Burden Tables

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Overview

Reporting Activity
Respondent Assumptions
Respondent Burden - ICR
Incremental Costs
Summary
Agency Assumptions
Agency Burden

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Sheet 1: Reporting Activity

Quarterly Reports	Number of unique facilities/companies
Producer	10
Imports	75
Exports	26
Exports (non-Importers)	4
Reclamation	31
Fire Suppression	4
Biannual Reports	Number of unique facilities/companies
App-specific Allowance Holder	55
One-Time Reports	Number of unique facilities/companies
Destruction	10
Transformation	3
Process Agent	4
Production	7
Reclamation
As Needed Reports	Number of unique facilities/companies	Number of Reports	Months of Activity	Average Reports/Company/Year
Transfers	11	34	12	3
Conferrals (Suppliers)	3	8	12	3
Conferrals (App-specific Allowance Holders)	25	93	13	3
RACA	16	249	12	16
Petitions	2	63	9	42
Transhipments	1	2	12	2
Source: HFC Submission Summary Report (2.14.23)

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Sheet 2: Respondent Assumptions

Responent Burden Assumptions
									Respondents per Year							Audit Costs				ACE Report Burden Assumptions
	Respondent Type	Acitvity	Technical Hours per Response	Clerical Hours per Response	Responses per Year	Maximum Respondents per Acitvity	Basis for Assumptions		Respondent Type	Acitvity	Y1 (2026)	Y2 (2027)	Y3 (2028)			Auditor Labor Rate ($)	Auditor Time (hours)	Total Cost to Respondent ($)		Respondent	Total Annual Shipments	Total Respondents	Responses/Respondent	Time per Response	Unit of Response Time	Time per Response (hours)
	HFC Producer	Submit one-time producer report	100	0	1	1.00	Assumes up to one response per year to account for revisions or new production facilities.		HFC Producer	Submit one-time producer report	1	1	1			$37.50 is the hourly wage rate for professional and related persons, derived from Bureau of Labor Statistics Occupational Outlook Handbook, September, 2023. https://www.bls.gov/ooh/business-and-financial/accountants-and-auditors.htm The rate was then increase by 110% for fringe and benefit. $78.75	ICF: National Refrigerants estimated that an audit would require a total of 160 hours for the auditors. Assuming this is on the higher end, we estimate that an audit would take, on average, 80 hours. 80	$6,300.00		Importer	ICF: Provided by EPA 7,500	75	100	15	Minutes	0.3
		Submit quarterly report	6	0	4	10.00	Number of facilities based on HFC 2022 report submissions			Submit quarterly report	10	10	10
		Submit annual inventory report (part of quarterly report)	20	0	1	10.00	Number of facilities based on HFC 2022 report submissions			Submit annual inventory report (part of quarterly report)	10	10	10
		Maintain records	0	100	1	10.00	Number of facilities based on HFC 2022 report submissions			Maintain records	10	10	10
		Submit annual HFC-23 emissions report	12	0	1	4.00	Burden estimate for reporting to eGGRT under subpart O from GHGRP ICR 2019 renewal; Respndents based on eGGRT subpart O reporting			Submit annual HFC-23 emissions report	4	4	4
		Submit HFC-23 proof of destruction	0.25	0	2	4.00				Submit HFC-23 proof of destruction	4	4	4
		Provide certification to third party (conferrer)	2	0	1	1.00	Based on second party transformation and destruction verification assumption			Provide certification to third party (conferrer)	1	1	1
		Submit quarterly production for export report	3	0	4	1	Provided by EPA			Submit quarterly production for export report	1	1	1
		Submit annual production for export certification	2	0	1	1	Provided by EPA			Submit annual production for export certification	1	1	1
	HFC Importer	Submit quarterly report	6	0	4	75.00	Number of companies based on HFC 2022 report submissions		HFC Importer	Submit quarterly report	75	75	75
		Submit annual inventory report (part of quarterly report)	10	0	1	75.00	Number of companies based on HFC 2022 report submissions			Submit annual inventory report (part of quarterly report)	75	75	75
		Maintain records	0	100	1	75.00	Number of companies based on HFC 2022 report submissions			Maintain records	75	75	75
		Petition to import HFCs for transformation/destruction	2	0	42	2.00	Activity based on HFC 2022 report submissions from mid-March			Petition to import HFCs for transformation/destruction	2	2	2
		Petition to import used HFCs for destruction	6	0	5	2.00	Activity based on 2022 DPETI submissions			Petition to import used HFCs for destruction	2	2	2
		Submit ACE report	0.25000	0	100	75.00	7500 unique shipments based on historical ACE data; Number of companies based on HFC 2022 report submissions			Submit ACE report	75	75	75
		Submit proof of destruction of used imports	0.25	0	5	2.00				Submit proof of destruction of used imports	2	2	2
		Maintain records on used imports for destruction	0	20	1	2.00				Maintain records on used imports for destruction	2	2	2
		Provide certification to third party (conferrer)	2	0	1	2.00	Based on second party transformation and destruction verification assumption			Provide certification to third party (conferrer)	2	2	2
		Submit Importer of Record annual report	2	0	1	75.00	Number of companies based on HFC 2022 report submissions			Submit Importer of Record annual report	75	75	75
		Submit notification of transhipments	1	0	4	1.00	Based on 2022 HSHIP submissions			Submit notification of transhipments	1	1	1
		Maintain records on HFCs purchased at government auction	0	1	1	10.00	Provided by EPA			Maintain records on HFCs purchased at government auction	10	10	10
	HFC Aggregator	Maintain records	0	20	1	5.00	Provided by EPA		HFC Aggregator	Maintain records	5	5	5
	Vessel Owner	Maintain records	0	20	1	100.00	Provided by EPA		Vessel Owner	Maintain records	100	100	100
	HFC Exporter	Submit quarterly report	6	0	4	26.00	Number of companies based on HFC 2022 report submissions		HFC Exporter	Submit quarterly report	26	26	26
		Submit annual inventory report (part of quarterly report)	10	0	1	26.00	Number of companies based on HFC 2022 report submissions			Submit annual inventory report (part of quarterly report)	26	26	26
		Maintain records	0	20	1	4.00	Number of companies based on HFC 2022 report submissions; reflects companies that only export (i.e., non-importers)			Maintain records	4	4	4
		Submit request for additional consumption allowances	6	0	16	16.00	Activity based on 2022 HRACA submissions			Submit request for additional consumption allowances	16	16	16
