Burden Calculation Tables

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Overview

Reporting Activity
Respondent Assumptions
Respondent Burden - ICR
Agency Assumptions
Agency Burden

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Sheet 1: Reporting Activity

Quarterly Reports	Number of unique facilities/companies
Producer	6
Imports	61
Exports	16
Reclamation	20
Fire Suppression	3
One-Time Reports	Number of unique facilities/companies
Destruction	6
Transformation	2
Process Agent	2
Reclamation
As Needed Reports	Number of unique facilities/companies	Number of Reports	Months of Activity	Average Reports/Company/Year
Transfers	6	13	6	4
Conferrals	23	47	6	4
RACA	5	25	6	10
Petitions	2	16	3	32
Transhipments	1	2	6	4
Source: HFC Submission Summary Report (6.16.22)

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Sheet 2: Respondent Assumptions

Responent Burden Assumptions
									Respondents per Year						Certification ID Respondent Burden Assumptions												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 (2024)	Y2 (2025)	Y3 (2026)		Respondent	Number of Cylinders	Cylinder Capacity (lbs)	Total HFC Quantity (lbs)	ISO Tank Capacity (lbs)	Number of ISO Tanks	Number of ID Generators/ Scanners	Responses/ Year/Respondent	Time per Response	Unit of Response Time	Time per Response (hours)		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	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		Producer, importer	5,940,000	30	178,200,000	60,000	2,970	62	48	2	Hours	2.0		$77.99	80	$6,239.20		Importer	7,500	61	123	15	Minutes	0.3
		Submit quarterly report	6	0	4	6	Number of facilities based on HFC Q1 2022 report submissions			Submit quarterly report	6	6	6		Reclaimer, filler/packager, fire suppression recycler	5,940,000	NA	NA	NA	NA	51	116,471	20	Seconds	0.006
		Submit annual inventory report (part of quarterly report)	40	0	1	6	Number of facilities based on HFC Q1 2022 report submissions			Submit annual inventory report (part of quarterly report)	6	6	6		Supplier	8,910,000	NA	NA	NA	NA	10,000	891	10	Seconds	0.003
		Maintain records	0	100	1	6	Number of facilities based on HFC Q1 2022 report submissions			Maintain records	6	6	6
		Register with certification ID system	0.50	0	1	6	Number of facilities based on HFC Q1 2022 report submissions			Register with certification ID system	6	1	1
		Enter data into certification ID system	2	0	48	6	See 'Certification ID Respondent Burden Assumptions' table			Enter data into certification ID system	2	6	6		Certification ID Respondent Percentage per Year
		Submit annual HFC-23 emissions report	12	0	1	4	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			Certification ID Registration
		Submit HFC-23 proof of destruction	0.25	0	2	4				Submit HFC-23 proof of destruction	4	4	4			Y1 (2024)	Y2 (2025)	Y3 (2026)
		Provide certification to third party (conferrer)	2	0	1	2	Based on second party transformation and destruction verification assumption			Provide certification to third party (conferrer)	2	2	2		Producer	100%	17%	17%
		Provide certification to third party (exporter)	2	0	1	2	Based on 2022 HRACA submissions through June 2022			Provide certification to third party (exporter)	2	2	2		Importer	100%	1.6%	1.6%
	HFC Importer	Submit quarterly report	6	0	4	61	Number of companies based on HFC Q1 2022 report submissions		HFC Importer	Submit quarterly report	61	61	61		Reclaimer	0%	100%	5%
		Submit annual inventory report (part of quarterly report)	10	0	1	61	Number of companies based on HFC Q1 2022 report submissions			Submit annual inventory report (part of quarterly report)	61	61	61		Filler/Packager	0%	100%	2%
