SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Plastic Parts and Products Surface Coating (40 CFR part 63,
subpart PPPP)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

	NESHAP for Plastic Parts and Products Surface Coating (40 CFR part 63,
subpart PPPP).

1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for Plastic Parts and Products Surface Coating published at 40 CFR part
63, subpart PPPP were proposed on December 4, 2002, and promulgated on
April 19, 2004.  These regulations apply to existing facilities and new
facilities that perform surface coating of plastic parts and products
where the total Hazardous Air Pollutants (HAPs) emitted are greater than
or equal to 10 tons per year of any one HAP, or where the total HAPs
emitted are greater than or equal to 25 tons per year of any combination
of HAPs, that use at least 100 gallons of HAP-containing coatings
annually.  New facilities include those that commenced construction or
reconstruction after the date of the proposal.  This information is
being collected to ensure compliance with 40 CFR part 63, subpart PPPP.

	In general, all NESHAP standards require initial notifications,
performance tests, and periodic reports by the owners/operators of the
affected facilities.  They are also required to maintain records of the
occurrence and duration of any startup, shutdown, or malfunction in the
operation of an affected facility, or any period during which the
monitoring system is inoperative.  These notifications, reports, and
records are essential in determining compliance, and are required of all
affected facilities subject to NESHAP.

Any owner or operator subject to the provisions of this part shall
maintain a file of these measurements, and retain the file for at least
five years following the date of such measurements, maintenance reports,
and records.  All reports are sent to the delegated state or local
authority.  In the event that there is no such delegated authority, the
reports are sent directly to the United States Environmental Protection
Agency (EPA) regional office.

Based on our consultations with industry representatives, there is an
average of one affected facility at each plant site and each plant site
has only one respondent (i.e., the owner/operator of the plant site).

Approximately 827 sources are currently subject to the standard, and it
is estimated that one additional source per year will become subject to
the regulation in the next three years.

The form OMB 83-I for the previous ICR incorrectly indicated that the
affected public included federal government, and state, local, or tribal
government facilities.  The affected public includes only private
business or other for-profit facilities.  This has been corrected in
this ICR.

	The active (previous) ICR had the following Terms of Clearance (TOC):
“Under the terms of the Government Paperwork Elimination Act, EPA
should review this collection before resubmitting it for approval and
ensure that, to the extent practicable, the collection has been revised
to include electronic means of reporting.”  EPA has addressed each
item of concern in the TOC by reviewing the collection to determine
whether it may be revised to include electronic means of reporting. 
Based upon EPA’s experience with similar collections, EPA estimates
that electronic reporting would be approximately 10 percent of the
collection.  The Paperwork Reduction Act Submission Worksheet, Part II:
Information Collection Detail, Item 10, has been revised to reflect this
estimate.

2(a)  Need/Authority for the Collection

The EPA is charged under section 112 of the Clean Air Act, as amended,
to establish standards of performance for each category or subcategory
of major sources and area sources of hazardous air pollutants.  These
standards are applicable to new or existing sources of hazardous air
pollutants and shall require the maximum degree of emission reduction. 
In addition, section 114(a) states that the Administrator may require
any owner or operator subject to any requirement of this Act to: 

(A) Establish and maintain such records; (B) make such reports; (C)
install, use, and maintain such monitoring equipment, and use such audit
procedures, or methods; (D) sample such emissions (in accordance with
such procedures or methods, at such locations, at such intervals, during
such periods, and in such manner as the Administrator shall prescribe);
(E) keep records on control equipment parameters, production variables
or other indirect data when direct monitoring of emissions is
impractical; (F) submit compliance certifications in accordance with
Section 114(a)(3); and (G) provide such other information as the
Administrator may reasonably require.

In the Administrator's judgment, hazardous air pollutant (HAP) emissions
from plastic parts and products surface coating facilities cause or
contribute to air pollution that may reasonably be anticipated to
endanger public health or welfare.  Therefore, NESHAP for this source
category were promulgated at 40 CFR part 63, subpart PPPP.