		Submit notification of transhipments	1	0	4	1.00	Based on 2022 HSHIP submissions			Submit notification of transhipments	1	1	1
	HFC Suppliers	Submit conferral request	6	0	3	3.00	Based on 2022 HCONF submissions		HFC Supplies	Submit conferral request	3	3	3
		Provide certification to third party (conferee)	2.00	0	3	3.00	Based on 2022 HCONF submissions			Provide certification to third party (conferee)	3	3	3
		Provide certification to third party (conferrer)	2	0	4	3.00	Based on 2022 HCONF submissions			Provide certification to third party (conferrer)	3	3	3
		Maintain records	0	20	1	3.00	Based on 2022 HCONF submissions			Maintain records	3	3	3
	HFC Destoyer	Submit one-time report	100	0	1	1.00	Assumes up to one response per year to account for revisions or new destruction facilities.		HFC Destoyer	Submit one-time report	1	1	1
		Submit annual second party report	4	0	1	10.00	Number of facilities based on HFC 2022 one-time report submissions			Submit annual second party report	10	10	10
		Maintain records	0	20	1	10.00	Number of facilities based on HFC 2022 one-time report submissions			Maintain records	10	10	10
		Provide destruction verification to third party	2	0	1	10.00	Number of facilities based on HFC 2022 one-time report submissions			Provide destruction verification to third party	10	10	10
		Provide proof of destruction to third party	2	0	1	10.00	Number of petitions to import HFCs for destruction			Provide proof of destruction to third party	10	10	10
	HFC Transformer	Submit one-time report	100	0	1	1.00	Assumes up to one response per year to account for revisions or new transformation facilities.		HFC Transformer	Submit one-time report	1	1	1
		Submit annual second party report	4	0	1	3.00	Number of facilities based on HFC 2022 one-time report submissions			Submit annual second party report	3	3	3
		Maintain records	0	20	1	3.00	Number of facilities based on HFC 2022 one-time report submissions			Maintain records	3	3	3
		Provide transformation verification to third party	2	0	1	3.00	Number of facilities based on HFC 2022 one-time report submissions			Provide transformation verification to third party	3	3	3
	HFC Process Agent Use	Submit one-time report	100	0	1	1.00	Assumes up to one response per year to account for revisions or new process agent end-users		HFC Process Agent Use	Submit one-time report	1	1	1
		Submit annual report	6	0	1	4.00	Number of facilities based on HFC 2022 one-time report submissions			Submit annual report	4	4	4
	HFC Reclaimers	Submit one-time report	40	0	1	0.00	Assumes up to one response per year to account for revisions.		HFC Reclaimers	Submit one-time report	0	0	0
		Submit quarterly report	9.4	0	4	31.00	Burden for annual activity report from Section 608 ICR, number of companies based on HFC 2022 report submissions			Submit quarterly report	31	31	31
		Submit annual inventory report (part of quarterly report)	10	0	1	31.00	Number of companies based on HFC 2022 report submissions			Submit annual inventory report (part of quarterly report)	31	31	31
		Maintain records	0	60	1	31.00	Number of companies based on HFC 2022 report submissions			Maintain records	31	31	31
	HFC Fillers and Packagers	Maintain records	0	20	1	50.00			HFC Fillers and Packagers	Maintain records	50	50	50
	HFC Fire Suppression Agent Recyclers	Submit quarterly report	9.4	0	4	4.00	Burden for annual activity report from Section 608 ICR, number of respondents based on HFC 2022 report submissions		HFC Fire Suppression Agent Recyclers	Submit quarterly report	4	4	4
		Submit annual inventory report (part of quarterly report)	10.0	0	1	4.00	Number of respondents based on HFC 2022 report submissions			Submit annual inventory report (part of quarterly report)	4	4	4
		Maintain records	0	40	1	4.00	Number of respondents based on HFC 2022 report submissions			Maintain records	4	4	4
	HFC Transfers	Submit inter-company transfer request	6	0	3	11.00	Activity based on 2022 HTRAN submissions		HFC Transfers	Submit inter-company transfer request	11	11	11
		Submit request to transfer from a person in a foreign country	6	0	1	1.00	ICF estimate			Submit request to transfer from a person in a foreign country	1	1	1
		Submit request to transfer to a person in a foreign country	6	0	1	1.00	ICF estimate			Submit request to transfer to a person in a foreign country	1	1	1
		Submit request to sell/transfer HFCs produced/imported with application-specific allowances	6	0	1	5.00	ICF estimate			Submit request to sell/transfer HFCs produced/imported with application-specific allowances	5	5	5
	Application-Specific Allowance Holders	Submit biannual report	6	0	2	46.00	Based on 2023 allowance recipients		Application-Specific Allowance Holders	Submit biannual report	46	46	46
		Submit annual report (part of biannual report)	6	0	1	54.00	Based on 2023 allowance recipients plus 8 to account for new applicants			Submit annual report (part of biannual report)	54	54	54
		Submit conferral request	6	0	2	46.00	Based on application-specific allowance holders minus companies with consumption allowances; based on HCONF submissions			Submit conferral request	46	46	46
		Provide certification to third party (conferee)	2	0	2	46.00				Provide certification to third party (conferee)	46	46	46
		Maintain records	0	80	1	46.00	Based on 2023 allowance recipients			Maintain records	46	46	46
		Submit mid-year request for additional consumption allowances in the event of a public health emergency (MDIs)	6	0	1	8.00	Based on 2024 MDI allowance recipients			Submit mid-year request for additional consumption allowances in the event of a public health emergency (MDIs)	8	8	8
	Potential Application-Specific Allowance Holders	Submit new application petition	90	0	0.20	5.00	Provided by EPA (assume 1 petition during 5-year rule period)		Entities Petitioning for New Application	Submit new application petition	5	5	5
	Third Party Audits	Submit annual audit report	40	0	1	162.00	Importers + producers + reclaimers + application specific allowance holders		Third Party Audits	Submit annual audit report	162	162	162
	Unique number of Respondents					342	aggregators + producers + importers + suppliers + reclaimers+ destroyers + transformers + fillers/packagers + vessel owners + application-specific allowance holders + potential application-specific allowance holders (assumes other respondents overlap with these activities)