		Maintain records	0	100	1	61	Number of companies based on HFC Q1 2022 report submissions			Maintain records	61	61	61		Fire Suppression Recycler	0%	100%	33%
		Register with certification ID system	0.50	0	1	61	Number of companies based on HFC Q1 2022 report submissions			Register with certification ID system	61	1	1		Supplier	0%	0%	100%
		Enter data into certification ID system	2	0	48	61	See 'Certification ID Respondent Burden Assumptions' table			Enter data into certification ID system	15	61	61
		Petition to import HFCs for transformation/destruction	2	0	32	2	Activity based on HFC 2022 report submissions from mid-March through mid-June			Petition to import HFCs for transformation/destruction	2	2	2
		Petition to import used HFCs for destruction	6	0	6	2	Activity based on 2022 DPETI submissions through June 2022.			Petition to import used HFCs for destruction	2	2	2			Certification ID Data Entry
		Petition to import HFCs for laboratory testing with eventual destruction	6	0	48	3	Based on input from EPA			Petition to import HFCs for laboratory testing with eventual destruction	3	3	3			Y1 (2024)	Y2 (2025)	Y3 (2026)
		Submit ACE report	0.25	0	123	61	7500 unique shipments based on historical ACE data; Number of companies based on HFC Q1 2022 report submissions			Submit ACE report	61	61	61		Producer	25%	100%	100%
		Submit proof of destruction of used imports	0.25	0	6	2				Submit proof of destruction of used imports	2	2	2		Importer	25%	100%	100%
		Maintain records on used imports for destruction	0	20	1	2				Maintain records on used imports for destruction	2	2	2		Reclaimer	0%	25%	100%
		Provide certification to third party (conferrer)	2	0	1	2	Based on second party transformation and destruction verification assumption			Provide certification to third party (conferrer)	2	2	2		Filler/Packager	0%	25%	100%
		Provide certification to third party (exporter)	2	0	1	2	Based on 2022 HRACA submissions through June 2022			Provide certification to third party (exporter)	2	2	2		Fire Suppression Recycler	0%	25%	100%
		Submit Importer of Record annual report	2	0	1	61	Number of companies based on HFC Q1 2022 report submissions			Submit Importer of Record annual report	61	61	61		Supplier	0%	0%	25%
		Submit notification of transhipments	1	0	4	2	Based on 2022 HSHIP submissions through June 2022			Submit notification of transhipments	2	2	2
	Testing Laboratories	Submit notification of delivery to destruction facility	2	0	48	3	Based on input from EPA		Testing Laboratories	Submit notification of delivery to destruction facility	3	3	3
	HFC Aggregator	Maintain records	0	20	1	5	Provided by EPA		HFC Aggregator	Maintain records	5	5	5
	Vessel Owner	Maintain records	0	20	1	100	Provided by EPA		Vessel Owner	Maintain records	100	100	100
	HFC Exporter	Submit quarterly report	6	0	4	16	Number of companies based on HFC Q1 2022 report submissions		HFC Exporter	Submit quarterly report	16	16	16
		Submit annual inventory report (part of quarterly report)	10	0	1	16	Number of companies based on HFC Q1 2022 report submissions			Submit annual inventory report (part of quarterly report)	16	16	16
		Submit request for additional consumption allowances	8	0	10	5	Activity based on 2022 HRACA submissions through June 2022.			Submit request for additional consumption allowances	5	5	5
		Submit notification of transhipments	1	0	4	2	Based on 2022 HSHIP submissions through June 2022			Submit notification of transhipments	2	2	2
	HFC Suppliers	Register with certification ID system	0.50	0	1	10,000	2x HARDI wholesaler/distributor locations		HFC Suppliers	Register with certification ID system	0	0	10000