2(b)  Practical Utility/Users of the Data

 

The recordkeeping and reporting requirements in the standard ensure
compliance with the applicable regulations that were promulgated in
accordance with the Clean Air Act.  The collected information is also
used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected
facility(s initial capability to comply with the emission standards. 
Continuous emission monitors are used to ensure compliance with the
standards at all times.

The notifications required in the standards are used to inform the
Agency or delegated authority when a source becomes subject to the
requirements of the regulations.  The reviewing authority may then
inspect the source to check if the pollution control devices are
properly installed and operated, that leaks are being detected and
repaired and that the standards are being met.  The performance test may
also be observed.

The required semiannual reports are used to determine periods of excess
emissions, identify problems at the facility, verify
operation/maintenance procedures and for compliance determinations.

3.  Nonduplication, Consultations, and Other Collection Criteria

The recordkeeping and reporting requested is required under 40 CFR part
63, subpart PPPP.

3(a)  Nonduplication

 If the subject standards have not been delegated, the information is
sent to the appropriate EPA regional office.  Otherwise, the information
is sent directly to the delegated state or local Agency.  If a state or
local agency has adopted their own similar standards to implement the
Federal standards, a copy of the report submitted to the state or local
agency can be sent to the Administrator in lieu of the report required
by the Federal standards.  Therefore, no duplication exists.

3(b)  Public Notice Required Prior to ICR Submission to Office of
Management and Budget (OMB)

An announcement of a public comment period for the renewal of this ICR
was published in the Federal Register (71 FR 35652) on June 21, 2006. 
No comments were received on the burden published in the Federal
Register.

3(c)  Consultations

Any comments received since the last ICR renewal including those
submitted in response to the first federal register notice announcing
the renewal of this ICR have been reviewed.  In this case, no comments
were received.  The Agency’s industry experts have been consulted. 
The Agency’s internal data sources and any projections of industry
growth over the next three years have been considered.

EPA solicited additional comments from Susan Darbro and Brian Perkins of
A-1 Fiberglass at 402-463-0180.  These contacts provided no additional
comments on the ICR. 

The Agency’s primary source of information as reported by industry is
the AFS (Air Facility Subsystem) which is operated and maintained by
EPA's Office of Compliance.  AFS is EPA(s database for the collection,
maintenance, and retrieval of all compliance data.  Approximately 827
respondents are currently subject to the regulation, and our
consultations with Agency industry experts regarding the growth rate for
the industry indicated that one additional respondent per year will
become subject to the regulation over the next three years.

Estimates of growth rate, and burden were developed with extensive
participation and consultation with plastic parts surface coating
industry representatives during recent rulemaking for 40 CFR part 63,
subpart PPPP.  EPA believes that these estimates remain valid, and are
the best information available.  EPA has revised the number of
facilities subject to the NESHAP, based upon an improved estimate from
EPA’s AFS database.

3(d)  Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of
assurance that facilities are continuing to meet the required standards.
 Requirements for information gathering and recordkeeping are useful
techniques to ensure that good operation and maintenance practices are
applied and emission limitations are met.  If the information required
by these standards was collected less frequently, the likelihood of
detecting poor operation and maintenance of control equipment and
noncompliance would decrease.

3(e)  General Guidelines

These reporting or recordkeeping requirements do not violate any of the
regulations established by OMB at 5 CFR part 1320, section 1320.5.

 	These standards require affected facilities to maintain all records,
including reports and notifications for at least five years.  This is
consistent with the General Provisions as applied to the standards.  EPA
believes that the five-year records retention requirement is consistent
with the part 70 permit program and the five-year statute of limitations
on which the permit program is based.  In addition, the retention of
records for five years would allow EPA to establish the compliance
history of a source and any pattern of compliance for purposes of
determining the appropriate level of enforcement action.  Historically,
EPA has found that the most flagrant violators frequently have
violations extending beyond the five years.  EPA would be prevented from
pursuing the worst violators due to the destruction or nonexistence of
records if records were retained for less than five years.

