Direct Mail Advertising
                                      188

541870
Advertising Material Distribution Services
                                      48

541890
Other Services Related to Advertising
                                      513

541910
Marketing Research and Public Opinion Polling
                                      297

541921
Photography Studios, Portrait
                                      635

541922
Commercial Photography
                                      266

541930
Translation and Interpretation Services
                                      125

541940
Veterinary Services
                                     1,747

541990
All Other Professional, Scientific and Technical Services
                                     1,166

551111
Offices of Bank Holding Companies
                                      38

551112
Offices of Other Holding Companies
                                      328

561110
Office Administrative Services
                                     1,638

561210
Facilities Support Services
                                      100

56131
Employment Placement Agencies
                                      511

561320
Temporary Help Services
                                      800

561330
Professional Employer Organizations
                                      278

561410
Document Preparation Services
                                      319

561421
Telephone Answering Services
                                      102

561422
Telemarketing Bureaus and Other contact Centers
                                      138

561431
Private Mail Centers
                                      356

561439
Other Business Service Centers (including Copy Shops)
                                      198

561440
Collection Agencies
                                      279

561450
Credit Bureaus
                                      40

561491
Repossession Services
                                      58

561492
Court Reporting and Stenotype Services
                                      215

561499
All Other Business Support Services
                                      212

561510
Travel Agencies
                                      781

561520
Tour Operators
                                      194

561591
Convention and Visitors Bureaus
                                      66

561599
All Other Travel Arrangement and Reservation Services
                                      107

561611
Investigation Services
                                      312

561612
Security Guards and Patrol Services
                                      367

561613
Armored Car Services
                                       9

561621
Security Systems Services (except Locksmiths)
                                      353

561622
Locksmiths
                                      250

561710
Exterminating and Pest Control Services
                                      700

561720
Janitorial Services
                                     3,307

561730
Landscaping Services
                                     5,994

561740
Carpet and Upholstery Cleaning Services
                                      572

561790
Other Services to Buildings and Dwellings  
                                      781

561910
Packaging and Labeling Services
                                      117

561920
Convention and Trade Show Organizers
                                      262

561990
All Other Support Services
                                      829

712110
Museums
                                      309

712130
Zoos and Botanical Gardens
                                      37

721110
Hotels (except Casino Hotels) and Motels
                                     2,598

721120
Casino Hotels
                                       8

813110
Religious Organizations
                                    11,736

813211
Grantmaking Foundations
                                      552

813212
Voluntary Health Organizations
                                      167

813219
Other Grantmaking and Giving Services
                                      192

813311
Human Rights Organizations
                                      155

813312
Environment, Conservation and Wildlife Organizations
                                      322

813319
Other Social Advocacy Organizations
                                      372

813410
Civic and Social Organizations
                                     1,796

813910
Business Associations
                                     1,054

813920
Professional Organizations
                                      405

813930
Labor Unions and Similar Labor Organizations 
                                      969

813940
Political Organizations
                                      150

813990
Other Similar Organizations (except Business, Professional, Labor, and Political Organizations) 
                                     1,389

92
Public Administration
                                       -
Arts, Entertainment, and Recreation
711310
Promoters of performing arts, sports, and similar events with facilities
                                      205

713940
Fitness and recreational sports centers
                                     2,046
Reclaimers
325120
Industrial Gas Manufacturing
                                       1

423930
Recyclable Material Merchant Wholesalers
                                      26

562920
Materials Recovery Facilities
                                       3

562212
Solid Waste Landfill
                                       2

424690
Other Chemical and Allied Products Merchant Wholesalers
                                      22
Disposal Establishments
562920
Materials Recovery Facilities
                                      32

562212
Solid Waste Landfill
                                      24

423990
Other Miscellaneous Durable Goods Merchant Wholesalers
                                      289
Service Establishments
811310
Commercial Industrial Machinery and Equipment (not Automotive and Electronic) Repair and Maintenance
                                     1,800

811412
Appliance Repair and Maintenance
                                      376
Refrigerant Wholesalers
325120
Industrial Gas Manufacturing
                                      52

424690
Other Chemical and Allied Products Merchant Wholesalers
                                     3,700

42
Wholesale Trade
                                    189,364
Service Technicians
238220
Plumbing, heating, and air-conditioning contractors
                                    295,592
Small Can Manufacturers
441310
Automotive Parts and Accessories Stores
                                       2

325120
Industrial Gas Manufacturing
                                       3
 Total
                                    950,486

Sensitivity Analysis for SBREFA
Aggregate Economic Analysis with 3% Discount Rate


The following table shows the impacts to small businesses associated with a 3% discount rate.