		Enter data into certification ID system	0.003	0	891	10,000	2x HARDI wholesaler/distributor locations; See 'Certification ID Respondent Burden Assumptions' table			Enter data into certification ID system	0	0	2500
		Submit conferral request	6	0	2	4	Based on HCONF submissions through June 2022			Submit conferral request	4	4	4
		Provide certification to third party (conferee)	2	0	2	4	Based on HCONF submissions through June 2022			Provide certification to third party (conferee)	4	4	4
		Provide certification to third party (conferrer)	2	0	4	4	Based on HCONF submissions through June 2022			Provide certification to third party (conferrer)	4	4	4
		Maintain records	0	20	1	4	Based on HCONF submissions through June 2022			Maintain records	4	4	4
	HFC Destoyer	Submit one-time report	100	0	1	1	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	6	Number of facilities based on HFC 2022 one-time report submissions			Submit annual second party report	6	6	6
		Maintain records	0	20	1	6	Number of facilities based on HFC 2022 one-time report submissions			Maintain records	6	6	6
		Provide destruction verification to third party	2	0	1	6	Number of facilities based on HFC 2022 one-time report submissions			Provide destruction verification to third party	6	6	6
		Provide proof of destruction to third party	2	0	1	12	Number of petitions to import HFCs for destruction			Provide proof of destruction to third party	12	12	12
	HFC Transformer	Submit one-time report	100	0	1	1	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	2	Number of facilities based on HFC 2022 one-time report submissions			Submit annual second party report	2	2	2
		Maintain records	0	20	1	2	Number of facilities based on HFC 2022 one-time report submissions			Maintain records	2	2	2
		Provide transformation verification to third party	2	0	1	2	Number of facilities based on HFC 2022 one-time report submissions			Provide transformation verification to third party	2	2	2
	HFC Process Agent Use	Submit one-time report	100	0	1	1	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	2	Number of facilities based on HFC 2022 one-time report submissions			Submit annual report	2	2	2
	HFC Reclaimers	Submit one-time report	40	0	1	1	Assumes up to one response per year to account for revisions or new reclaimers.		HFC Reclaimers	Submit one-time report	1	1	1
		Submit quarterly report	9.4	0	4	20	Burden for annual activity report from Section 608 ICR, number of companies based on HFC Q1 2022 report submissions			Submit quarterly report	20	20	20
		Submit annual inventory report (part of quarterly report)	10	0	1	20	Number of companies based on HFC Q1 2022 report submissions			Submit annual inventory report (part of quarterly report)	20	20	20
		Maintain records	0	40	1	20	Number of companies based on HFC Q1 2022 report submissions			Maintain records	20	20	20
		Register with certification ID system	0.50	0	1	20	Number of companies based on HFC Q1 2022 report submissions			Register with certification ID system	0	20	1
		Enter data into certification ID system	0.006	0	116,471	20	See 'Certification ID Respondent Burden Assumptions' table			Enter data into certification ID system	0	5	20
	HFC Fillers and Packagers	Register with certification ID system	0.50	0	1	50	Provided by EPA		HFC Fillers and Packagers	Register with certification ID system	0	50	1
		Enter data into certification ID system	0.006	0	116,471	50	See 'Certification ID Respondent Burden Assumptions' table			Enter data into certification ID system	0	13	50
		Maintain records	0	20	1	50				Maintain records	0	50	50