3(f)  Confidentiality

Any information submitted to the Agency for which a claim of
confidentiality is made will be safeguarded according to the Agency
policies set forth in title 40, chapter 1, part 2, subpart B -
Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902,
September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR
42251, September 20, 1978; 44 FR 17674, March 23, 1979).

3(g)  Sensitive Questions

The reporting or recordkeeping requirements do not contain sensitive
questions.

4.  The Respondents and the Information Requested 

4(a)  Respondents/SIC Codes

The respondents of the recordkeeping and reporting requirements are
plastic parts and products surface coating facilities.  The United
States Standard Industrial Classification (SIC) codes for the
respondents affected by the standards, which correspond to the North
American Industry Classification System (NAICS) codes, are listed below
for source category descriptions.

Standard	SIC Codes	NAICS Codes

40 CFR part 63, subpart PPPP	2522	337214

	3086	32614, 32615

	3089, 3999	326199

	3578, 3579	333313

	3663, 3679	33422

	3429, 3519, 3599, 3714, 3799	336399

	3799	336999

	2599, 3821, 3841	339111, 339112

	3949, 3069	33992

	3993	33995

	2499, 3634, 3999	339999



4(b)  Information Requested

(i)  Data Items

All data in this ICR that is recorded and/or reported is required by 40
CFR part 63, subpart PPPP.

A source must make the following reports:

Notifications

Initial notification	63.4510(b), 63.5(d), 63.9(b)

Notification of compliance status	63.4510(c), 63.9(h)

Notification of construction or reconstruction	63.4510(a), 63.5

Notification of actual startup	63.4510(a), 63.9(b)

Notification of performance test	63.4510(a), 63.7(b), 63.8(e), 63.9(e)



Notification Reports

Semiannual report	63.4520(a)

Excess emissions report	63.4520(a)(4-7)

Report of performance test	63.4720(b)

Startup, shutdown, malfunction report	63.4720(c)



	A source must keep the following records:

Recordkeeping

Five year retention of records	63.4531(b), 63.10(b)

Material formulation data	63.4530(b)

Records of HAP content calculations	63.4530(c)

Copies of notifications and reports	63.4530(a)

Records of names of materials used	63.4530(d)

HAP fractions in each material used	63.4530(e)

Coating solids fraction in each material used	63.4530(f)

Density of materials used	63.4530(b)

Documentation of waste material shipped offsite	63.4530(g)

Documentation of deviations	63.4530(h)

Start-up, shutdown, and malfunction plan/records	63.4530(i), 63.6(e)

Records of continuous compliance with operating limits	63.4530(i)

Documentation of capture system efficiency determination	63.4530(i)

Documentation of add-on control device destruction or removal efficiency
determination	63.4530(i)

Documentation of control device performance tests	63.4530(i), 63.10(b)

Determination of capture system and add-on control operating limits
63.4530(i)

Work practice plan/records	63.4530(i)



Electronic Reporting

Currently, sources are using monitoring equipment that provides
parameter data in an automated way, e.g., inlet and outlet
concentrations when determining percent efficiency.  Although personnel
at the source still need to evaluate the data, this type of monitoring
equipment has significantly reduced the burden associated with
monitoring and recordkeeping.  In addition, some regulatory agencies are
setting up electronic reporting systems to allow sources to report
electronically which is reducing the reporting burden.  However,
electronic reporting systems are still not widely used by the regulatory
agencies.  It is estimated that approximately 10 percent of the
respondents use electronic reporting.

(ii)  Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CMS for temperature, for gas
flow, or for pressure drop for oxidizer, carbon adsorber, condenser,
concentrator, or capture system.