Table 47. Aggregated Economic Impacts on Small Businesses with 3% Discount Rate
Economic Impact 
Industry
Number of Small Entities Subject to the Rule and Experiencing Given Economic Impact
Percent of All Small Entities Subject to the Rule That are Experiencing Given Economic Impact
Less than 1% for all affected small entities a
Agriculture and Crop Support Services 
                                                                          3,780


Grocery & Specialty Food Stores
                                                                         64,170


Warehouse Clubs & Supercenters 
                                                                             10


Utilities
                                                                            560


Food Manufacturing
                                                                         37,840


Beverage & Ice Manufacturing
                                                                          4,530


Non-food Manufacturing
                                                                         57,810


General Merchandise Stores
                                                                          <5


Refrigerated Warehousing and Storage
                                                                            560


Other Warehousing, Storage, and Transportation
                                                                          3,670


Non-durable Goods Wholesalers and Dealers
                                                                         43,140


Durable Goods Wholesalers and Dealers
                                                                        105,750


Educational Services
                                                                          1,420


Hospitals
                                                                             90


Research and Development
                                                                            820


Office Buildings
                                                                        128,510


Arts, Entertainment, and Recreation
                                                                          2,250


Reclaimers
                                                                             50


Refrigerant Wholesalers
                                                                        193,120


Service Technicians
                                                                        295,590


Small Can Manufacturers
                                                                          <5


Total
                                                                        943,680
                                                                            99%
1% or more for one or more affected small entities
Agriculture and Crop Support Services 
                                                                          <5


Grocery & Specialty Food Stores
                                                                             40


Warehouse Clubs & Supercenters
                                                                             20


Food Manufacturing
                                                                             10


Non-food Manufacturing
                                                                          <5


Other Warehousing, Stor, Trans.
                                                                          <5


Durable Goods Wholesalers
                                                                             20


Office Buildings
                                                                             20


Small Can Manufacturers
                                                                          <5


Total
                                                                            120
                                                                          0.01%
Greater than 3% for one or more affected small entities b
Grocery & Specialty Food Stores
                                                                             10


Warehouse Clubs & Supercenters
                                                                             20


Non-food Manufacturing
                                                                          <5


Other Warehousing, Stor, Trans.
                                                                          <5


Durable Goods Wholesalers
                                                                             10


Office Buildings
                                                                             20


Total
                                                                             60
                                                                          0.01%
Totals may not sum due to independent rounding.
[a] Represents small entities affected with an economic impact equal to or lesser than 1% but greater than 0%.  
b This category aggregates the number of small entities that would be expected to experience an impact of 1% to 3% with the number of small entities that would be expected to experience an impact of 3% or greater.


NAICS Codes
NAICS Classification for Leak Repair Requirements

Table 48: NAICS Codes Included in the Leak Repair Regulation Analysis
                              Sector Description
                                NAICS Category
                                  NAICS Code
                             NAICS Code Definition




Agriculture and Crop Support Activities
Support Activities for Agriculture and Forestry (115)
115112
Soil Preparation, Planting, and Cultivating


115113
Crop Harvesting, Primarily by Machine


115114
Postharvest Crop Activities (except Cotton Ginning)
Arts, Entertainment, and Recreation
Arts, Entertainment, and Recreation (71)
711310
Promoters of performing arts, sports, and similar events with facilities


713940
Fitness and recreational sports centers
Beverage and Ice Manufacturing
Beverage Manufacturing (312)
312111
Soft drink manufacturing


312112
Bottled water manufacturing


312113
Ice manufacturing


312120
Breweries


312130
Wineries
Durable Goods Wholesalers and Dealers
Merchant Wholesalers - Durable Goods (423)
423410
Photographic equipment and supplies merchant wholesalers


423740
Refrigeration equipment and supplies merchant wholesalers


423990
Other miscellaneous durable goods merchant wholesalers

Motor Vehicle and Parts Dealers (441)
441110
New Car Dealers


441120
Used Car Dealers


441210
Recreational Vehicle Dealers  


441222
Boat Dealers


441228
Motorcycle, ATV, and All Other Motor Vehicle Dealers


441310
Automotive Parts and Accessories Stores


                                    441320
Tire Dealers
Educational Services
Educational Services (611)
                                    611110
Elementary and second schools


