Screening Analysis to Examine 

the Economic Impact of Proposed 

Revisions to the Refrigerant 

Recycling and Emissions Rule 

Draft Report 

Prepared for: 

Julius Banks 

U.S. EPA Headquarters 

Ariel Rios Building 

1200 Pennsylvania Avenue, N.W. (6205J) 

Washington, DC 20460 
Prepared for: 

Julius Banks 

U.S. EPA Headquarters 

Ariel Rios Building 

1200 Pennsylvania Avenue, NW (6205J) 

Washington, DC 20460 

Prepared by: 

Stratus Consulting Inc. 

1920 L St. NW, Ste. 420 

Washington, DC 20036 

202-466-3731 

PO Box 4059 

Boulder, CO 80306-4059 

Contact: 

Nimmi Damodaran 

October 23, 2009 

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SC11138 

Screening Analysis to Examine 

the Economic Impact of 

Proposed Revisions to the 

Refrigerant Recycling and 

Emissions Rule 

Draft Report 
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SC11138

Contents 

List of Figures..............................................................................................................................ix 

List of Tables...............................................................................................................................xi 

Executive Summary................................................................................................................. S-1 

Section 1 Introduction..........................................................................................................1 

1.1 Regulatory Baseline...............................................................................................4 

1.1.1 Regulated community ................................................................................4 

1.1.2 Current leak repair requirements ...............................................................4 

1.1.3 Current recordkeeping and reporting requirements...................................5 

1.2 Proposed Regulatory Revisions .............................................................................5 

1.2.1 Proposed leak repair requirements.............................................................5 

1.2.2 Proposed recordkeeping and reporting requirements ................................7 

1.3 Analytical Requirements........................................................................................8 

1.4 Contents .................................................................................................................8 

Section 2 Approach ..............................................................................................................9 

2.1 Repair and Retire/Retrofit Actions ........................................................................9 

2.2 Evaluating the Aggregate Incremental Impact of Proposed Rule 

on the Economy ...................................................................................................11 

2.2.1 Model equipment costs ............................................................................11 

2.2.2 Model facility costs..................................................................................12 

2.2.3 Model entity costs and incremental impacts of the rule ..........................13 

2.3 Estimating the Impact of the Proposed Rule on Small Entities...........................13 

2.4 Monte Carlo Analysis ..........................................................................................14 

2.5 Benefits Estimation..............................................................................................15 

2.5.1 Baseline benefits ......................................................................................16 

2.5.2 Benefits of proposed changes ..................................................................16 

2.5.3 Health benefits analysis ...........................................................................17 

2.6 Synthesis of Benefits and Costs...........................................................................17 

2.6.1 Cost-effectiveness estimation ..................................................................17 

2.6.2 Net benefits estimation ............................................................................18 
 

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Section 3 Industry Characterization.................................................................................18 

3.1 Comfort Cooling ..................................................................................................19 

3.1.1 CC equipment characterization................................................................20 

3.1.2 Affected business sectors in the CC category..........................................20 

3.2 Commercial Refrigeration ...................................................................................23 

3.2.1 CR equipment characterization................................................................24 

3.2.2 Affected business sectors in the CR category..........................................25 

3.3 Industrial Process Refrigeration...........................................................................26 

3.3.1 IPR equipment characterization...............................................................26 

3.3.2 Affected businesses in the IPR category..................................................26 

Section 4 Economic Impacts Analysis ..............................................................................28 

4.1 Characterization of All Affected Sectors.............................................................28 

4.2 Cost Input Assumptions.......................................................................................35 

4.3 Compliance Costs by Equipment Type Associated with Different 

Levels of Action...................................................................................................38 

4.4 Recordkeeping and Reporting Costs....................................................................38 

4.5 Regulatory Impacts ..............................................................................................39 

4.5.1 Aggregate incremental impact of proposed rule on the economy ...........39 

4.5.2 Impact of proposed rule on small entities................................................42 

Section 5 Benefits Estimation............................................................................................49 

5.1 Emissions Reduction Analysis.............................................................................66 

5.2 Health Benefits Analysis .....................................................................................70 

5.3 Health Benefits Economic Analysis ....................................................................78 

5.3.1 Valuing fatal skin cancers........................................................................78 

5.3.2 Valuing nonfatal cases of melanoma .......................................................78 

5.3.3 Valuing nonfatal cases of carcinomas .....................................................79 

5.3.4 Estimated value of reduced health effects ...............................................79 

Section 6 Synthesis of Benefits and Costs.........................................................................81 

6.1 Cost-Effectiveness Analysis ................................................................................81 

6.2 Net Benefits Analysis ..........................................................................................84 

6.3 Discussion of Uncertainties in Net Benefits Analysis.........................................85 

6.3.1 Potentially overestimated costs................................................................86 

6.3.2 Additional benefits...................................................................................87 

6.3.3 Summary of discussion of uncertainty in costs and benefits analysis .....89 
 

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Section 7 Statutory and Executive Order Impact Analysis............................................90 

Section 8 Conclusions.........................................................................................................92 

Bibliography ...............................................................................................................................92 

Attachment. Economic Analysis Detail Tables 
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Figures 

1 Example of lag in health effects from emissions reductions in 2010.................................76 
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Tables 

1 Business sectors and NAICS codes examined in this screening analysis............................ 3 

2 Options for annual leak rates ............................................................................................... 5

3 Types of repairs ................................................................................................................. 10 

4 Types and sequence of repairs assumed for each repair level in the different scenarios .. 11 

5 Characterization of CC equipment .................................................................................... 21 

6 CC equipment annual leak rate data .................................................................................. 21 

7 Distribution of CC systems................................................................................................ 22 

8 Sectors with CC equipment with a charge size greater than 50 pounds............................ 23 

9 Characterization of CR equipment .................................................................................... 24 

10 CR equipment annual leak rate data .................................................................................. 25 

11 Sectors with CR equipment with a charge size greater than 50 pounds and 

units per facility ................................................................................................................. 25 

12 Characterization of IPR equipment.................................................................................... 27 

13 IPR equipment annual leak rate data ................................................................................. 27 

14 Sectors with IPR equipment with a charge size greater than 50 pounds and 

units per facility ................................................................................................................. 28 

15 Industries characterized by size categories, number of entities and facilities, 

facilities per entity, equipment use, and average revenues................................................ 29 

16 Compliance costs for applicable types of refrigeration and cooling equipment 

under Scenario 1 ................................................................................................................ 39 

17 Compliance costs for applicable types of refrigeration and cooling equipment 

under Scenario 2 ................................................................................................................ 39 

18 Incremental cost of the different options for the proposed rule under Scenario 1 

per piece of equipment....................................................................................................... 40

19 Incremental cost of the different options for the proposed rule under Scenario 2 

per piece of equipment....................................................................................................... 41

20 Incremental cost of the different options for the proposed rule under Scenario 1 

per equipment category...................................................................................................... 43 

21 Incremental cost of the different options for the proposed rule under Scenario 2 

per equipment category...................................................................................................... 44 

22 Percentage of regulatory impacts attributed to each equipment category 

under Scenario 1 ................................................................................................................ 45 

23 Percentage of regulatory impacts attributed to each equipment category 

under Scenario 2 ................................................................................................................ 46 

24 Total incremental cost of each regulatory option under Scenario 1 by sector................... 47 

25 Total incremental cost of each regulatory option under Scenario 2 by sector................... 48 
 

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26 Expected number of entities with compliance costs greater than 1% of average 

value of shipments under Scenario 1..................................................................................50 

27 Expected number of entities with compliance costs greater than 1% of average 

value of shipments under Scenario 2..................................................................................54 

28 Expected number of entities with compliance costs greater than 3% of average 

value of shipments under Scenario 1..................................................................................58 

29 Expected number of entities with compliance costs greater than 3% of average 

value of shipments under Scenario 2..................................................................................62 

30 Benefits assumptions of months avoided emissions if process stops at 

each regulatory stage specified below................................................................................67 

31 Incremental benefits of the different options for the proposed rule under 

Scenario 1 per equipment category (ODP-weighted tonnes).............................................69 

32 Incremental benefits of the different options for the proposed rule under 

Scenario 2 per equipment category (ODP-weighted tonnes).............................................69 

33 Incremental benefits of the different options for the proposed rule under 

Scenario 1 per equipment category (MMTCE)..................................................................69 

34 Incremental benefits of the different options for the proposed rule under 

Scenario 2 per equipment category (MMTCE)..................................................................70 

35 Total incremental benefit of each regulatory option under Scenario 1 by sector 

(ODP-weighted tonnes)......................................................................................................71 

36 Total incremental benefit of each regulatory option under Scenario 2 by sector 

(ODP-weighted tonnes)......................................................................................................72 

37 Total incremental benefit of each regulatory option under Scenario 1 by sector 

(MMTCE)...........................................................................................................................73 

38 Total incremental benefit of each regulatory option under Scenario 2 by sector 

(MMTCE)...........................................................................................................................74 

39 Health benefits of the different options for the proposed rule under Scenario 1 ...............77 

40 Health benefits of the different options for the proposed rule under Scenario 2 ...............77 

41 Value of health benefits of the different options for the proposed rule under 

Scenario 1...........................................................................................................................80 

42 Value of health benefits of the different options for the proposed rule under 

Scenario 2...........................................................................................................................80 

43 Average cost-effectiveness of options for proposed regulation under Scenario 1.............81 

44 Average cost-effectiveness of options for proposed regulation under Scenario 2.............82 

45 Incremental cost-effectiveness of options for proposed regulation under Scenario 1 .......83 

46 Incremental cost-effectiveness of options for proposed regulation under Scenario 2 .......83 

47 Average cost-effectiveness of options for proposed regulation under Scenario 1.............84 

48 Average cost-effectiveness of options for proposed regulation under Scenario 2.............84 

49 Monetized net benefits of regulation under Scenario 1 .....................................................84 

50 Monetized net benefits of regulation under Scenario 2 .....................................................85 
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Executive Summary 

The U.S. Environmental Protection Agency (EPA or the Agency) is proposing to change the leak 

rate repair requirements and associated practices for equipment used for commercial 

refrigeration (CR), industrial process refrigeration (IPR), and comfort cooling (CC) containing 

more than 50 pounds of refrigerants that are ozone-depleting substances (ODS). The options for 

revisions under consideration include requiring owners or operators of this type of equipment to 

repair leaks at the annual leak rates presented in Table S.1, for CC and commercial and industrial 

process equipment, respectively. 

The economic analysis examines a total of 12 regulatory options, with each of the six leak rate 

repair options (Table S.1) analyzed under two scenarios. The scenarios represent different types 

of repairs. Under the first scenario, leaking components that fail verification tests must be 

replaced. Under the second scenario, the owners and operators must repair leaking equipment, 

but whether or not repairs will include the replacement of leaking components is at their 

discretion. For example, under the first scenario, upon the failure of an initial attempt to repair an 

owner or operator would be required to replace a leaking compressor in its entirety, while in the 

second scenario the owner or operator would be allowed to replace a part of that compressor. 

Table S.1. Options for annual leak rates 

Leak rate since last verification 

Option CC CR and IPR 

1 (5% and 10%) 5% 10% 

2 (5% and 20%) 5% 20% 

3 (5% and 30%) 5% 30% 

4 (10% and 10%) 10% 10% 

5 (10% and 20%) 10% 20% 

6 (10% and 30%) 10% 30% 

Under both scenarios, repairs must be completed within 30 days of leak detection, and 

verifications (immediate, and follow-up within 30 days) must be conducted. Leaking 

components that fail verification tests must be repaired, and owners or operators that have 

repaired the leaking equipment three times within a consecutive 12-month period due to the 

failure of an initial verification or follow-up verification test must retire the equipment or retrofit 

it to use non-ODS refrigerants. 
 

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The regulatory alternative selected for the proposed rule is Option 5 under Scenario 2. This 

option represents annual leak rate thresholds of 10% for CC and 20% for CR and IPR, with no 

required component replacements and the type of repairs conducted left to the discretion of 

owners and operators. 

Objectives of the economic analysis 

This document presents an economic screening analysis that examines the impacts of these 

potential revisions to the current regulation. The purposes of the screening analysis are to 

determine (1) whether the revisions under consideration represent a significant regulatory action 

resulting in a total annual impact on the economy greater than $100 million as per Executive 

Orders (EOs) 12866 and 13422, and (2) whether the proposed revisions could result in a 

“significant economic impact on a substantial number of small entities” (SISNOSE) under the 

Regulatory Flexibility Act (RFA) as amended by the Small Business Regulatory Enforcement 

Fairness Act (SBREFA). 

This screening analysis satisfies the Agency’s obligations under EO 12866, which requires an 

assessment of costs, benefits, and of potentially effective and reasonably feasible alternatives to 

the planned regulatory action, and the Unfunded Mandates Reform Act, which requires a 

qualitative and quantitative assessment of the anticipated costs and benefits of a Federal mandate 

resulting in annual expenditures of $100 million or more, including the costs and benefits to 

State, local, and Tribal governments or the private sector. This analysis also complies with the 

RFA as amended by the SBREFA, which requires agencies to endeavor, consistent with the 

objectives of the rule and applicable statutes, to fit regulatory and information requirements to 

the scale of businesses, organizations, and governmental jurisdictions subject to their regulations. 

In addition, the document summarizes analyses of the proposed rule’s impacts that are needed to 

meet certain relevant regulatory development statues and EOs. 

The business sectors examined in this analysis are shown in Table S.2. 

Analytical methods: Costs and impacts 

The economic analysis uses a “model entity” approach for size categories based on the number 

of employees within each affected sector. The model entity analysis uses a “model facility” 

analysis, which in turn relies on a “model equipment” analysis. The characteristics and costs of 

model piece of equipment are used to estimate the costs of compliance for model facilities, and 

the model facility costs are then used to estimate the model entity level costs. 
 

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Table S.2. Business sectors examined 

Business sector NAICS code 

Supermarkets and grocery stores 445110 

Convenience stores 445120 

Gas station convenience stores 447110 

Warehouse and club supercenters 45291 

Refrigerated warehouse and storage 49312 

Refrigerated warehouse farm product storage 49313 

Office building managers 531312 

Lodging 72 

Chemical manufacturing 325 

Pharmaceutical manufacturing 3254 

Petrochemical manufacturing 324110 

Bakeries 3118 

Food manufacturing other than bakeries 311 

Breweries 31212 

Soft drink manufacturing 312111 

Bottled water manufacturing 312112 

Ice manufacturing 312113 

Ice rinks 713940 

Elementary and secondary schools 6111 

Junior colleges, colleges and universities 6112, 6113 

Hospitals 622 

The model entity analysis is used to estimate the impact on the economy as a whole 

(i.e., aggregate cost of the proposed rule) and on small businesses individually (i.e., for a 

SISNOSE analysis). The specific Small Business Administration size category definitions are 

only relevant to the small business impacts analysis, however, for consistency the same size 

category breakdowns are used in the description of a model plant to assess the economic impact 

of the proposed rule on the economy as a whole. 

The analysis assumes that owners and operators of refrigeration and cooling equipment with a 

charge size greater than 50 pounds of an ODS will make repairs only as mandated by regulation, 

which is likely to lead to an overestimate of the costs. In all likelihood, there would be a number 

of cases in which normal maintenance practices would include making the repairs to ensure that 

the refrigeration and cooling systems satisfactorily perform their functions regardless of 
 

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proposed changes to the rule. In addition, in some cases, owners and operators could choose to 

skip one of the regulatory steps (e.g., move from making minor repairs to retrofitting the system 

without replacing a component), reducing the expected cost of the rule. 

The analysis for estimating the impact of the proposed rule uses a statistical modeling technique 

called Monte Carlo analysis to estimate the number of entities in each sector that are expected to 

experience costs exceeding 1% (and 3%) of the average annual value of shipments. This analysis 

does not account for actions mandated by current regulations. 

Results: Costs and impacts 

Based on the analysis, the total expected annual incremental cost of the rule across all sectors is 

between $86.5 million and $135.6 million for the six options under the first scenario (requiring 

component replacement), and between $28.5 million and $53.2 million for the six options under 

the second scenario. All but one of the regulatory options under the first scenario are above the 

$100 million adverse impact threshold for the purposes of EO 12866 and 13422, while all the 

options under Scenario 2 are below that threshold. The regulatory option (Option 5 under 

Scenario 2) selected for the rule would result in a total expected annual incremental cost of 

$38.2 million and is therefore not an economically significant regulatory action based on the 

threshold of an annual effect on the economy of $100 million or more. 

This screening analysis found that the revised rule will only significantly impact between 1,396 

and 1,775 small businesses under Scenario 1 and between 336 and 409 small businesses under 

the second scenario for the purposes of the RFA. With the preferred regulatory option, Option 5 

under Scenario 2, a total of 353 small businesses will experience compliance costs greater than 

or equal to 1% of their average value of shipments. This represents 0.34% of the 104,068 total 

potentially affected small businesses examined across all sectors. At the 1% level, the most 

heavily impacted sector, the ice rink sector, is predicted to have 36 impacted entities (out of 

443 small businesses in the sector, or 8.1% of the sector). The sector with the most impacted 

small entities, bakeries, is predicted to have 114 affected small businesses (of the 9,598 

potentially impacted small businesses in the sector, or 1.2% of the sector). 

There are 74 small businesses with anticipated compliance costs greater than or equal to 3% of 

their average value of shipments, mainly in the bakery and ice rink sectors. In the bakery sector, 

24 companies are expected to have impacts between 3 and 4%, while 6 are expected to have 

impacts between 4 and 9.5%. In the ice rink sector, 25 companies are expected to experience 

impacts between 3 and 4%, 4 companies will likely experience impacts between 4 and 10%, and 

there is a small chance that 1 of those 4 companies may experience impacts between 10 and 

26%. 
 

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Benefits assessment: Methods and results 

The benefits analysis, like the cost analysis, is based on a “model entity” approach for size 

categories based on the number of employees within each affected sector. Again, the “model 

entity” analysis is developed from a “model facility” analysis, which relies on a “model 

equipment” analysis. The characteristics and benefits associated with model pieces of equipment 

are used to establish potential avoided emissions for model facilities, and the benefits associated 

with model facilities are used to establish benefits for the model entities. This model entity 

analysis is used to estimate the impact on the economy as a whole (i.e., aggregate benefit of the 

proposed rule). 

Using this approach, it is estimated that the total expected benefits – in terms of avoided 

refrigerant emissions  are between 263 and 493 ozone-depleting potential (ODP)-weighted 

tonnes or between 1.5 and 2.5 million metric tonnes of carbon equivalent (MMTCE) of avoided 

refrigerant emissions under Scenario 1, and between 198 and 423 ODP-weighted tonnes or 1.2 

and 2.3 MMTCE under Scenario 2. 

The estimated total benefits for the preferred regulatory alternative, Option 5 under Scenario 2, 

are 316 ODP-weighted tones or 1.8 MMTCE. 

The sector generating the largest environmental benefit in terms of both ODP- and global 

warming potential-weighted emissions is the supermarket and grocery store sector, with 

estimated annual avoided refrigerant emissions between 110.5 and 178.7 ODP-weighted tones, 

or between 0.89 and 1.49 MMTCE under Scenario 1, and between 100 and 166.8 ODP-weighted 

tonnes or 0.80 and 1.40 MMTCE under Scenario 2. 

ODS emissions deplete stratospheric ozone, which protects the biosphere from potentially 

damaging doses of ultraviolet (UV) radiation. Depletion of stratospheric ozone caused by the 

release of man-made ODS can lead to increases in UV radiation reaching the Earth’s surface, 

which could in turn lead to adverse human and animal health effects, as well as ecosystem 

impacts. A health-based benefits analysis was conducted for the most important type of 

quantified health effect: skin cancers. Other health effects not included in the analysis, but which 

are known or suspected to be associated with damage to stratospheric ozone, including premature 

aging, cataracts, and immune system suppression. 

The health effects for each of the 12 regulatory options were estimated using EPA’s Atmospheric 

Health Effect Framework (AHEF) model to estimate decreases in fatal and nonfatal cases of 

three types of skin cancer. The reduced skin cancers caused by reducing ODS emissions in a 

single year (2010) will occur over an extended period of time. Additional skin cancers will be 

reduced by emissions reductions occurring in subsequent years. Using the estimated emissions 

reductions occurring in 2010, AHEF estimates the decreased incidence of new cases of each type 
 

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of skin cancer and the number of skin cancer fatalities in each year through 2150. The AHEF 

estimates that a single year of emission reductions will reduce a cumulative total of between 85 

and 228 cases of skin cancer in the United States between 2010 and 2150, with approximately 

one avoided fatal case. Because the estimated avoided skin cancers occur over a 140-year period, 

the economic value of the reduced skin cancers is greatly effected by discounting to calculate a 

present value. 

For Scenario 1, the skin-cancer-related benefits range between $1.3 million and $2.5 million with 

a 3% discount rate, and between $0.4 million and $0.8 million with a 7% discount rate. For 

Scenario 2, the total benefits range between $1.0 million and $2.2 million with a 3% discount 

rate, and between $0.3 million and $0.7 million with a 7% discount rate. Option 5 under Scenario 

2 has estimated avoided skin cancer benefits of $1.6 million with a 3% discount rate and $0.5 

with a 7% discount rate. 

The benefits analysis has some limitations. There is no analysis of benefits that may be obtained 

by preventing a chronically leaking system from continuing operation. There is also no analysis 

of the benefits of an accelerated transition to non-ODS alternative refrigerants. This means that 

the benefits estimates presented here are likely to underestimate the total benefits potentially 

realized through the proposed rule. The monetization of benefits is based solely on the avoidance 

of incidences of skin cancer. Other health and environmental benefits are not examined in 

monetized fashion and, therefore, there is an underestimation of the dollar value of total benefits. 

Cost-effectiveness: Methods and results 

Cost-effectiveness (C-E) analysis examines the cost per kilogram of avoided emissions for each 

option. C-E is calculated by dividing the total cost of an option by the avoided emissions [in 

ODP-weighted kilograms (ODP-kilograms)] for that option. The C-E analysis of the leak rate 

regulatory options helps identify the equipment categories that are relatively less expensive per 

pound of avoided emissions as well as the incremental costs of increasing the stringency of the 

regulation on each equipment type. 

When the average C-E results of regulatory options for each equipment type are examined 

independently of one another (e.g., the costs and benefits of a 20% leak rate for CR are examined 

independently of a 20% leak rate for IPR), the most cost-effective option for CC is 10% under 

Scenarios 1 and 2 ($290 and $118/ODP-kilogram, respectively), for CR is 20% under Scenario 1 

and 30% under Scenario 2 ($350 and $169/ODP-kilogram, respectively), and for IPR is 10% 

under Scenario 1 and 20% under Scenario 2 ($161 and $45/ODP-kilogram, respectively). 

The incremental C-E analysis of increasingly stringent regulatory options reveals that the 

incremental emissions reductions attained by moving from a 10% to a 5% leak rate for CC are 

relatively more expensive than emissions reductions attained with the less stringent option 
 

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(10%). The most cost-effective (i.e., lowest cost/ODP-kilogram) incremental emissions 

reductions for CR and IPR are attained by moving from a 30% annual leak rate to a 20% leak 

rate. 

When the average C-E is examined for option packages [e.g., Option 1 (5% and 10%)], then 

Option 4 (10% and 10%) appears to have the lowest (i.e., most efficient) C-E result under 

Scenario 1, and Option 5 (10% and 20%) has the lowest C-E result under Scenario 2. This is 

driven largely by the average C-E of IPR equipment mentioned above. 

Net benefits: Methods and results 

The net benefits of each of the options represents the difference between the costs and benefits 

associated with that option. The costs outweigh the monetized portion of the benefits for each of 

the options, resulting in negative net monetized benefits with both a 3% and 7% discount rate. 