Perform initial performance test, Reference Method 1, 1A, 2, 2A, 2C, 2D,
2F, 2G, 3, #A, 3B, 4, 24, 25, 25A, 204, 204A, 204B, 204C, 204D, 204E,
204F, 311, or ASTM Method D1475-98, D2697-86, D6093-97 test, and repeat
performance tests if necessary.

Write the notifications and reports listed above.

Enter required recordkeeping information detailed above.

Submit the required reports developing, acquiring, installing, and
utilizing technology and systems for the purpose of collecting,
validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the
purpose of processing and maintaining information.

Develop, acquire, install, and utilize technology and systems for the
purpose of disclosing and providing information.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.



5.  The Information Collected -- Agency Activities, Collection
Methodology, and Information Management

5(a)  Agency Activities

EPA conducts the following activities in connection with the
acquisition, analysis, storage, and distribution of the required
information.

Agency Activities

Observe initial performance tests and repeat performance tests if
necessary.

Review notifications and reports, including performance test reports,
excess emissions reports, startup, shutdown, malfunction plan, and
quality control plan for CMS required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Air Facility System (AFS).



5(b)  Collection Methodology and Management

Following notification of startup, the reviewing authority might inspect
the source to determine whether the pollution control devices are
properly installed and operated.  Performance test reports are used by
the Agency to discern a source(s initial capability to comply with the
emission standard.  Data and records maintained by the respondents are
tabulated and published for use in compliance and enforcement programs. 
The semiannual reports are used for problem identification, as a check
on source operation and maintenance, and for compliance determinations.

Information contained in the reports is entered into the AFS which is
operated and maintained by EPA's Office of Compliance.  AFS is EPA(s
database for the collection, maintenance, and retrieval of compliance
data for approximately 125,000 industrial and government-owned
facilities.  EPA uses the AFS for tracking air pollution compliance and
enforcement by local and state regulatory agencies, EPA regional offices
and EPA headquarters.  EPA and its delegated Authorities can edit,
store, retrieve and analyze the data.

 The records required by this regulation must be retained by the owner
or operator for five years.

5(c)  Small Entity Flexibility

	A majority of the respondents are large entities (i.e., large
businesses).  However, the impact on small entities (i.e., small
businesses) was taken into consideration during the development of the
regulation.  Due to technical considerations involving the process
operations and the types of control equipment employed, the
recordkeeping and reporting requirements are the same for both small and
large entities.  The Agency considers these requirements the minimum
needed to ensure compliance and, therefore, cannot reduce them further
for small entities.  To the extent that larger businesses can use
economies of scale to reduce their burden, the overall burden will be
reduced.

5(d)  Collection Schedule

	The specific frequency for each information collection activity within
this request is shown in Table 1:  Annual Respondent Burden and Cost,
NESHAP for Plastic Parts and Products Surface Coating (40 CFR Part 63,
Subpart PPPP).

6.  Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the
recordkeeping and reporting requirements applicable to the industry for
the subpart included in this ICR.  The individual burdens are expressed
under standardized headings believed to be consistent with the concept
of burden under the Paperwork Reduction Act.  Where appropriate,
specific tasks and major assumptions have been identified.  Responses to
this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a currently
valid OMB Control Number.

6(a)  Estimating Respondent Burden

The average annual burden to industry over the next three years from
these recordkeeping and reporting requirements is estimated to be
320,917 (Total Labor Hours from Table 1).  These hours are based on
Agency studies and background documents from the development of the
regulation, Agency knowledge and experience with the NESHAP program, the
previously approved ICR, and any comments received.

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial	$100.99 ($48.09 + 110%)

Technical	$87.97   ($41.89 + 110%)

Clerical	$43.81   ($20.86 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, December 2005, (Table 2. Civilian Workers, by
occupational and industry group.(  The rates are from column 1, (Total
compensation.(  The rates have been increased by 110% to account for the
benefit packages available to those employed by private industry.

