Burden Calculation Tables

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Overview

Summary
Table 1
Table 2
Capital O&M
Responses
Respondents

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Sheet 1: Summary

ICR Summary Information
Hours per Response	3
Number of Respondents	32
Total Estimated Burden Hours	14
Total Estimated Costs	$1,850
Annualized Capital O&M	$0
Total Annual Responses	5
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – National Volatile Organic Compound Emission Standards for Automobile Refinish Coatings (40 CFR Part 59, Subpart B) (Renewal)
Burden Item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Cost, $ b
1. Application	N/A									Labor Rates
2. Surveys and Studies	N/A									Management	$163.17
3. Reporting Requirements										Technical	$130.28
A. Read Instructions c	2	1	2	1	2	0	0	$260.56		Clerical	$65.71
B. Gather Existing Information	Included in 3.C.
C. Write Report
i. Initial Report c	2	1	2	1	2	0	0	$260.56
ii. Date Code Explanation c	4	1	4	1	4	0	0	$521.12
iii. Update Date Code d	2	1	2	3.1	6.2	0	0	$807.74
Subtotal for Reporting Requirements					14			$1,850
4. Recordkeeping requirements	N/A
5. Labeling e	N/A
Subtotal for Recordkeeping Requirements					0			$0		3	hr/response
Total Labor Burden and Costs (rounded) f					14			$1,850
Total Capital and O&M Cost (rounded) f								$0
GRAND TOTAL (rounded) f								$1,850
Assumptions:
a We assume that an average of 31 respondents will be subject to this rule. We assume that one new source each year will become subject to the rule over the three-year period of the ICR.
b This ICR uses the following labor rates: $163.17 ($77.70 + 110%) per hour for Executive, Administrative, and Managerial labor; $130.28 ($62.04 + 110%) per hour for Technical labor, and $65.71 ($31.29 + 110%) per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees. All tasks are assumed to be performed by a technical person ($130.28/hr) unless otherwise noted.
c We assume there will be one new regulated entity every year.
d We assume that 10% of manufacturers will update their codes each year.
e Although the rule requires the date (or code) to appear on the label, such labeling is already performed.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost – National Volatile Organic Compound Emission Standards for Automobile Refinish Coatings (40 CFR Part 59, Subpart B) (Renewal)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Cost, $ b
A. Initial Report	1	1	1	1	1	0.05	0.1	$61.13		Labor Rates
B. Date Code Report	0.5	1	0.5	1	0.5	0.025	0.05	$30.57		Management	$73.46
C. Date Code Updates	0.5	1	0.5	3.1	1.55	0.0775	0.155	$95		Technical	$54.51
TOTAL (rounded) c					4			$186		Clerical	$29.50
Assumptions:
a We assume that an average of 31 respondents will be subject to this rule, and that one new source will become subject to the rule each year over the three-year period of the ICR.
b This cost is based on the average hourly labor rate as follows: Managerial $73.46 (GS-13, Step 5, $45.91 + 60%); Technical $54.51 (GS-12, Step 1, $34.07 + 60%); and Clerical $29.50 (GS-6, Step 3, $18.44 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2023 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Capital O&M

The only type of industry costs associated with the information collection activity in the regulations are labor costs. There are no capital/startup or operation and maintenance costs.

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Sheet 5: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents a	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Initial Report	1	1	0	1
Date Code Explanation	1	1	0	1
Update Date Codes	3.1	1	0	3.1
			Total	5
a We assume one new regulated facility per year and 10% of facilities will update their date codes.

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Sheet 6: Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents a	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents (E=A+B+C-D)
1	1	30	0	0	31
2	1	31	0	0	32
3	1	32	0	0	33
Average	1	31	0	0	32
a New respondents include sources with constructed, reconstructed, and modified affected facilities.