Under Scenario 1, the net monetized benefits range from $-85.2 million to $-133.1 million with a 

3% discount rate, and from $-86.1 million to $-134.9 million with a 7% discount rate. Under 

Scenario 2, the net monetized benefits range from $-27.4 million to $-51.1 million with a 3% 

discount rate, and from $-28.1 million to $-52.6 million with a 7% discount rate. Option 5 under 

Scenario 2 has a net monetized benefit of $-36.6 million with a 3% discount rate and $-37.7 with 

a 7% discount rate. As indicated above in the discussion of limitations of monetization of 

benefits, it should be noted that the net benefits are underestimated due to the omission of several 

types of nonmonetized benefits. 

Conclusions 

In summary, the total expected annual incremental cost of the rule across all sectors is between 

$86.5 million and $135.6 million under the first scenario, and between $28.5 million and 

$53.2 million under the second scenario. All but one of the regulatory options under Scenario 1 

have a cost above the $100 million adverse impact threshold for the purposes of EO 12866 

and 13422, while all options under Scenario 2 are below this threshold. 

The selected option, Option 5 under Scenario 2, has an expected incremental cost of 

$38.2 million with a total emissions reduction of 316 ODP-weighted tonnes or 1.8 MMTCE. The 

value of the monetized portion of the avoided health effects is less than the total incremental cost 

for all regulatory options, but there are nonmonetized benefits that are omitted from those 

estimates. 

The RFA screening analysis found that the revised rule will only significantly impact between 

1,396 and 1,775 small businesses under Scenario 1 and between 336 and 409 small businesses 

under the second scenario for the purposes of the RFA. The regulatory option selected for the 

rule, described in Section 1.2, would result in a total expected annual incremental cost of 

$38.2 million and only significantly impact 353 small businesses. 
 

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1. Introduction 

Section 608 of the Clean Air Act (CAA) Amendments of 1990, the National Recycling and 

Emissions Reduction Program, required the U.S. Environmental Protection Agency (EPA or the 

Agency) to establish regulations to reduce emissions of ozone-depleting substances (ODS). 

These regulations were established to maximize the recycling of ODS, including 

chlorofluorocarbons (CFCs), hydrochlorofluorocarbons (HCFCs), and their blends. 

CFR Title 40, Part 82, Subpart F (2003) details the rules and regulations that prohibit knowingly 

venting ODS from refrigeration and air-conditioning equipment during maintenance, service, 

repair, or disposal of the equipment and addresses several issues, including: 

 Leak repair in refrigeration and air-conditioning equipment with a charge size greater 

than 50 pounds 

 Service practices that maximize the recycling of ODS during the servicing and disposal 

of air-conditioning and refrigeration equipment 

 Certification requirements for the equipment and technicians involved in the recycling, 

recovery, and reclamation of ODS 

 Restrictions on the sale of refrigerants to certified technicians 

 Certification of servicing equipment 

 Safe disposal requirements for appliances that are disposed of with their charges intact 

 Recordkeeping requirements 

 Enforcement. 

The EPA is considering revising the rules associated with leak repair and recordkeeping 

requirements for equipment with a charge size greater than 50 pounds of an ODS refrigerant 

used in comfort cooling (CC), commercial refrigeration (CR), and industrial process refrigeration 

(IPR). This report documents an economic screening analysis conducted to evaluate the impact 

of the proposed revisions. 

This document provides information to assist the Agency in satisfying its obligations under 

relevant statutes and Executive Orders (EOs) such as EO 12866, 13132, 13045, and 12898; the 

Paperwork Reduction Act; the Regulatory Flexibility Act (RFA); and the Unfunded Mandates 

Reform Act (UMRA) of 1995 (P.L. 104-4). EO 12866 directs agencies to prepare a Regulatory 
 

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Impact Analysis (RIA) for any “significant regulatory action.” The EO defines a “significant 

regulatory action” to be any regulation that may: 

 Have an annual effect on the economy of $100 million or more or adversely affect in a 

material way the economy, a sector of the economy, productivity, competition, jobs, the 

environment, public health or safety, or State, local, or tribal governments or 

communities 

 Create a serious inconsistency or otherwise interfere with an action taken or planned by 

another agency 

 Materially alter the budgetary impact of entitlements, grants user fees, or loan programs 

or the rights and obligations of recipients thereof 

 Raise novel legal or policy issues arising out of legal mandates, the President’s priorities, 

or the principles set forth in the EO. 

Pursuant to the terms of the EO, the revision to the rule has the potential to meet the criteria of 

the first condition above, depending on the regulatory option chosen. 

Under section 202 of the UMRA, EPA generally must prepare a written statement, including a 

cost-benefit analysis, for proposed and final rules with “Federal mandates” that may result in 

expenditures to State, local, and tribal governments, in the aggregate, or to the private sector, of 

$100 million or more in any one year. In accordance with UMRA, the cost and benefit 

calculations are included in this document. 

The RFA generally requires an agency to prepare a regulatory flexibility analysis of any rule 

subject to notice and comment rulemaking requirements under the Administrative Procedure Act 

or any other statute unless the agency certifies that the rule will not have a significant economic 

impact on a substantial number of small entities (SISNOSE). Small entities include small 

businesses, small organizations, and small governmental jurisdictions. This document presents 

an economic screening analysis that examines the impacts of these proposed revisions on small 

entities. 

Table 1 shows the business sectors potentially affected by the proposed revisions and therefore 

considered in this analysis, along with the North American Industry Classification System 

(NAICS) codes (U.S. Census Bureau, 2002a). The Small Business Administration’s (SBA’s) 

Table of Size Standards by NAICS code is used to determine what constitutes a small entity 

under the RFA. These size standards are expressed in millions of dollars (annual receipts) or 

number of employees (U.S. SBA, 2007). 
 

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Table 1. Business sectors and NAICS codes examined in this 

screening analysis 

Business sector NAICS code 

Supermarkets and grocery stores 445110 

Convenience stores 445120 

Gas station convenience stores 447110 

Warehouse and club supercenters 45291 

Refrigerated warehouse and storage 49312 

Refrigerated warehouse farm product storage 49313 

Office building managers 531312 

Lodging 72 

Chemical manufacturing 325 

Pharmaceutical manufacturing 3254 

Petrochemical manufacturing 324110 

Bakeries 3118 

Food manufacturing other than bakeries 311 

Breweries 31212 

Soft drink manufacturing 312111 

Bottled water manufacturing 312112 

Ice manufacturing 312113 

Ice rinks 713940 

Elementary and secondary schools 6111 

Junior colleges, colleges, and universities 6112, 6113 

Hospitals 622 

The economic analysis examines 12 regulatory options, consisting of six leak rate repair 

requirements, each applied for two scenarios, with the scenarios representing the type of repairs. 

Leaking components that fail verification tests must be replaced under the first scenario, while 

the owners and operators may replace leaking components at their discretion under the second 

scenario. 

Based on the screening analysis described in this report, the total expected annual incremental 

costs of the rule across all sectors range between $86.5 million and $135.6 million for the six 

options under the first scenario and $28.5 million and $53.2 million for the six options under 

Scenario 2. Estimates for all but one of the options are above the $100 million per year cost 
 

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threshold under the first scenario and under the $100 million cost threshold for all options under 

the second scenario. 

This screening analysis found that the revised rule will only significantly impact between 1,396 

and 1,775 small businesses under Scenario 1 and between 336 and 409 small businesses under 

the second scenario for the purposes of the RFA. The regulatory option selected for the rule, 

described in Section 1.2, would result in a total expected annual incremental cost of 

$38.2 million and only significantly impact 353 small businesses. 

1.1 Regulatory Baseline 

1.1.1 Regulated community 

The rule examined here applies to a variety of business sectors. Most large buildings in all the 

business sectors identified in Table 1 have large CC appliances. Requirements for CR equipment 

apply to supermarkets, warehouse clubs, and refrigerated warehouses. IPR refers to appliances 

that are integral to the manufacturing process; these are used in food processing, pharmaceutical 

and chemical manufacturing, and petroleum refinement, among other applications. 

1.1.2 Current leak repair requirements 

Under the current leak repair requirements, all equipment not classified as CR or IPR, including 

CC equipment, with a charge greater than 50 pounds of an ODS must be repaired within 30 days 

of discovery when the leak rate would result in a 15% or more loss of the charge over one year. 

Leaks in CR and IPR equipment with a charge greater than 50 pounds of an ODS must be 

repaired within 30 days of discovery if lack of repair would result in the release of 35% or more 

of the charge over one year. These requirements may be waived if the owners develop a one-year 

retrofit or retirement plan for the leaking equipment within 30 days of leak discovery. The 

deadlines for repair and retrofit/retirement may be extended if the owner of the equipment 

qualifies for one of several exemptions provided in these rules. 

In the case of IPR, like CR, owners or operators are allowed 30 days to repair the leak (however, 

they may be allowed up to 120 days for repair if an industrial process shutdown is required for 

repairs). Unlike CR, IPR equipment owners or operators are also required to conduct an initial 

verification of a repair and a follow-up verification within 30 days. If the initial or follow-up 

verification indicates that the repair was unsuccessful, EPA must be informed within 30 days and 

the equipment must be retired or retrofitted. The requirement to retire or retrofit may be avoided 

if within 30 days of the first unsuccessful verification (120 days for an industrial process 

shutdown) the leak is successfully repaired, as determined by an initial and follow-up 
 

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verification. A failed initial or follow-up verification following the second 30-day repair period 

requires retrofitting or retirement of the equipment. 

1.1.3 Current recordkeeping and reporting requirements 

Section 82.166 of CFR Title 40, Part 82, Subpart B, details recordkeeping requirements. The 

current requirements potentially affected by this rule follow: (1) technicians servicing large 

appliances (those containing 50 pounds or more of refrigerant) must provide the owner or 

operator with an invoice that details the amount of refrigerant added to the appliance, and must 

maintain a copy for their own records; and (2) owners or operators of large appliances must keep 

servicing records documenting the date and type of service and the amount of refrigerant added. 

1.2 Proposed Regulatory Revisions 

1.2.1 Proposed leak repair requirements 

EPA is proposing to change the leak repair requirements for equipment used for CC, CR, and 

IPR containing more than 50 pounds of ODS refrigerant, and associated practices by owners and 

operators of such equipment. The proposed rule would require owners and operators of leaking 

equipment to repair all leaks within 30 days of discovery that the leak rate exceeds the proposed 

regulatory threshold. This economic analysis examines the impact of the options, shown in 

Table 2, representing different annual leak rate thresholds for the proposed rule under two 

scenarios for required repairs resulting in 12 regulatory options. 

Table 2. Options for annual leak rates 

Leak rate since last verification 

Option CC CR and IPR 

1 (5% and 10%) 5% 10% 

2 (5% and 20%) 5% 20% 

3 (5% and 30%) 5% 30% 

4 (10% and 10%) 10% 10% 

5 (10% and 20%) 10% 20% 

6 (10% and 30%) 10% 30% 
 

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Scenario 1 

 Owners or operators of refrigeration and air-conditioning equipment must repair a leak 

that exceeds the leak rate threshold within 30 days of discovery, and must conduct an 

initial verification test immediately upon completion of repairs, and a follow-up 

verification test within 30 days of completion but no sooner than 24 hours after repair and 

recharge of the appliance 

 If either the initial verification or the follow-up verification test indicates that the repairs 

have not been successful, meaning that leaks are still apparent within the appliance 

component(s) requiring repair, the owner or operator must replace the leaking 

component(s) in its/their entirety within 30 days of the failed verification. Owners or 

operators that have replaced any two components of the leaking equipment within a 

consecutive 12-month period due to the failure of an initial verification or follow-up 

verification test must replace the leaking component, and retire the equipment or retrofit 

it to use non-ODS refrigerants (i.e., retrofit or retirement occurs after three failed 

verifications in a 12-month period). 

 Owners and operators do not have to repair leaks within 30 days if they retire the 

equipment or retrofit it to use non-ODS refrigerants. 

Scenario 2 

 Scenario 2 is similar to Scenario 1, except that the type of repairs conducted are left to the 

discretion of owners and operators (i.e., there are no required component replacements). 

Similar to the current rules, deadlines for repair and retrofit may be extended if the owner of the 

equipment qualifies for one of several exemptions provided in these rules. Because of a lack of 

data, this analysis does not address differences in the methods for calculating the annual leak rate 

between the current and proposed rules. 

The regulatory alternative selected for the proposed rule is Option 5 under Scenario 2. This 

option represents annual leak rate thresholds of 10% for CC and 20% for CR and IPR, with no 

required component replacements and the type of repairs conducted left to the discretion of 

owners and operators. 
 

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1.2.2 Proposed recordkeeping and reporting requirements 

1. Technicians servicing large appliances (those containing 50 pounds or more of 

refrigerant) must: 

a. Provide the owner or operator with an invoice or other documentation which 

includes: the quantity and type of refrigerant added to the appliance; the identity 

and location of the appliance; the date and type of service performed; the physical 

location of any leaks; the amount and type of refrigerant recovered from the 

appliance; and the date, method, and results of initial verification and follow-up 

verification tests 

b. Maintain records for a minimum of three years on refrigerant recovered but not 

returned to appliances. 

2. Owners or operators of large appliances (those containing 50 pounds or more of 

refrigerant) must maintain on site for a minimum of three years: 

a. Records documenting the quantity and type of refrigerant added to the appliance; 

the full charge of the appliance; the calculated leak rate of the appliance; the 

identity and location of the appliance; the date and type of service performed; the 

physical location of any leaks; the amount and type of refrigerant recovered from 

the appliance; and the date, method, and results of initial verification and followup verification tests 

b. Records on refrigerants purchased 

c. Records of the types and amounts of refrigerant recovered from their appliances 

that are transferred to a different owner 

d. A dated retrofit or retirement plan that establishes a six-month schedule to retrofit 

or retire the leaking appliance 

e. Information justifying any inability to complete repairs or retrofits/retirements on 

schedule 

f. Documents showing all appliance or appliance component data, measurements, 

calculations, and assumptions used to determine the full charge 

g. Amount and type of refrigerant and the date that refrigerant was added to and 

removed from the appliance due to seasonal variance. 
 

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1.3 Analytical Requirements 

EPA is required to evaluate the anticipated economic impact of the proposed revisions. This 

involves performing a screening analysis to estimate the total impact of the rule on the economy 

and to determine whether a full RIA is necessary, and conducting a screening analysis to ensure 

agencies endeavor, consistent with the objectives of the rule and applicable statutes, to fit 

regulatory and information requirements to the scale of businesses, organizations, and 

governmental jurisdictions subject to their regulations. 

As mentioned previously, an economically significant regulatory action is an action that may 

have an annual effect on the economy of $100 million or more. A significant regulatory action 

requires a detailed RIA with an assessment of the costs and benefits of the action and alternative 

regulatory options. 

EPA guidance (U.S. EPA, 2006a) details specific requirements for the assessment of whether or 

not a rule has a SISNOSE. Consistent with the EPA guidance, the analysis presented here was 

performed at multiple levels of aggregation. Results are summarized at the level of the overall 

rulemaking (i.e., encompassing all affected NAICS codes), at the level of individual NAICS 

codes, and at the level of company size categories (defined in terms of the number of 

employees). Small businesses are defined in this analysis by annual receipts or number of 

employees, as appropriate. 

1.4 Contents 

The rest of this report is laid out as follows: 

 Section 2, approach, describes the methods employed in this screening analysis 

 Section 3, industry characterization, describes the affected sectors and states assumptions 

made about each industry category 

 Section 4, economic impacts analysis, presents results of the cost analysis 

 Section 5, benefits estimation, presents results of the benefits analysis (based on weighted 

avoided emissions) 

 Section 6, synthesis of benefits and costs, indicates the efficiency of the potential 

regulatory changes in terms of cost per weighted pound of emissions reduced 
 

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 Section 7, statutory and EO impact analysis, summarizes analyses of the proposed rule’s 

impacts that are needed to meet certain relevant regulatory development statutes and EOs 

 Section 8, conclusions, summarizes the findings 

 A bibliography follows 

 The attachment presents detailed tables of results of the screening analysis. 

2. Approach 

The analyses of the impacts of different options for the proposed rule were based on a model 

entity approach to estimate the impact on the economy as a whole (i.e., aggregate cost of each 

option for the proposed rule) and on small businesses individually (i.e., for a RFA screening 

analysis). The model entity analysis was developed from a model facility analysis, which relied 

on a model equipment analysis. The steps follow. 

1. The compliance cost associated with repair of the different kinds of equipment affected 

by the rule were calculated in the model equipment analysis based the type of equipment, 

the type of repair required, and related labor and materials costs. 

2. The costs associated with the facilities were calculated in the model facility analysis 

based on the compliance costs for individual pieces of equipment developed in the 

previous step and the equipment typically used in a given type of facility. The model 

facilities varied by affected business sector and size (defined by number of employees) in 

terms of the types and number of pieces of equipment used. 

3. The costs associated with entities were calculated in the model entity analysis based on 

the model facility costs developed in the previous step and the number of facilities in an 

entity. The number of facilities owned by an entity varied by affected business sector and 

size. Therefore, each model entity reflected information about the typical number of 

facilities an entity has in a given sector and size, and the number of pieces of equipment 

in each equipment category that are likely to be owned and/or operated by each facility. 

2.1 Repair and Retire/Retrofit Actions 

The proposed revisions result in compliance costs for owners or operators when leaks are 

identified in CC, CR, and IPR equipment. Four repair levels (relying on different sequences of 

four different types of repairs) were assumed in this analysis, based on possible scenarios 
 

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resulting from compliance with the rule. Table 3 describes the possible types of repairs and their 

rates of success, while Table 4 lists the sequence of repair types at the four repair levels for the 

two scenarios under consideration (the first requiring component replacements and the second 

leaving the type of repair to the discretion of the owner or operator). This analysis assumes that 

under the second scenario, the owner or operator will attempt lower cost repairs rather than 

immediately resorting to component replacement, but that they will choose to attempt higher cost 

repairs with greater rates of success as they get closer to the retrofit/retirement requirement. 

Detailed information on the actions and associated costs for each repair type are discussed in 

Section 4.2. The leakage assumptions indicate the amount of days the equipment leaks before a 

repair. For repair level 1, it is assumed that it takes 30 days for a leak in a piece of IPR or CR 

equipment to be discovered and 60 days for a leak in a piece of CC equipment. In addition, 

owners or operators of equipment have 30 days from the date of discovery to repair a leak. Using 

a worst case scenario, it is assumed that owners or operators take the maximum time allowed to 

repair the leak, resulting in a total of 60 days of leakage for IPR and CR and 90 days for CC. 

Looking again at a worst case scenario for subsequent repair levels (where repairs are conducted 

as a result of a failed verification of a repair at a previous level) it is assumed that the prior repair 

fails a follow-up verification conducted 30 days after the repair (i.e., the prior repair was 

unsuccessful and equipment leaked for the 30 days before the verification was performed), and 

the subsequent repair is done 30 days after the failed verification resulting in a total of 60 days of 

leakage. This information was used first in the model equipment analysis to develop the 

compliance costs associated with repairing or retrofitting a piece of equipment. 

Table 3. Types of repairs 

Repair type Actions taken 

Repair success 

rate (%) 

Repair type A Perform leak test, recover refrigerant, perform vacuum test, replace gaskets 

and seals, tighten joints, recharge system, and verify 

80 

Repair type B Perform leak test, recover refrigerant, perform vacuum test, replace low-cost 

subcomponent component (e.g., coupling or valve), recharge system, and 

verify 

90 

Repair type C Perform leak test, recover refrigerant, perform vacuum test, replace 

component (e.g., compressor), recharge system, and verify 

95 

Repair type D Recover refrigerant, retrofit or retire equipment, recharge system, perform 

leak test, and report 

100 

Source: Expert judgment of SAIC, Inc. 
 

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Table 4. Types and sequence of repairs assumed for each repair level in the 

different scenarios 

Scenario 1 Scenario 2 

Repair level 

Type of 

repair 

Leakage 

assumptions 

Repair 

success rate 

Type of 

repair 

Leakage 

assumptions 

Repair 

success rate 

Repair level 1 B 90 days of refrigerant 

leakage for CC 

equipment, and 

60 days for CR and 

IPR equipmenta

90 A 90 days of refrigerant 

leakage for CC 

equipment, and 

60 days for CR and 

IPR equipmenta

80 

Repair level 2 C 60 days of refrigerant 

leakageb

95 B 60 days of refrigerant 

leakageb

90 

Repair level 3 C 60 days of refrigerant 

leakageb

95 C 60 days of refrigerant 

leakageb

95 

Repair level 4 C and D 60 days of refrigerant 

leakageb and system 

must be fully 

recharged 

95 for repair 

type C 

100 for 

repair type D

A and D 60 days of refrigerant 

leakageb and system 

must be fully 

recharged 

80 for repair 

type A 

100 for 

repair type D

a. 30 days for leak discovery for IPR and CR and 60 days for CC, and 30 days to repair after leak detection.

b. 30 days for follow-up verification for prior repair, and 30 days to repair after failed follow-up verification.

Source: Expert judgment of SAIC, Inc. 

2.2 Evaluating the Aggregate Incremental Impact of Proposed 

Rule on the Economy 

The aggregate incremental impact on the economy was based on model equipment, model 

facility, and model entity compliance costs. 

2.2.1 Model equipment costs 

An expected cost of compliance for an owner or operator of a piece of cooling or refrigeration 

equipment with a charge size greater than 50 pounds of an ODS refrigerant was calculated as 

follows, based on the costs associated with each piece of model equipment and the likelihood of 

each regulatory scenario. First, equipment was divided into two groups: group 1 consisted of 

equipment affected by the current rule, and group 2 consisted of newly affected equipment. 

Then, the probability that a piece of equipment would stop leaking above the rate in the proposed 

revisions was calculated at each of the four stages (e.g., the percentage of equipment that would 

have no repair requirement versus the percentage of equipment that would go only through repair 
 

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level 1 versus the percentage of equipment that would go through repair levels 1, 2, and 3) such 

that the combined probabilities of ending at each of the stages for group 1 and group 2 sum to 

one (see the attachment to this report). Then, the aggregate cost associated with reaching each 

level for each group was calculated. It was assumed that to reach the next level of repairs, an 

owner or operator of the equipment would go through all prior levels and incur all of the 

associated costs (e.g., to reach level 3, one would incur all costs from levels 1, 2, and 3). 

We assumed that owners and operators of refrigeration and cooling equipment with a charge size 

greater than 50 pounds of an ODS would make repairs only as mandated by regulation, which is 

likely to lead to an overestimate of the costs. In all likelihood, there would be some cases in 

which normal maintenance would involve making similar repairs to ensure that the system in 

question was operating smoothly and performing its function regardless of proposed changes to 

the rule. In addition, in some cases, owners and operators could choose to skip one of the 

regulatory steps (e.g., move from making minor repairs to replacing a major component without 

replacing a minor component), thus reducing the expected cost of the rule. 

The probability of equipment in each group ending at each regulatory level was then multiplied 

by the aggregate cost of reaching that level to find the expected cost of each level for a given 

piece of equipment [e.g., the probability of a newly affected direct expansion (DX) CR system 

completing its regulatory requirement with level 1 repairs was multiplied by the costs associated 

with those group 2 level 1 repairs for a DX system]. The expected costs associated with both 

groups at each regulatory level were summed to find the total expected cost of the regulation for 

a given piece of equipment. Expected costs were calculated for both a baseline scenario 

(i.e., following current regulatory requirements) and different options for the proposed rule. The 

baseline assumed that for CC and CR equipment, owners and operators would be required to 

perform the actions associated with repair type A (with the exception of verification). For 

industrial process equipment, it was assumed that owners and operators would choose to conduct 

the a similar sequence of repairs to those outlined in Scenario 2.1

2.2.2 Model facility costs 

The percentage of facilities that use each type of equipment within the three equipment 

categories was then multiplied by the expected cost of each type of equipment, and these 

products were summed within each equipment category to get the expected cost of a piece of 

 

1. Although the current rule allows owners and operators of IPR equipment the opportunity to attempt to repair 

equipment that is leaking greater than 35% of its full charge and which has failed an initial verification test as 

many times as they wish over a 30-day period, we assumed for this analysis that attempting to replace a part in 

the component subassembly at the beginning of the 30-day period, followed by a component in its entirety 

nearing the end of the 30-day period, was a logical course of action before committing to a retrofit or system 

retirement. 
 