(ii)  Estimating Capital and Operations and Maintenance Costs

This section covers the costs associated with all types of continuous
monitoring equipment [e.g., continuous emissions monitoring systems
(CEMS) and continuous parameter monitors].  The type of industry costs
associated with the information collection activity in the subject
standards are both labor costs which are addressed elsewhere in this ICR
and the costs associated with continuous monitoring.  The
capital/startup costs are one-time costs when a facility becomes subject
to the regulation.  The annual operation and maintenance costs are the
ongoing costs to maintain the monitors and other costs such as
photocopying and postage.

(iii)  Capital/Startup vs. Operating and Maintenance (O&M) Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs

(A)

Continuous Monitoring Device	(B)

Capital/Startup Cost for One Respondent	(C)

Number of New Respondents	(D)

Total Capital/Startup Cost

(B X C)	(E)

Annual O&M Costs for One Respondent	(F)

Number of Respondents  with O&M	(G)

Total O&M,

(E X F)

CEM	$16,000	1	$16,000	$1,200	2071	$248,400

		1 Estimated 25 percent of existing facilities use add-on controls.

The total Capital/Start-up costs for this ICR are $16,000.

 

The total Operating and Maintenance (O&M) Costs for this ICR are
$248,400.

The average annual cost for capital/startup and operation and
maintenance costs to industry over the next three years of the ICR is
estimated to be $264,400.  The continuous monitoring costs that are
included in this section consist only of those capital/start-up and O&M
costs that a source incurs as a result of the standard.  Some continuous
monitoring costs may not be included in this section.  For instance, if
a particular industry typically utilizes a control device that must have
a continuous monitor (e.g., temperature, pressure drop, etc.) to
function properly, and the recordation of additional measurements beyond
the minimum are required by the standard, then there is no
capital/startup or O&M cost, but there is a labor cost to record the
additional readings.  Such a cost would not appear in this section, but
in the industry burden Section 6(d) below.

6(c)  Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of
the reported information.  EPA's overall compliance and enforcement
program includes activities such as the examination of records
maintained by the respondents, periodic inspection of sources of
emissions, and the publication and distribution of collected
information.

The average annual Agency cost during the three years of the ICR is
estimated to be $3,824,062 [see Table 2 in Section 6(e)].

This cost is based on the average hourly labor rate as follows:

	Managerial	$57.20  (GS-13, Step 5, $35.75 x 1.6)   

	Technical	$42.45  (GS-12, Step 1, $26.53 x 1.6)

	Clerical	$22.96  (GS-6, Step 3, $14.35 x 1.6)

These rates are from the Office of Personnel Management (OPM) (2006
General Schedule( which excludes locality rates of pay.  Details upon
which this estimate is based appear in Table 2:  NESHAP for Plastic
Parts and Products Surface Coating (40 CFR Part 63, Subpart PPPP).

6(d)  Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, there are approximately 827 existing
sources currently subject to the standard.  It is estimated that one
additional source will become subject to the regulation in each of the
next three years.

Number of respondents is calculated using the following table which
addresses the three years covered by this ICR.

Number of Respondents

	Respondents That Submit Reports	Respondents That Do Not Submit Any
Reports

	Year	(A)

Number of New Respondents 1	(B)

Number of Existing Respondents	(C)

Number of Existing Respondents That Keep Records but Do Not Submit
Reports	(D)

Number of Existing Respondents That Are Also New Respondents	(E)

Number of Respondents

(E=A+B+C-D)

1	1	827	0	0	828

2	1	828	0	0	829

3	1	829	0	0	830

Average	1	828	0	0	829

1 New respondents include sources with constructed, reconstructed and
modified affected facilities.

To avoid double-counting respondents, column D is subtracted.  As shown
above, the average Number of Respondents over the three-year period of
this ICR is 829.