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Sheet 3: Respondent Burden - ICR

Responent Burden
	Respondent Type	Activity	Responses per Respondent per Year	Technical Hours per Response	Clerical Hours per Response	Total Hours per Respondent per Year	Labor Cost per Respondent per Year	O&M Costs per Respondent per Year	Respondents per Activity per Year			Total Responses per Year			Total Hours per Year			Total Labor Cost per Year			Total O&M Costs per Year	Total Cost per Year					Year	Total Responses	Total Hours	Total Labor Costs	Total O&M Costs	Total Costs
									Y1	Y2	Y3	Y1	Y2	Y3	Y1	Y2	Y3	Y1	Y2	Y3		Y1	Y2	Y3
1	HFC Producer	Submit one-time producer report	1	100.0	0	100.0	$14,175	$0	1	1	1	1	1	1	100	100	100	$14,175	$14,175	$14,175	$0	$14,175	$14,175	$14,175	1		Year 1	9,661	36,248	$4,447,786	$1,038,450	$5,486,236
1		Submit quarterly report	4	6.0	0	24.0	$3,402	$0	10	10	10	40	40	40	240	240	240	$34,020	$34,020	$34,020	$0	$34,020	$34,020	$34,020	1		Year 2	9,661	36,248	$4,447,786	$1,038,450	$5,486,236
		Submit annual inventory report (part of quarterly report)	1	20.0	0	20.0	$2,835	$0	10	10	10	10	10	10	200	200	200	$28,350	$28,350	$28,350	$0	$28,350	$28,350	$28,350	1		Year 3	9,661	36,248	$4,447,786	$1,038,450	$5,486,236
		Maintain records	1	0.0	100	100.0	$10,286	$50	10	10	10	10	10	10	1,000	1,000	1,000	$102,860	$102,860	$102,860	$500	$103,360	$103,360	$103,360	2		Annual Average	9,661	36,248	$4,447,786	$1,038,450	$5,486,236
1		Submit annual HFC-23 emissions report	1	12.0	0	12.0	$1,701	$50	4	4	4	4	4	4	48	48	48	$6,804	$6,804	$6,804	$200	$7,004	$7,004	$7,004	1			-	-	-	-	-
1		Submit HFC-23 proof of destruction	2	0.3	0	0.5	$71	$0	4	4	4	8	8	8	2	2	2	$284	$284	$284	$0	$284	$284	$284	1				3.75
		Provide certification to third party (conferrer)	1	2.0	0	2.0	$284	$0	1	1	1	1	1	1	2	2	2	$284	$284	$284	$0	$284	$284	$284	3
		Submit quarterly production for export report	4	3.0	0	12.0	$1,701	$0	1	1	1	4	4	4	12	12	12	$1,701	$1,701	$1,701	$0	$1,701	$1,701	$1,701	1
1		Submit annual production for export certification	1	2.0	0	2.0	$284	$0	1	1	1	1	1	1	2	2	2	$284	$284	$284	$0	$284	$284	$284	1
1	HFC Importer	Submit quarterly report	4	6.0	0	24.0	$3,402	$0	75	75	75	300	300	300	1,800	1,800	1,800	$255,150	$255,150	$255,150	$0	$255,150	$255,150	$255,150	1
		Submit annual inventory report (part of quarterly report)	1	10.0	0	10.0	$1,418	$0	75	75	75	75	75	75	750	750	750	$106,313	$106,313	$106,313	$0	$106,313	$106,313	$106,313	1		Total Hours/Year	Year 1	Year 2	Year 3	Average
		Maintain records	1	0.0	100	100.0	$10,286	$50	75	75	75	75	75	75	7,500	7,500	7,500	$771,450	$771,450	$771,450	$3,750	$775,200	$775,200	$775,200	2		Reporting	18,220	18,220	18,220	18,220
		Petition to import HFCs for transformation/destruction	42	2.0	0	84.0	$11,907	$0	2	2	2	84	84	84	168	168	168	$23,814	$23,814	$23,814	$0	$23,814	$23,814	$23,814	1		Recordkeeping	17,750	17,750	17,750	17,750
		Petition to import used HFCs for destruction	5	6.0	0	30.0	$4,253	$0	2	2	2	10	10	10	60	60	60	$8,505	$8,505	$8,505	$0	$8,505	$8,505	$8,505	1						35,970
		Submit ACE report	100	0.3	0	25.0	$3,544	$0	75	75	75	7,500	7,500	7,500	1,875	1,875	1,875	$265,781	$265,781	$265,781	$0	$265,781	$265,781	$265,781	1		Third-party	278
1		Submit proof of destruction of used imports	5	0.3	0	1.3	$177	$0	2	2	2	10	10	10	3	3	3	$354	$354	$354	$0	$354	$354	$354	1
		Maintain records on used imports for destruction	1	0.0	20	20.0	$2,057	$50	2	2	2	2	2	2	40	40	40	$4,114	$4,114	$4,114	$100	$4,214	$4,214	$4,214	2
		Provide certification to third party (conferrer)	1	2.0	0	2.0	$284	$0	2	2	2	2	2	2	4	4	4	$567	$567	$567	$0	$567	$567	$567	3
1		Submit Importer of Record annual report	1	2.0	0	2.0	$284	$0	75	75	75	75	75	75	150	150	150	$21,263	$21,263	$21,263	$0	$21,263	$21,263	$21,263	1