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equipment in each of the three equipment categories. For instance, in the supermarket sector, the 

expected cost of a DX system was multiplied by the percentage of supermarkets likely to have a 

DX system, the expected cost of a distributed system was multiplied by the percentage of 

supermarkets likely to have a distributed system, and these values were summed to get an 

expected cost of a piece of CR equipment in a facility within the supermarket sector. 

For each size category within each sector, the expected cost of a piece of equipment in each 

equipment category was multiplied by the number of pieces of equipment in that category that a 

typical facility is likely to have, and the products in each category were summed to find the total 

expected cost per facility. In the supermarket example, a supermarket with fewer than 

20 employees is likely to have one piece of CC equipment, three pieces of CR equipment, and no 

IPR equipment. Thus, the expected cost of a piece of CC equipment was multiplied by one, the 

expected cost of a piece of CR equipment was multiplied by three, and the expected cost of a 

piece of IPR equipment was multiplied by zero. These products were then summed to find the 

total expected cost to a facility. 

2.2.3 Model entity costs and incremental impacts of the rule 

The expected cost per facility was multiplied by the number of facilities that an entity in each 

size category of each sector is likely to have to ascertain the expected cost per entity. This was 

then multiplied by the number of entities in each size category to find the expected cost per size 

category in each sector. The expected costs in the size categories were summed to find the 

expected cost per sector. The totals from all affected sectors were summed to find the total 

impact of the baseline scenario and of each option for the proposed rule. The total expected cost 

of the baseline scenario was then subtracted from the total expected cost of each option for the 

proposed rule to find the incremental expected cost of the options for the proposed rule. 

2.3 Estimating the Impact of the Proposed Rule on Small Entities 

The RFA generally requires an agency to prepare a regulatory flexibility analysis of any rule 

subject to notice and comment rulemaking requirements under the Administrative Procedure Act 

or any other statute unless the agency certifies that the rule will not have a SISNOSE. Small 

entities include small businesses, small organizations, and small governmental jurisdictions. 

For purposes of assessing the economic impacts of this rule on small entities, a small entity is 

defined as: (1) a small business as defined by the SBA’s regulations at 13 CFR 121.201; (2) a 

small governmental jurisdiction that is a government of a city, county, town, school district or 

special district with a population of less than 50,000; and (3) a small organization that is any notfor-profit enterprise which is independently owned and operated and is not dominant in its field. 
 

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A statistical technique known as Monte Carlo analysis was used to estimate the number of 

entities, in each relevant size category, expected to experience costs exceeding 1% (and 3%) of 

revenues. The RFA requires the assessment of small government jurisdictions and small 

nonprofits; the analysis of these entities was based on operating expenses rather than revenues as 

for for-profit entities. Because of the lack of information on small nonprofits and governments 

that might be affected by the rule, it was not possible to calculate the typical cost per entity or the 

impact ratios for them. However, the cost for nonprofits and governments was expected to be 

similar to that incurred by businesses. In particular, the education sector (largely nonprofit) was 

not evaluated in the RFA screening analysis because of a lack of information on operating 

expenses and revenues. The nature of educational buildings is such, however, that it was 

assumed they would be likely to have impacts that are similar to those experienced for small 

office buildings. 

2.4 Monte Carlo Analysis 

Individual analyses were performed for each of the sectors. These analyses were based on typical 

facilities in each of the size categories within a sector that use refrigeration and air-conditioning 

equipment with charge sizes greater than 50 pounds. The costs associated with these facilities 

were then aggregated to assess costs at the entity level. These entity level costs were then 

compared with average revenues per entity to estimate the number of entities significantly 

affected by different options for the proposed rule. 

Estimating the number of entities in each size category requires careful consideration of a 

complex set of joint probabilities. For example, the model warehouse and club supercenter 

facility contains six pieces of equipment (two CC systems and four CR units), and each piece of 

equipment has the potential to reach four different repair levels (as well as the “no leak” level), 

leading to many possible permutations of cost combinations for this sector. Although most of the 

permutations may result in a facility cost below 1% of revenues, it is important to estimate how 

many facilities are expected to experience costs that exceed 1% (and 3%) of revenues. 

This analysis used a Monte Carlo technique to simulate numerous model facilities (each analysis 

used 65,000 sample facilities). Each piece of affected equipment in each sample facility was 

randomly assigned a type of equipment and a repair level. The probability of each piece of 

equipment requiring repair was assumed to be independent of the probability of repair for other 

pieces of equipment in the same sample facility. The analysis estimated the percentage of these 

sample facilities with a total cost exceeding 1% (and 3%) of revenues. 

The cost of repair for each piece of equipment was calculated using the assigned equipment 

types and repair level. Again it was assumed that to reach each repair level all previous repair 

levels were reached (e.g., to reach repair level 3, one would incur costs associated with repair 
 

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levels 1, 2, and 3). The sample facility’s total cost of required repairs to all pieces of equipment 

is the sum of the cost for each piece of equipment. These facility-level costs were multiplied by 

the number of facilities per entity in each size category to estimate the entity-level cost of 

compliance. Multiplying by the number of facilities represents a slight overestimation of costs 

for facilities with multiple instances of high level repairs, because the probabilities of reaching 

those repair levels for all equipment in multiple facilities decrease as the aggregate number of 

pieces of equipment across both facilities increases. 

This process was followed for each type of model entity 65,000 times to find 65,000 sample 

costs of compliance based on the joint probabilities of having specific types of equipment and 

reaching specific repair levels. The percentages of scenarios where entities had costs that were 

greater than 1% and 3% of average revenues in a given size category were calculated. These 

percentages were then multiplied by the potential number of affected entities in each size 

category to find an estimate of the number of affected entities and to assess whether or not the 

proposed rule should be presumed to have a SISNOSE. Fractional numbers of entities were 

rounded up to the nearest whole entity. 

The economic analysis described in this section was conducted to examine the impacts on the 

affected business sectors that are described in Section 3. 

2.5 Benefits Estimation 

The environmental benefits of the options examined for revising the rule are the ODS emissions 

that would be avoided as a result of rule modifications. This screening analysis estimates the 

environmental benefits as pounds of avoided ODS emissions, measured in terms of both ozonedepleting potential (ODP) (i.e., as ODP-weighted tonnes) and global warming potential (GWP) 

[million metric tonnes of carbon equivalent (MMTCE)]. 

The benefits analysis, like the cost analysis, uses the model plant method to estimate the 

expected benefits of the proposed rule. The benefits analysis builds up benefits from the 

expected benefits of a model piece of equipment to the expected benefits in a size category to the 

total benefits of the rule. 

The benefits analysis makes the following assumptions: 

 As in the cost analysis, it is assumed that once a repair has been made, whether or not it is 

successful, there will be no subsequent repairs unless mandated by regulation (i.e., unless 

a repair is verified and fails). 

 The benefits of the rule are projected only over the one-year period in which costs are 

assumed to be incurred. 
 

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 As with the cost analysis, it is assumed in the benefit analysis that owners or operators 

will wait the full 30 days before performing a follow-up verification and the full 30 days 

before fixing a leaking system or performing a mandatory component replacement. In 

addition, owners and operators are expected to wait the full 180 days allowed to retrofit 

or retire a system from the time of the third failed verification. 

2.5.1 Baseline benefits 

The baseline benefits of the current rule are consistent with the baseline costs of the current rule. 

For CC and CR equipment, it is assumed that under the current rule owners or operators will 

make a single repair to a system leaking over the trigger rate of 15% and 35%, respectively. For 

IPR equipment, it is assumed that once a system reaches the trigger rate (35%), a certain 

percentage of owners/operators will conduct each of the four repair levels. However, once an 

owner or operator has decided to retrofit or retire their system, it is unlikely that under the 

current rule they will choose to replace a third component before retrofitting or retiring the 

equipment. 

2.5.2 Benefits of proposed changes 

The options under consideration for the proposed rule would result in avoided emissions based 

on the repair level at which a successful repair is completed. The cumulative amount of assumed 

time that passes before each repair is completed follows: 

 Repair level 1, 30 days 

 Repair level 2, 90 days 

 Repair level 3, 150 days 

 Repair level 4, repair type A or C, 210 days 

 Repair level 4, repair type D, 365 days. 

For example, if the first repair was completed at the end of the 30-day period and was successful, 

the proposed rule avoided 11 months of emissions that would have occurred if the repair had not 

been made. If the repair was unsuccessful (as determined by a follow-up verification at the end 

of the 30-day period) and a successful component replacement was performed (at the end of a 

30-day period), 9 months of emissions would have been avoided. 
 

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2.5.3 Health benefits analysis 

Reducing ODS emissions will reduce depletion of stratospheric ozone concentrations, leading to 

reductions in ultraviolet (UV) radiation reaching the Earth’s surface. Reduced UV radiation at 

the surface will lead to reductions in adverse UV-related human and animal health effects, as 

well as ecosystem impacts. In previous EPA analyses, the quantified benefits of stratospheric 

ozone protection programs were dominated by the reduced adverse health impacts expected from 

reductions in UV radiation. Because health effects were found to be the dominant quantified 

benefit category for stratospheric ozone protection, this economic screening analysis of the 

options for reducing ODS emissions is limited to an analysis of the most important type of 

quantified health effect: skin cancers. 

The health analysis uses EPA’s Atmospheric Health Effects Framework (AHEF) to estimate the 

reductions in fatal and nonfatal cases of skin cancers. AHEF was originally developed for EPA 

to conduct the analysis of the Montreal Protocol on Substances that Deplete the Ozone Layer, 

and has been revised and updated numerous times to incorporate new scientific information and 

emissions data. The analysis in this screening analysis uses the version of AHEF, which is 

described in detail in a 2006 EPA peer reviewed report (U.S. EPA, 2006b). AHEF is used to 

estimate the reductions in future cases of fatal and nonfatal skin cancers that will result from 

emissions reductions in a single year (2010). The single-year estimates of the rule’s ODS 

emissions reductions is consistent with the single-year cost estimates in this screening analysis. 

ODS emissions reductions in subsequent years will produce additional health benefits (and have 

additional costs). The economic value of the reductions in future cases of skin cancers is derived 

from methods used in previous EPA regulatory analyses. The economic values have been 

updated to reflect 2007 prices and 2010 income levels. 

2.6 Synthesis of Benefits and Costs 

2.6.1 Cost-effectiveness estimation 

A cost-effectiveness (C-E) analysis explores a different aspect of a set of proposed regulatory 

options. While a complete benefit-cost analysis compares all incremental benefits with the 

incremental costs for each option, C-E analysis examines the cost per kilogram of avoided 

emission for each option. C-E is calculated by dividing the total cost of an option by the avoided 

emissions for that option. The C-E analysis of the leak rate regulatory options helps identify the 

equipment categories that are relatively less expensive per pound of avoided emissions as well as 

the incremental costs of increasing the stringency of the regulation on each equipment type. C-E 

analysis also helps compare the relative costs of this rule with other rules reducing ODS 

emissions. 
 

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2.6.2 Net benefits estimation 

A net benefits analysis compares the incremental benefits with the incremental costs for each 

option as compared to the baseline with the difference representing net benefits. 

3. Industry Characterization 

Section 608 leak repair regulations (40 CFR Part 82, subpart F) affects owners and operators of 

equipment with a charge size of 50 pounds or greater of an ODS refrigerant in the following 

categories: 

 CC 

 CR 

 IPR. 

This section characterizes each category by equipment types, charge sizes, and leak rates and 

identifies the affected businesses within each sector. In the RFA screening analyses, the affected 

businesses are frequently analyzed based on NAICS codes. These codes are useful because the 

U.S. Census Bureau collects information about the number of businesses, breaks them down by 

number of employees, and estimates the volume of sales (i.e., revenues) for each code. 

This section provides information on the extent of use of different equipment types within each 

of the categories and typical charge sizes and types of refrigerants used by each of the equipment 

types. An A.D. Little (2002) report provides a more detailed description of different airconditioning and refrigeration equipment, including types of refrigerants used and charge sizes. 

The only consistent source of information on equipment leaks (affected by this rule) on an 

annual basis is California’s South Coast Air Quality Management District (SCAQMD) data. 

Similar to federal regulations, the purpose of SCAQMD Rule 1415 (SCAQMD, 1994) is to 

reduce emissions of Class I and Class II refrigerants from stationary refrigeration and airconditioning systems by requiring any person within SCAQMD’s jurisdiction who owns or 

operates a refrigeration system to reclaim, recover, or recycle refrigerant and to minimize 

refrigerant leakage. A refrigeration system is defined for the purposes of the rule as any 

nonvehicular equipment used for cooling or freezing that holds more than 50 pounds of any 

combination of Class I and/or Class II refrigerant, including but not limited to refrigerators, 

freezers, and air-conditioning equipment or systems. 

Under Rule 1415, SCAQMD collects information every two years from owners and operators of 

stationary refrigeration systems holding more than 50 pounds of an ozone-depleting refrigerant 

using a standard registration form (AQMD, 2006). The information includes the number of 

refrigeration systems in operation, the type of refrigerant in each refrigeration system, the 
 

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amount of refrigerant in each refrigeration system, the date of the last annual audit or 

maintenance performed for each refrigeration system, and the amount of additional refrigerant 

charged every year. The SCAQMD data do not differentiate between small and large businesses. 

For the purposes of the rule, additional refrigerant charge is defined as the quantity of refrigerant 

(in pounds) charged to a refrigeration system to bring the system to a full-capacity charge and to 

replace the refrigerant that has leaked. Information from 2004 and 2005 was used to develop the 

proportion of equipment expected to leak and the expected leak rates by equipment type for this 

analysis. It was assumed that equipment used in southern California is similar to that used in the 

rest of the country and that the leak rates observed there are representative of the rest of the 

country. 

This section also characterizes the affected business sectors by size categories based on the 

number of employees, the number of entities in each size category, the number of facilities per 

entity, the number of entities using equipment with a charge size greater than 50 pounds of an 

ozone-depleting refrigerant, and the average revenues. 

3.1 Comfort Cooling 

Most businesses rely on air-conditioning units to provide CC for their employees and customers. 

The CC equipment with an ODS refrigerant charge size of 50 pounds or greater, and therefore 

affected by this rule, includes: 

1. DX equipment that cools building air directed via ductwork over evaporator cooling 

coils. This is in contrast to chiller systems (number 4 in this list) where chilled water is 

passed through an evaporator.

2. Unitary roof-top equipment that is mounted on the roof deck which can have an 

integrated or remote condenser. Each unit may house several smaller compressors staged 

and optimized to satisfy the cooling load. 

3. Large split systems where the refrigerant is used as the main heat transfer fluid 

throughout the building and circulates between the condensing unit and evaporator 

through long refrigerant lines. Evaporators are typically located within the spaces that 

they condition and can be integrated with the terminal room distribution systems. Some 

units come equipped with reversing valves, which enable them to act as a heat pump 

providing both heating and cooling. Compressors are typically located in attics or 

mechanical rooms and condensers are outdoors. This system is marketed as ductless 

splits specifically targeting buildings that do not have room to accommodate large ducts 

for air distribution. 
 

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4. Chillers that do not directly condition building air but instead cool water as a secondary 

refrigerant circulated in a chilled water loop. Typically they are used in applications such 

as large office buildings where the cooling load is significantly higher than could be 

economically satisfied by a series of smaller unitary systems, or where it is impractical to 

distribute smaller units throughout a building. Chillers typically use a reciprocating, 

screw, or centrifugal compressor. 

a. Reciprocating chiller compressors use a reciprocating piston driven by a rotating 

crankshaft to compress the refrigerant. Multiple stages can be used to produce 

higher condensing pressures. 

b. Screw type chillers have a rotary compressor with helical screws. The 

interlocking grooves in the compressor screws compress the refrigerant as they 

rotate. 

c. Centrifugal chiller compressors use a mechanical impellor rotating at high speeds 

to compress the refrigerant. The refrigerant is compressed in either a single- or a 

multistage compression process. 

3.1.1 CC equipment characterization 

Table 5 shows the estimated distribution of equipment type (with an ODS charge size greater 

than 50 pounds) used for CC, typical equipment charge sizes, and types of refrigerants used. It is 

estimated that chillers account for half the equipment, and DX, unitary roof top, and large split 

systems equally account for the remaining half. Because 5% and 10% are the different leak rate 

requirements being examined in this analysis for CC, the percentage of equipment affected under 

those rates and the average leak rates, based on 2,701 pieces of equipment represented in the 

SCAQMD data, are shown in Table 6. 

3.1.2 Affected business sectors in the CC category 

The affected businesses were identified from an earlier RIA on this issue (ICF, 1997), the 

Commercial Buildings Energy Consumption Survey (CBECS; EIA, 2006), and an analysis of 

SCAQMD reports from 2004 and 2005. The CBECS data come from a national sample survey 

that collects information on the stock of U.S. commercial buildings, their energy-related building 

characteristics, and their energy consumption and expenditures. Commercial buildings include 

all buildings in which at least half of the floor space is used for a purpose that is not residential, 

industrial, or agricultural, including building types that might not generally be considered 

“commercial,” such as schools, correctional institutions, and buildings used for religious worship

(EIA, 2006).The distribution of CC equipment was estimated based on the CBECS data for 

buildings with air-conditioning equipment. The total number of commercial buildings in the 
 

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Table 5. Characterization of CC equipment 

Equipment type 

Percentage of 

systems in use 

Average charge sizea

 

(pounds) Refrigerants used 

DX 16.7 650 HCFC-22: 77.2% 

HCFC-123: 7 % 

CFC-11: 10% 

CFC-12: 1.5% 

HFCs: 4.3% 

Unitary roof top 16.7 160 HCFC-22: 95% 

HFCs: 5% 

Large split systems 16.7 160 HCFC-22: 95% 

HFCs: 5% 

Chiller (reciprocating) 42.0 338 HCFC-22: 90% 

CFC-12: 5% 

HFCs: 5% 

Chiller (screw) 4.0 1,000 HCFC-22: 90% 

CFC-12: 5% 

HFCs: 5% 

Chiller (centrifugal) 4.0 1,189 HCFC-22: 40.2% 

CFC-11: 32% 

CFC-12: 0.5% 

HCFC-123: 23% 

HFCs: 4.3% 

HFCs: Hydrofluorocarbons. 

a. While charge sizes vary by refrigerant type, the average charge sizes shown here are used in this analysis.

Sources: A.D. Little (2002) and expert opinion of SAIC, Inc., based on review of SCAQMD data. 

Table 6. CC equipment annual leak rate data

Leak rate range (%) Percent of equipment Average leak rate (%) 

0-5 85.34% 0.03%a 

5-15 3.11% 9.61% 

> or = 15 11.55% 68.67% 

0-10 87.02% 0.18%a 

10-15 1.43% 11.90% 

> or = 15 11.55% 68.67% 

a. Since the equipment in this category does not meet the proposed regulatory threshold, 

and thus is not required to act under the proposed regulation, the average leak rate in this 

range is not relevant for subsequent analyses. 

Sources: SCAQMD, 2004, 2005. 
 

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United States is 4,645,000 and the number using one or more types of air-conditioning systems is 

3,997,000 (EIA, 2006). Of these, 144,000 use chillers and 3,853,000 use a roof-top, DX, or splittype system.2

 Based on an A.D. Little (2002) study, all CC systems identified in this analysis are 

expected to have a charge size on average of 2.6 pounds per ton of cooling capacity with greater 

than 20-ton capacity, and therefore have a charge size greater than 50 pounds. 

Shipment data from the Air-Conditioning and Refrigeration Institute (ARI, 2007) were used to 

calculate the number of installed nonchiller units based on the CBECS data. Using the 

A.D. Little (2002) study and a basis of 12,000 British thermal unit (Btu)-hour per ton of air 

conditioning, all pieces of equipment having a capacity of 231,000 Btu-hour or greater are 

estimated to have at least a 50-pound refrigerant charge size. ARI shipment data indicate that 

approximately 3.8% of the unitary air-conditioning units shipped are more than 231,000 tons 

(ARI, 2007). Therefore, approximately 3.76% of the installed nonchiller air-conditioning units 

are estimated to be affected by this rule. Table 7 shows the estimates of the number of these 

systems installed in U.S. buildings that are expected to have a charge size greater than 

50 pounds. 

Table 7. Distribution of CC systems 

Equipment type 

Number of 

buildings with 

equipment 

Percentage of equipment with 

charge size greater than 

50 pounds ODS 

Estimated number of 

affected buildings 

Chillers 144,000 100 144,000 

DX, rooftop, split systems 3,853,000 3.76 145,000 

Sources: A.D. Little, 2002; EIA, 2006; ARI, 2007. 

Based on this analysis, it is expected that 289,000 buildings out of 4,645,000 total buildings in 

the United States, or approximately 6%, will have a charge size of 50 pounds or greater. This 

percentage was used to calculate the actual numbers of businesses impacted. 

Table 8 shows the businesses affected, by NAICS code, with the average number of refrigeration 

systems per facility. Three types of buildings that use CC equipment and are not included in 

Table 8 were considered in this analysis: office buildings, outpatient health care services 

buildings, and public assembly buildings. These buildings are owned by multiple owners and are 

not captured under any of the NAICS codes in Table 8; they are considered to be similar to 

facilities owned by office building managers in this analysis. 

 

2. Listed in the CBECS as residential-type central air conditioners, heat pumps, individual air conditioners, and 

packaged air conditioners. 
 

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Table 8. Sectors with CC equipment with a charge size greater than 50 pounds 

Sector NAICS code 

Average number of units of 

cooling equipment per facility 

Supermarkets and grocery stores 445110 1 

Convenience stores 445120 1 

Gas station convenience stores 447110 1 

Warehouse and club supercenters 45291 2 

Refrigerated warehouse and storage 49312 2 

Refrigerated warehouse farm products storage 49313 2 

Office building managers 531312 1 

Lodging 72 2 

Chemical manufacturing 325 4 

Pharmaceutical manufacturing 3254 4 

Petrochemical manufacturing 324110 4 

Bakeries 3118 2 

Food manufacturing other than bakeries 311 2 

Breweries 31212 4 

Soft drink manufacturing 312111 4 

Bottled water 312112 

Ice manufacturing 312113 3 

Ice rinks 713940 1 

Elementary and secondary schools 6111 2 

Junior colleges, colleges, and universities 6112, 6113 2 

Hospitals 622 4 

Source: Expert opinion of SAIC, Inc., based on review of SCAQMD data. 

3.2 Commercial Refrigeration 

Supermarkets, convenience stores, warehouses, and other businesses use CR equipment to 

preserve fresh and frozen food. The four major types of equipment in the CR sector are DX 

systems (e.g., rack type systems), distributed systems, stand-alone cases, and secondary-loop 

systems. Equipment using non-ODS as refrigerants or with charge sizes of less than 50 pounds 

are not included in this analysis because they are not affected by the proposed rule (e.g., standalone cases with charge sizes of less than 50 pounds and secondary-loop systems primarily using 

non-ODS refrigerant, typically either ammonia or R-507). 
 

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The types of equipment used in CR and potentially affected by the proposed revisions include: 

1. DX rack-type systems that are made up of multiple compressors on a single “rack” that 

circulate refrigerant throughout a store (e.g., to supply several low- or mediumtemperature display cases). Typically these systems use either reciprocating or scroll-type 

compressors with different capacities but mounted together on a single rack. They can 

support either low or medium temperature refrigeration as required for refrigerating or 

freezing food products. 

2. Distributed systems that typically have a single compressor serving a dedicated display 

case or bank of cases. They may use scroll compressors to reduce noise of operation. 