	HFC Fire Suppression Agent Recyclers	Submit quarterly report	9.4	0	4	3	Burden for annual activity report from Section 608 ICR, number of respondents based on HFC Q1 2022 report submissions		HFC Fire Suppression Agent Recyclers	Submit quarterly report	3	3	3
		Submit annual inventory report (part of quarterly report)	10.0	0	1	3	Number of respondents based on HFC Q1 2022 report submissions			Submit annual inventory report (part of quarterly report)	3	3	3
		Maintain records	0	40	1	3	Number of respondents based on HFC Q1 2022 report submissions			Maintain records	3	3	3
		Register with certification ID system	0.50	0	1	3	Number of respondents based on HFC Q1 2022 report submissions			Register with certification ID system	0	3	1
		Enter data into certification ID system	0.006	0	116,471	3	See 'Certification ID Respondent Burden Assumptions' table			Enter data into certification ID system	0	1	3
	HFC Transfers	Submit inter-company transfer request	6	0	2	12	Activity based on 2022 HTRAN submissions through June 2022.		HFC Transfers	Submit inter-company transfer request	12	12	12
		Submit request to transfer from a person in a foreign country	6	0	1	1	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	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	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	42	Based on 2022 allowance recipients		Application-Specific Allowance Holders	Submit biannual report	42	42	42
		Submit annual report (part of biannual report)	6	0	1	50	Based on 2022 allowance recipients plus 8 to account for new applicants			Submit annual report (part of biannual report)	50	50	50
		Submit conferral request	6	0	2	40	Based on application-specific allowance holders minus companies with consumption allowances; based on HCONF submissions through June 2022			Submit conferral request	40	40	40
		Provide certification to third party (conferee)	2	0	2	40				Provide certification to third party (conferee)	40	40	40
		Maintain records	0	80	1	42	Based on 2022 allowance recipients			Maintain records	42	42	42
	Third Party Audits	Submit annual audit report	40	0	1	129	Importers + producers + reclaimers + application specific allowance holders		Third Party Audits	Submit annual audit report	129	129	129
	Unique number of Respondents					10,195	aggregators + producers + importers + suppliers + reclaimers+ destroyers + transformers + fillers/packagers + 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	$12,713	$0	1	1	1	1	1	1	100	100	100	$12,713	$12,713	$12,713	$0	$12,713	$12,713	$12,713	1		Year 1	10,194	30,339	$3,497,620	$817,607	$4,315,227
1		Submit quarterly report	4	6.0	0	24.0	$3,051	$0	6	6	6	24	24	24	144	144	144	$18,307	$18,307	$18,307	$0	$18,307	$18,307	$18,307	1		Year 2	2,138,248	47,966	$5,711,653	$817,607	$6,529,260
		Submit annual inventory report (part of quarterly report)	1	40.0	0	40.0	$5,085	$0	6	6	6	6	6	6	240	240	240	$30,511	$30,511	$30,511	$0	$30,511	$30,511	$30,511	1		Year 3	10,752,442	94,545	$11,633,238	$817,607	$12,450,845
		Maintain records	1	0.0	100	100.0	$10,023	$50	6	6	6	6	6	6	600	600	600	$60,138	$60,138	$60,138	$300	$60,438	$60,438	$60,438	2		Annual Average	4,300,295	57,617	$6,947,504	$817,607	$7,765,111
		Register with certification ID system	1	0.5	0	0.5	$64	$0	6	1	1	6	1	1	3	1	1	$381	$64	$64	$0	$381	$64	$64	1			-	-	-	-	-
		Enter data into certification ID system	48	2.0	0	95.8	$12,180	$0	2	6	6	72	287	287	144	575	575	$18,270	$73,079	$73,079	$0	$18,270	$73,079	$73,079	1				0.013398332420684
1		Submit annual HFC-23 emissions report	1	12.0	0	12.0	$1,526	$50	4	4	4	4	4	4	48	48	48	$6,102	$6,102	$6,102	$200	$6,302	$6,302	$6,302	1