                                    611210
Junior Colleges


                                    611310
College, universities, and professional schools
Food Manufacturing
Food Manufacturing (311)
                                    311111
Dog and Cat Food Manufacturing


                                    311119
Other Animal Food Manufacturing


                                    311211
Flour Milling


                                    311212
Rice Milling


                                    311213
Malt Manufacturing


                                    311221
Wet Corn Milling


                                    311224
Soybean and Other Oilseed Processing


                                    311225
Fats and Oils Refining and Blending


                                    311230
Breakfast Cereal Manufacturing


                                    311313
Beet Sugar Manufacturing


                                    311314
Cane Sugar Manufacturing


                                    311340
Nonchocolate Confectionery Manufacturing


                                    311351
Chocolate and Confectionery Manufacturing from Cacao Beans


                                    311352
Confectionery Manufacturing from Purchased Chocolate


                                    311411
Frozen Fruit, Juice and Vegetable Manufacturing


                                    311412
Frozen Specialty Food Manufacturing


                                    311421
Fruit and Vegetable Canning3


                                    311422
Specialty Canning


                                    311423
Dried and Dehydrated Food Manufacturing


                                    311511
Fluid Milk Manufacturing


                                    311512
Creamery Butter Manufacturing


                                    311513
Cheese Manufacturing


                                    311514
Dry, Condensed, and Evaporated Dairy Product Manufacturing


                                    311520
Ice Cream and Frozen Dessert Manufacturing


                                    311611
Animal (except Poultry) Slaughtering


                                    311612
Meat Processed from Carcasses


                                    311613
Rendering and Meat Byproduct Processing


                                    311615
Poultry Processing


                                    311710
Seafood Product Preparation and Packaging


                                    311811
Retail Bakeries


                                    311812
Commercial Bakeries


                                    311813
Frozen Cakes, Pies, and Other Pastries Manufacturing


                                    311821
Cookie and Cracker Manufacturing


                                    311824
Dry Pasta, Dough, and Flour Mixes Manufacturing from Purchased Flour


                                    311830
Tortilla Manufacturing


                                    311911
Roasted Nuts and Peanut Butter Manufacturing


                                    311919
Other Snack Food Manufacturing


                                    311920
Coffee and Tea Manufacturing


                                    311930
Flavoring Syrup and Concentrate Manufacturing


                                    311941
Mayonnaise, Dressing and Other Prepared Sauce Manufacturing


                                    311942
Spice and Extract Manufacturing


                                    311991
Perishable Prepared Food Manufacturing


                                    311999
All Other Miscellaneous Food Manufacturing
General Merchandise Stores
General Merchandise Stores (452)
                                    452112
Discount department stores


                                    452990
All other general merchandise stores

All Other Miscellaneous Store Retailers (except Tobacco Stores) (453998)
                                    453998
All other miscellaneous store retailers (except tobacco stores)
Grocery and Specialty Food Stores
Grocery Stores (4451)
                                    445110
Supermarkets and other grocery (except convenience) stores

Specialty Food Stores (4452)
                                    445210
Meat markets


                                    445230
Fruit and vegetable markets


                                    445299
All other specialty food stores

Food Service Contractors (72231)
                                    722310
Food service contractors
Hospitals
Hospitals (622)
                                    622110
General medical and surgical hospitals
Non-durable Goods Wholesalers and Dealers
Merchant Wholesalers  -  Non-durable Goods (424)
                                    424210
Drugs and druggists' sundries merchant wholesalers


                                    424410
General line grocery merchant wholesalers


                                    424420
Packaged frozen food merchant wholesalers


                                    424430
Dairy product (except dried or canned) merchant wholesalers


                                    424440
Poultry and poultry product merchant wholesalers


                                    424460
Fish and seafood merchant wholesalers


                                    424470
Meat and meat product merchant wholesalers


                                    424480
Fresh fruit and vegetable merchant wholesalers


                                    424490
Other grocery and related products merchant wholesalers


                                    424590
Other farm product raw material merchant wholesalers


                                    424710
Petroleum bulk stations and terminals


                                    424810
Beer and ale merchant wholesalers


                                    424930
Flower, nursery stock, and florists' supplies merchant wholesalers
Non-food Manufacturing
Paper Manufacturing (322)
                                    322121
Paper (except newsprint) mills