3.2.1 CR equipment characterization 

Table 9 shows the estimated distribution of equipment type (with an ODS charge size greater 

than 50 pounds) in CR, typical equipment charge sizes, and types of refrigerants used. DX 

systems charged with HCFC-22 dominate the type of refrigeration systems used across these 

businesses. Because 10%, 20%, and 30% are the different leak rate requirements being examined 

in this analysis for CR, the percentages of equipment affected under those rates and the average 

leak rates, based on 1,722 pieces of equipment represented in the SCAQMD data, are shown in 

Table 10. 

Table 9. Characterization of CR equipment 

Equipment type 

Percentage of 

systems in use 

Average charge size 

(pound)a Refrigerants used 

Rack type DX system 81 585 HCFC-22: > 87% 

CFC-12: < 1% 

HFCs: 12% 

Distributed systems 19 146 HCFC-22: 94% 

CFC-12: 2% 

HFCs: 4% 

a. While charge sizes vary by refrigerant type, the average charge sizes shown here are used in this analysis. 

Sources: A.D. Little (2002) and expert opinion of SAIC, Inc., based on review of SCAQMD data. 
 

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Table 10. CR equipment annual leak rate data

Leak rate range (%) Percent of equipment Average leak rate (%) 

0-10 69.41% 0.28%a 

10-35 15.14% 21.26% 

> or = 35 15.46% 80.25% 

0-20 76.55% 1.64%a 

20-35 7.99% 27.00% 

> or = 35 15.46% 80.25% 

0-30 81.93% 3.15%a 

30-35 2.61% 32.03% 

> or = 35 15.46% 80.25% 

a. Since the equipment in this category does not meet the proposed regulatory 

threshold, and thus is not required to act under the proposed regulation, the 

average leak rate in this range is not relevant for subsequent analyses. 

Sources: SCAQMD, 2004, 2005. 

3.2.2 Affected business sectors in the CR category 

A review of the SCAQMD data indicated that businesses in the affected NAICS codes shown in 

Table 11 use CR equipment with a charge size of 50 pounds or greater. Table 11 shows the 

businesses affected, by NAICS code, with the average number of refrigeration systems per 

facility. The three types of businesses affected by this rule are supermarkets and grocery stores, 

warehouse and club supercenters, and refrigerated warehouse and storage facilities. Convenience 

stores were originally included, however, it was determined that typical convenience store 

refrigeration systems have a charge size of greater than 50 pounds of an ODS and thus they are 

not considered in subsequent analyses. 

Table 11. Sectors with CR equipment with a charge size greater than 50 pounds and units 

per facility 

Sector NAICS code 

Average number of units of 

refrigeration equipment per facility

Supermarkets and grocery stores 445110 4.2 

Warehouse and club supercenters 45291 4 

Refrigerated warehouse and storage 49312 4 

Refrigerated warehouse farm product storage 49313 4 

Source: Expert opinion of SAIC, Inc., based on review of SCAQMD data. 
 

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3.3 Industrial Process Refrigeration 

Industrial process refrigeration is used to cool production processes and working fluids and has a 

wide range of applications, including the manufacturing of many industrial commodities such as 

pharmaceuticals, chemicals, plastics, cosmetics, food, and other products. 

Because the end uses for IPR are varied, IPR systems are often “built-up” systems that are 

specially designed for a particular application. They can, however, be characterized according to 

the compressor type, much like CC chillers. The significant difference between CC and process 

cooling is that the evaporating temperature can vary widely, depending on the process fluid 

being cooled, the production speed, and other variables. The types of equipment include: 

1. Reciprocating compressors that compress refrigerant by means of a reciprocating piston 

driven by a rotating crankshaft. Multiple stages can be used to produce higher condensing 

pressures. 

2. Screw type chillers that have a rotary compressor with helical screws. The interlocking 

grooves in the compressor screws compress the refrigerant as they rotate. 

3. Centrifugal industrial process cooling equipment that compresses refrigerant by means of 

a mechanical impellor rotating at high speed. The refrigerant is compressed in either a 

single- or a multistage compression process, depending on the evaporating and 

condensing temperature desired, the refrigerant, and the fluid being cooled. 

4. Scroll type chillers use a compressor with two interleaved spiral-like vanes to pump or 

compress fluids such as liquids and gases. 

3.3.1 IPR equipment characterization 

Table 12 shows the estimated distribution of equipment type (with an ODS charge size greater 

than 50 pounds) used for IPR, average equipment charge sizes, and types of refrigerants used. 

Because 10%, 20%, and 30% are the different leak rate requirements being examined in this 

analysis for IPR, the percentage of equipment affected under those rates and the average leak 

rates, based on 349 pieces of equipment represented in the SCAQMD data, are shown in 

Table 13. 

3.3.2 Affected businesses in the IPR category 

Table 14 shows the affected businesses that use IPR equipment identified using the SCAQMD 

data by NAICS code, with the average number of refrigeration systems per facility. 
 

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Table 12. Characterization of IPR equipment 

Equipment type 

Percentage of 

systems in use 

Charge size 

(pound)a

 Refrigerants used 

Reciprocating 22 1,189 HCFC-22: 92.4% 

CFC-12: 5% 

HFCs: 2.6% 

Screw 32 1,000 HCFC-22: 92.4% 

CFC-12: 5% 

HFCs: 2.6% 

Centrifugal 41 338 HCFC-22: 41.2% 

CFC-11: 32% 

CFC-12: 0.5% 

HCFC-123: 23% 

CFC-113: 1% 

CFC-114: 1% 

HFCs: 1.3% 

Scroll 5 160 HCFC-22: 95% 

HFCs: 5% 

a. While charge sizes vary by refrigerant type, the average charge sizes shown 

here are used in this analysis. 

Sources: A.D. Little (2002) and expert opinion of SAIC, Inc., based on review 

of SCAQMD data. 

Table 13. IPR equipment annual leak rate data 

Leak rate range (%) Percent of equipment Average leak rate (%) 

0-10 72.81% 0.24%a 

10-35 9.69% 20.45% 

> or = 35 17.50% 116.27% 

0-20 77.66% 1.12%a 

20-35 4.84% 26.59% 

> or = 35 17.50% 116.27% 

0-30 81.09% 2.10%a 

30-35 1.41% 31.89% 

> or = 35 17.50% 116.27% 

a. Since the equipment in this category does not meet the proposed regulatory 

threshold, and thus is not required to act under the proposed regulation, the 

average leak rate in this range is not relevant for subsequent analyses. 

Sources: SCAQMD, 2004, 2005. 
 

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Table 14. Sectors with IPR equipment with a charge size greater than 50 pounds and units 

per facility 

Sector NAICS code 

Average number of units of 

refrigeration equipment per facility 

Chemical manufacturing 325 4 

Pharmaceutical manufacturing 3254 4 

Petrochemical manufacturing 324110 4 

Bakeries 3118 2 

Food manufacturing other than bakeries 311 2 

Breweries 31212 4 

Soft drink manufacturing 312111 4 

Bottled water manufacturing 312112 4 

Ice manufacturing 312113 3 

Ice rinks 713940 2 

Source: Expert opinion of SAIC, Inc., based on review of SCAQMD data. 

4. Economic Impacts Analysis 

4.1 Characterization of All Affected Sectors 

Once the affected sectors in each of the categories were identified, the number of entities, the 

number of facilities, and average revenues per entity by size category were obtained from the 

U.S. Census Bureau (2002b). Table 15 shows this information along with the number of entities 

with equipment affected by the proposed revisions. The number of entities affected by the 

revisions (those with equipment greater than 50 pounds of ODS refrigerant charge) was 

estimated based on factors identified in equipment characterizations in Section 3 and the expert 

judgment of SAIC, Inc. staff. 

The CBECS (EIA, 2006) reports 824,000 office buildings, 121,000 outpatient health care 

buildings, and 277,000 public assembly buildings that use CC equipment affected by the rule 

(EIA, 2006); these are not included in Table 15. The number of office buildings reported in the 

CBECS (824,000) is clearly much larger than those managed by office building managers (about 

12,000) shown in Table 15. The difference (812,000) was assumed to be managed by multiple 

owners not captured in a single NAICS code. 
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Table 15. Industries characterized b

y size cate

gories, number of entities and facilities, facilities per entity, 

average revenues 

Sector 

NAICS 

code(s) 

Number of 

employees 

Number of 

entities 

Number of 

facilities 

Number of 

facilities 

per entity 

Number of firms us

equipment with 

> 50 lbs of an ozon

depleting refrigera

Supermarkets and grocery storesa 445110 < 20 32,246 32,374 1.00 32,246 

 20-99 6,438 7,212 1.12 6,438  100-499 1,157 3,171 2.74 1,157  500+ 335 20,177 60.23 335 

Totals 40,176 62,934 N/A 40,176 

Convenience stores 445120 < 20 28,464 28,657 1.01 1,708 

 20-99 923 1,264 1.37 55 

 100-499 141 741 5.26 8  500+ 88 3,570 40.57 5 

Totals 29,616 34,232 N/A 1,777 Gas station convenience stores 447110 < 20 34,962 35,998 1.03 2,098 

 20-99 3,665 9,043 2.47 220 

 100-499 764 10,843 14.19 46  500+ 207 28,817 139.21 12 

Totals 39,598 84,701 N/A 2,376 Warehouse and club supercenters 45291 < 20 179 179 1.00 179 

 20-99 10 11 1.10 10  100-499 4 28 7.00 4  500+ 11 2,023 183.91 11 

Totals 204 2,241 N/A 204 
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Table 15. Industries characterized b

y size cate

gories, number of entities and facilities, facilities per entity, 

average revenues (cont.) 

Sector 

NAICS 

code(s) 

Number of 

employees 

Number of 

entities 

Number of 

facilities 

Number of 

facilities 

per entity 

Number of firms us

equipment with 

> 50 lbs of an ozon

depleting refrigera

Refrigerated warehouse and storage 49312 < 20 411 420 1.02 411 

 20-99 138 204 1.48 138  100-499 34 96 2.82 34  500+ 25 250 10.00 25 

Totals 608 970 N/A 812 

Refrigerated warehouse farm product 49313 < 20 276 289 1.05 276 storage 20-99 48 78 1.63 48 

 100-499 18 73 4.06 18  500+ 21 99 4.71 21 

Totals 363 539 N/A 1,175 Office building managers 531312 < 20 8,568 8,630 1.01 514 

 20-99 880 1,172 1.33 53  100-499 239 569 2.38 14  500+ 146 1,529 10.47 9 

Totals 9,833 11,900 N/A 76 Lodging 72 < 20 342,431 344,341 1.01 20,546 

 20-99 75,392 88,963 1.18 4,524  100-499 7,954 34,731 4.37 477  500+ 1,688 97,114 57.53 101 

Totals 427,465 565,149 N/A 5,102 
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Table 15. Industries characterized b

y size cate

gories, number of entities and facilities, facilities per entity, 

average revenues (cont.) 

Sector 

NAICS 

code(s) 

Number of 

employees 

Number of 

entities 

Number of 

facilities 

Number of 

facilities 

per entity 

Number of firms us

equipment with 

> 50 lbs of an ozon

depleting refrigera

Chemical manufacturing 325 < 20 5,192 5,219 1.01 5,192 

 20-99 1,679 1,899 1.13 1,679  100-499 622 1,144 1.84 622  500+ 437 3,055 6.99 437 

Totals 7,930 11,317 N/A 7,930 Pharmaceutical manufacturing 3254 < 20 812 815 1.00 812 

 20-99 295 309 1.05 295  100-499 168 208 1.24 168  500+ 136 447 3.29 136 

Totals 1,411 1,779 N/A 1,411 Petrochemical manufacturing 324110 < 20 106 107 1.01 106 

 20-99 24 29 1.21 24  100-499 23 28 1.22 23  500+ 49 185 3.78 49 

Totals 202 349 N/A 202 Bakeries 3118 < 20 7,948 7,981 1.00 7,948 

 20-99 1,375 1,490 1.08 1,375  100-499 275 445 1.62 275  500+ 131 618 4.72 131 

Totals 9,729 10,534 N/A 11,549 
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Table 15. Industries characterized b

y size cate

gories, number of entities and facilities, facilities per entity, 

average revenues (cont.) 

Sector 

NAICS 

code(s) 

Number of 

employees 

Number of 

entities 

Number of 

facilities 

Number of 

facilities 

per entity 

Number of firms us

equipment with 

> 50 lbs of an ozon

depleting refrigera

Food manufacturing other than bakeries 311 < 20 7,703 7,745 1.01 7,703 

 20-99 2,560 2,764 1.08 2,560  100-499 972 1,506 1.55 972  500+ 420 3,149 7.50 420 

Totals 11,655 15,164 N/A 33,135 Breweries 31212 < 20 292 292 1.00 292 

 20-99 95 98 1.03 95  100-499 18 24 1.33 18  500+ 10 32 3.20 10 

Totals 415 446 N/A 66,685 Soft drink manufacturing 312111 < 20 132 132 1.00 132 

 20-99 73 74 1.01 73  100-499 62 73 1.18 62  500+ 50 272 5.44 50 

Totals 317 551 N/A 317 Bottled water 312112 < 20 181 181 1.00 181 

 20-99 33 38 1.15 33  100-499 8 11 1.38 8  500+ 7 55 7.86 7 

Totals 229 285 N/A 229 
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Table 15. Industries characterized b

y size cate

gories, number of entities and facilities, facilities per entity, 

average revenues (cont.) 

Sector 

NAICS 

code(s) 

Number of 

employees 

Number of 

entities 

Number of 

facilities 

Number of 

facilities 

per entity 

Number of firms us

equipment with 

> 50 lbs of an ozon

depleting refrigera

Ice manufacturing 312113 < 20 369 370 1.00 369 

 20-99 44 55 1.25 44  100-499 6 11 1.83 6  500+ 3 52 17.33 3 

Totals 422 488 N/A 422 Ice rinks 713940 < 20 18,568 18,612 1.00 381 

 20-99 3,534 3,853 1.09 62  100-499 596 1,103 1.85 0  500+ 159 1,909 12.01 0 

Totals 22,857 25,477 N/A 443 Elementary and secondary schools 6111 < 20 8,205 8,219 1.00 492 

 20-99 8,298 8,637 1.04 498  100-499 1,883 3,205 1.70 113  500+ 161 833 5.17 10 

Totals 18,547 20,894 N/A 1,113 

6112, < 20 1,237 1,239 1.00 74 

6113 20-99 551 585 1.06 33 

Junior colleges, colleges and universities 

 100-499 709 830 1.17 43 

 500+ 720 1,654 2.30 43 

Totals 3,217 4,308 N/A 193 
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Table 15. Industries characterized b

y size cate

gories, number of entities and facilities, facilities per entity, 

average revenues (cont.) 

Sector 

NAICS 

code(s) 

Number of 

employees 

Number of 

entities 

Number of 

facilities 

Number of 

facilities 

per entity 

Number of firms us

equipment with 

> 50 lbs of an ozon

depleting refrigera

Hospitals 622 < 20 637 651 1.02 38 

 20-99 487 513 1.05 29  100-499 1,590 1,725 1.08 95  500+ 1,834 4,680 2.55 110 

Totals 4,548 7,569 N/A 273 Other not included above N/A N/A 72,600 72,600 1.00 72,600 

a. The 2007 Directory of Supermarket, Grocery and Convenience Store Chains estimates that there are 31,036 supermarket and g

and 77,148 convenience store facilities in the United States. While these numbers differ from the ones obtained through the Cens

use Census Bureau numbers because they are broken down in a way that allows for a small business analysis. Sources: U.S. Census Bureau, 2002b; number of entities with equipment charged with more than 50 pounds of ODS estimated ba

of SAIC, Inc.; Chain Store Guide, 2007. 
 

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4.2 Cost Input Assumptions 

Labor rates used in this analysis were assumed to be equal to the U.S. mean wage for a heating, 

air conditioning, and refrigeration mechanic, plus an allowance for wage taxes, fringe benefits, 

overhead, and profit. The estimated cost per hour of labor for repairs (including replacement of 

equipment if necessary) used in this analysis was $39.28/hour. This cost per hour reflects the 

price charged by the service company in the air-conditioning and refrigeration service industry. 

The $39.28/hour cost estimate was derived from information obtained from the Bureau of Labor 

Statistics, the Census Bureau, and the EPA. The total labor cost per hour was calculated as: 

Labor Cost per Hour = wage rate*(1 + fringe rate)*(1 + overhead rate)*(1 + profit rate). 

The following information was used to derive the $39.28/hour estimate: 

 The national mean hourly wage for heating, air conditioning and refrigeration mechanics 

(Labor Category 49-021) in 2006 was $19.09/hour, an average of four quarters in 2006 

(U.S. BLS, 2007). 

 The total employer cost of fringe benefits (including voluntary and legally required 

expenditures, including vacation and sick leave, health and group insurance, Social 

Security, Medicare, and unemployment and workers compensation) for the Installation, 

Maintenance and Repair Occupations category was 46.6% of the hourly wage (U.S. BLS, 

2007). 

 A labor overhead rate of 17% was used. This labor overhead rate is used in many EPA 

Information Collection Request analyses and regulatory impact analyses for all private 

sector employment, and was derived from a survey of the chemical industry and trade 

associations (U.S. EPA, 2005a). 

The gross profit rate for the Plumbing, Heating and Air Conditioning Contractor industry used in 

the analysis was 19.9%. This was derived from 2002 gross sales in the industry ($118.7 billion) 

and total expenditures in the industry ($95.0 billion), including total payroll (with fringe), 

materials, subcontracting costs, property and equipment rent, purchased services (e.g., phone, 

legal), and depreciation of assets (1 – $95.0/$118.7 = 19.9%) (U.S. Census Bureau, 2004). 

SAIC, Inc. staff estimated, for each type of equipment and repair, the level of effort in labor 

hours, costs associated with a repair, and the percentage of time that the repair was successful. A 

core set of activities happen at each visit by a service technician, with additional activities 

occurring for all repair types. The core activities and the labor time taken were assumed as 

follows: 
 

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 Perform leak test: 0.5 hour 

 Recover refrigerant: 1 hour 

 Conduct vacuum test: 0.5 hour 

 Recharge system: 1 hour 

 Verify repair: 1 hour 

 Develop report: 0.25 hour 

 Total for core activities: 4.25 hours. 

Repair type A assumptions 

 A leak test is performed, the refrigerant is completely recovered before repair begins, and 

a vacuum test is performed before equipment is recharged. 

 Minor parts such as gaskets and seals are replaced at a cost of $20. 

 The labor required is 5.75 hours and includes the following: 

 Core activities: 4.25 hours 

 Replace gaskets and seals, tighten joints: 1 hour 

 Conduct leak test: 0.5 hour. 

 A cost is incurred to replace the refrigerant that leaked from the equipment and caused 

the need for repair. The cost of refrigerant replaced is equal to the cost per pound of 

refrigerant typically found in each type of equipment times the respective length of time 

leakage occurs before detection in fractions of a year times the average annual leak rate 

for each type of equipment. 

 Both initial and follow-up verifications are conducted. 

Repair type B assumptions 

 A leak test is performed, the refrigerant is completely recovered before repair begins, and 

a vacuum test is performed before equipment is recharged. 

 A type B repair includes the replacement of a low-cost sub-component (e.g., coupling or 

valve), and involves the actions described in Table 3. To estimate the cost of a part 

replacement, several typical components for each of the equipment types were identified, 
 

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and estimates of the costs for replacement parts were obtained from manufacturer and 

parts catalogues (Parker Hannifin, ThermaCom Ltd.). The average retail costs3

 for typical 

low-cost replacement parts were assumed to be $179 for commercial refrigeration, and 

$105 for process refrigeration and comfort cooling. The average cost of a small part was 

assumed to be higher for commercial refrigeration equipment based on the higher cost of 

components such as hot gas bypass valves not assumed to be typically encountered on 

process refrigeration or comfort cooling. 

 The labor required is 5.92 hours and includes the following: 

 Core activities: 4.25 hours 

 Replace inexpensive fitting or valve: 0.67 hour 

 Install/replace drier: 1 hour. 

 A cost is incurred to replace the refrigerant that leaked from the equipment and caused 

the need for repair. The cost of refrigerant replaced is equal to the cost per pound of 

refrigerant typically found in each type of equipment times the respective length of time 

leakage occurs before detection in fractions of a year times the average annual leak rate 

for each type of equipment. 

 Both initial and follow-up verifications are conducted. 

Repair type C assumptions 

 A leak test is performed, the refrigerant is completely recovered before repair begins, and 

a vacuum test is performed before equipment is recharged. 

 A type C repair includes the replacement of a component, and involves the actions 

described in Table 3. To estimate the cost of a part replacement, prices for typical 

compressors used were identified on each of the equipment types and estimates of prices 

were obtained from a compressor supplier (ThermaCom Ltd.). The average retail costs4

for typical replacement compressors range from $2,550 (CR) to $9,300 (IPR, centrifugal 

type compressor). 

 The labor required is 20.25 hours and includes the following: 

 Core activities: 4.25 hours 

 Replace component: 16 hours. 

 

3. Retail price was assumed to be 200% of catalogue (trade) price. 

4. Retail prices for major components were assumed as given in the ThermaCom catalogue. 
 

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 A cost is incurred to replace the refrigerant that leaked from the equipment and 

perpetrated the need for repair. The cost of refrigerant replaced is equal to the cost per 

pound of refrigerant typically found in each type of equipment times the respective length 

of time leakage occurs before detection in fractions of a year times the average annual 

leak rate for each type of equipment. 

 Both initial and follow-up verifications are conducted. 

Repair type D assumptions 

 A leak test is performed, the refrigerant is completely recovered before repair begins, and 

a vacuum test is performed before equipment is recharged. 

 Repair type D is the retirement or retrofit of an entire piece of equipment, and involves 

the actions described in Table 3. The cost of an entire piece of retrofit equipment is 

between two and three times the cost of the compressor, ranging from $7,500 (CR) to 

$20,000 (IPR, centrifugal type compressor). 

 The labor required to retrofit/retire equipment is 20.25 hours and includes the following: 

 Core activities: 4.25 hours 

 Retrofit/retire equipment: 16 hours 

 A cost is incurred to replace the entire refrigerant charge with virgin refrigerant. 

4.3 Compliance Costs by Equipment Type Associated with 

Different Levels of Action 

Tables 16 and 17 show the compliance costs associated with the different levels of repair and 

retire/retrofit option based on the labor costs and equipment costs discussed in Section 4.2 for 

each of the two scenarios. These costs were used in conducting the screening analysis. 

4.4 Recordkeeping and Reporting Costs 

As described in Section 1.2.2, the proposed action requires technicians servicing large appliances 

(those containing 50 pounds or more of refrigerant) to provide the owner or operator with 

detailed invoice or other documentation when repairing the appliances, and to maintain records 

for a minimum of three years on refrigerant recovered but not returned to appliances. Owners or 

operators of large appliances (those containing 50 pounds or more of refrigerant) must maintain 

records on repairs and verifications, refrigerants purchased, refrigerants recovered and 

transferred to a different owner, retrofit or retirement plans, justifications for any inability to 
 

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Table 16. Compliance costs for applicable types of refrigeration and cooling equipment 

under Scenario 1a 

Equipment category Repair level 1 Repair level 2 Repair level 3 Repair level 4

CR: DX and distributed $450 $3,345 $3,345 $8,295 

IPR: Reciprocating and scroll $395 $6,629 $6,629 $8,295 

IPR: Screw and centrifugal $395 $10,095 $10,095 $20795 

CC: Rooftop, split, and reciprocating $395 $5,505 $5,505 $8,295 

CC: DX, screw, and centrifugal $395 $5,917 $5,917 $20,795 

a. These costs are composed of parts and labor and do not include the costs associated with recharging 

equipment, which will vary slightly based on differences in the leak rate modeled for each option. 