		Submit notification of transhipments	4	1.0	0	4.0	$567	$0	1	1	1	4	4	4	4	4	4	$567	$567	$567	$0	$567	$567	$567	1
		Maintain records on HFCs purchased at government auction	1	0.0	1	1.0	$103	$50	10	10	10	10	10	10	10	10	10	$1,029	$1,029	$1,029	$500	$1,529	$1,529	$1,529	2
	HFC Aggregator	Maintain records	1	0.0	20	20.0	$2,057	$50	5	5	5	5	5	5	100	100	100	$10,286	$10,286	$10,286	$250	$10,536	$10,536	$10,536	2
	Vessel Owner	Maintain records	1	0.0	20	20.0	$2,057	$50	100	100	100	100	100	100	2,000	2,000	2,000	$205,720	$205,720	$205,720	$5,000	$210,720	$210,720	$210,720	2		1,020,800.00
1	HFC Exporter	Submit quarterly report	4	6.0	0	24.0	$3,402	$0	26	26	26	104	104	104	624	624	624	$88,452	$88,452	$88,452	$0	$88,452	$88,452	$88,452	1
		Submit annual inventory report (part of quarterly report)	1	10.0	0	10.0	$1,418	$0	26	26	26	26	26	26	260	260	260	$36,855	$36,855	$36,855	$0	$36,855	$36,855	$36,855	1
		Maintain records	1	0.0	20	20.0	$2,057	$50	4	4	4	4	4	4	80	80	80	$8,229	$8,229	$8,229	$200	$8,429	$8,429	$8,429	2
1		Submit request for additional consumption allowances	16	6.0	0	96.0	$13,608	$0	16	16	16	256	256	256	1,536	1,536	1,536	$217,728	$217,728	$217,728	$0	$217,728	$217,728	$217,728	1
		Submit notification of transhipments	4	1.0	0	4.0	$567	$0	1	1	1	4	4	4	4	4	4	$567	$567	$567	$0	$567	$567	$567	1
1	HFC Suppliers	Submit conferral request	3	6.0	0	18.0	$2,552	$0	3	3	3	9	9	9	54	54	54	$7,655	$7,655	$7,655	$0	$7,655	$7,655	$7,655	1
		Provide certification to third party (conferee)	3	2.0	0	6.0	$851	$0	3	3	3	9	9	9	18	18	18	$2,552	$2,552	$2,552	$0	$2,552	$2,552	$2,552	3
		Provide certification to third party (conferrer)	4	2.0	0	8.0	$1,134	$0	3	3	3	12	12	12	24	24	24	$3,402	$3,402	$3,402	$0	$3,402	$3,402	$3,402	3
		Maintain records	1	0.0	20	20.0	$2,057	$50	3	3	3	3	3	3	60	60	60	$6,172	$6,172	$6,172	$150	$6,322	$6,322	$6,322	2
1	HFC Destroyer	Submit one-time report	1	100.0	0	100.0	$14,175	$0	1	1	1	1	1	1	100	100	100	$14,175	$14,175	$14,175	$0	$14,175	$14,175	$14,175	1
1		Submit annual second party report	1	4.0	0	4.0	$567	$0	10	10	10	10	10	10	40	40	40	$5,670	$5,670	$5,670	$0	$5,670	$5,670	$5,670	1
		Maintain records	1	0.0	20	20.0	$2,057	$50	10	10	10	10	10	10	200	200	200	$20,572	$20,572	$20,572	$500	$21,072	$21,072	$21,072	2
		Provide destruction verification to third party	1	2.0	0	2.0	$284	$0	10	10	10	10	10	10	20	20	20	$2,835	$2,835	$2,835	$0	$2,835	$2,835	$2,835	3
		Provide proof of destruction to third party	1	2.0	0	2.0	$284	$0	10	10	10	10	10	10	20	20	20	$2,835	$2,835	$2,835	$0	$2,835	$2,835	$2,835	3
1	HFC Transformer	Submit one-time report	1	100.0	0	100.0	$14,175	$0	1	1	1	1	1	1	100	100	100	$14,175	$14,175	$14,175	$0	$14,175	$14,175	$14,175	1
1		Submit annual second party report	1	4.0	0	4.0	$567	$0	3	3	3	3	3	3	12	12	12	$1,701	$1,701	$1,701	$0	$1,701	$1,701	$1,701	1
		Maintain records	1	0.0	20	20.0	$2,057	$50	3	3	3	3	3	3	60	60	60	$6,172	$6,172	$6,172	$150	$6,322	$6,322	$6,322	2
		Provide transformation verification to third party	1	2.0	0	2.0	$284	$0	3	3	3	3	3	3	6	6	6	$851	$851	$851	$0	$851	$851	$851	3
1	HFC Process Agent Use	Submit one-time report	1	100.0	0	100.0	$14,175	$0	1	1	1	1	1	1	100	100	100	$14,175	$14,175	$14,175	$0	$14,175	$14,175	$14,175	1
1		Submit annual report	1	6.0	0	6.0	$851	$0	4	4	4	4	4	4	24	24	24	$3,402	$3,402	$3,402	$0	$3,402	$3,402	$3,402	1
1	HFC Reclaimers	Submit one-time report	1	40.0	0	40.0	$5,670	$0	0	0	0	-	-	-	0	0	0	$0	$0	$0	$0	$0	$0	$0	1
1		Submit quarterly report	4	9.4	0	37.6	$5,330	$0	31	31	31	124	124	124	1,166	1,166	1,166	$165,224	$165,224	$165,224	$0	$165,224	$165,224	$165,224	1
		Submit annual inventory report (part of quarterly report)	1	10.0	0	10.0	$1,418	$0	31	31	31	31	31	31	310	310	310	$43,943	$43,943	$43,943	$0	$43,943	$43,943	$43,943	1
