| Summary |
|
| Type of Respondent |
Total Responses per Year |
Total Hours per Year |
Total Cost per Year (Labor and Non-Labor) |
|
| RIN Generators (Renewable Fuel Producers) |
144,392 |
8,854 |
$568,612 |
|
| Obligated Parties |
20 |
10 |
$980 |
|
| RIN Owners |
4,004 |
2,002 |
$196,196 |
|
| QAP Providers |
25 |
11 |
$1,164 |
|
| Third Parties |
0 |
0 |
$0 |
|
| GRAND TOTAL |
148,441 |
10,876 |
$766,952 |
* Third parties are counted as respondents, but their responses/hours/$ are assigned |
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|
to the party for whom they do the work. (Purchased service providers.) |
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|
The exception is QAP providers, whose burden is shown on this line. |
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| TOTAL NUMBER of Respondents: |
|
|
|
|
|
3,395.00 |
|
|
|
| Non-Labor Costs* Only - Used for OMB Inventory: |
|
|
|
|
|
20,323.00 |
|
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| *Non-Labor Costs include capital, O&M, and purchased services. For this collection, all are purchased services. |
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| These costs are reflected in the "OMB Inventory." |
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| Annual Respondent Burden and Cost by Type of Party |
|
| Table 1 - RIN Generators - Renewable Fuels Producers (domestic, only, assuming 548) |
|
| Information Collection Activity |
Hours and Cost |
Total Hours and Cost |
Forms & Notes |
|
| 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 Costs - Purchased Services |
|
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|
|
Reporting Activities |
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|
|
| 80.1449 |
Annual production outlook reporting is eliminating 11 fields by requiring only annual estimates for all projections. Reduced estimated Standard hours by half. |
0.50 |
0.00 |
0.00 |
49.00 |
548 |
1.00 |
548.00 |
548.00 |
26,852.00 |
RFS09XX; RFS2 PRODUCTION OUTLOOK REPORT.
If EPA finalizes the form, then we may seek reduction in the burden under OMB Control No, 2060-0725. |
- |
| §80.1451 |
Reduced list of codes for a single field in an existing form by removing defunct buisness activity codes. |
0.50 |
0.00 |
0.00 |
49.00 |
67 |
4.00 |
268.00 |
1072.00 |
13,132.00 |
RFS06XX: RFS RENEWABLE FUEL PRODUCER SUPPLEMENTAL REPORT
If finalized, modified list has no new burden, and may seek burden reduction under OMB Control No, 2060-0725. |
|
| 80.1451(b), 80.1452 |
Reporting of the feedstock origin as domestic or foreign as part of batch reporting. See 80.1451(b)(1)(ii)(L). |
0.05 |
0.00 |
0.00 |
4.90 |
548 |
1.00 |
548.00 |
27.40 |
2,685.20 |
REPORTED WITHIN EMTS; if you have only domestic or only foreign, no new burden - but if you have both, then you a small burden equivalent to one field |
- |
| 80.1464 |
Additional cost to respondents for attest auditor to perform additional verification related to feedstock origin. |
0.00 |
0.00 |
0.15 |
36.75 |
548 |
1.00 |
548.00 |
82.20 |
20,139.00 |
PURCHASED SERVICE - attest auditor submits report on behalf of respondents; attest auditor already has to verify feedstock info under OMB Control No. 2060-0725 |
20,139.00 |
|
Recordkeeping Activities |
|
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|
| 80.1454 |
Recordkeeping related to feedstock purchased and transfers that identify the feedstock point of origin for each feedstock, domestic or foreign. These records are needed for QAP and attest engagement purposes, as well. |
0.00 |
0.05 |
0.00 |
3.55 |
548 |
260.00 |
142480.00 |
7124.00 |
505,804.00 |
CBP methods (bills of sale, delivery receipts) to keep the information required by the proposed regulation. |
- |
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| GRAND TOTAL |
|
|
|
|
2,259 |
|
144,392.00 |
8,853.60 |
568,612.20 |
|
20,139.00 |
| Annual Respondent Burden and Cost by Type of Party |
|
| Table 2 - Obligated Parties* |
|
| Information Collection Activity |
Hours and Cost |
Total Hours and Cost |
Forms & Notes |
|
| 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 (Labor and Non-Labor) |
$ Non-Labor Costs (Purchased Services) |
|
RECORDKEEPING AND REPORTING RELATED TO SET2 |
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|
| §80.1451 |
Added instructions and a single code to the response code list for an existing field in an existing form to clarify reporting requirements for small refiner petitioners. |
0.50 |
0.00 |
0.00 |
49.00 |
20 |
1.00 |
20.00 |
10.00 |
980.00 |
RFS03XX: RFS ANNUAL COMPLIANCE REPORT/URF
Parties are a subset of all obligated parties and were included in broader estimates. Effecively there is no additional burden. |
- |
|
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| GRAND TOTAL |
|
|
|
|
20 |
|
20.00 |
10.00 |
980.00 |
|
- |
| Annual Respondent Burden and Cost by Type of Party |
|
| Table 3 - RIN Owners* |
|
| Information Collection Activity |
Hours and Cost |
Total Hours and Cost |
Forms & Notes |
|
| 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 (Labor and Non-Labor) |
$ Non-Labor Costs (Purchased Services) |
|
Reporting Activities |
|
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|
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|
|
| §80.1451(c) |
Removing end of quarter renewable fuel volume owned reporting requirement (single field). |
0.50 |
0.00 |
0.00 |
49.00 |
1001 |
4.00 |
4004.00 |
2002.00 |
196,196.00 |
RFS01XX: RFS AACTIVITY REPORT/URF
Elimination of a single field is a slight reduction in burden. |
- |
|
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| GRAND TOTAL |
|
|
|
|
1001 |
|
4,004.00 |
2,002.00 |
196,196.00 |
|
- |
| Annual Respondent Burden and Cost by Type of Party |
|
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|