Table 17. Compliance costs for applicable types of refrigeration and cooling equipment 

under Scenario 2a 

Equipment category Repair level 1 Repair level 2 Repair level 3 Repair level 4

CR: DX and distributed $246 $450 $3,345 $8,295 

IPR: Reciprocating and scroll $226 $395 $6,629 $8,295 

IPR: Screw and centrifugal $226 $395 $10,095 $20,795 

CC: Rooftop, split, and reciprocating $246 $395 $5,505 $8,295 

CC: DX, screw, and centrifugal $246 $395 $5,917 $20,795 

a. These costs are composed of parts and labor and do not include the costs associated with recharging 

equipment, which will vary slightly based on differences in the leak rate modeled for each option. 

complete repairs or retrofits/retirements on schedule, determination of the full charge, and 

addition and removal of refrigerants due to seasonal variance. There is no reporting cost 

associated with the proposed action. According to the analysis of burden conducted in 

accordance with the Paperwork Reduction Act of 1995, the regulatory alternative selected for the 

proposed rule (Option 5 under Scenario 2) has an annual recordkeeping cost of $148,365 (cite 

ICR supporting document once published in the docket). 

4.5 Regulatory Impacts 

4.5.1 Aggregate incremental impact of proposed rule on the economy 

The total expected economic impact on the economy was estimated at between $86.5 million and 

$135.6 million under Scenario 1 and between $28.5 million and $53.2 million under Scenario 2. 

The total expected economic impact for Option 5 under Scenario 2 (the option selected for the 

rule) was estimated at $38.2 million. As discussed in Section 2, the regulatory impacts were 

based on a model entity analysis as follows: 
 

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1. An expected cost of compliance for an owner or operator of a piece of cooling or 

refrigeration equipment with a charge size greater than 50 pounds of an ODS refrigerant 

was calculated based on the costs associated with each piece of model equipment and the 

likelihood of each regulatory scenario. The model equipment costs were derived through 

the combination of costs incurred by two groups. Group 1 includes those pieces affected 

by current regulation (i.e., those pieces of equipment past the trigger leak rate), and 

group 2 includes those pieces that are not affected by current regulation but would be 

affected by the given option for the proposed rule. These costs differ slightly because of 

differences in leak rates and therefore differences in the amount of refrigerant required 

for recharging once a repair is completed. Tables 18 and 19 give the expected average 

costs of compliance by equipment for different options for the proposed rule and the 

baseline and the incremental cost. 

Table 18. Incremental cost of the different options for the 

proposed rule under Scenario 1 per piece of equipment 

Equipment type Proposed Baseline Incremental 

 Option 1 (5% and 10%) 

CC $174 $50 $124 

CR $284 $59 $225 

IPR $508 $228 $280 

 Option 2 (5% and 20%) 

CC $174 $50 $124 

CR $224 $59 $165 

IPR $438 $228 $210 

 Option 3 (5% and 30%) 

CC $174 $50 $124 

CR $178 $59 $118 

IPR $386 $228 $158 

 Option 4 (10% and 10%) 

CC $157 $50 $107 

CR $284 $59 $225 

IPR $508 $228 $280 

 Option 5 (10% and 20%) 

CC $157 $50 $107 

CR $224 $59 $165 

IPR $438 $228 $210 

 Option 6 (10% and 30%) 

CC $157 $50 $107 

CR $178 $59 $118 

IPR $386 $228 $158 

Note: Values may vary slightly due to rounding. 
 

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Table 19. Incremental cost of the different options for the 

proposed rule under Scenario 2 per piece of equipment 

Equipment type Proposed Baseline Incremental 

Option 1 (5% and 10%) 

CC $97 $50 $47 

CR $169 $59 $109 

IPR $291 $228 $63 

Option 2 (5% and 20%) 

CC $97 $50 $47 

CR $136 $59 $77 

IPR $261 $228 $34 

Option 3 (5% and 30%) 

CC $97 $50 $47 

CR $110 $59 $51 

IPR $238 $228 $10 

Option 4 (10% and 10%) 

CC $89 $50 $39 

CR $169 $59 $109 

IPR $291 $228 $63 

Option 5 (10% and 20%) 

CC $89 $50 $39 

CR $136 $59 $77 

IPR $261 $228 $34 

Option 6 (10% and 30%) 

CC $89 $50 $39 

CR $110 $59 $51 

IPR $238 $228 $10 

Note: Values may vary slightly due to rounding. 

2. For each size category within each sector, the expected cost of a piece of equipment in 

each equipment category was multiplied by the number of pieces of equipment in that 

category that a typical facility is likely to have, and the products in each category were 

summed to find the total expected cost per facility. 

3. The expected cost per facility was multiplied by the average number of facilities per 

entity in each size category of each sector to ascertain the expected cost per entity. 

4. This was then multiplied by the number of entities in each size category to find the 

expected cost per size category in each sector. 
 

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5. The expected costs in the size categories were summed to find the expected cost per 

sector. 

6. The totals from all affected sectors were summed to find the total impact of the baseline 

scenario and proposed rule. 

7. The total expected cost of the baseline scenario was then subtracted from the total 

expected cost of different options for the proposed rule to find the incremental expected 

cost of different options for the proposed rule. 

8. As mentioned in Section 4.1, there are 824,000 office buildings, 121,000 outpatient 

health care buildings, and 277,000 public assembly buildings reported in the CBECS 

(EIA, 2006) that use CC equipment affected by the rule (EIA, 2006) and are not included 

in the analysis by NAICS code and size categories. Six percent of these buildings, or 

72,600 buildings, are affected by the rule (Section 3.1.2). These buildings were 

considered similar to those in the office building managers sector where the average 

number of CC equipment is one. The impact of different options for the proposed rule on 

these buildings is therefore 72,600 times the expected regulatory impact on a piece of CC 

equipment at each of the options for proposed regulation. These costs were then added to 

the total incremental expected costs described previously. 

The incremental impacts on the economy from each of the options for proposed regulation are 

presented in Tables 20 and 21. 

Tables 22 and 23 present the percentage of costs that can be attributed to each equipment 

category under each scenario. Because baseline requirements are currently higher in IPR 

equipment, and CC equipment has leak rates that are generally low, expected incremental 

impacts will generally be highest in the CR equipment sector. 

Tables 24 and 25 present the aggregated incremental impacts of the options for the proposed rule 

by sector. The most heavily impacted sector is the supermarket and grocery store sector, with 

between $37.8 million and $66.9 million in expected costs under Scenario 1 and between 

$15.9 million and $31.7 million under Scenario 2. 

4.5.2 Impact of proposed rule on small entities 

The Monte Carlo analysis described in Section 2.4 estimated the number of entities in each 

relevant size category expected to experience costs exceeding 1% (and 3%) of the average 

annual value of shipments. This analysis did not account for actions mandated by current 

regulations. 
 

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Table 20. Incremental cost of the different options for the 

proposed rule under Scenario 1 per equipment category 

(million dollars) 

Equipment type Proposed Baseline Incremental 

Option 1 (5% and 10%) 

CC $58.4 $16.8 $41.5 

CR $79.0 $16.5 $62.5 

IPR $57.3 $25.7 $31.6 

Total $194.6 $59.0 $135.6 

Option 2 (5% and 20%) 

CC $58.4 $16.8 $41.5 

CR $62.3 $16.5 $45.8 

IPR $49.3 $25.7 $23.7 

Total $170.0 $59.0 $111.0 

Option 3 (5% and 30%) 

CC $58.4 $16.8 $41.5 

CR $49.4 $16.5 $32.9 

IPR $43.5 $25.7 $17.8 

Total $151.3 $59.0 $92.2 

Option 4 (10% and 10%) 

CC $52.7 $16.8 $35.8 

CR $79.0 $16.5 $62.5 

IPR $57.3 $25.7 $31.6 

Total $188.9 $59.0 $129.9 

Option 5 (10% and 20%) 

CC $52.7 $16.8 $35.8 

CR $62.3 $16.5 $45.8 

IPR $49.3 $25.7 $23.7 

Total $164.3 $59.0 $105.3 

Option 6 (10% and 30%) 

CC $52.7 $16.8 $35.8 

CR $49.4 $16.5 $32.9 

IPR $43.5 $25.7 $17.8 

Total $145.6 $59.0 $86.5 

Note: Values may vary slightly due to rounding. 
 

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Table 21. Incremental cost of the different options for the 

proposed rule under Scenario 2 per equipment category 

(million dollars) 

Equipment type Proposed Baseline Incremental 

Option 1 (5% and 10%) 

CC $32.6 $16.8 $15.8 

CR $46.8 $16.5 $30.3 

IPR $32.8 $25.7 $7.1 

Total $112.2 $59.0 $53.2 

Option 2 (5% and 20%) 

CC $32.6 $16.8 $15.8 

CR $37.9 $16.5 $21.3 

IPR $29.4 $25.7 $3.8 

Total $99.9 $59.0 $40.9 

Option 3 (5% and 30%) 

CC $32.6 $16.8 $15.8 

CR $30.7 $16.5 $14.2 

IPR $26.8 $25.7 $1.2 

Total $90.2 $59.0 $31.1 

Option 4 (10% and 10%) 

CC $30.0 $16.8 $13.1 

CR $46.8 $16.5 $30.3 

IPR $32.8 $25.7 $7.1 

Total $109.6 $59.0 $50.5 

Option 5 (10% and 20%) 

CC $30.0 $16.8 $13.1 

CR $37.9 $16.5 $21.3 

IPR $29.4 $25.7 $3.8 

Total $97.3 $59.0 $38.2 

Option 6 (10% and 30%) 

CC $30.0 $16.8 $13.1 

CR $30.7 $16.5 $14.2 

IPR $26.8 $25.7 $1.2 

Total $87.5 $59.0 $28.5 

Note: Values may vary slightly due to rounding. 
 

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Table 22. Percentage of regulatory impacts attributed to 

each equipment category under Scenario 1 

Equipment type Proposed Baseline Incremental 

Option 1 (5% and 10%) 

CC 30% 29% 31% 

CR 41% 28% 46% 

IPR 29% 43% 23% 

Option 2 (5% and 20%) 

CC 34% 29% 37% 

CR 37% 28% 41% 

IPR 29% 43% 21% 

Option 3 (5% and 30%) 

CC 39% 29% 45% 

CR 33% 28% 36% 

IPR 29% 43% 19% 

Option 4 (10% and 10%) 

CC 28% 29% 28% 

CR 42% 28% 48% 

IPR 30% 43% 24% 

Option 5 (10% and 20%) 

CC 32% 29% 34% 

CR 38% 28% 43% 

IPR 30% 43% 22% 

Option 6 (10% and 30%) 

CC 36% 29% 41% 

CR 34% 28% 38% 

IPR 30% 43% 21% 

Note: Values may vary slightly due to rounding. 
 

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Table 23. Percentage of regulatory impacts attributed to 

each equipment category under Scenario 2 

Equipment type Proposed Baseline Incremental 

Option 1 (5% and 10%) 

CC 29% 29% 30% 

CR 42% 28% 57% 

IPR 29% 43% 13% 

Option 2 (5% and 20%) 

CC 33% 29% 39% 

CR 38% 28% 52% 

IPR 29% 43% 9% 

Option 3 (5% and 30%) 

CC 36% 29% 51% 

CR 34% 28% 46% 

IPR 30% 43% 4% 

Option 4 (10% and 10%) 

CC 27% 29% 26% 

CR 43% 28% 60% 

IPR 30% 43% 14% 

Option 5 (10% and 20%) 

CC 31% 29% 34% 

CR 39% 28% 56% 

IPR 30% 43% 10% 

Option 6 (10% and 30%) 

CC 34% 29% 46% 

CR 35% 28% 50% 

IPR 31% 43% 4% 

Note: Values may vary slightly due to rounding. 
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Table 24. Total incremental cost of each regulatory option under Scenario 1 by sector (million dollars) 

Option

Sector

1 

(5% and 10%)

2 

(5% and 20%)

3 

(5% and 30%) 

4 

(10% and 10%)

5 

(10% and 20

Supermarkets and grocery stores $66.9 $51.1 $38.9 $65.8 $50.0 Convenience stores $0.3 $0.3 $0.3 $0.2 $0.2 Gas station convenience stores $0.6 $0.6 $0.6 $0.5 $0.5 Warehouse and club supercenters $2.6 $2.0 $1.6 $2.5 $2.0 Refrigerated warehouse and storage $1.1 $0.9 $0.7 $1.1 $0.8 Refrigerated warehouse farm products $0.6 $0.5 $0.4 $0.6 $0.5 Office building managers $0.1 $0.1 $0.1 $0.1 $0.1 Lodging $8.4 $8.4 $8.4 $7.2 $7.2 Chemical manufacturing $18.3 $15.1 $12.8 $17.5 $14.3 Pharmaceutical manufacturing $2.9 $2.4 $2.0 $2.8 $2.3 Petrochemical manufacturing $0.6 $0.5 $0.4 $0.5 $0.4 Bakeries $8.5 $7.0 $5.9 $8.2 $6.7 Food manufacturing other than bakeries $12.3 $10.1 $8.5 $11.7 $9.6 Breweries $0.7 $0.6 $0.5 $0.7 $0.6 Soft drink manufacturing $0.9 $0.7 $0.6 $0.9 $0.7 Bottled water manufacturing $0.5 $0.4 $0.3 $0.4 $0.4 Ice manufacturing $0.6 $0.5 $0.4 $0.6 $0.5 Ice rinks $0.3 $0.2 $0.2 $0.3 $0.2 Elementary and secondary schools $0.3 $0.3 $0.3 $0.3 $0.3 Junior colleges, colleges, and universities $0.1 $0.1 $0.1 $0.1 $0.1 Hospitals $0.2 $0.2 $0.2 $0.2 $0.2 Other, buildings not included above $9.0 $9.0 $9.0 $7.7 $7.7 Total $135.6 $111.0 $92.2 $129.9 $105.3 
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Table 25. Total incremental cost of each regulatory option under Scenario 2 by sector (million dollars) 

Option

Sector

1 

(5% and 10%)

2 

(5% and 20%)

3 

(5% and 30%) 

4 

(10% and 10%)

5 

(10% and 2

Supermarkets and grocery stores $31.7 $23.1 $16.4 $31.1 $22.6 Convenience stores $0.1 $0.1 $0.1 $0.1 $0.1 Gas station convenience stores $0.2 $0.2 $0.2 $0.2 $0.2 Warehouse and club supercenters $1.2 $0.9 $0.7 $1.2 $0.9 Refrigerated warehouse and storage $0.5 $0.4 $0.3 $0.5 $0.4 Refrigerated warehouse farm products $0.3 $0.2 $0.2 $0.3 $0.2 Office building managers < $0.1 < $0.1 < $0.1 < $0.1 < $0.1 Lodging $3.2 $3.2 $3.2 $2.6 $2.6 Chemical manufacturing $5.0 $3.7 $2.6 $4.6 $3.3 Pharmaceutical manufacturing $0.8 $0.6 $0.4 $0.7 $0.5 Petrochemical manufacturing $0.2 $0.1 $0.1 $0.1 $0.1 Bakeries $2.3 $1.7 $1.2 $2.1 $1.5 Food manufacturing other than bakeries $3.3 $2.4 $1.7 $3.1 $2.2 Breweries $0.2 $0.1 $0.1 $0.2 $0.1 Soft drink manufacturing $0.2 $0.2 $0.1 $0.2 $0.2 Bottled water manufacturing $0.1 $0.1 $0.1 $0.1 $0.1 Ice manufacturing $0.2 $0.1 $0.1 $0.1 $0.1 Ice rinks $0.1 $0.1 < $0.1 $0.1 < $0.1 Elementary and secondary schools $0.1 $0.1 $0.1 $0.1 $0.1 Junior colleges, colleges, and universities < $0.1 < $0.1 < $0.1 < $0.1 < $0.1 Hospitals $0.1 $0.1 $0.1 $0.1 $0.1 Other, buildings not included above $3.4 $3.4 $3.4 $2.8 $2.8 Total $53.2 $40.9 $31.1 $50.5 $38.2 
 

Stratus Consulting (Draft, 10/23/2009) 

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Results of this analysis are presented in Tables 26 through 29. Under Scenario 1, between 1,396 

and 1,775 small entities are likely to experience compliance costs greater than or equal to 1% of 

their average value of shipments. Under Scenario 2, between 336 and 409 small entities are 

likely to experience costs at this level. With the selected alternative, Option 5 under Scenario 2, a 

total of 353 small businesses are likely to experience compliance costs greater than or equal to 

1% of their average value of shipments. This represents 0.34% of the 104,068 total potentially 

affected small businesses examined across all sectors. At the 1% level, the most heavily 

impacted sector, the ice rink sector, is predicted to have 36 impacted entities (out of 443 small 

businesses in the sector, or 8.1% of the sector). The sector with the most impacted small entities, 

bakeries, is predicted to have 114 affected small businesses (of the 9,598 potentially impacted 

small businesses in the sector, or 1.2% of the sector). 

Under Scenario 1, between 140 and 172 small entities are likely to experience compliance costs 

greater than or equal to 3% of their average value of shipments. Under Scenario 2, between 74 

and 88 small entities are likely to experience costs at this level. With the selected alternative, 

Option 5 under Scenario 2, there are 74 small businesses with anticipated compliance costs 

greater than or equal to 3% of their average value of shipments, mainly in the bakery and ice rink 

sectors. In the bakery sector, 24 companies are expected to have impacts between 3 and 4%, 

while 6 are expected to have impacts between 4 and 9.5%. In the ice rink sector, 25 companies 

are expected to experience impacts between 3 and 4%, 4 companies will likely experience 

impacts between 4 and 10%, and there is a small chance that 1 of those 4 companies may 

experience impacts between 10 and 26%. 

5. Benefits Estimation 

The benefits analysis of the ODS emissions reductions for each of the options for revising the 

rule consists of three separate, but sequential, analyses. Each of the three components of the 

benefits analysis presents a different measure of the benefits of revising the rule. The benefits 

analysis uses the results of the economy-wide impacts analyses described in previous sections of 

this report, resulting in the following set of three different types of benefits measures that are 

consistent with the cost and economic impact analyses. 

1. Environmental benefits, which are presented in terms of the amount of emissions 

reductions that would result from adopting each of the regulatory options. 

2. Health benefits, which are presented in terms of the reductions in future cases of both 

fatal and nonfatal skin cancers that would result from the emissions reductions for each 

regulatory option. 

3. Economic benefits, which are presented in terms of the economic value of the avoided 

cancers. 
Stratus Consulting 

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Table 26. Expected number of entities with compliance costs 

greater than 1% of avera

ge value of shipmen

nearest whole entity) under Scenario 1 

Option 

Sector 

Number of 

employees 

Average value 

of shipments 

per entity 

Entities with 

equipment containing 

> 50 lbs of an ozone 

depleting refrigerant

1 

(5% and 

10%) 

2 

(5% and 

20%) 

3 

(5% and 

30%) 

4 

(10% an

10%) 

Supermarkets and grocery < 20 $760,867 32,246 305 232 182 287 stores 20-99 $5,804,240 6,438 0 0 0 0 

 100-499 $26,814,603 1,157 0 0 0 0 

Total 39,841 305 232 182 287 Convenience stores < 20 $720,186 1,708 3 3 3 3 

 20-99 $3,161,638 55 1 1 1 0  100-499 $8,939,340 8 1 1 1 1 

 > 500 $87,857,296 5 0 0 0 0 Total 1,777 5 5 5 4 

Gas station convenience < 20 $1,576,988 2,098 1 1 1 1 stores 20-99 $6,855,701 220 1 1 1 0 

 100-499 $34,020,000 46 1 1 1 0 

Total 2,363 3 3 3 1 Warehouse and club < 20 $689,000 179 5 4 4 5 supercenters 20-99 $8,085,762 10 0 0 0 0 

 100-499 $30,629,911 4 0 0 0 0 

Total 193 5 4 4 5 Refrigerated warehouse and < 20 $844,175 411 4 4 3 4 storage 20-99 $5,540,779 138 0 0 0 1 

 100-499 $17,230,410 34 0 0 0 0 

 > 500 $127,657,208 25 0 0 0 0 Total 608 4 4 3 5 
Stratus Consulting 

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Table 26. Expected number of entities with compliance costs 

greater than 1% of avera

ge value of shipmen

nearest whole entity) under Scenario 1 (cont.) 

Option 

Sector 

Number of 

employees 

Average value 

of shipments 

per entity 

Entities with 

equipment containing 

> 50 lbs of an ozone 

depleting refrigerant

1 

(5% and 

10%) 

2 

(5% and 

20%) 

3 

(5% and 

30%) 

4 

(10% an

10%) 

Refrigerated warehouse and < 20 $1,474,575 276 1 1 1 1 storage farm products 20-99 $4,696,650 48 0 1 0 1 

 100-499 $17,545,505 18 0 0 0 0  > 500 $48,989,768 21 0 0 0 0 

Total 363 1 2 1 2 Office building managers < 20 $528,310 514 8 8 8 7 

 20-99 $4,531,681 53 1 1 1 1  100-499 $12,856,712 14 0 0 0 0 

Total 581 9 9 9 8 Lodging < 20 $312,013 20,546 592 592 592 534 

 20-99 $1,556,255 4,524 2 2 2 2  100-499 $8,115,097 477 1 1 1 1 

Total 25,547 595 595 595 537 Chemical manufacturing < 20 $2,185,664 5,192 34 26 23 33 

 20-99 $12,609,842 1,679 0 0 0 0  100-499 $55,672,937 622 0 0 0 0  > 500 $703,197,343 437 0 0 0 0 

Total 7,493 34 26 23 33 

Pharmaceutical < 20 $2,243,968 812 5 4 4 5 manufacturing 20-99 $11,816,746 295 0 0 0 0 

 100-499 $62,191,006 168 0 0 0 0  > 500 $1,098,753,829 136 0 0 0 0 

Total 1,275 5 4 4 5 
Stratus Consulting 

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Table 26. Expected number of entities with compliance costs 

greater than 1% of avera

ge value of shipmen

nearest whole entity) under Scenario 1 (cont.) 

Option 

Sector 

Number of 

employees 

Average value 

of shipments 

per entity 

Entities with 

equipment containing 

> 50 lbs of an ozone 

depleting refrigerant

1 

(5% and 

10%) 

2 

(5% and 

20%) 

3 

(5% and 

30%) 

4 

(10% an

10%) 

Bakeries < 20 $429,172 7,948 650 561 518 624 

 20-99 $3,604,377 1,375 1 1 1 1  100-499 $23,168,700 275 0 0 0 0  > 500 $326,837,633 131 0 0 0 0 

Total 9,598 651 562 519 625 

Food manufacturing other < 20 $1,751,164 7,703 25 22 22 26 than bakeries 20-99 $12,594,370 2,560 0 0 0 0 

 100-499 $60,629,867 972 0 0 0 0  > 500 $869,272,625 420 0 0 0 0 

Total 11,235 25 22 22 26 Breweries < 20 $1,144,500 292 22 20 18 22 

 20-99 $7,009,507 95 0 0 0 0  100-499 $44,900,857 18 0 0 0 0 

Total 405 22 20 18 22 Soft drink manufacturing < 20 $2,261,389 132 1 1 1 1 

 20-99 $16,166,651 73 0 0 0 0  100-499 $51,883,126 62 0 0 0 0 

Total 267 1 1 1 1 Bottled water < 20 $691,221 181 26 22 20 25 

 20-99 $8,399,303 33 0 0 0 0  100-499 $29,623,375 8 0 0 0 0 

Total 222 26 22 20 25 
Stratus Consulting 

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Table 26. Expected number of entities with compliance costs 

greater than 1% of avera

ge value of shipmen

nearest whole entity) under Scenario 1 (cont.) 