1		Submit HFC-23 proof of destruction	2	0.3	0	0.5	$64	$0	4	4	4	8	8	8	2	2	2	$254	$254	$254	$0	$254	$254	$254	1		Total Hours/Year	Year 1	Year 2	Year 3	Average
		Provide certification to third party (conferrer)	1	2.0	0	2.0	$254	$0	2	2	2	2	2	2	4	4	4	$509	$509	$509	$0	$509	$509	$509	3		Reporting	16,715	33,342	79,921	43,326
		Provide certification to third party (exporter)	1	2.0	0	2.0	$254	$0	2	2	2	2	2	2	4	4	4	$509	$509	$509	$0	$509	$509	$509	3		Recordkeeping	13,360	14,360	14,360	14,027
1	HFC Importer	Submit quarterly report	4	6.0	0	24.0	$3,051	$0	61	61	61	244	244	244	1,464	1,464	1,464	$186,118	$186,118	$186,118	$0	$186,118	$186,118	$186,118	1						57,353
		Submit annual inventory report (part of quarterly report)	1	10.0	0	10.0	$1,271	$0	61	61	61	61	61	61	610	610	610	$77,549	$77,549	$77,549	$0	$77,549	$77,549	$77,549	1
		Maintain records	1	0.0	100	100.0	$10,023	$50	61	61	61	61	61	61	6,100	6,100	6,100	$611,403	$611,403	$611,403	$3,050	$614,453	$614,453	$614,453	2
		Register with certification ID system	1	0.5	0	0.5	$64	$0	61	1	1	61	1	1	31	1	1	$3,877	$64	$64	$0	$3,877	$64	$64	1
		Enter data into certification ID system	48	2.0	0	95.8	$12,180	$0	15	61	61	731	2,922	2,922	1,461	5,844	5,844	$185,743	$742,972	$742,972	$0	$185,743	$742,972	$742,972	1
		Petition to import HFCs for transformation/destruction	32	2.0	0	64.0	$8,136	$0	2	2	2	64	64	64	128	128	128	$16,273	$16,273	$16,273	$0	$16,273	$16,273	$16,273	1
		Petition to import used HFCs for destruction	6	6.0	0	36.0	$4,577	$0	2	2	2	12	12	12	72	72	72	$9,153	$9,153	$9,153	$0	$9,153	$9,153	$9,153	1
		Petition to import HFCs for laboratory testing with eventual destruction	48	6.0	0	288.0	$36,613	$0	3	3	3	144	144	144	864	864	864	$109,840	$109,840	$109,840	$0	$109,840	$109,840	$109,840	1
1		Submit ACE report	123	0.3	0	30.7	$3,908	$0	61	61	61	7,500	7,500	7,500	1,875	1,875	1,875	$238,369	$238,369	$238,369	$0	$238,369	$238,369	$238,369	1
		Submit proof of destruction of used imports	6	0.3	0	1.5	$191	$0	2	2	2	12	12	12	3	3	3	$381	$381	$381	$0	$381	$381	$381	1
		Maintain records on used imports for destruction	1	0.0	20	20.0	$2,005	$50	2	2	2	2	2	2	40	40	40	$4,009	$4,009	$4,009	$100	$4,109	$4,109	$4,109	2
		Provide certification to third party (conferrer)	1	2.0	0	2.0	$254	$0	2	2	2	2	2	2	4	4	4	$509	$509	$509	$0	$509	$509	$509	3
		Provide certification to third party (exporter)	1	2.0	0	2.0	$254	$0	2	2	2	2	2	2	4	4	4	$509	$509	$509	$0	$509	$509	$509	3
1		Submit Importer of Record annual report	1	2.0	0	2.0	$254	$0	61	61	61	61	61	61	122	122	122	$15,510	$15,510	$15,510	$0	$15,510	$15,510	$15,510	1
		Submit notification of transhipments	4	1.0	0	4.0	$509	$0	2	2	2	8	8	8	8	8	8	$1,017	$1,017	$1,017	$0	$1,017	$1,017	$1,017	1
	Testing Laboratories	Submit notification of delivery to destruction facility	48	2.0	0	96.0	$12,204	$0	3	3	3	144	144	144	288	288	288	$36,613	$36,613	$36,613	$0	$36,613	$36,613	$36,613	1
	HFC Aggregator	Maintain records	1	0.0	20	20.0	$2,005	$50	5	5	5	5	5	5	100	100	100	$10,023	$10,023	$10,023	$250	$10,273	$10,273	$10,273	2
	Vessel Owner	Maintain records	1	0.0	20	20.0	$2,005	$50	100	100	100	100	100	100	2,000	2,000	2,000	$200,460	$200,460	$200,460	$5,000	$205,460	$205,460	$205,460	2
1	HFC Exporter	Submit quarterly report	4	6.0	0	24.0	$3,051	$0	16	16	16	64	64	64	384	384	384	$48,818	$48,818	$48,818	$0	$48,818	$48,818	$48,818	1
		Submit annual inventory report (part of quarterly report)	1	10.0	0	10.0	$1,271	$0	16	16	16	16	16	16	160	160	160	$20,341	$20,341	$20,341	$0	$20,341	$20,341	$20,341	1