| Table 4 - QAP Providers |
|
|
Hours and Cost |
Total Hours and Cost |
Forms & Notes |
|
| 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 Costs - Purchased Services |
| Reporting Activities |
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| 80.1451 |
Placeholder for any change in reporting burden due to NPRM to reflect foreign/domestic. |
0.5 |
0 |
0 |
49.00 |
5 |
4 |
20 |
10 |
980 |
INSERT FORMS NUMBERS HERE (there are four QAP forms) - if any change to them. I estimate a very small burden here as a placeholder. The forms are approved and accounted for under 2060-0725. If they are to be updated in any way, then list them here and provide to docket. We might have to change RFS200X, RFS210X, RFS220X, RFS2300X |
|
| 80.1464 |
Attest Engagement |
0 |
0 |
0.15 |
36.75 |
5 |
1 |
5 |
1 |
184 |
ATTEST ENGAGEMENTS: Attest engagements are already required to be kept under 2060-0725. Accounted for a very small burden over what is already approved in 2060-0725. |
184 |
| Recordkeeping Activities |
|
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|
| 80.1454 |
Recordkeeping burden. |
0 |
0.5 |
0 |
35.50 |
5 |
0 |
0 |
0 |
0 |
General records are already required to be kept under 2060-0725. Do not anticipate much additional burden to records kept as CBP format under 2060-0725, but added to table in case others disagree. |
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| GRAND TOTAL |
|
|
|
|
15 |
|
25 |
11 |
1164 |
|
184.00 |
| Annual Respondent Burden and Cost by Type of Party |
|
| Table 5 - QAP Providers & Other Third Parties: assumes 20 Auditors, 10 Third Party Engineers and Two (2) QAP Providers, for a total of 32 Third Parties |
|
| Information Collection Activity |
Hours and Cost |
Total Hours and Cost |
Forms & Notes |
|
| 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 - All Purchased Services for this Table |
|
Reporting Activities |
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|
|
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|
| 80.1464 |
Reporting: perform and submit attest engagement on behalf of clients - submitted on behalf of respondents on Tables I and II - costs and hours are attributed to parties on Tables I & II |
0.00 |
0.00 |
0.00 |
0.00 |
50 |
0.00 |
0.00 |
0.00 |
0.00 |
Cost is attributed to Renewable Fuel Producer or QAP Provider. |
0.00 |
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|
Recordkeeping Activities |
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| 80.1464 |
Retain records related to attest engagement - costs and hours are attributed to parties on Tables I & II |
0.00 |
0.00 |
0.00 |
0.00 |
50 |
0.00 |
0.00 |
0.00 |
0.00 |
Cost is attributed to Renewable Fuel Producer or QAP Provider. Records are CBP format. |
0.00 |
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| GRAND TOTAL |
|
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|
100 |
|
0 |
0 |
0 |
|
0.00 |
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| Notes to the Table: |
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| Only QAP providers have an hourly and dollar amount assigned, because they are regulated parties with reporting duties. |
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| For other third parties, the hourly and dollar amount is assigned to the party for whom they perform the service and whom they bill for such services. |
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| Form & Instruction Numbers: |
| · RFS01XX: RFS Activity Report – versions RFS0104, RFS0105, and RFS 0106 |
| · RFS03XX: RFS Annual Compliance Report, versions RFS0303, RFS0304 |
| · RFS060X: RFS Renewable Fuel Producer Supplemental Report |
| · RFS0901: RFS Production Outlook Report |
| · URF (unified reporting format; the format used to fill out most RFS forms) |
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| Reporting using templates or that occurs within systems; with system user guides listed: |
| · EMTS Renewable Fuels Standard User’s Guide (includes EMTS RIN generation and RIN transactional reporting) |
| Labor Costs |
| Labor Type |
Labor Cost/hour |
Labor + Overhead/ houra |
Portion attributed/hour |
Employer Cost/hour |
| Managerial (CEO - 11-1011) |
124.47 |
249 |
0.05 |
12.45 |
| Professional/Technical (Refinery Operators - 51-8093) |
44.35 |
89 |
0.7 |
62.3 |
| Clerical (Administrative Assistants 43-6010) |
35.42 |
71 |
0.2 |
14.2 |
| Legal (Lawyer 23-1011) |
84.84 |
170 |
0.05 |
8.5 |
| Total Employer Cost/hour |
98 |
| Purchased Servicesb |
245 |
| 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 2.5 times the Total Employer Cost. |
| (we had use 2.0 previously, but increased the factor to 2.5 times the total employer cost in response to industry feedback on similar ICRs) |
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| For these estimates, the most recently available Bureau of Labor Statistics, May 2023 figures, were used as follows: |
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| For CEOs, mean compensation of 124.47 was used; see: https://www.bls.gov/oes/current/oes111011.htm (accessed 2.25.2025). |
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| For professional/technical, compesation of 44.35, using entry for Petroleum and Coal Product Manufacturing, see: https://www.bls.gov/oes/current/oes518093.htm (accessed 2.25.2025). |
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| For clerical, mean compensation of 35.42 was used, see: https://www.bls.gov/oes/current/oes436011.htm (accessed 2.25.2025). |
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| For legal, mean compensation of 84.84 was used, see https://www.bls.gov/oes/current/oes231011.htm (accessed 2.25.2025). |
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