Option 

Sector 

Number of 

employees 

Average value 

of shipments 

per entity 

Entities with 

equipment containing 

> 50 lbs of an ozone 

depleting refrigerant

1 

(5% and 

10%) 

2 

(5% and 

20%) 

3 

(5% and 

30%) 

4 

(10% an

10%) 

Ice rinks < 20 $241,981 381 35 35 35 35 

 20-99 $1,294,443 62 1 1 1 1  100-499 $5,211,097 – 0 0 0 0 

Total 443 36 36 36 36 

Petrochemical < 20 $2,243,968 812 0 0 1 0 manufacturing 20-99 $11,816,746 295 0 0 0 0 

 100-499 $62,191,006 168 0 0 0 0  > 500 $1,098,753,829 136 0 0 0 0 

Total 1275 0 0 1 0 Ice manufacturing < 20 $592,025 369 45 40 36 44 

 20-99 $4,426,462 44 1 1 1 1  100-499 $9,901,666 6 1 1 0 1 

Total 419 47 42 37 46 Hospitals < 20 $2,405,495 38 1 1 1 1 

 20-99 $5,938,879 29 0 0 0 0  100-499 $21,103,169 95 0 0 0 0 

Total 163 1 1 1 1 Total 104,068 1,775 1,590 1,484 1,669 

Note: The expected number of entities are estimates from a probabilistic analysis of the potential impacts on small entities. Smalnumbers of entities (e.g., 178 vs. 182) are not statistically significant. Totals may vary slightly due to rounding. 
Stratus Consulting 

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Table 27. Expected number of entities with compliance costs 

greater than 1% of avera

ge value of shipmen

nearest whole entity) under Scenario 2 

Option

Sector

Number of 

employees

Average value 

of shipments 

per entity

Entities with 

equipment containing 

> 50 lbs of an ozone 

depleting refrigerant

1 

(5% and 

10%) 

2 

(5% and 

20%) 

3 

(5% and 

30%) 

4 

(10% an

10%) 

Supermarkets and grocery < 20 $760,867 32,246 56 42 37 58 stores 20-99 $5,804,240 6,438 0 0 0 0 

 100-499 $26,814,603 1,157 0 0 0 0 

Total 39,841 56 42 37 58 Convenience stores < 20 $720,186 1,708 2 2 2 2 

 20-99 $3,161,638 55 1 1 1 1  100-499 $8,939,340 8 1 1 1 1 

 > 500 $87,857,296 5 0 0 0 0 Total 1,777 4 4 4 4 

Gas station convenience < 20 $1,576,988 2,098 1 1 1 1 stores 20-99 $6,855,701 220 1 1 1 1 

 100-499 $34,020,000 46 1 1 1 1 

Total 2,363 3 3 3 3 Warehouse and club < 20 $689,000 179 1 1 1 1 supercenters 20-99 $8,085,762 10 0 0 0 0 

 100-499 $30,629,911 4 0 0 0 0 

Total 193 1 1 1 1 Refrigerated warehouse and < 20 $844,175 411 1 1 1 1 storage 20-99 $5,540,779 138 0 0 0 0 

 100-499 $17,230,410 34 0 0 0 0 

 > 500 $127,657,208 25 0 0 0 0 Total 608 1 1 1 1 
Stratus Consulting 

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Table 27. Expected number of entities with compliance costs 

greater than 1% of avera

ge value of shipmen

nearest whole entity) under Scenario 2 (cont.) 

Option

Sector

Number of 

employees

Average value 

of shipments 

per entity

Entities with 

equipment containing 

> 50 lbs of an ozone 

depleting refrigerant

1 

(5% and 

10%) 

2 

(5% and 

20%) 

3 

(5% and 

30%) 

4 

(10% an

10%) 

Refrigerated warehouse and < 20 $1,474,575 276 1 1 1 1 storage farm products 20-99 $4,696,650 48 1 1 1 1 

 100-499 $17,545,505 18 0 0 0 0  > 500 $48,989,768 21 0 0 0 0 

Total 363 2 2 2 2 Office building managers < 20 $528,310 514 2 2 2 2 

 20-99 $4,531,681 53 1 1 1 0  100-499 $12,856,712 14 0 0 0 0 

Total 581 3 3 3 2 Lodging < 20 $312,013 20,546 118 118 118 109 

 20-99 $1,556,255 4,524 2 2 2 2  100-499 $8,115,097 477 1 1 1 1 

Total 25,547 121 121 121 112 Chemical manufacturing < 20 $2,185,664 5,192 6 4 4 7 

 20-99 $12,609,842 1,679 0 0 0 0  100-499 $55,672,937 622 0 0 0 0  > 500 $703,197,343 437 0 0 0 0 

Total 7,493 6 4 4 7 

Pharmaceutical < 20 $2,243,968 812 1 1 1 1 manufacturing 20-99 $11,816,746 295 0 0 0 0 

 100-499 $62,191,006 168 0 0 0 0  > 500 $1,098,753,829 136 0 0 0 0 

Total 1,275 1 1 1 1 
Stratus Consulting 

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Table 27. Expected number of entities with compliance costs 

greater than 1% of avera

ge value of shipmen

nearest whole entity) under Scenario 2 (cont.) 

Option

Sector

Number of 

employees

Average value 

of shipments 

per entity

Entities with 

equipment containing

> 50 lbs of an ozone 

depleting refrigerant

1 

(5% and 

10%) 

2 

(5% and 

20%) 

3 

(5% and 

30%) 

4 

(10% an

10%) 

Bakeries < 20 $429,172 7,948 145 124 118 135 

 20-99 $3,604,377 1,375 1 1 1 1  100-499 $23,168,700 275 0 0 0 0  > 500 $326,837,633 131 0 0 0 0 

Total 9,598 146 125 119 136 

Food manufacturing other < 20 $1,751,164 7,703 5 6 4 5 than bakeries 20-99 $12,594,370 2,560 0 0 0 0 

 100-499 $60,629,867 972 0 0 0 0  > 500 $869,272,625 420 0 0 0 0 

Total 11,235 5 6 4 5 Breweries < 20 $1,144,500 292 5 5 4 5 

 20-99 $7,009,507 95 0 0 0 0  100-499 $44,900,857 18 0 0 0 0 

Total 405 5 5 4 5 Soft drink manufacturing < 20 $2,261,389 132 1 1 1 1 

 20-99 $16,166,651 73 0 0 0 0  100-499 $51,883,126 62 0 0 0 0 

Total 267 1 1 1 1 Bottled water < 20 $691,221 181 6 5 5 6 

 20-99 $8,399,303 33 0 0 0 0  100-499 $29,623,375 8 0 0 0 0 

Total 222 6 5 5 6 
Stratus Consulting 

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Table 27. Expected number of entities with compliance costs 

greater than 1% of avera

ge value of shipmen

nearest whole entity) under Scenario 2 (cont.) 

Option

Sector

Number of 

employees

Average value 

of shipments 

per entity

Entities with 

equipment containing 

> 50 lbs of an ozone 

depleting refrigerant

1 

(5% and 

10%) 

2 

(5% and 

20%) 

3 

(5% and 

30%) 

4 

(10% an

10%) 

Ice rinks < 20 $241,981 381 35 35 35 35 

 20-99 $1,294,443 62 1 1 1 1  100-499 $5,211,097 – 0 0 0 0 

Total 443 36 36 36 36 

Petrochemical < 20 $2,243,968 812 0 0 0 0 manufacturing 20-99 $11,816,746 295 0 0 0 0 

 100-499 $62,191,006 168 0 0 0 0  > 500 $1,098,753,829 136 0 0 0 0 

Total 1275 0 0 0 0 Ice manufacturing < 20 $592,025 369 10 9 8 10 

 20-99 $4,426,462 44 1 1 1 1  100-499 $9,901,666 6 0 0 0 0 

Total 419 11 10 9 11 Hospitals < 20 $2,405,495 38 1 1 1 1 

 20-99 $5,938,879 29 0 0 0 0  100-499 $21,103,169 95 0 0 0 0 

Total 163 1 1 1 1 Total 104,068 409 371 356 392 

Note: The expected number of entities are estimates from a probabilistic analysis of the potential impacts on small entities. Smalnumbers of entities (e.g., 56 vs. 58) are not statistically significant. Totals may vary slightly due to rounding. 
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Table 28. Expected number of entities with compliance costs 

greater than 3% of avera

ge value of shipmen

nearest whole entity) under Scenario 1 

Option

Sector

Number of 

employees

Average value 

of shipments 

per entity

Entities with 

equipment containing 

> 50 lbs of an ozone 

depleting refrigerant

1 

(5% and 

10%) 

2 

(5% and 

20%) 

3 

(5% and 

30%) 

4 

(10% an

10%) 

Supermarkets and grocery < 20 $760,867 32,246 2 0 0 1 stores 20-99 $5,804,240 6,438 0 0 0 0 

 100-499 $26,814,603 1,157 0 0 0 0 

Total 39,841 2 0 0 1 Convenience stores < 20 $720,186 1,708 1 1 1 0 

 20-99 $3,161,638 55 0 0 0 0  100-499 $8,939,340 8 0 0 0 0 

 > 500 $87,857,296 5 0 0 0 0 Total 1,777 1 1 1 0 

Gas station convenience < 20 $1,576,988 2,098 0 0 0 0 stores 20-99 $6,855,701 220 0 0 0 0 

 100-499 $34,020,000 46 0 0 0 0 

Total 2,363 0 0 0 0 Warehouse and club < 20 $689,000 179 1 1 1 1 supercenters 20-99 $8,085,762 10 0 0 0 0 

 100-499 $30,629,911 4 0 0 0 0 

Total 193 1 1 1 1 Refrigerated warehouse and < 20 $844,175 411 1 1 1 1 storage 20-99 $5,540,779 138 0 0 0 0 

 100-499 $17,230,410 34 0 0 0 0 

 > 500 $127,657,208 25 0 0 0 0 Total 608 1 1 1 1 
Stratus Consulting 

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Table 28. Expected number of entities with compliance costs 

greater than 3% of avera

ge value of shipmen

nearest whole entity) under Scenario 1 (cont.) 

Option

Sector

Number of 

employees

Average value 

of shipments 

per entity

Entities with 

equipment containing 

> 50 lbs of an ozone 

depleting refrigerant

1 

(5% and 

10%) 

2 

(5% and 

20%) 

3 

(5% and 

30%) 

4 

(10% an

10%) 

Refrigerated warehouse and < 20 $1,474,575 276 0 0 0 0 storage farm products 20-99 $4,696,650 48 0 0 0 0 

 100-499 $17,545,505 18 0 0 0 0  > 500 $48,989,768 21 0 0 0 0 

Total 363 0 0 0 0 Office building managers < 20 $528,310 514 1 1 1 1 

 20-99 $4,531,681 53 0 0 0 0  100-499 $12,856,712 14 0 0 0 0 

Total 581 1 1 1 1 Lodging < 20 $312,013 20,546 37 37 37 31 

 20-99 $1,556,255 4,524 0 0 0 0  100-499 $8,115,097 477 0 0 0 0 

Total 25,547 37 37 37 31 Chemical manufacturing < 20 $2,185,664 5,192 0 0 0 0 

 20-99 $12,609,842 1,679 0 0 0 0  100-499 $55,672,937 622 0 0 0 0  > 500 $703,197,343 437 0 0 0 0 

Total 7,493 0 0 0 0 

Pharmaceutical < 20 $2,243,968 812 0 0 0 0 manufacturing 20-99 $11,816,746 295 0 0 0 0 

 100-499 $62,191,006 168 0 0 0 0  > 500 $1,098,753,829 136 0 0 0 0 

Total 1,275 0 0 0 0 
Stratus Consulting 

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Table 28. Expected number of entities with compliance costs greater than 3% of average value of shipmennearest whole entity) under Scenario 1 (cont.) 

Option

Sector

Number of 

employees

Average value 

of shipments 

per entity

Entities with 

equipment containing 

> 50 lbs of an ozone 

depleting refrigerant

1 

(5% and 

10%) 

2 

(5% and 

20%) 

3 

(5% and 

30%) 

4 

(10% an

10%) 

Bakeries < 20 $429,172 7,948 94 85 73 95 

 20-99 $3,604,377 1,375 0 0 0 0  100-499 $23,168,700 275 0 0 0 0  > 500 $326,837,633 131 0 0 0 0 

Total 9,598 94 85 73 95 

Food manufacturing other < 20 $1,751,164 7,703 0 1 1 0 than bakeries 20-99 $12,594,370 2,560 0 0 0 0 

 100-499 $60,629,867 972 0 0 0 0  > 500 $869,272,625 420 0 0 0 0 

Total 11,235 0 1 1 0 Breweries < 20 $1,144,500 292 1 1 1 1 

 20-99 $7,009,507 95 0 0 0 0  100-499 $44,900,857 18 0 0 0 0 

Total 405 1 1 1 1 Soft drink manufacturing < 20 $2,261,389 132 0 0 0 0 

 20-99 $16,166,651 73 0 0 0 0  100-499 $51,883,126 62 0 0 0 0 

Total 267 0 0 0 0 Bottled water < 20 $691,221 181 2 2 1 2 

 20-99 $8,399,303 33 0 0 0 0  100-499 $29,623,375 8 0 0 0 0 

Total 222 2 2 1 2 
Stratus Consulting 

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Table 28. Expected number of entities with compliance costs 

greater than 3% of avera

ge value of shipmen

nearest whole entity) under Scenario 1 (cont.) 

Option

Sector

Number of 

employees

Average value 

of shipments 

per entity

Entities with 

equipment containing 

> 50 lbs of an ozone 

depleting refrigerant

1 

(5% and 

10%) 

2 

(5% and 

20%) 

3 

(5% and 

30%) 

4 

(10% an

10%) 

Ice rinks < 20 $241,981 381 28 28 28 28 

 20-99 $1,294,443 62 1 1 1 1  100-499 $5,211,097 – 0 0 0 0 

Total 443 29 29 29 29 

Petrochemical < 20 $2,243,968 812 0 0 0 0 manufacturing 20-99 $11,816,746 295 0 0 0 0 

 100-499 $62,191,006 168 0 0 0 0  > 500 $1,098,753,829 136 0 0 0 0 

Total 1275 0 0 0 0 Ice manufacturing < 20 $592,025 369 3 3 2 3 

 20-99 $4,426,462 44 0 0 0 0  100-499 $9,901,666 6 0 0 0 0 

Total 419 3 3 2 3 Hospitals < 20 $2,405,495 38 0 0 0 0 

 20-99 $5,938,879 29 0 0 0 0  100-499 $21,103,169 95 0 0 0 0 

Total 163 0 0 0 0 Total 104,068 172 162 148 165 

Note: The expected number of entities are estimates from a probabilistic analysis of the potential impacts on small entities. Smalnumbers of entities (e.g., 93 vs. 94) are not statistically significant. Totals may vary slightly due to rounding. 
Stratus Consulting 

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Table 29. Expected number of entities with compliance costs 

greater than 3% of avera

ge value of shipmen

nearest whole entity) under Scenario 2 

Option

Sector

Number of 

employees

Average value 

of shipments 

per entity

Entities with 

equipment containing 

> 50 lbs of an ozone 

depleting refrigerant

1 

(5% and 

10%) 

2 

(5% and 

20%) 

3 

(5% and 

30%) 

4 

(10% an

10%) 

Supermarkets and grocery < 20 $760,867 32,246 3 2 2 2 stores 20-99 $5,804,240 6,438 0 0 0 0 

 100-499 $26,814,603 1,157 0 0 0 0 

Total 39,841 3 2 2 2 Convenience stores < 20 $720,186 1,708 1 1 1 1 

 20-99 $3,161,638 55 0 0 0 0  100-499 $8,939,340 8 0 0 0 0 

 > 500 $87,857,296 5 0 0 0 0 Total 1,777 1 1 1 1 

Gas station convenience < 20 $1,576,988 2,098 0 0 0 0 stores 20-99 $6,855,701 220 0 0 0 0 

 100-499 $34,020,000 46 0 0 0 0 

Total 2,363 0 0 0 0 Warehouse and club < 20 $689,000 179 1 1 1 1 supercenters 20-99 $8,085,762 10 0 0 0 0 

 100-499 $30,629,911 4 0 0 0 0 

Total 193 1 1 1 1 Refrigerated warehouse and < 20 $844,175 411 1 1 1 1 storage 20-99 $5,540,779 138 0 0 0 0 

 100-499 $17,230,410 34 0 0 0 0 

 > 500 $127,657,208 25 0 0 0 0 Total 608 1 1 1 1 
Stratus Consulting 

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Table 29. Expected number of entities with compliance costs 

greater than 3% of avera

ge value of shipmen

nearest whole entity) under Scenario 2 (cont.) 

Option

Sector

Number of 

employees

Average value 

of shipments 

per entity

Entities with 

equipment containing 

> 50 lbs of an ozone 

depleting refrigerant

1 

(5% and 

10%) 

2 

(5% and 

20%) 

3 

(5% and 

30%) 

4 

(10% an

10%) 

Refrigerated warehouse and < 20 $1,474,575 276 0 0 0 0 storage farm products 20-99 $4,696,650 48 0 0 0 0 

 100-499 $17,545,505 18 0 0 0 0  > 500 $48,989,768 21 0 0 0 0 

Total 363 0 0 0 0 Office building managers < 20 $528,310 514 1 1 1 1 

 20-99 $4,531,681 53 0 0 0 0  100-499 $12,856,712 14 0 0 0 0 

Total 581 1 1 1 1 Lodging < 20 $312,013 20,546 8 8 8 7 

 20-99 $1,556,255 4,524 0 0 0 0  100-499 $8,115,097 477 0 0 0 0 

Total 25,547 8 8 8 7 Chemical manufacturing < 20 $2,185,664 5,192 0 0 0 0 

 20-99 $12,609,842 1,679 0 0 0 0  100-499 $55,672,937 622 0 0 0 0  > 500 $703,197,343 437 0 0 0 0 

Total 7,493 0 0 0 0 

Pharmaceutical < 20 $2,243,968 812 0 0 0 0 manufacturing 20-99 $11,816,746 295 0 0 0 0 

 100-499 $62,191,006 168 0 0 0 0  > 500 $1,098,753,829 136 0 0 0 0 

Total 1,275 0 0 0 0 
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Table 29. Expected number of entities with compliance costs 

greater than 3% of avera

ge value of shipmen

nearest whole entity) under Scenario 2 (cont.) 

Option

Sector

Number of 

employees

Average value 

of shipments 

per entity

Entities with 

equipment containing 

> 50 lbs of an ozone 

depleting refrigerant

1 

(5% and 

10%) 

2 

(5% and 

20%) 

3 

(5% and 

30%) 

4 

(10% an

10%) 

Bakeries < 20 $429,172 7,948 41 30 35 40 

 20-99 $3,604,377 1,375 0 0 0 0  100-499 $23,168,700 275 0 0 0 0  > 500 $326,837,633 131 0 0 0 0 

Total 9,598 41 30 35 40 

Food manufacturing other < 20 $1,751,164 7,703 0 0 0 0 than bakeries 20-99 $12,594,370 2,560 0 0 0 0 

 100-499 $60,629,867 972 0 0 0 0  > 500 $869,272,625 420 0 0 0 0 

Total 11,235 0 0 0 0 Breweries < 20 $1,144,500 292 1 1 1 1 

 20-99 $7,009,507 95 0 0 0 0  100-499 $44,900,857 18 0 0 0 0 

Total 405 1 1 1 1 Soft drink manufacturing < 20 $2,261,389 132 0 0 0 0 

 20-99 $16,166,651 73 0 0 0 0  100-499 $51,883,126 62 0 0 0 0 

Total 267 0 0 0 0 Bottled water < 20 $691,221 181 1 1 1 1 

 20-99 $8,399,303 33 0 0 0 0  100-499 $29,623,375 8 0 0 0 0 

Total 222 1 1 1 1 
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Table 29. Expected number of entities with compliance costs greater than 3% of average value of shipmennearest whole entity) under Scenario 2 (cont.) 

Option

Sector

Number of 

employees

Average value 

of shipments 

per entity

Entities with 

equipment containing 

> 50 lbs of an ozone 

depleting refrigerant

1 

(5% and 

10%) 

2 

(5% and 

20%) 

3 

(5% and 

30%) 

4 

(10% an

10%) 

Ice rinks < 20 $241,981 381 28 28 28 28 

 20-99 $1,294,443 62 1 1 1 1  100-499 $5,211,097 – 0 0 0 0 

Total 443 29 29 29 29 

Petrochemical < 20 $2,243,968 812 0 0 0 0 manufacturing 20-99 $11,816,746 295 0 0 0 0 

 100-499 $62,191,006 168 0 0 0 0  > 500 $1,098,753,829 136 0 0 0 0 

Total 1275 0 0 0 0 Ice manufacturing < 20 $592,025 369 1 1 1 1 

 20-99 $4,426,462 44 0 0 0 0  100-499 $9,901,666 6 0 0 0 0 

Total 419 1 1 1 1 Hospitals < 20 $2,405,495 38 0 0 0 0 

 20-99 $5,938,879 29 0 0 0 0  100-499 $21,103,169 95 0 0 0 0 

Total 163 0 0 0 0 Total 104,068 88 76 81 85 

Note: The expected number of entities are estimates from a probabilistic analysis of the potential impacts on small entities. Smalnumbers of entities (e.g., 30 vs. 35) are not statistically significant. Totals may vary slightly due to rounding. 
 

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5.1 Emissions Reduction Analysis 

The environmental benefits of the options examined for revising the rule are portrayed in this 

analysis in terms of the ODS emissions that would be avoided as a result of rule modifications. 

In the model plant analysis for the benefits estimation, each equipment type was divided into two 

groups to estimate the expected avoided emissions from a model piece of equipment. The first 

group consisted of those pieces of equipment above the current trigger leak rate (i.e., 15% for 

CC, and 35% for CR and IPR applications). The baseline avoided emissions from current 

requirements were subtracted from the potential avoided emissions from the proposed regulation 

for this group to find the incremental potential benefits of the rule. The second group consisted 

of equipment that would be required to be fixed under the proposed regulation, but currently 

requires no action (i.e., the baseline for group 2 is zero). The combined benefits from these two 

groups capture all potential avoided emissions as a result of proposed regulation. 

For example, in the case of CC and CR equipment, group 1 generates the benefits mentioned 

above, minus the baseline. Therefore there are minor incremental benefits associated with a 

successful level 1 repair in Scenario 1, due to the slightly higher success rate of repairs type B, 

and no incremental benefits in Scenario 2, where the same type of repair is performed in the 

baseline and proposed rule. The majority of the benefits of the proposed regulation begin with a 

successful level 2 repair and capture all subsequent benefits. In the case of IPR equipment, the 

only majority of benefits of the proposed regulation for group 1 come from emissions avoided as 

a result of a third component replacement before a system is retrofitted or retired. Group 2 

captures the benefits possible as a result of each repair level, because the baseline for these 

pieces of equipment is no action and thus no avoided emissions. Table 30 presents the number of 

months of potential avoided emissions as a result of the proposed regulation. Note that the 

retrofit/retirement of a system shows no months of avoided emissions, because these potential 

benefits must occur in subsequent years and are thus beyond the scope of this analysis. 

The following equation was used to calculate the volume of avoided emissions: 

Avoided emissions = (leak rate) × (charge size) × (months avoided emissions/12 months) 

The procedure used to calculate the expected avoided emissions of each type of equipment 

follows: 

1. The potential avoided emissions at each repair level were multiplied by the probability of 

ending at that level to get the total expected avoided emissions at that level. 