		Maintain records	1	0.0	60	60.0	$6,172	$50	31	31	31	31	31	31	1,860	1,860	1,860	$191,320	$191,320	$191,320	$1,550	$192,870	$192,870	$192,870	2
	HFC Fillers and Packagers	Maintain records	1	0.0	20	20.0	$2,057	$50	50	50	50	50	50	50	1,000	1,000	1,000	$102,860	$102,860	$102,860	$2,500	$105,360	$105,360	$105,360	2
1	HFC Fire Suppression Agent Recyclers	Submit quarterly report	4	9.4	0	37.6	$5,330	$0	4	4	4	16	16	16	150	150	150	$21,319	$21,319	$21,319	$0	$21,319	$21,319	$21,319	1
		Submit annual inventory report (part of quarterly report)	1	10.0	0	10.0	$1,418	$0	4	4	4	4	4	4	40	40	40	$5,670	$5,670	$5,670	$0	$5,670	$5,670	$5,670	1
		Maintain records	1	0.0	40	40.0	$4,114	$50	4	4	4	4	4	4	160	160	160	$16,458	$16,458	$16,458	$200	$16,658	$16,658	$16,658	2
	HFC Transfers	Submit inter-company transfer request	3	6.0	0	18.0	$2,552	$0	11	11	11	33	33	33	198	198	198	$28,067	$28,067	$28,067	$0	$28,067	$28,067	$28,067	1
		Submit request to transfer from a person in a foreign country	1	6.0	0	6.0	$851	$0	1	1	1	1	1	1	6	6	6	$851	$851	$851	$0	$851	$851	$851	1
		Submit request to transfer to a person in a foreign country	1	6.0	0	6.0	$851	$0	1	1	1	1	1	1	6	6	6	$851	$851	$851	$0	$851	$851	$851	1
		Submit request to sell/transfer HFCs produced/imported with application-specific allowances	1	6.0	0	6.0	$851	$0	5	5	5	5	5	5	30	30	30	$4,253	$4,253	$4,253	$0	$4,253	$4,253	$4,253	1
1	Application-Specific Allowance Holders	Submit biannual report	2	6.0	0	12.0	$1,701	$0	46	46	46	92	92	92	552	552	552	$78,246	$78,246	$78,246	$0	$78,246	$78,246	$78,246	1
		Submit annual report (part of biannual report)	1	6.0	0	6.0	$851	$0	54	54	54	54	54	54	324	324	324	$45,927	$45,927	$45,927	$0	$45,927	$45,927	$45,927	1
1		Submit conferral request	2	6.0	0	12.0	$1,701	$0	46	46	46	92	92	92	552	552	552	$78,246	$78,246	$78,246	$0	$78,246	$78,246	$78,246	1
		Provide certification to third party (conferee)	2	2.0	0	4.0000	$567	$0	46	46	46	92	92	92	184	184	184	$26,082	$26,082	$26,082	$0	$26,082	$26,082	$26,082	3
		Maintain records	1	0.0	80	80.0	$8,229	$50	46	46	46	46	46	46	3,680	3,680	3,680	$378,525	$378,525	$378,525	$2,300	$380,825	$380,825	$380,825	2
1		Submit mid-year request for additional consumption allowances in the event of a public health emergency (MDIs)	1	6.0	0	6.0	$851	$0	8	8	8	8	8	8	48	48	48	$6,804	$6,804	$6,804	$0	$6,804	$6,804	$6,804	1
1	Potential Application-Specific Allowance Holders	Submit new application petition	0.2	90.0	0	18.0	$2,552	$0	5	5	5	1	1	1	90	90	90	$12,758	$12,758	$12,758	$0	$12,758	$12,758	$12,758	1
	Third Party Audits	Submit annual audit report	1	40.0	0	40.0	$5,670	$6,300	162	162	162	162	162	162	6,480	6,480	6,480	$918,540	$918,540	$918,540	$1,020,600	$1,939,140	$1,939,140	$1,939,140	1
	Annual Total											9,661	9,661	9,661	36,248	36,248	36,248	$4,447,785.63	$4,447,785.63	$4,447,785.63	$1,038,450.00	$5,486,235.63	$5,486,235.63	$5,486,235.63
	3 Year Total											28,983			108,743			$13,343,357			$3,115,350	$16,458,707
	Annual Average											9,661			36,248			$4,447,786			$1,038,450	$5,486,236
	Respondent Burden
	$67.50 is the hourly wage rate for professional and related persons, derived from Bureau of Labor Statistics Employer Cost and Employee Compensation Table 2 (“Civilian workers by occupational and industry group”), December, 2023. https://www.bls.gov/news.release/ecec.t02.htm#ect_table2.f.1 The rate was then increase by 110% for fringe and benefit. $141.75	Hourly Labor Rate - Technical Staff
	$48.98 is the hourly wage rate for administrative services and facilities managers, derived from Bureau of Labor Statistics Occupational Outlook Handbook, September, 2023. https://www.bls.gov/ooh/management/administrative-services-managers.htm The rate was then increase by 110% for fringe and benefit. $102.86	Hourly Labor Rate - Clerical Staff