1		Submit request for additional consumption allowances	10	8.0	0	80.0	$10,170	$0	5	5	5	50	50	50	400	400	400	$50,852	$50,852	$50,852	$0	$50,852	$50,852	$50,852	1
		Submit notification of transhipments	4	1.0	0	4.0	$509	$0	2	2	2	8	8	8	8	8	8	$1,017	$1,017	$1,017	$0	$1,017	$1,017	$1,017	1
	HFC Suppliers	Register with certification ID system	1	0.5	0	0.5	$64	$0	0	0	10,000	-	-	10,000	0	0	5,000	$0	$0	$635,650	$0	$0	$0	$635,650	1
		Enter data into certification ID system	891	0.0	0	2.5	$315	$0	0	0	2,500	-	-	2,227,500	0	0	6,188	$0	$0	$786,617	$0	$0	$0	$786,617	1
1		Submit conferral request	2	6.0	0	12.0	$1,526	$0	4	4	4	8	8	8	48	48	48	$6,102	$6,102	$6,102	$0	$6,102	$6,102	$6,102	1
		Provide certification to third party (conferee)	2	2.0	0	4.0	$509	$0	4	4	4	8	8	8	16	16	16	$2,034	$2,034	$2,034	$0	$2,034	$2,034	$2,034	3
		Provide certification to third party (conferrer)	4	2.0	0	8.0	$1,017	$0	4	4	4	16	16	16	32	32	32	$4,068	$4,068	$4,068	$0	$4,068	$4,068	$4,068	3
		Maintain records	1	0.0	20	20.0	$2,005	$50	4	4	4	4	4	4	80	80	80	$8,018	$8,018	$8,018	$200	$8,218	$8,218	$8,218	2
1	HFC Destroyer	Submit one-time report	1	100.0	0	100.0	$12,713	$0	1	1	1	1	1	1	100	100	100	$12,713	$12,713	$12,713	$0	$12,713	$12,713	$12,713	1
1		Submit annual second party report	1	4.0	0	4.0	$509	$0	6	6	6	6	6	6	24	24	24	$3,051	$3,051	$3,051	$0	$3,051	$3,051	$3,051	1
		Maintain records	1	0.0	20	20.0	$2,005	$50	6	6	6	6	6	6	120	120	120	$12,028	$12,028	$12,028	$300	$12,328	$12,328	$12,328	2
		Provide destruction verification to third party	1	2.0	0	2.0	$254	$0	6	6	6	6	6	6	12	12	12	$1,526	$1,526	$1,526	$0	$1,526	$1,526	$1,526	3
		Provide proof of destruction to third party	1	2.0	0	2.0	$254	$0	12	12	12	12	12	12	24	24	24	$3,051	$3,051	$3,051	$0	$3,051	$3,051	$3,051	3
1	HFC Transformer	Submit one-time report	1	100.0	0	100.0	$12,713	$0	1	1	1	1	1	1	100	100	100	$12,713	$12,713	$12,713	$0	$12,713	$12,713	$12,713	1
1		Submit annual second party report	1	4.0	0	4.0	$509	$0	2	2	2	2	2	2	8	8	8	$1,017	$1,017	$1,017	$0	$1,017	$1,017	$1,017	1
		Maintain records	1	0.0	20	20.0	$2,005	$50	2	2	2	2	2	2	40	40	40	$4,009	$4,009	$4,009	$100	$4,109	$4,109	$4,109	2
		Provide transformation verification to third party	1	2.0	0	2.0	$254	$0	2	2	2	2	2	2	4	4	4	$509	$509	$509	$0	$509	$509	$509	3
1	HFC Process Agent Use	Submit one-time report	1	100.0	0	100.0	$12,713	$0	1	1	1	1	1	1	100	100	100	$12,713	$12,713	$12,713	$0	$12,713	$12,713	$12,713	1
1		Submit annual report	1	6.0	0	6.0	$763	$0	2	2	2	2	2	2	12	12	12	$1,526	$1,526	$1,526	$0	$1,526	$1,526	$1,526	1
1	HFC Reclaimers	Submit one-time report	1	40.0	0	40.0	$5,085	$0	1	1	1	1	1	1	40	40	40	$5,085	$5,085	$5,085	$0	$5,085	$5,085	$5,085	1
1		Submit quarterly report	4	9.4	0	37.6	$4,780	$0	20	20	20	80	80	80	752	752	752	$95,602	$95,602	$95,602	$0	$95,602	$95,602	$95,602	1
		Submit annual inventory report (part of quarterly report)	1	10.0	0	10.0	$1,271	$0	20	20	20	20	20	20	200	200	200	$25,426	$25,426	$25,426	$0	$25,426	$25,426	$25,426	1
		Maintain records	1	0.0	40	40.0	$4,009	$50	20	20	20	20	20	20	800	800	800	$80,184	$80,184	$80,184	$1,000	$81,184	$81,184	$81,184	2
		Register with certification ID system	1	0.5	0	0.5	$64	$0	0	20	1	-	20	1	0	10	1	$0	$1,271	$64	$0	$0	$1,271	$64	1
		Enter data into certification ID system	116,471	0.0	0	647.1	$82,261	$0	0	5	20	-	582,353	2,329,412	0	3,235	12,941	$0	$411,303	$1,645,212	$0	$0	$411,303	$1,645,212	1
	HFC Fillers and Packagers	Register with certification ID system	1	0.5	0	0.5	$64	$0	0	50	1	-	50	1	0	25	1	$0	$3,178	$64	$0	$0	$3,178	$64	1
		Enter data into certification ID system	116,471	0.0	0	647.1	$82,261	$0	0	13	50	-	1,455,882	5,823,529	0	8,088	32,353	$0	$1,028,257	$4,113,029	$0	$0	$1,028,257	$4,113,029	1