The total number of annual responses per year is calculated using the
following table:

Total Annual Responses

(A)

Information Collection Activity	(B)

Number of Respondents	(C)

Number of Responses	(D)

Number of Existing Respondents That Keep Records But Do Not Submit
Reports	(E)

Total Annual Responses 

E=(BxC)+D

Initial notification	1	1	0	1

Notification of compliance status	1	1	0	1

Notification of construction/reconstruction	1	1	0	1

Notification of actual startup 	1	1	0	1

Notification of performance test 	1	1.2	0	1

Report of performance test	1	1.2	0	1

Semiannual report 	828	2	0	1,656

Excess emissions report	828	2	0	1,656

Startup, shutdown, malfunction report	828	1	0	828



	Total	4,146



The number of Total Annual Responses is 4,146.

Note that the total annual capital and O&M costs to the regulated entity
are $264,400.

6(e)  Bottom Line Burden Hours and Cost Tables

The bottom line burden hours and cost tables for both the Agency and the
respondents appear below.  The annual public reporting and recordkeeping
burden for this collection of information is estimated to average 77
hours per response.

The detailed bottom line burden hours and cost calculations for the
respondents and the Agency are shown in Tables 1 and 2, respectively,
and summarized below.

(i) Respondent Tally

	The total annual labor costs are $27,180,428.  Details regarding these
estimates may be found in Table 1:  Annual Respondent Burden and Cost: 
NESHAP for Plastic Parts and Products Surface Coating (40 CFR Part 63,
Subpart PPPP).  Furthermore, the annual public reporting and
recordkeeping burden for this collection of information is estimated to
average 77 hours per response.

The total annual capital and O&M costs to the regulated entity are
$264,400.

(ii) The Agency Tally

	The average annual Agency burden and cost over next three years is
estimated to be 60,615 labor hours at a cost of $3,824,062.  See Table
2:  NESHAP for Plastic Parts and Products Surface Coating (40 CFR Part
63, Subpart PPPP).

6(f)  Reasons for Change in Burden

The increase in burden from the most recently approved ICR is due to an
adjustment.  The adjustment increase in burden is due to routine actions
taken by the facilities to comply with 40 CFR part 63, subpart PPPP. 
The previous ICR included only the burden incurred by facilities
initiating activities related to compliance in advance of the compliance
date.  The increase in burden reflects the need for facilities to fully
comply with the rule requirements.

The adjustment increase in burden is also due to a revision in the
number of facilities subject to the NESHAP, based upon an improved
estimate from EPA’s AFS database.

The increase in O&M costs is due to maintenance of equipment used to
verify compliance with the rule requirements.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 77 hours per response.  Burden
means the total time, effort, or financial resources expended by persons
to generate, maintain, retain, or disclose or provide information to or
for a Federal agency.  This includes the time needed to review
instructions; develop, acquire, install, and utilize technology and
systems for the purposes of collecting, validating, and verifying
information, processing and maintaining information, and disclosing and
providing information; adjust the existing ways to comply with any
previously applicable instructions and requirements; train personnel to
be able to respond to a collection of information; search data sources;
complete and review the collection of information; and transmit or
otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a valid OMB
Control Number.  The OMB Control Numbers for EPA(s regulations are
listed at 40 CFR part 9 and 48 CFR chapter 15.

	To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
EPA-HQ-OECA-2006-0433.  An electronic version of the public docket is
available at http://www.regulations.gov/ which may be used to obtain a
copy of the draft collection of information, submit or view public
comments, access the index listing of the contents of the docket, and to
access those documents in the public docket that are available
electronically.  When in the system, select “search,” then key in
the docket ID number identified in this document.  The documents are
also available for public viewing at the Enforcement and Compliance
Docket and Information Center in the EPA Docket Center (EPA/DC), EPA
West, Room B102, 1301 Constitution Ave., NW, Washington, DC.  The EPA
Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m.,
Monday through Friday, excluding legal holidays.  The telephone number
for the Reading Room is (202) 566-1744, and the telephone number for the
docket center is (202) 566-1752.  Also, you can send comments to the
Office of Information and Regulatory Affairs, Office of Management and
Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk
Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OECA-2006-0433 and OMB Control Number 2060-0537 in any
correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in
collecting this information.

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