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Sheet 4: Incremental Costs

Respondent Type	Activity	Responses per Respondent per Year	Incremental Technical Hours per Response	Incremental Clerical Hours per Response	Total Incremental Hours per Respondent per Year	Incremental Labor Cost per Respondent per Year	Incremental O&M Costs per Respondent per Year	Respondents per Activity per Year			Total Responses per Year			Total Incremental Hours per Year			Total Incremental Labor Cost per Year			Total Incremental O&M Costs per Year	Total Incremental Costs per Year
								Y1	Y2	Y3	Y1	Y2	Y3	Y1	Y2	Y3	Y1	Y2	Y3		Y1	Y2	Y3
HFC Producer	Submit quarterly production for export report	4	3	0	12.0	$1,701	$0	1	1	1	4	4	4	12	12	12	$1,701	$1,701	$1,701	$0	$1,701	$1,701	$1,701
	Submit annual production for export certification	1	2	0	2.0	$284	$0	1	1	1	1	1	1	2	2	2	$284	$284	$284	$0	$284	$284	$284
HFC Importer	Maintain records on HFCs purchased at government auction	1	0	1	1.0	$103	$0	10	10	10	10	10	10	10	10	10	$1,029	$1,029	$1,029	$0	$1,029	$1,029	$1,029
Application-Specific Allowance Holders	Submit mid-year request for additional consumption allowances in the event of a public health emergency (MDIs)	1	6	0	6.0	$851	$0	8	8	8	8	8	8	48	48	48	$6,804	$6,804	$6,804	$0	$6,804	$6,804	$6,804
Potential Application-Specific Allowance Holders	Submit new application petition	0.2	90	0	18.0	$2,552	$0	5	5	5	1	1	1	90	90	90	$12,758	$12,758	$12,758	$0	$12,758	$12,758	$12,758
																					$22,575	$22,575	$22,575
Respondent Burden - Prior ICR Rates
$60.54 is the hourly wage rate for professional and related persons, derived from Bureau of Labor Statistics Employer Cost and Employee Compensation Table 2 (“Civilian workers, by occupational and industry group”), June, 2022. https://www.bls.gov/news.release/ecec.t02.htm#ect_table2.f.1 The rate was then increase by 110% for fringe and benefit. $127.13	Hourly Labor Rate - Technical Staff
$47.73 is the hourly wage rate for administrative services and facilities managers, derived from Bureau of Labor Statistics Occupational Outlook Handbook, April, 2022. https://www.bls.gov/ooh/management/administrative-services-managers.htm The rate was then increase by 110% for fringe and benefit. $100.23	Hourly Labor Rate - Clerical Staff