		Maintain records	1	0.0	20	20.0	$2,005	$50	0	50	50	-	50	50	0	1,000	1,000	$0	$100,230	$100,230	$0	$0	$100,230	$100,230	2
1	HFC Fire Suppression Agent Recyclers	Submit quarterly report	4	9.4	0	37.6	$4,780	$0	3	3	3	12	12	12	113	113	113	$14,340	$14,340	$14,340	$0	$14,340	$14,340	$14,340	1
		Submit annual inventory report (part of quarterly report)	1	10.0	0	10.0	$1,271	$0	3	3	3	3	3	3	30	30	30	$3,814	$3,814	$3,814	$0	$3,814	$3,814	$3,814	1
		Maintain records	1	0.0	40	40.0	$4,009	$50	3	3	3	3	3	3	120	120	120	$12,028	$12,028	$12,028	$150	$12,178	$12,178	$12,178	2
		Register with certification ID system	1	0.5	0	0.5	$64	$0	0	3	1	-	3	1	0	2	1	$0	$191	$64	$0	$0	$191	$64	1
		Enter data into certification ID system	116,471	0.0	0	647.1	$82,261	$0	0	1	3	-	87,353	349,412	0	485	1,941	$0	$61,695	$246,782	$0	$0	$61,695	$246,782	1
	HFC Transfers	Submit inter-company transfer request	2	6.0	0	12.0	$1,526	$0	12	12	12	24	24	24	144	144	144	$18,307	$18,307	$18,307	$0	$18,307	$18,307	$18,307	1
		Submit request to transfer from a person in a foreign country	1	6.0	0	6.0	$763	$0	1	1	1	1	1	1	6	6	6	$763	$763	$763	$0	$763	$763	$763	1
		Submit request to transfer to a person in a foreign country	1	6.0	0	6.0	$763	$0	1	1	1	1	1	1	6	6	6	$763	$763	$763	$0	$763	$763	$763	1
		Submit request to sell/transfer HFCs produced/imported with application-specific allowances	1	6.0	0	6.0	$763	$0	5	5	5	5	5	5	30	30	30	$3,814	$3,814	$3,814	$0	$3,814	$3,814	$3,814	1
1	Application-Specific Allowance Holders	Submit biannual report	2	6.0	0	12.0	$1,526	$0	42	42	42	84	84	84	504	504	504	$64,074	$64,074	$64,074	$0	$64,074	$64,074	$64,074	1
		Submit annual report (part of biannual report)	1	6.0	0	6.0	$763	$0	50	50	50	50	50	50	300	300	300	$38,139	$38,139	$38,139	$0	$38,139	$38,139	$38,139	1
1		Submit conferral request	2	6.0	0	12.0	$1,526	$0	40	40	40	80	80	80	480	480	480	$61,022	$61,022	$61,022	$0	$61,022	$61,022	$61,022	1
		Provide certification to third party (conferee)	2	2.0	0	4.0	$509	$0	40	40	40	80	80	80	160	160	160	$20,341	$20,341	$20,341	$0	$20,341	$20,341	$20,341	3
		Maintain records	1	0.0	80	80.0	$8,018	$50	42	42	42	42	42	42	3,360	3,360	3,360	$336,773	$336,773	$336,773	$2,100	$338,873	$338,873	$338,873	2
	Third Party Audits	Submit annual audit report	1	40.0	0	40.0	$5,085	$6,239	129	129	129	129	129	129	5,160	5,160	5,160	$655,991	$655,991	$655,991	$804,857	$1,460,848	$1,460,848	$1,460,848	1
	Annual Total											10,194	2,138,248	10,752,442	30,339	47,966	94,545	3,497,620	5,711,653	11,633,238	817,607	4,315,227	6,529,260	12,450,845
	3 Year Total											12,900,885			172,850			$20,842,512			$2,452,820	$23,295,332
	Annual Average											4,300,295			57,617			$6,947,504			$817,607	$7,765,111
	Respondent Burden
	$127.13	Hourly Labor Rate - Technical Staff
	$100.23	Hourly Labor Rate - Clerical Staff

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Sheet 4: Agency Assumptions

Agency Assumptions
	Activity	Managerial Hours per activity	Technical Hours per activity	Clerical Hours per activity	Contractor Hours per activity	Source
	Develop and Maintain a Certification ID Tracking System	120.0	3000.0	0.0	12000.0	Based on input from EPA
	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	1.0	Based on ODS ICR and input from EPA
	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
	Activity	Number of Activities			Source
		Y1	Y2	Y3
	Develop and Maintain a Certification ID Tracking System	1	1	0.8	Assumes development will be complete after year 2
	Notify Submitters of Baseline Allowances	67	67	67	Equals the number of producers + importers