2. The expected avoided emissions at each repair level were divided into emissions of each 

common refrigerants used in that type of equipment. This was accomplished by 

multiplying total expected avoided emissions at each repair level by the percentage of 

equipment that uses each common type of refrigerant. As noted in the cost analysis, the 
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Table 30. Benefits assumptions of months avoided emissions if process stops at each regulatory stage speci

Repair level 1 Repair level 2 Repair level 3 

Repair level 4 

(repair type A or C 

successful) 

Equipment category Group Baseline Proposed Baseline Proposed Baseline Proposed Baseline Proposed BCR 2 0 11 0 9 0 7 0 5  1 11 11 0 9 0 7 0 5 IPR 2 0 11 0 9 0 7 0 5  1 11 11 9 9 9 7 0 5 CC 2 0 11 0 9 0 7 0 5  1 11 11 0 9 0 7 0 5 
 

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refrigerants considered are the most commonly used refrigerants for each of the types of 

equipment. Although there may be other refrigerants used in the equipment, the 

SCAQMD data indicate that these other refrigerants are a negligible percentage of all 

refrigerant usage. 

3. The emissions of each type of refrigerant were weighted using the ODP and GWP of 

each chemical to get the ODP- and GWP-weighted pounds of expected avoided 

refrigerant emissions. 

Once this procedure was completed for each type of equipment at each repair level, the group 1 

and group 2 expected avoided emissions in ODP-weighted pounds were summed across each 

equipment type to find the total expected avoided ODP-weighted emissions per piece of 

equipment. A similar calculation was used to estimate the avoided GWP-weighted emissions per 

piece of equipment. 

The benefits analysis has the following limitations: 

 There is no analysis of benefits that may be obtained by preventing a chronically leaking 

system from continuing operation. There is also no analysis of the benefits of an 

accelerated transition to non-ODS alternative refrigerants. This means that the benefits 

estimations presented here are likely to underestimate benefits potentially realized 

through the proposed rule. 

 This analysis does not address any differences in the timing of leak discovery and repair 

as a result of changes in the methods used to calculate annual leak rates mandated by the 

current and proposed rules. The data do not exist to assess if and how the timing of leak 

discovery and repair would change with the proposed rule changes. 

 The benefits are estimated in terms of the projected emissions reductions (i.e., ODPweighted tonnes and MMTCE of avoided emissions). This screening analysis does not 

estimate the economic value of the emissions reductions. A more comprehensive 

economic benefit-cost analysis using conventional economic theory requires estimating 

the total societal willingness to pay to avoid the ODS emissions. 

The benefits analysis estimates the total expected benefits are between 263 and 493 ODPweighted tonnes or between 1.5 and 2.5 MMTCE of avoided refrigerant emissions under 

Scenario 1, and between 198 and 423 ODP-weighted tonnes or 1.2 and 2.3 MMTCE under 

Scenario 2. The estimated total benefits for Option 5 under Scenario 2 are 316 ODP-weighted 

tones or 1.8 MMTCE. Tables 31 through 34 present the benefits in terms of avoided emissions 

for all options. 
 

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Table 31. Incremental benefits of the different options for the proposed 

rule under Scenario 1 per equipment category (ODP-weighted tonnes) 

Expected incremental benefit

Option CC CR IPR Total 

1 (5% and 10%) 134 162 197 493 

2 (5% and 20%) 134 131 129 394 

3 (5% and 30%) 134 92 47 273 

4 (10% and 10%) 124 162 197 483 

5 (10% and 20%) 124 131 129 384 

6 (10% and 30%) 124 92 47 263 

Note: Values may vary slightly due to rounding. 

Table 32. Incremental benefits of the different options for the proposed 

rule under Scenario 2 per equipment category (ODP-weighted tonnes) 

Expected incremental benefit

Option CC CR IPR Total 

1 (5% and 10%) 120 153 150 423 

2 (5% and 20%) 120 122 84 326 

3 (5% and 30%) 120 84 4 208 

4 (10% and 10%) 111 153 150 413 

5 (10% and 20%) 111 122 84 316 

6 (10% and 30%) 111 84 4 198 

Note: Values may vary slightly due to rounding. 

Table 33. Incremental benefits of the different options for the proposed 

rule under Scenario 1 per equipment category (MMTCE) 

Expected incremental benefit

Option CC CR IPR Total 

1 (5% and 10%) 0.6 1.5 0.5 2.5 

2 (5% and 20%) 0.6 1.2 0.3 2.1 

3 (5% and 30%) 0.6 0.8 0.1 1.5 

4 (10% and 10%) 0.5 1.5 0.5 2.5 

5 (10% and 20%) 0.5 1.2 0.3 2.0 

6 (10% and 30%) 0.5 0.8 0.1 1.5 

Note: Values may vary slightly due to rounding. 
 

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Table 34. Incremental benefits of the different options for the proposed 

rule under Scenario 2 per equipment category (MMTCE) 

Expected incremental benefit

Option CC CR IPR Total 

1 (5% and 10%) 0.5 1.4 0.4 2.3 

2 (5% and 20%) 0.5 1.1 0.2 1.8 

3 (5% and 30%) 0.5 0.8 0.0 1.3 

4 (10% and 10%) 0.5 1.4 0.4 2.2 

5 (10% and 20%) 0.5 1.1 0.2 1.8 

6 (10% and 30%) 0.5 0.8 0.0 1.2 

Note: Values may vary slightly due to rounding. 

Tables 35 through 38 list the benefits results by sector. Note that the sector with the largest 

environmental benefit in terms of both ODP- and GWP-weighted emissions is the supermarket 

and grocery store sector, with estimated annual avoided refrigerant emissions between 110.5 and 

178.7 ODP-weighted tonnes or between 0.89 and 1.49 MMTCE under Scenario 1, and between 

100 and 166.8 ODP weighted tonnes or 0.80 and 1.40 MMTCE under Scenario 2. 

5.2 Health Benefits Analysis 

ODS emissions deplete stratospheric ozone, which protects the biosphere from potentially 

damaging doses of UV radiation. Depletion of stratospheric ozone caused by the release of manmade ODS can lead to increases in UV radiation reaching the Earth’s surface, which could in 

turn lead to adverse human and animal health effects, as well as ecosystem impacts. The ODS 

emissions reductions for the different options for revising the rule will reduce the depletion of 

stratospheric ozone, and hence reduce the adverse health effects of UV radiation. 

In previous EPA analyses, the quantified benefits of stratospheric ozone protection programs 

were dominated by the reduced adverse health impacts expected from reductions in UV 

radiation. Because health effects were found to be the dominant quantified benefit category for 

stratospheric ozone protection, this economic screening analysis of the options for reducing ODS 

emissions is limited to an analysis of the most important type of quantified health effect: skin 

cancers. Other health effects are known or suspected to be associated with damage to 

stratospheric ozone, including premature aging, cataracts, and immune system suppression. 
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Table 35. Total incremental benefit of each regulatory option under Scenario 1 by sector (ODP-weighted t

Option

Sector

1 

(5% and 10%)

2 

(5% and 20%)

3 

(5% and 30%) 

4 

(10% and 10%)

5 

(10% and 2

Supermarkets and grocery stores 178.7 149.1 112.3 176.9 147.3 Convenience stores 0.8 0.8 0.8 0.8 0.8 Gas station convenience stores 2.0 2.0 2.0 1.9 1.9 Warehouse and club supercenters 7.0 6.0 4.8 6.9 5.9 Refrigerated warehouse and storage 3.0 2.6 2.1 3.0 2.5 Refrigerated warehouse farm products 1.7 1.4 1.1 1.7 1.4 Office building managers 0.3 0.3 0.3 0.3 0.3 Lodging 27.0 27.0 27.0 25.0 25.0 Chemical manufacturing 97.1 69.9 37.0 95.7 68.6 Pharmaceutical manufacturing 15.3 11.0 5.8 15.1 10.8 Petrochemical manufacturing 3.0 2.2 1.1 3.0 2.1 Bakeries 45.2 32.5 17.2 44.6 31.9 Food manufacturing other than bakeries 65.0 46.8 24.8 64.1 45.9 Breweries 3.8 2.8 1.5 3.8 2.7 Soft drink manufacturing 4.7 3.4 1.8 4.7 3.3 Bottled water manufacturing 2.4 1.8 0.9 2.4 1.7 Ice manufacturing 3.1 2.3 1.2 3.1 2.2 Ice rinks 1.7 1.2 0.6 1.7 1.2 Elementary and secondary schools 1.0 1.0 1.0 0.9 0.9 Junior colleges, colleges, and universities 0.2 0.2 0.2 0.2 0.2 Hospitals 0.7 0.7 0.7 0.7 0.7 Other, buildings not included above 28.9 28.9 28.9 26.8 26.8 Total 492.8 393.9 273.0 483.0 384.1 
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Table 36. Total incremental benefit of each regulatory option under Scenario 2 by sector (ODP-weighted t

Option

Sector

1 

(5% and 10%)

2 

(5% and 20%)

3 

(5% and 30%) 

4 

(10% and 10%)

5 

(10% and 

Supermarkets and grocery stores 166.8 137.8 101.8 165.0 136.1 Convenience stores 0.7 0.7 0.7 0.7 0.7 Gas station convenience stores 1.8 1.8 1.8 1.7 1.7 Warehouse and club supercenters 6.5 5.5 4.3 6.4 5.4 Refrigerated warehouse and storage 2.8 2.4 1.9 2.8 2.3 Refrigerated warehouse farm products 1.6 1.3 1.0 1.5 1.3 Office building managers 0.3 0.3 0.3 0.2 0.2 Lodging 24.3 24.3 24.3 22.3 22.3 Chemical manufacturing 76.4 49.9 17.6 75.2 48.6 Pharmaceutical manufacturing 12.0 7.8 2.8 11.8 7.6 Petrochemical manufacturing 2.4 1.5 0.5 2.3 1.5 Bakeries 35.6 23.2 8.2 35.0 22.6 Food manufacturing other than bakeries 51.2 33.4 11.8 50.4 32.5 Breweries 3.0 2.0 0.7 3.0 1.9 Soft drink manufacturing 3.7 2.4 0.9 3.7 2.4 Bottled water manufacturing 1.9 1.3 0.4 1.9 1.2 Ice manufacturing 2.5 1.6 0.6 2.4 1.6 Ice rinks 1.4 0.8 0.2 1.3 0.8 Elementary and secondary schools 0.9 0.9 0.9 0.8 0.8 Junior colleges, colleges, and universities 0.2 0.2 0.2 0.2 0.2 Hospitals 0.6 0.6 0.6 0.6 0.6 Other, buildings not included above 26.0 26.0 26.0 23.9 23.9 Total 422.6 325.8 207.5 413.1 316.3 
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Table 37. Total incremental benefit of each regulatory option under Scenario 1 by sector (MMTCE) 

Option

Sector

1 

(5% and 10%)

2 

(5% and 20%)

3 

(5% and 30%) 

4 

(10% and 10%)

5 

(10% and 

Supermarkets and grocery stores 1.49 1.23 0.89 1.49 1.2Convenience stores < 0.01 < 0.01 < 0.01 < 0.01 < 0.0Gas station convenience stores 0.01 0.01 0.01 0.01 0.0Warehouse and club supercenters 0.05 0.05 0.03 0.05 0.0Refrigerated warehouse and storage 0.02 0.02 0.01 0.02 0.0Refrigerated warehouse farm products 0.01 0.01 0.01 0.01 0.0Office building managers < 0.01 < 0.01 < 0.01 < 0.01 < 0.0Lodging 0.12 0.12 0.12 0.11 0.1Chemical manufacturing 0.26 0.20 0.12 0.26 0.1Pharmaceutical manufacturing 0.04 0.03 0.02 0.04 0.0Petrochemical manufacturing 0.01 0.01 < 0.01 0.01 0.0Bakeries 0.12 0.09 0.06 0.12 0.0Food manufacturing other than bakeries 0.18 0.13 0.08 0.17 0.1Breweries 0.01 0.01 < 0.01 0.01 0.0Soft drink manufacturing 0.01 0.01 0.01 0.01 0.0Bottled water manufacturing 0.01 0.01 < 0.01 0.01 < 0.0Ice manufacturing 0.01 0.01 < 0.01 0.01 0.0Ice rinks < 0.01 < 0.01 < 0.01 < 0.01 < 0.0Elementary and secondary schools < 0.01 < 0.01 < 0.01 < 0.01 < 0.0Junior colleges, colleges, and universities < 0.01 < 0.01 < 0.01 < 0.01 < 0.0Hospitals < 0.01 < 0.01 < 0.01 < 0.01 < 0.0Other, buildings not included above 0.12 0.12 0.12 0.11 0.1Total 2.50 2.06 1.51 2.46 2.0
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Table 38. Total incremental benefit of each regulatory option under Scenario 2 by sector (MMTCE) 

Option

Sector

1 

(5% and 10%)

2 

(5% and 20%)

3 

(5% and 30%) 

4 

(10% and 10%)

5 

(10% and 

Supermarkets and grocery stores 1.40 1.14 0.81 1.39 1.1Convenience stores < 0.01 < 0.01 < 0.01 < 0.01 < 0.0Gas station convenience stores 0.01 0.01 0.01 0.01 0.0Warehouse and club supercenters 0.05 0.04 0.03 0.05 0.0Refrigerated warehouse and storage 0.02 0.02 0.01 0.02 0.0Refrigerated warehouse farm products 0.01 0.01 0.01 0.01 0.0Office building managers < 0.01 < 0.01 < 0.01 < 0.01 < 0.0Lodging 0.10 0.10 0.10 0.10 0.1Chemical manufacturing 0.21 0.15 0.08 0.21 0.1Pharmaceutical manufacturing 0.03 0.02 0.01 0.03 0.0Petrochemical manufacturing 0.01 < 0.01 < 0.01 0.01 < 0.0Bakeries 0.10 0.07 0.04 0.10 0.0Food manufacturing other than bakeries 0.14 0.10 0.05 0.14 0.1Breweries 0.01 0.01 < 0.01 0.01 0.0Soft drink manufacturing 0.01 0.01 < 0.01 0.01 0.0Bottled water manufacturing 0.01 < 0.01 < 0.01 0.01 < 0.0Ice manufacturing 0.01 < 0.01 < 0.01 0.01 < 0.0Ice rinks < 0.01 < 0.01 < 0.01 < 0.01 < 0.0Elementary and secondary schools < 0.01 < 0.01 < 0.01 < 0.01 < 0.0Junior colleges, colleges, and universities < 0.01 < 0.01 < 0.01 < 0.01 < 0.0Hospitals < 0.01 < 0.01 < 0.01 < 0.01 < 0.0Other, buildings not included above 0.11 0.11 0.11 0.10 0.1Total 2.25 1.82 1.28 2.21 1.7
 

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The health analysis used the AHEF to estimate the reductions in fatal and nonfatal cases of skin 

cancers. AHEF was originally developed for EPA to conduct analysis of stratospheric ozone 

depletion, and EPA has relied on AHEF analysis since prior to the 1987 signing of the Montreal 

Protocol on Substances That Deplete the Ozone Layer. 

AHEF has been revised and updated numerous times, incorporating new scientific information 

on the complex relationships between ODS emissions, stratospheric ozone depletion, and human 

health. The analysis is this screening analysis uses the version of AHEF, which is described in 

detail in a 2006 EPA peer reviewed report (U.S. EPA, 2006c). 

AHEF is an integrated model of stratospheric ozone levels, ODS emissions, UV exposure, 

population, and health effects. The analytical structure of AHEF is as follows. 

1. Compute projections of baseline incidence and mortality based on historical rates 

assuming stratospheric ozone concentrations remain constant. Baseline incidence and 

morality projections vary by latitude to reflect differing UV radiation levels. 

2. Model the impacts of future emissions of ODS on stratospheric ozone concentrations. 

3. Estimate changes in ground-level UV radiation. UV changes vary by latitude. 

4. Select dose-response relationships for skin cancer incidence and mortality. 

5. Combine all the inputs to project future skin cancer incidence and mortality. 

ODS emissions reductions result in health benefits that occur over an extended period of time. 

The extended lag time is the result of two separate issues. First, ODS emissions can deplete 

stratospheric ozone for an extended period time, with some ODS chemicals reducing ozone 

concentrations for decades. Second, cumulative UV exposure over a lifetime is the most 

important risk factor for skin cancer. As discussed in the AHEF documentation, early life 

exposure has been identified as a potentially important risk factor, people receive 50% of their 

cumulative lifetime UV exposure before the age of 18. Some skin cancers that result from 

childhood UV exposure, however, will not occur until an individual is elderly. 

The combination of the two lag effect issues means that ODS emissions reductions occurring in a 

single year (modeled as 2010) will result in new fatal and nonfatal skin cancer cases occurring 

through the year 2140. AHEF estimates that the maximum reduction in new cases of skin cancers 

associated with a single year’s ODS emissions reductions will occur between 25 and 60 years 

after the emissions are reduced. The AHEF estimates of the impact of the lagged impacts for 

emissions reductions occurring in 2010 from a single ODS option (Scenario 1, Option 1) are 

shown in Figure 1. All the rule revision options in this analysis have a similar pattern of the 

timing of health effects resulting from emissions reductions occurring in 2010. 
 

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0

0.01

0.02

0.03

0.04

20102030205020702090211021302150

Year

Reduced mortality

0.0

1.0

2.0

3.0

4.0

Reduced cases of non-fatal 

cancers

Mortality Non-Fatal Cancers

Figure 1. Example of lag in health effects from emissions reductions in 2010 (results for 

Scenario 1, Option 1). 

AHEF estimates the reduction in cases in the United States for three types of skin cancer: 

 Cutaneous malignant melanoma 

 Basal cell carcinoma 

 Squamous cell carcinoma. 

AHEF estimates the decreased incidence of new cases of each type of skin cancer and the 

number of these new cancer cases that will result in a fatality in each year through 2150. 

The dose-response functions selected for use in AHEF are only applied to lighter-skinned racial 

populations in the United States. While higher UV levels are a known risk factor for skin cancers 

in people with darker skin, the dose-response functions appropriate for individuals with darker 

skin are likely to be different than the functions currently selected in AHEF. Modeling only the 

lighter-skinned U.S. population leads to an underestimate of the total health effects of reducing 

ODS emissions. 

Tables 39 and 40 present the AHEF estimates of the cumulative reductions in each type of skin 

cancer for each of the 12 regulatory options. The avoided cases of skin cancers in Tables 39 and 

40 are the total number of cases that occur over a 120-year period. The final incidence reductions 

associated with emissions reductions occurring in 2010 occur in 2131. 
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Table 39. Health benefits of the different options for the proposed rule under Scenario 1

Cumulative reductions in incidence of skin cancers (2010 through 2131)

Cumulative cases (fatal or non-fatal) Cumulative mortality

Option

Cutaneous 

malignant 

melanoma 

Basal cell 

carcinoma 

(BCC) 

Squamous cell 

carcinoma 

(SCC) 

Total 

cases, all 

cancers 

Melanoma 

mortality 

All carcinoma 

mortality 

(BCC + SCC) 

1 (5% and 10%) 5.0 121.2 62.2 188.4 0.6 0.3 2 (5% and 20%) 4.0 96.9 49.7 150.5 0.5 0.3 3 (5% and 30%) 2.8 67.1 34.4 104.3 0.3 0.2 4 (10% and 10%) 4.9 118.8 60.9 184.6 0.6 0.3 5 (10% and 20%) 3.9 94.5 48.4 146.8 0.5 0.3 6 (10% and 30%) 2.7 64.7 33.2 100.6 0.3 0.2 

Table 40. Health benefits of the different options for the proposed rule under Scenario 2

Cumulative reductions in incidence of skin cancers (2010 through 2131)

Cumulative cases (fatal or non-fatal) Cumulative mortality

Option

Cutaneous 

malignant 

melanoma 

Basal cell 

carcinoma 

(BCC) 

Squamous cell 

carcinoma 

(SCC) 

Total cases, 

all cancers 

Melanoma 

mortality 

Carcinoma 

mortality 

(BCC + SCC) 

m

1 (5% and 10%) 4.3 103.9 53.3 161.5 0.5 0.3 2 (5% and 20%) 3.3 80.1 41.1 124.5 0.4 0.2 3 (5% and 30%) 2.1 51.0 26.2 79.3 0.3 0.1 4 (10% and 10%) 4.2 101.6 52.1 157.9 0.5 0.3 5 (10% and 20%) 3.2 77.8 39.9 120.9 0.4 0.2 6 (10% and 30%) 2.0 48.7 25.0 75.7 0.3 0.1 
 

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5.3 Health Benefits Economic Analysis 

The valuation approach used to estimate the economic value of the avoided skin cancers is 

derived from the approach used in previous EPA regulatory analyses. As described below, the 

specific value functions (i.e., “unit values”) used in this analysis have been adjusted to reflect 

2007 price levels, and expected U.S. income levels in 2010. 

5.3.1 Valuing fatal skin cancers 

There is extensive literature about the appropriate value of a change in the risk of premature 

morality to use in EPA regulatory analyses. The value of a fatal risk is referred to as the value of 

a statistical life (VSL). The value selected for use in this analysis is derived from the specific 

VSL methods EPA used in RIAs for the Clean Air Interstate Rule (U.S. EPA, 2005b), the 

Regulatory Impact Analysis for Particulate Matter (U.S. EPA, 2006d), and the RIA for the 

Proposed Revisions to the National Ambient Air Quality Standards for Ground-Level Ozone 

(U.S. EPA, 2007). 

In terms of 1999 prices and 2010 income, the VSL used in the previous EPA RIAs is 

$6.05 million. Adjusting from 1999 prices to November 2007 prices using the Consumer Price 

Index-Urban increases the VSL by a factor of 1.26. The resulting VSL in 2007 prices and 2010 

income is $7.63 million. 

The ODS emissions reductions in 2010 will result in the estimated reduced future fatalities 

presented in Tables 39 and 40. Consistent with the methods used in previous EPA RIAs to value 

the lagging mortality associated with particulate matter (which occurs over a 20-year period 

following the change in emissions), the present value of the ODS-related avoided fatalities 

occurring in the future must be discounted. Because of the extended lag involved with skin 

cancer fatalities associated with ODS emissions reductions, discounting substantially reduces the 

VSL. This analysis presents the results using both a 3% and a 7% discount rate. With a 3% 

discount rate, the average present value of VSL for the ODS-related fatalities is $2.0 million. A 

7% discount rate results in a present value of VSL of $602,000. 

5.3.2 Valuing nonfatal cases of melanoma 

The values used for reduced cases of nonfatal cutaneous malignant melanoma used in previous 

EPA regulatory impact and policy analyses are derived from the estimated medical cost of 

treating nonfatal melanoma presented in the EPA Report to Congress on the Benefits and Costs 

of the CAA (U.S. EPA, 1999), which is known as the Section 812 First Prospective Report. 

Valuation approaches based on medical costs are referred to as cost of illness measures, rather 

than a willingness-to-pay based values. 
 

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The medical cost of treating a nonfatal case of melanoma used in the Section 812 First 

Prospective Report is $15,000, measured in 1990 prices. Adjusting the 1990 prices to November 

2007 prices using the Consumer Price Index for Medical Care Services increases the estimated 

cost by a factor of 2.31. This results in an estimated cost of $34,700 (in 2007 prices) to treat a 

case of nonfatal melanoma. 

Because the cases of nonfatal cases of melanoma occur in the future, and the future costs of 

treating the melanoma cases are incurred in the future, the future costs must be discounted. The 

average present values of the avoided cases of nonfatal melanoma are $10,300 using a 3% 

discount rate, and $3,400 using a 7% discount rate. 

5.3.3 Valuing nonfatal cases of carcinomas 

The Section 812 First Prospective Report reports that the medical cost of treating nonfatal 

carcinomas (including both basal cell carcinoma and squamous cell carcinoma) is $5,000 (in 

1990 prices). Following the same procedures used for valuing nonfatal melanomas (including 

using the same 2.31 factor to adjust to November 2007 prices), the average present value of the 

cost of treating a nonfatal case of basal cell carcinoma is $3,100 using a 3% discount rate, and 

$1,000 using a 7% discount rate. The average present value of the cost of treating squamous cell 

carcinoma is $3,000 (with 3% discounting) and $900 (with 7% discounting). The costs differ 

because the lag structure is somewhat different for the two types of carcinoma. The lag time to 

the onset of squamous cell carcinomas somewhat longer than the lag to onset of basal cell 

carcinomas, which results in the somewhat lower present value of the average cost for squamous 

cell carcinomas. 