                                    322211
Corrugated and solid fiber box manufacturing


                                    322220
Paper Bag and Coated and Treated Paper Manufacturing

Printing and Related Support Activities (323)
                                    323111
Commercial Printing (except Screen and Books)

Petroleum Manufacturing (324)
                                    324110
Petroleum refineries

Chemical Manufacturing (325)
                                    325120
Industrial gas manufacturing


                                    325180
Other Basic Inorganic Chemical Manufacturing


                                    325211
Plastics material and resin manufacturing


                                    325320
Pesticide and other agricultural chemical manufacturing


                                    325620
Toilet preparation manufacturing


                                    325991
Custom compounding of purchased resins


                                    325998
All other miscellaneous chemical product and preparation manufacturing

Pharmaceutical Manufacturing (3254)
                                    325412
Pharmaceutical preparation manufacturing


                                    325413
In-vitro diagnostic substance manufacturing


                                    325414
Biological product (except diagnostic) manufacturing

Plastics and Rubber Manufacturing (326)
                                    326122
Plastics pipe and pipe fitting manufacturing


                                    326140
Polystyrene foam product manufacturing


                                    326160
Plastics bottle manufacturing


                                    326199
All other plastics product manufacturing


                                    326211
Tire manufacturing (except retreading)

Metals Manufacturing (332)
                                    332431
Metal can manufacturing


                                    332812
Metal coating, engraving (except jewelry and silverware), and allied services to manufacturers


                                    332813
Electroplating, plating, polishing, anodizing, and coloring

Machinery Manufacturing (333)
                                    333241
Food Product Machinery Manufacturing


                                    333242
Semiconductor Machinery Manufacturing


                                    333415
Air-conditioning and warm air heating equipment and commercial and industrial refrigeration equipment manufacturing


                                    333611
Turbine and turbine generator set units manufacturing

Computer and Electronic Product Manufacturing (334)
                                    334112
Computer storage device manufacturing


                                    334419
Other Electronic Component Manufacturing


                                    334413
Semiconductor and related device manufacturing


                                    334419
Other electric component manufacturing


                                    334510
Electromedical and electrotherapeutic apparatus manufacturing


                                    334515
Instrument manufacturing for measuring and testing electricity and electrical systems


                                    334516
Analytical laboratory instrument manufacturing


                                    334613
Blank magnetic and optical recording media manufacturing

Transportation Equipment Manufacturing (336)
                                    336411
Aircraft manufacturing


                                    336415
Guided missile and space vehicle propulsion unit and propulsion unit parts manufacturing

Medical Equipment and Supplies Manufacturing (3391)
                                    339112
Surgical and medical instrument manufacturing

Miscellaneous Manufacturing (339999)
                                    339999
All other miscellaneous manufacturing
Office Buildings
Publishing Industries (except Internet) (511)
                                    511110
Newspaper Publishers


                                    511120
Periodical Publishers


                                    511130
Book Publishers


                                    511140
Directory and Mailing List Publishers


                                    511191
Greeting Card Publishers


                                    511199
All Other Publishers


                                    511210
Software Publishers

Motion Picture and Video Industries (512)
                                    512110
Motion Picture and Video Production


                                    512120
Motion Picture and Video Distribution


                                    512131
Motion Picture Theaters (except Drive-Ins)


                                    512132
Drive-In Motion Picture Theaters


                                    512191
Teleproduction and Other Postproduction Services


                                    512199
Other Motion Picture and Video Industries


                                    512210
Record Production


                                    512220
Integrated Record Production/Distribution


                                    512230
Music Publishers


                                    512240
Sound Recording Studios


                                    512290
Other Sound Recording Industries

Broadcasting (515)
                                    515111
Radio Networks


                                    515112
Radio Stations


                                    515120
Television Broadcasting


                                    515210
Cable and Other Subscription Programming

Telecommunications (517)
                                    517110
Wired Telecommunications Carriers


                                    517210
Wireless Telecommunications Carriers (except Satellite)


                                    517410
Satellite Telecommunications


                                     51791
Other Telecommunications

Data Processing, Hosting, and Related Services (518)
                                    518210
Data Processing, Hosting, and Related Services

Libraries and Archives (519)
                                    519120
Libraries and Archives