	Review Data for Reporting Completeness and Compliance	8,234	8,234	8,234	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	31	31	31	Equals the number of trade reports received per year
	Review Petitions to Import HFCs	76	76	76	Equals the number of petitions to import for destruction received per year
	Review Importer of Record Reports	61	61	61	Equals the maximum number of importers
	Review Third-Party Audits	129	129	129
	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	64	64	64	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

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Sheet 5: 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
	Develop and Maintain a Certification ID Tracking System	120.0	3,000.0	0.0	12,000.0	1	1	0.8	15,120	15,120	11,340		$13,661	$13,661	$10,246	$245,670	$245,670	$184,253	$0	$0	$0	$1,566,240	$1,566,240	$1,174,680	$1,825,571	$1,825,571	$1,369,178		Year 1	37,099	$4,242,079
	Notify Submitters of Baseline Allowances	0.1	1.0	0.0	1.0	67	67	67	141	141	141		$763	$763	$763	$5,487	$5,487	$5,487	$0	$0	$0	$8,745	$8,745	$8,745	$14,994	$14,994	$14,994		Year 2	37,099	$4,242,079
	Review Data for Reporting Completeness and Compliance	0.0	0.3	0.0	1.0	8,234	8,234	8,234	10,951	10,951	10,951		$0	$0	$0	$222,513	$222,513	$222,513	$0	$0	$0	$1,074,702	$1,074,702	$1,074,702	$1,297,215	$1,297,215	$1,297,215		Year 3	33,319	$3,785,686
	Process Transfer Reports	0.1	0.5	0.0	0.5	31	31	31	34	34	34		$353	$353	$353	$1,269	$1,269	$1,269	$0	$0	$0	$2,023	$2,023	$2,023	$3,645	$3,645	$3,645		Annual Average	35,839	$4,089,948
	Review Petitions to Import HFCs	0.1	1.0	0.0	0.5	76	76	76	122	122	122		$865	$865	$865	$6,224	$6,224	$6,224	$0	$0	$0	$4,960	$4,960	$4,960	$12,049	$12,049	$12,049
	Review Importer of Record Reports	0.1	1.0	0.0	0.0	61	61	61	67	67	67		$694	$694	$694	$4,995	$4,995	$4,995	$0	$0	$0	$0	$0	$0	$5,690	$5,690	$5,690				$11,855,058
	Review Third-Party Audits	0.1	2.0	0.0	4.0	129	129	129	787	787	787		$1,469	$1,469	$1,469	$21,128	$21,128	$21,128	$0	$0	$0	$67,348	$67,348	$67,348	$89,944	$89,944	$89,944
	Provide Reporting Guidance	0.0	2.0	0.0	2.0	40	40	40	160	160	160		$0	$0	$0	$6,551	$6,551	$6,551	$0	$0	$0	$10,442	$10,442	$10,442	$16,993	$16,993	$16,993
	Conduct Stakeholder Outreach Efforts	4.0	60.0	0.0	120.0	1	1	1	184	184	184		$455	$455	$455	$4,913	$4,913	$4,913	$0	$0	$0	$15,662	$15,662	$15,662	$21,031	$21,031	$21,031
	Maintain the Data Tracking System	40.0	750.0	0.0	1,800.0	1	1	1	2,590	2,590	2,590		$4,554	$4,554	$4,554	$61,418	$61,418	$61,418	$0	$0	$0	$234,936	$234,936	$234,936	$300,907	$300,907	$300,907
	Review Import Data Submitted in ACE	0.0	0.3	0.0	0.1	64	64	64	23	23	23		$73	$73	$73	$1,310	$1,310	$1,310	$0	$0	$0	$835	$835	$835	$2,218	$2,218	$2,218
	Conduct Compliance Monitoring Activities	120.0	2,500.0	0.0	750.0	2	2	2	6,740	6,740	6,740		$27,322	$27,322	$27,322	$409,450	$409,450	$409,450	$0	$0	$0	$195,780	$195,780	$195,780	$632,552	$632,552	$632,552
	Ensure Non-Exceedance of AIM Act Limits	20.0	80.0	0.0	80.0	1	1	1	180	180	180		$2,277	$2,277	$2,277	$6,551	$6,551	$6,551	$0	$0	$0	$10,442	$10,442	$10,442	$19,270	$19,270	$19,270
	TOTAL								37,099	37,099	33,319		$52,485	$52,485	$49,070	$997,479	$997,479	$936,062	$0	$0	$0	$3,192,115	$3,192,115	$2,800,555	$4,242,079	$4,242,079	$3,785,686
	3 Year Total								107,516.0				$154,039			$2,931,020			$0			$9,184,784			$12,269,843
	Annual Average								35,839				$51,346			$977,007			$0			$3,061,595			$4,089,948
	Hourly Rates
	Managerial Rate	GS 15 Step 1	$71.15	1.6	$113.84
	Technical Rate	GS 13 Step 1	$51.18	1.6	$81.89
	Clerical Rate	GS 11 Step 1	$49.04	1.6	$78.46
	Extramural Rate				$130.52