| Annual Respondent Burden and Cost by Type of Party |
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| Table 1 - Retailers, Wholesale Purchase-Consumers - Assuming 115K gas stations* that sell fuel (retail and wp-c) and 1,800 retail outlets selling E15** |
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| Information Collection Activity |
Hours and Cost |
Total Hours and Cost |
Forms & Notes |
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| Citation |
Activity |
Standard Industry Mix Hours/ Response |
Clerical Only Hours/ Response |
Purchased Services Hours/ Response |
Total Cost/ Response (dollars) |
Number of Respondents |
Number of Responses per party/year |
Total Number of Responses per Year |
Total Hours/ Year |
Total Cost/Year |
Non-Labor Only Portion of Column K (Capital, O&M and Purchased Services) |
| 40 CFR part 80, Subpart N - §80.1501 |
Reporting: Acquire (in some cases, purchase) and affix fuel label required for E15 |
0.00 |
0.01 |
0.01 |
2.08 |
1,800 |
1 |
1,800 |
36 |
3,744 |
No Form; format of label is specified. Assumed all 1,800 E15 stations change label, assumed a 1% subset of 115K retail stations add E15 each year. Assumes label cost equivalent to 0.01 PS. |
2,952 |
| 40 CFR part 80, Subpart N - §80.1501 |
Reporting: Request alternative label |
0.50 |
0.00 |
0.00 |
41.00 |
1 |
1 |
1 |
0.5 |
41 |
Request for alternative labels are expected to be very rare, we assume one per year. Assumes this is a labor cost only. |
0 |
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| GRAND TOTAL |
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1,801 |
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1,801 |
37 |
3,785 |
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2,952 |
| Notes to the Table: |
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| * Source: MarketWatch: "How Many Gas Stations are there in the the U.S.? How Many Will There Be in 10 Years?" |
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| https://www.marketwatch.com/story/how-many-gas-stations-are-in-us-how-many-will-there-be-in-10-years-2020-02-16 |
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| Accessed September 16, 2020. |
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| ** Source: Email from Growth Energy to EPA, October 9, 2019, “Growth Energy Higher Blend Infrastructure.” Available in the docket for this action. |
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| Labor Costs |
| Labor Type |
Labor Cost/hour |
Labor + Overhead/ houra |
Portion attributed/hour |
Employer Cost/hour |
| Managerial (CEO - 11-1011) |
104.23 |
209 |
0.05 |
10.45 |
| Professional/Technical (Refinery Operators - 51-8093) |
38.29 |
77 |
0.7 |
53.9 |
| Clerical (Administrative Assistants 43-6010) |
21.75 |
44 |
0.2 |
8.8 |
| Legal (Lawyer 23-1011) |
83.03 |
167 |
0.05 |
8.35 |
| Total Employer Cost/hour |
82 |
| Purchased Servicesb |
164 |
| a Overhead is calculated to be equal to the cost of labor. |
| b The cost of purchased services (for example, cost of attest auditors) is calculated at twice the Total Employer Cost. |
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| These estimates use Bureau of Labor Statistics figures from the "National Industry-Specific Occupational Wage and |
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| Employment Estimate - Petroleum and Coal Products Manufacturing - May 2019" (March 2020). |
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| (Updated from NPRM to FRM to reflect newer BLS figures now available.) |
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| Median hourly wage is used. |
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