Credit Intermediation and Related Activities (522)
                                    522220
Sales Financing


                                    522291
Consumer Lending


                                    522292
Real Estate Credit


                                    522293
International Trade Financing


                                    522294
Secondary Market Financing


                                    522298
All Other Nondepository Credit Intermediation


                                    522310
Mortgage and Nonmortgage Loan Brokers


                                    522320
Financial Transactions Processing, Reserve, and Clearinghouse Activities


                                    522390
Other Activities Related to Credit Intermediation

Insurance Carriers (524)
                                    524113
Direct Life Insurance Carriers


                                    524114
Direct Health and Medical Insurance Carriers


                                    524126
Direct Property and Casualty Insurance Carriers


                                    524127
Direct Title Insurance Carriers


                                    524128
Other Direct Insurance (except Life, Health and Medical) Carriers


                                    524130
Reinsurance Carriers


                                    524210
Insurance Agencies and Brokerages


                                    524291
Claims Adjusting


                                    524292
Third Party Administration of Insurance and Pension Funds


                                    524298
All Other Insurance Related Activities

Real Estate (531)
                                    531110
Lessors of Residential Buildings and Dwellings


                                    531120
Lessors of Nonresidential Buildings (except Miniwarehouses)


                                    531130
Lessors of Miniwarehouses and Self Storage Units


                                    531190
Lessors of Other Real Estate Property


                                    531210
Offices of Real Estate Agents and Brokers


                                    531311
Residential Property Managers


                                    531312
Nonresidential Property Managers


                                    531320
Offices of Real Estate Appraisers


                                    531390
Other Activities Related to Real Estate

Professional, Scientific, and Technical Services (541)
                                    541110
Offices of Lawyers


                                    541191
Title Abstract and Settlement Offices


                                    541199
All Other Legal Services


                                    541211
Offices of Certified Public Accountants


                                    541213
Tax Preparation Services


                                    541214
Payroll Services


                                    541219
Other Accounting Services


                                    541310
Architectural Services


                                    541320
Landscape Architectural Services


                                    541330
Engineering Services


                                    541340
Drafting Services


                                    541350
Building Inspection Services


                                    541360
Geophysical Surveying and Mapping Services


                                    541370
Surveying and Mapping (except Geophysical) Services


                                    541380
Testing Laboratories


                                    541410
Interior Design Services


                                    541420
Industrial Design Services


                                    541430
Graphic Design Services


                                    541490
Other Specialized Design Services


                                    541511
Custom Computer Programming Services


                                    541512
Computer Systems Design Services


                                    541513
Computer Facilities Management Services


                                    541519
Other Computer Related Services


                                    541611
Administrative Management and General Management Consulting Services


                                    541612
Human Resources Consulting Services


                                    541613
Marketing Consulting Services


                                    541614
Process, Physical Distribution and Logistics Consulting Services


                                    541618
Other Management Consulting Services


                                    541620
Environmental Consulting Services


                                    541690
Other Scientific and Technical Consulting Services  


                                     54171
Research and Development in the Physical, Engineering, and Life Sciences


                                    541720
Research and Development in the Social Sciences and Humanities


                                    541810
Advertising Agencies


                                    541820
Public Relations Agencies


                                    541830
Media Buying Agencies


                                    541840
Media Representatives


                                    541850
Outdoor Advertising


                                    541860
Direct Mail Advertising


                                    541870
Advertising Material Distribution Services


                                    541890
Other Services Related to Advertising


                                    541910
Marketing Research and Public Opinion Polling


                                    541921
Photography Studios, Portrait


                                    541922
Commercial Photography


                                    541930
Translation and Interpretation Services


                                    541940
Veterinary Services


                                    541990
All Other Professional, Scientific and Technical Services

Management of Companies and Enterprises (551)
                                    551111
Offices of Bank Holding Companies


                                    551112
Offices of Other Holding Companies

Administrative and Support Services (561)
                                    561110
Office Administrative Services