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Sheet 5: Summary

Prior ICR (2024 Allocation Rule)
Year	Total Responses	Total Hours	Total Labor Costs	Total O&M Costs	Total Costs
Year 1 (2024)	9,637	36,086	$4,110,344	$1,028,100	$5,138,444
Year 2 (2025)	9,637	36,086	$4,110,344	$1,028,100	$5,138,444
Year 3 (2026)	9,637	36,086	$4,110,344	$1,028,100	$5,138,444
This ICR
Year	Total Responses	Total Hours	Total Labor Costs	Total O&M Costs	Total Costs
Year 1 (2026)	9,661	36,248	$4,447,786	$1,038,450	$5,486,236
Year 2 (2027)	9,661	36,248	$4,447,786	$1,038,450	$5,486,236
Year 3 (2028)	9,661	36,248	$4,447,786	$1,038,450	$5,486,236
Annual Average	9,661	36,248	$4,447,786	$1,038,450	$5,486,236
Difference relative to Adjusted Prior ICR
Year	Total Responses	Total Hours	Total Labor Costs	Total O&M Costs	Total Costs
Year 1 (2026)	24	162	$337,442	$10,350	$347,792
Year 2 (2027)	NA	NA	NA	NA	NA
Year 3 (2028)	NA	NA	NA	NA	NA

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Sheet 6: Agency Assumptions

Agency Assumptions
	Activity	Managerial Hours per activity	Technical Hours per activity	Clerical Hours per activity	Contractor Hours per activity	Source
	Notify Submitters of Baseline Allowances	0.1	1.0	0.0	1.0	Based on ODS ICR and input from EPA
	Review Data for Reporting Completeness and Compliance	0.0	0.3	0.0	0.5	Based on ODS ICR, input from EPA, and HFC reporting experience
	Process Transfer Reports	0.1	0.5	0.0	0.5	Based on ODS ICR
	Review Petitions to Import HFCs	0.1	1.0	0.0	0.5	Based on ODS ICR and input from EPA
	Review Importer of Record Reports	0.1	1.0	0.0	0.0
	Review Third-Party Audits	0.1	2.0	0.0	4.0	Based on input from EPA
	Provide Reporting Guidance	0.0	2.0	0.0	2.0	Based on ODS ICR plus an increase since new program
	Conduct Stakeholder Outreach Efforts	4.0	60.0	0.0	120.0	Based on ODS ICR plus an increase since new program
	Maintain the Data Tracking System	40.0	750.0	0.0	1800.0	Based on input from EPA
	Review Import Data Submitted in ACE	0.0	0.3	0.0	0.1	Based on input from EPA
	Conduct Compliance Monitoring Activities	120.0	2500.0	0.0	750.0	Based on input from EPA
	Ensure Non-Exceedance of AIM Act Limits	20.0	80.0	0.0	80.0	Based on ODS ICR and input from EPA
	Review Application-specific Allowance Petitions	200.0	500.0	0.0	1000.0	Based on input from EPA
	Activity	Number of Activities			Source
		Y1	Y2	Y3
	Notify Submitters of Baseline Allowances	85	85	85	Equals the number of producers + importers
	Review Data for Reporting Completeness and Compliance	1,161	1,161	1,161	Equals the number of one-time reports, producer, importer, exporter, transformation, destruction, process agent, RACA, and application-specific allowance holder reports received per year
	Process Transfer Reports	40	40	40	Equals the number of trade reports received per year
	Review Petitions to Import HFCs	94	94	94	Equals the number of petitions to import for destruction received per year
	Review Importer of Record Reports	75	75	75	Equals the maximum number of importers
	Review Third-Party Audits	162	162	162
	Provide Reporting Guidance	40	40	40	Based on ODS ICR
	Conduct Stakeholder Outreach Efforts	1	1	1
	Maintain the Data Tracking System	1	1	1
	Review Import Data Submitted in ACE	84	84	84	Based on current import level and EPA estimated effort
	Conduct Compliance Monitoring Activities	2	2	2	imports and exports
	Ensure Non-Exceedance of AIM Act Limits	1	1	1
	Review Application-specific Allowance Petitions	0.2	0.2	0.2	Based on estimate of receiving one petition over five-year period