                                    561210
Facilities Support Services


                                     56131
Employment Placement Agencies


                                    561320
Temporary Help Services


                                    561330
Professional Employer Organizations


                                    561410
Document Preparation Services


                                    561421
Telephone Answering Services


                                    561422
Telemarketing Bureaus and Other contact Centers


                                    561431
Private Mail Centers


                                    561439
Other Business Service Centers (including Copy Shops)


                                    561440
Collection Agencies


                                    561450
Credit Bureaus


                                    561491
Repossession Services


                                    561492
Court Reporting and Stenotype Services


                                    561499
All Other Business Support Services


                                    561510
Travel Agencies


                                    561520
Tour Operators


                                    561591
Convention and Visitors Bureaus


                                    561599
All Other Travel Arrangement and Reservation Services


                                    561611
Investigation Services


                                    561612
Security Guards and Patrol Services


                                    561613
Armored Car Services


                                    561621
Security Systems Services (except Locksmiths)


                                    561622
Locksmiths


                                    561710
Exterminating and Pest Control Services


                                    561720
Janitorial Services


                                    561730
Landscaping Services


                                    561740
Carpet and Upholstery Cleaning Services


                                    561790
Other Services to Buildings and Dwellings  


                                    561910
Packaging and Labeling Services


                                    561920
Convention and Trade Show Organizers


                                    561990
All Other Support Services

Museums, Historical Sites and Similar Institutions (712)
                                    712110
Museums


                                    712130
Zoos and Botanical Gardens

Accommodation (721)
                                    721110
Hotels (except Casino Hotels) and Motels


                                    721120
Casino Hotels

Religious, Grantmaking, Civic, Professional, and Similar Organizations (813)
                                    813110
Religious Organizations


                                    813211
Grantmaking Foundations


                                    813212
Voluntary Health Organizations


                                    813219
Other Grantmaking and Giving Services


                                    813311
Human Rights Organizations


                                    813312
Environment, Conservation and Wildlife Organizations


                                    813319
Other Social Advocacy Organizations


                                    813410
Civic and Social Organizations


                                    813910
Business Associations


                                    813920
Professional Organizations


                                    813930
Labor Unions and Similar Labor Organizations 


                                    813940
Political Organizations


                                    813990
Other Similar Organizations (except Business, Professional, Labor, and Political Organizations) 
Other Warehousing, Storage, and Transportation
Transportation and Warehousing (48)
                                    484220
Specialized freight (except used goods) trucking, local


                                    488119
Other airport operations


                                    488510
Freight transportation arrangement


                                    488991
Packing and crating

Warehousing and Storage (4931)
                                    493110
General warehousing and storage


                                    493130
Farm product warehousing and storage


                                    493190
Other warehousing and storage
Refrigerated Warehousing and Storage
Refrigerated Warehousing and Storage (49312)
                                    493120
Refrigerated warehousing and storage
Research and Development
Research and Development (5417)
                                     54171
Research and development in the Physical, Engineering and Life Sciences
Utilities
Utilities (221)
                                    221111
Hydroelectric Power Generation


                                    221112
Fossil fuel electric power generation


                                    221113
Nuclear Electric Power Generation


                                    221114
Solar Electric Power Generation


                                    221115
Wind Electric Power Generation


                                    221116
Geothermal Electric Power Generation


                                    221117
Biomass Electric Power Generation


                                    221118
Other Electric Power Generation


                                    221121
Electric Bulk Power Transmission and Control


                                    221122
Electric power distribution


                                    221210
Natural gas distribution


                                    221310
Water supply and irrigation systems


                                    221320
Sewage treatment facilities


                                    221330
Steam and air-conditioning supply

Oil and gas extraction (211)
                                    211111
Crude petroleum and natural gas extraction
Warehouse Clubs and Supercenters
Warehouse Clubs and Supercenters (45291)
                                    452910
Warehouse clubs and supercenters
Source: U.S. Census Data. 2012.

NAICS Classification for Small Can Requirements
Table 49: NAICS Codes Included in the Small-can Analysis
Industry
NAICS Code
Definition
Small Can Manufacturers
                                    441310
Automotive Parts and Accessories Stores

                                    325120
Industrial Gas Manufacturing
Source: U.S. Census Data. 2012.
NAICS Classification for Recordkeeping and Reporting Requirements
Table 50: NAICS Codes Included in the Recordkeeping and Reporting Requirements Analysis
Industry
NAICS Code
Definition
Reclaimers
                                    325120
Industrial Gas Manufacturing

                                    423930
Recyclable Material Merchant Wholesalers

                                    562920
Materials Recovery Facilities

                                    562212
Solid Waste Landfill

                                    424690
Other Chemical and Allied Products Merchant Wholesalers
Disposal Establishments
                                    562920
Materials Recovery Facilities

                                    562212
Solid Waste Landfill

                                    423990
Other Miscellaneous Durable Goods Merchant Wholesalers
Service Establishments
                                    811310
Commercial Industrial Machinery and Equipment (not Automotive and Electronic) Repair and Maintenance

                                    811412
Appliance Repair and Maintenance
Refrigerant Wholesalers
                                    325120
Industrial Gas Manufacturing

                                    424690
Other Chemical and Allied Products Merchant Wholesalers

                                      42
Wholesale Trade
Small Can Manufacturers
                                    441310
Automotive Parts and Accessories Stores

                                    325120
Industrial Gas Manufacturing
Service Technicians
                                    238220
Plumbing, heating, and air-conditioning contractors
Source: U.S. Census Data. 2012.

Costs Incurred by DIYers for a Sales Restriction 
To estimate the costs incurred by DIYers for a refrigerant sales restriction without an exemption for small cans, total annual sales of DIY small cans (14.1 million) were divided by the average number of cans used per servicing event (1.3). The result (10.8 million) is assumed to be equivalent to the number of annual DIY servicing events that would necessitate a DIYer to either become a certified technician under section 609 or take her or his vehicle to a professional service shop. Table 51 and Table 52 below show key assumptions and the estimated costs incurred by DIYers for each course of action. 
Table 51. Costs Incurred by DIYers to Take Vehicle to a Professional Service Shop
Action to Comply with Sales Restriction
Annual Sales of R-134a Small Cans to DIY Market[1] (millions)
Number of Annual Servicing Events[2]
(millions)
Cost of Professional Service Job[3]
Cost of R-134a Small Can[4]
Percent of DIYers Who Would Forgo AC[5]
Total Annual Cost to DIYers (million $)[6][,7]
Take vehicle to professional service shop
                                     14.1
                                     10.8
                                  $50 - $200
                                $7.49 - $19.99
                                      19%
                               $333.2 - $1,473.1
[1] Represents an average of the total R-134a cans sold in the United States in 2006 and 2007 (NPD 2008; CARB 2009b).
[2] Based on research commissioned by CARB, the average number of cans used per recharging event is 1.3 (Clodic et al. 2008; CARB 2009b).
[3] Based on a survey of professional shops, costs for a professional diagnosis and recharging range from $50 to $200 (Clodic et al. 2008).
[4] Based on various results from an online search.
[5] Based on research commissioned by CARB, 19% of DIYers would opt to forgo AC rather than take their vehicles to a professional service shop (Clodic et al. 2008; CARB 2009b).
[6] Total annual costs exclude DIYers who would opt to forgo AC.
[7] Total annual costs exclude the cost to purchase a can of R-134a since the cost of the refrigerant is already factored into the cost for a professional service job.

Table 52. Costs Incurred by DIYers to Become a 609 Certified Technician
Action to Comply with Sales Restriction
Annual Sales of R-134a Small Cans to DIY Market[1] (millions)
Number of DIY Vehicles[2][,3]
(millions)
Number of DIY Operators[4] (millions)
Cost of 609 Technician Certification Training Manual & Exam[5]
Percent of DIYers Who Would Forgo AC[6]
Total Annual Cost for DIYers to Become Certified Technicians (million $)[7,8]
Become a certified technician under section 609
                                     14.1
                                     10.8
                                      7.1
                                      $20
                                      19%
                                    $114.5
1 Represents an average of the total R-134a cans sold in the United States in 2006 and 2007 (NPD 2008; CARB 2009b).
[2] Based on research commissioned by CARB, the average number of cans used per recharging event is 1.3 (Clodic et al. 2008; CARB 2009b).
[3] Assumed a DIY service rate of once per year per vehicle (CARB 2009b).
[4] Assumed some DIYers own and service more than one vehicle per year. According to data from the Oak Ridge National Laboratory on household vehicle ownership, approximately 38% of households own one vehicle, 41% of households own two vehicles, and 21% of households own three or more vehicles (ORNL 2014).
[5] Based on various results from an online search.
[6] Assumed 19% of DIYers would opt to forgo AC rather than become a certified technician (Clodic et al. 2008; CARB 2009b).
[7] Total annual costs exclude DIYers who would opt to forgo AC.
[8] Total costs do not include the value of leisure time a DIYer would spend to become a 609 certified technician. 