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Sheet 7: Agency Burden

Agency Burden
	Activity	Managerial Hours per Activity	Technical Hours per Activity	Clerical Hours per Activity	Contractor Hours per Activity	Number of Activities			Total Hours				Managerial Cost			Technical Cost			Clerical Cost			Contractor Cost			Total Cost				Year	Total Hours	Total Costs
						Y1	Y2	Y3	Y1	Y2	Y3		Y1	Y2	Y3	Y1	Y2	Y3	Y1	Y2	Y3	Y1	Y2	Y3	Y1	Y2	Y3
	Notify Submitters of Baseline Allowances	0.1	1.0	0.0	1.0	85	85	85	179	179	179		$1,068	$1,068	$1,068	$7,687	$7,687	$7,687	$0	$0	$0	$11,656	$11,656	$11,656	$20,411	$20,411	$20,411		Year 1	12,631	$1,397,422
	Review Data for Reporting Completeness and Compliance	0.0	0.3	0.0	0.5	1,161	1,161	1,161	964	964	964		$0	$0	$0	$34,646	$34,646	$34,646	$0	$0	$0	$79,604	$79,604	$79,604	$114,250	$114,250	$114,250		Year 2	12,631	$1,397,422
	Process Transfer Reports	0.1	0.5	0.0	0.5	40	40	40	44	44	44		$503	$503	$503	$1,809	$1,809	$1,809	$0	$0	$0	$2,743	$2,743	$2,743	$5,054	$5,054	$5,054		Year 3	12,631	$1,397,422
	Review Petitions to Import HFCs	0.1	1.0	0.0	0.5	94	94	94	150	150	150		$1,182	$1,182	$1,182	$8,500	$8,500	$8,500	$0	$0	$0	$6,445	$6,445	$6,445	$16,127	$16,127	$16,127		Annual Average	12,631	$1,397,422
	Review Importer of Record Reports	0.1	1.0	0.0	0.0	75	75	75	83	83	83		$943	$943	$943	$6,782	$6,782	$6,782	$0	$0	$0	$0	$0	$0	$7,725	$7,725	$7,725
	Review Third-Party Audits	0.1	2.0	0.0	4.0	162	162	162	988	988	988		$2,036	$2,036	$2,036	$29,299	$29,299	$29,299	$0	$0	$0	$88,860	$88,860	$88,860	$120,196	$120,196	$120,196		Respondent + EPA Avg		$6,883,658
	Provide Reporting Guidance	0.0	2.0	0.0	2.0	40	40	40	160	160	160		$0	$0	$0	$7,234	$7,234	$7,234	$0	$0	$0	$10,970	$10,970	$10,970	$18,205	$18,205	$18,205
	Conduct Stakeholder Outreach Efforts	4.0	60.0	0.0	120.0	1	1	1	184	184	184		$503	$503	$503	$5,426	$5,426	$5,426	$0	$0	$0	$16,456	$16,456	$16,456	$22,384	$22,384	$22,384
	Maintain the Data Tracking System	40.0	750.0	0.0	1,800.0	1	1	1	2,590	2,590	2,590		$5,028	$5,028	$5,028	$67,823	$67,823	$67,823	$0	$0	$0	$246,834	$246,834	$246,834	$319,685	$319,685	$319,685
	Review Import Data Submitted in ACE	0.0	0.3	0.0	0.1	84	84	84	30	30	30		$106	$106	$106	$1,899	$1,899	$1,899	$0	$0	$0	$1,152	$1,152	$1,152	$3,157	$3,157	$3,157
	Conduct Compliance Monitoring Activities	120.0	2,500.0	0.0	750.0	2	2	2	6,740	6,740	6,740		$30,168	$30,168	$30,168	$452,150	$452,150	$452,150	$0	$0	$0	$205,695	$205,695	$205,695	$688,013	$688,013	$688,013
	Ensure Non-Exceedance of AIM Act Limits	20.0	80.0	0.0	80.0	1	1	1	180	180	180		$2,514	$2,514	$2,514	$7,234	$7,234	$7,234	$0	$0	$0	$10,970	$10,970	$10,970	$20,719	$20,719	$20,719
	Review Application-specific Allowance Petitions	200.0	500.0	0.0	1,000.0	0.2	0.2	0.2	340	340	340		$5,028	$5,028	$5,028	$9,043	$9,043	$9,043	$0	$0	$0	$27,426	$27,426	$27,426	$41,497	$41,497	$41,497
	TOTAL								12,631	12,631	12,631		$49,078	$49,078	$49,078	$639,533	$639,533	$639,533	$0	$0	$0	$708,811	$708,811	$708,811	$1,397,422	$1,397,422	$1,397,422
	3 Year Total								37,894.4				$147,235			$1,918,598			$0			$2,126,434			$4,192,267
	Annual Average								12,631				$49,078			$639,533			$0			$708,811			$1,397,422
	Hourly Rates
	Managerial Rate	From 2024 OPM hourly base pay table for DC region: https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/24Tables/html/DCB_h.aspx GS 15 Step 1	$78.56	Standard Government Benefits Multiplier 1.6	$125.70
	Technical Rate	From 2024 OPM hourly base pay table for DC region: https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/24Tables/html/DCB_h.aspx GS 13 Step 1	$56.52	Standard Government Benefits Multiplier 1.6	$90.43
	Clerical Rate	From 2024 OPM hourly base pay table for DC region: https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/24Tables/html/DCB_h.aspx GS 11 Step 1	$54.14	Standard Government Benefits Multiplier 1.6	$86.62
	Extramural Rate				Source: Based on average hourly rate for Senior Technical Analyst III and Consultant I under EPA contract 68HERH19D0029 (contract period 5) $137.13