5.3.4 Estimated value of reduced health effects 

The present value of the monetizable benefits of avoided health effects for the Scenario 1 and 

Scenario 2 options, using both a 3% and a 7% discount rate, are presented in Tables 41 and 42, 

respectively. For Scenario 1, the total monetized health benefits range between $1.3 million and 

$2.5 million with a 3% discount rate and between $0.4 million and $0.8 million with a 7% 

discount rate. For Scenario 2, the total monetized health benefits range between $1.0 million and 

$2.2 million with a 3% discount rate and between $0.3 million and $0.7 million with a 7% 

discount rate. Option 5 under Scenario 2 has total benefits of $1.6 million with a 3% discount 

rate and $0.5 with a 7% discount rate. 
 

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Table 41. Value of health benefits of the different options for the proposed rule under 

Scenario 1 

Present value of reductions in incidence of skin cancers (2010 through 2131) 

Option

Value of 

avoided 

mortality 

Value of 

non-fatal 

melanoma 

Value of 

non-fatal basal 

cell carcinoma 

Value of 

non-fatal squamish 

cell carcinoma 

Total 

benefits 

3% discount rate 

1 (5% and 10%) $1,916,000 $45,000 $378,000 $182,000 $2,521,000 

2 (5% and 20%) $1,531,000 $36,000 $302,000 $146,000 $2,015,000 

3 (5% and 30%) $1,061,000 $25,000 $209,000 $101,000 $1,396,000 

4 (10% and 10%) $1,878,000 $44,000 $370,000 $179,000 $2,471,000 

5 (10% and 20%) $1,493,000 $35,000 $294,000 $142,000 $1,965,000 

6 (10% and 30%) $1,023,000 $24,000 $202,000 $97,000 $1,347,000 

7% discount rate 

1 (5% and 10%) $577,000 $15,000 $116,000 $46,000 $754,000 

2 (5% and 20%) $461,000 $12,000 $93,000 $35,000 $601,000 

3 (5% and 30%) $320,000 $8,000 $64,000 $23,000 $415,000 

4 (10% and 10%) $565,000 $14,000 $114,000 $45,000 $739,000 

5 (10% and 20%) $450,000 $12,000 $90,000 $34,000 $586,000 

6 (10% and 30%) $308,000 $8,000 $62,000 $22,000 $400,000 

Table 42. Value of health benefits of the different options for the proposed rule under 

Scenario 2 

Present value of reductions in incidence of skin cancers (2010 through 2131) 

Option

Value of 

avoided 

mortality 

Value of nonfatal 

melanoma 

Value of nonfatal basal cell 

carcinoma 

Value of non-fatal 

squamish cell 

carcinoma 

Total 

benefits 

3% discount rate 

1 (5% and 10%) $1,643,000 $41,000 $324,000 $156,000 $2,164,000 

2 (5% and 20%) $1,267,000 $32,000 $250,000 $120,000 $1,669,000 

3 (5% and 30%) $807,000 $20,000 $159,000 $77,000 $1,063,000 

4 (10% and 10%) $1,606,000 $40,000 $317,000 $153,000 $2,116,000 

5 (10% and 20%) $1,230,000 $31,000 $242,000 $117,000 $1,620,000 

6 (10% and 30%) $770,000 $19,000 $152,000 $73,000 $1,014,000 

7% discount rate 

1 (5% and 10%) $495,000 $13,000 $100,000 $46,000 $653,000 

2 (5% and 20%) $381,000 $10,000 $77,000 $35,000 $503,000 

3 (5% and 30%) $243,000 $6,000 $49,000 $23,000 $321,000 

4 (10% and 10%) $484,000 $12,000 $97,000 $45,000 $638,000 

5 (10% and 20%) $370,000 $9,000 $74,000 $34,000 $489,000 

6 (10% and 30%) $232,000 $6,000 $47,000 $22,000 $306,000 
 

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6. Synthesis of Benefits and Costs 

The final step was to compare the benefits and costs of the different options. Both costeffectiveness analysis and net benefits analysis were conducted for each of the options and 

described below. 

6.1 Cost-Effectiveness Analysis 

The avoided ODS emissions can be measured in terms of both ODP-weighted kilograms (ODPkilograms) and metric tonnes of carbon equivalent (MTCE). There is, therefore, a separate 

C-E estimate for ODP-kilograms and MTCE for each option. Because the primary purpose of the 

regulatory options is to reduce ODS emissions, the ODP-kilogram C-E measure is the most 

relevant. The MTCE measure is included in the analysis for completeness (see Tables A.13 

through A.18 in the attachment). The two C-E measures cannot be considered as additive. For 

each regulatory option the numerator (total cost) in both measures is the same. Only the 

denominator in the C-E calculation (emissions measured in terms of ODP-kilograms or MTCE) 

differs. 

C-E analysis calculates the cost of emissions reductions in terms of cost per ODP-kilogram. An 

option with a lower C-E value is thus less expensive (per kilogram) than an option with a higher 

C-E value, and is considered more cost-effective. 

Tables 43 and 44 present the average C-E in terms of ODP-weighted kilograms of each 

equipment category for each of the regulatory options. As an average C-E analysis, each option 

is compared to the baseline. 

Table 43. Average cost-effectiveness of options for proposed regulation under Scenario 1 

Equipment 

Allowable annual 

leak rate 

Cost 

(million dollars)

Benefit 

(ODP-weighted tonnes) 

Cost-effectiveness 

($/ODP-weighted kg) 

CC 10% $35.8 124 $289 

 5% $41.5 134 $311 

CR 30% $32.9 92 $357 

 20% $45.8 131 $349 

 10% $62.5 162 $385 

IPR 30% $17.8 47 $378 

 20% $23.7 129 $183 

 10% $31.6 197 $161 
 

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Table 44. Average cost-effectiveness of options for proposed regulation under Scenario 2 

Equipment 

Allowable annual 

leak rate 

Cost 

(million dollars)

Benefit 

(ODP-weighted tonnes) 

Cost-effectiveness 

($/ODP-weighted kg) 

CC 10% $13.1 111 $118 

 5% $15.8 120 $132 

CR 30% $14.2 84 $169 

 20% $21.3 122 $175 

 10% $30.3 153 $199 

IPR 30% $1.2 4 $325 

 20% $3.8 84 $45 

 10% $7.1 150 $47 

Tightening the CC annual leak rate option from 10% to 5% increases the average cost per 

kilogram, raising the average C-E per ODP-weighted kilogram from $290 under Scenario 1 and 

$118 under Scenario 2 per ODP-kilogram to $311 and $132 per ODP-kilogram, respectively. 

The average C-E of CR equipment decreases (becoming less expensive per kilogram) between 

the 30% and 20% option in Scenario 1. Further tightening the stringency to 10%, however, 

increases the average cost to $385 per ODP-kilogram. Under Scenario 2, however, costs steadily 

increase with stringency. The average C-E for IPR equipment decreases continually as the leak 

rate options becomes more stringent (i.e., from 30% to 10%) in Scenario 1. In Scenario 2, C-E 

for IPR equipment is the lowest at 20%.

Tables 45 and 46 present the incremental C-E of increasing levels of stringency for the annual 

leak rate options. For CC equipment, it costs $336 per ODP-kilogram under Scenario 1 and $143 

under Scenario 2 to implement the least stringent requirement (10%). The cost per kilogram of 

the additional emissions reductions as a result of tightening the allowable emission rate to 5% is 

higher, $587 per ODP-kilogram under Scenario 1 and $283 under Scenario 2. 

For CR equipment, the C-E of the least stringent (30%) option is $357 per ODP-kilogram under 

Scenario 1 and $169 under Scenario 2. The cost per kilogram of the additional emissions reduced 

by increasing the stringency to 20% declines to $332 in Scenario 1 and increases to $188 per 

ODP-kilogram in Scenario 2. Increasing the stringency further to a 10% leak rate is more 

expensive per additional kilogram reduced, with the incremental C-E of $534 and $294 per 

ODP-kilogram, respectively. The CR stringency options under Scenario 1 have a classic 

“U-shaped” marginal cost curve, with the cost per emissions reduction initially decreasing, and 

then increasing.
 

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Table 45. Incremental cost-effectiveness of options for proposed regulation under 

Scenario 1 

Equipment 

Allowable 

annual 

leak rate 

Incremental 

cost 

(million dollars)

Incremental 

benefit 

(ODP-weighted tonnes)

Incremental 

cost-effectiveness 

($/ODP-weighted kg) 

CC 10% $41.5 124 $335 

 5% $5.7 10 $587 

CR 30% $32.9 92 $357 

 20% $12.9 39 $332 

 10% $16.7 31 $533 

IPR 30% $17.8 47 $378 

 20% $5.9 82 $72 

 10% $7.9 68 $117 

Table 46. Incremental cost-effectiveness of options for proposed regulation under 

Scenario 2 

Equipment 

Allowable 

annual 

leak rate 

Incremental 

cost 

(million dollars)

Incremental 

benefit 

(ODP-weighted tonnes) 

Incremental 

cost-effectiveness 

($/ODP-weighted kg)

CC 10% $15.8 111 $143 

 5% $2.7 10 $283 

CR 30% $14.2 84 $169 

 20% $7.2 38 $188 

 10% $9.0 31 $294 

IPR 30% $1.2 4 $325 

 20% $2.6 80 $33 

 10% $3.3 66 $50 

IPR equipment also has a “U-shaped” marginal cost curve. The C-E of the least stringent (30%) 

option is $379 under Scenario 1 and $325 under Scenario 2 per ODP-kilogram. The marginal 

cost per kilogram of increasing the stringency to the 20% option is less expensive, $72 and 

$33 per ODP-kilogram, respectively. The additional emissions reductions from the 10% option 

become more expensive, at $117 and $50 per ODP- kilogram, respectively. 

Tables 47 and 48 present the average C-E of the combined options for the proposed regulation. It 

appears that under Scenario 1, Option 4 (10% and 10%) is the most cost-effective at $269 per 

ODP-kilogram. Under Scenario 2, Option 5 (10% and 20%) is most cost effective at $121 per 

ODP-kilogram. The least cost-effective option under both scenarios appears to be Option 3 (5% 

and 30%) at $338 and $150 per ODP-kilogram, respectively. The average C-E of these options is 

driven in large part by the average C-E of IPR. 

The C-E in terms of MTCE follows similar patterns. 
 

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Table 47. Average cost-effectiveness of options for proposed regulation 

under Scenario 1 

Option 

Cost 

(million dollars) 

Benefit 

(ODP-weighted tonnes)

Cost-effectiveness 

($/ODP-weighted kg) 

1 (5% and 10%) $135.6 493 $275 

2 (5% and 20%) $111.0 394 $282 

3 (5% and 30%) $92.2 273 $338 

4 (10% and 10%) $129.9 483 $269 

5 (10% and 20%) $105.3 384 $274 

6 (10% and 30%) $86.5 263 $329 

Table 48. Average cost-effectiveness of options for proposed regulation 

under Scenario 2 

Option 

Cost 

(million dollars)

Benefit 

(ODP-weighted tonnes)

Cost-effectiveness 

($/ODP-weighted kg) 

1 (5% and 10%) $53.2 423 $126 

2 (5% and 20%) $40.9 326 $126 

3 (5% and 30%) $31.1 208 $150 

4 (10% and 10%) $50.5 413 $122 

5 (10% and 20%) $38.2 316 $121 

6 (10% and 30%) $28.5 198 $144 

6.2 Net Benefits Analysis 

The net benefits of each of the options represents the difference between the costs and monetized 

portion of the benefits associated with that option. The costs outweigh the monetizable benefits 

for each of the options resulting in negative net monetized benefits, as shown in Tables 49 and 

50 for Scenarios 1 and 2 with both a 3% and 7% discount rate. 

Table 49. Monetized net benefits of regulation under Scenario 1 (million $) 

3% discount rate 7% discount rate 

Leak rate Costs Total benefits Net Benefits Total benefits Net Benefits

1 (5% and 10%) 135.6 2.5 -133.1 0.8 -134.9 

2 (5% and 20%) 111.0 2.0 -109.0 0.6 -110.4 

3 (5% and 30%) 92.2 1.4 -90.8 0.4 -91.8 

4 (10% and 10%) 129.9 2.5 -127.4 0.7 -129.2 

5 (10% and 20%) 105.3 2.0 -103.3 0.6 -104.7 

6 (10% and 30%) 86.5 1.3 -85.2 0.4 -86.1 
 

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Table 50. Monetized net benefits of regulation under Scenario 2 (million $) 

3% discount rate 7% discount rate 

Leak rate Costs Total benefits Net Benefits Total benefits Net Benefits

1 (5% and 10%) 53.2 2.2 -51.1 0.7 -52.6 

2 (5% and 20%) 40.9 1.7 -39.2 0.5 -40.4 

3 (5% and 30%) 31.1 1.1 -30.1 0.3 -30.8 

4 (10% and 10%) 50.5 2.1 -48.4 0.6 -49.9 

5 (10% and 20%) 38.2 1.6 -36.6 0.5 -37.7 

6 (10% and 30%) 28.5 1.0 -27.4 0.3 -28.1 

Under Scenario 1, the net benefits range from $-85.2 million to $-133.1 million with a 3% 

discount rate, and from $-86.1 million to $-134.9 million with a 7% discount rate. Under 

Scenario 2, the monetized net benefits range from $-27.4 million to $-51.1 million with a 3% 

discount rate, and from $-28.1 million to $-52.6 million with a 7% discount rate. Option 5 under 

Scenario 2 has a monetized net benefit of $-36.6 million with a 3% discount rate and $-37.7 with 

a 7% discount rate. 

It should be noted that these estimates of net benefits are understated, because the benefits reflect 

only the portion of health risk reductions that were readily monetized. Other potential human 

health risk reductions, and other types of benefits, are not reflected in these net benefit 

calculations. 

6.3 Discussion of Uncertainties in Net Benefits Analysis 

The fundamental design of this analysis was to conduct a worst case scenario regulatory analysis. 

The analytical design included features likely leading to an overestimation of the actual costs, 

and an underestimation of the likely benefits. 

Specifically, the analysis selected methods by which the costs were intentionally measured and 

analyzed to provide a ceiling (i.e., worst case) analysis of the potential economic impact of the 

proposed regulation. However, the actual costs may be lower in practice. A comprehensive 

analysis using complete information (much of which is not available) would result in a lower 

estimated cost for each of the regulatory options. 

Similarly, due to a lack of complete information, the benefits analysis omitted categories of 

benefits that would likely increase the estimated benefits. These omitted benefit categories 

include both non-monetized benefits from the long-term health benefits from additional years of 
 

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the rule, as well as benefit categories from other mechanisms, such as health and ecological 

benefits from reductions in the GWP of the ODS emissions. 

This section discusses several of the important issues involved with the cost and benefit 

uncertainties. 

6.3.1 Potentially overestimated costs 

A comprehensive analysis using complete information (much of which is not available) would 

likely estimate a lower cost of each of the regulatory options than is presented in this screening 

analysis. Ways in which the actual costs will likely be lower than the worst case cost analysis 

estimates include the following examples. 

 The existing analysis assumes that owners and operators will sequentially go through 

each level of repairs until the leaks are successfully repaired. In practice, owners and 

operators may skip intermediate steps, and their accompanying costs, in order to ensure 

leaks are properly repaired. After an initial Level 1 repair is unsuccessfully completed, 

good business practices will lead some equipment owners to voluntarily choose to 

accelerate a planned equipment replacement cycle, rather than following the step-by-step 

procedure required by the proposed rule. Such actions are a business-based decision, not 

a response to a regulatory mandate. Business-based decisions should not be considered a 

cost of the rule (although an earlier investment in replacement equipment would increase 

the present value of the investment cost). In this situation only the costs of the Level 1 

repair would appropriately be included as a cost of the rule (along with any increase in 

the present value of the investment cost), which would substantially lower the cost of the 

rule. For example, for the Commercial Refrigerant, Distributed System (the equipment 

category contributing the largest portion of the total costs of the rule as reported in the 

Draft Report), this good business practice assumption would lower the cost of the rule for 

this equipment category by 48% (the current portion of the cost from Levels 2 through 4 

repairs). Because adequate data are not available on the probability that such good 

business practice based activity will occur, the Draft Report assumes that this type of 

good business practice response will not occur; the companies are modeled as fully 

implementing each level repair as necessary. 

 The analysis assumes that owners and operators will only make repairs when mandated 

by regulation, thus overstating the costs of the regulation’s implementation. In practice, 

owners and operators may choose to repair leaks entirely independent of regulatory 

requirements. For businesses that follow such good business practice, there is no cost 

attributable to rule. 
 

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 Most likely, owners and operators, through routine maintenance, will make similar 

repairs to the prescribed regulation procedures in order to ensure functionality regardless 

of the implementation of the regulatory action. Routine maintenance following good 

business practices will lower the probability a leak will occur in the first place, lowering 

the number of pieces of equipment that ever exceed the leak threshold level in the first 

place. An additional compelling reason for business owners to properly maintain their 

equipment, and repair leaking equipment as quickly as possible, is energy efficiency. 

Clark (2008), an energy consultant to the food service industry, reports that refrigeration 

equipment operating with a 15% refrigerant loss consumes twice the electricity to achieve 

the same cooling results as properly maintained equipment. The substantial energy costs 

of operating cooling equipment with even a modest loss of refrigerant provides a 

powerful economic incentive to avoid leaks as much as possible, and repair them as soon 

as they are detected. 

 As regulations under EPA’s CAA continues to reduce the commercial supply of ODS, the 

cost of replacement refrigerant will continue to rise, providing greater financial incentive 

to owners to reduce leaks as quickly and effectively as possible. 

 The analysis assumes that owners and operators will wait the full length of time allowed 

under regulatory action before fixing leaks. In practice, a portion of owners and operators 

will likely choose not to wait this long to conduct repairs. Faster repairs will reduce both 

the costs of refilling the leaked refrigerant and the environmental impact of the leak. 

6.3.2 Additional benefits 

In order to create a worst case scenario RIA, this analysis did not monetize several benefit 

categories that have the potential for substantial economic and environmental benefits. These 

benefits include the following qualitative and non-monetized examples: 

Non-monetized benefits 

 The ODS benefits of regulation are only projected over the first year of implementation. 

The analysis does not monetize the potential long-term benefits of a reduction in 

refrigerant leaks and the accompanying decrease in ODS in the atmosphere. 

 As mentioned above in Section 6.3.1, higher energy costs provide an incentive to 

equipment owners to avoid leaks in their cooling and refrigeration equipment. Not only 

do energy savings provide an incentive to avoid leaks, but the energy savings from 

repairing a leak through rule compliance also avoids unnecessary energy use from using 

inefficient equipment. The potentially substantial energy savings generated by the rule 

are thus another non-quantified benefit category not reflected in the Draft Report. 
 

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Omitted greenhouse gas benefits 

Carbon-equivalent emission benefits were estimated only in terms of projected emissions 

reductions and not the economic value of emissions reductions. The amount of carbon-equivalent 

emission reductions from the proposed rules are substantial: between 1.5 and 2.5 MMTCE under 

the Scenario 1 options, and between 1.2 and 2.3 MMTCE under Scenario 2. The benefits of these 

avoided carbon emissions are not assigned an economic value in the Draft Report. 

There is, however, a burgeoning body of scientific and economic research on the “social cost of 

carbon.” The social cost of carbon is the monetized value of reducing carbon emissions. In a 

comprehensive review of the literature on estimates of the social cost of carbon, Tol (2005) 

identified 103 estimates in 28 published papers. The Fourth Assessment Report of the United 

Nation’s Intergovernmental Panel on Climate Change (IPCC, 2007) drew heavily on the Tol 

(2005) review, and developed a mean estimate of $43 (in 2006 dollars) for the value of a 

marginal reduction in a metric ton of carbon emissions in the year 2050. The IPCC estimated the 

social cost of carbon is growing at approximately 2.4% per year, hence the value in earlier years 

is lower. Expressed in 2011 terms (adjusting for growth from 2011 to 2050), the IPCC estimate 

is $14/ton. 

A quantified sensitivity analysis in a recent (June 2008) Preliminary Regulatory Impact Analysis 

June by the National Highway Traffic Safety Administration (NHTSA) used the $14/ton value 

derived from the IPCC as an upper bound estimate of the social cost of carbon. The NHTSA 

used $0/ton as a lower bound estimate, and the NHTSA’s central estimate was the midpoint of 

the range: $7/ton. The NHTSA Preliminary RIA noted that while this range of values for the 

social cost of carbon reflects was derived from an estimate of worldwide benefits, the NHTSA 

decided to use the same estimate for a benefit/ton value in the United States. 

In August 2008, EPA submitted a comment to the NHTSA rulemaking docket (Docket Number 

NHTSA 2008-0060). Among other comments, EPA recommended that NHTSA calculate and 

present worldwide benefits of the reductions in U.S. emissions (along the domestic-only benefits 

estimates). EPA comments noted that the estimates of the social cost of carbon that NHTSA used 

are only a partial accounting of benefits of reducing greenhouse gases. EPA quoted the IPCC 

report that was the source of the social cost of carbon estimates as stating that these social cost of 

carbon values are “very likely” underestimates of the true social cost of carbon. The IPCC 

defines “very likely” as a greater than 90% probability. 

Applying the NHTSA estimate of $7/ton as the social cost of carbon of reducing the carbonequivalent emissions of the leak rule (1.2 to 2.5 million ton) results in omitted first year benefits 

of $8.4 million to $15.5 million, which are not reflected in the monetized benefits analysis in the 

Draft Report. Using the NHTSA’s range of $0/ton to $14/ton produces a range of $0 to 

$31 million in the first year of the rule. Additional ODS reductions attributable to the rule in 

subsequent years will produce additional benefits. 
 

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Qualitative benefits 

In addition to the omitted quantified benefits estimates, there are also other qualitative benefits 

that were not included in the assessment. These benefit categories are qualitative because there 

are not methods currently available to quantify or monetize the benefits. The omitted qualitative 

benefits include the following. 

 The analysis does not monetize any of the environmental benefits of preventing a 

chronically leaking refrigerant system from continual operation. Additionally, the 

analysis does not quantify the ecological benefits of an accelerated transition to non-ODS 

alternative refrigerants. 

 Destruction of the ozone layer by ODS can result in increases in UV radiation, thus 

having potential impacts on animal and ecological well-being, in addition to the human 

health effects that are included in the analysis. 

 This analysis only quantifies the human health benefits of reducing the incidence of skin 

cancer infection, while omitting the additional benefits of limiting other health effects 

known to be associated with the accumulation of ODS. Elevated levels of ODS have been 

linked to premature aging, cataracts, and immune system suppression. 

Many of these benefits were excluded from the analysis because of the overwhelming challenge 

of placing clear economic benefits on non-market goods and services. However, their presence 

as non-quantified benefits adds substantial potential value associated with the proposed 

regulations. These omitted benefit categories lead to further underestimation of the total benefits 

of the proposed regulation. 

6.3.3 Summary of discussion of uncertainty in costs and benefits analysis 

Overall, there are a variety of factors that have been intentionally omitted from this analysis in 

order to generate a worst case scenario RIA. Conducting the analysis in this manner ensures that 

the policy is carefully constructed with the most pessimistic of benefit-cost possibilities in mind, 

thus allowing for regulation to potentially exceed expectations and generate greater net benefits 

upon implementation than presented in the draft screening analysis report. The greater net 

benefits could be better considered if some of the worst case scenario cost assumptions, and/or 

the limited scope of the benefits assessment, were revised using more complete information. 
 

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7. Statutory and Executive Order Impact Analysis 

This section summarizes the Statutory and EO impact analyses relevant for the regulation 

associated with leak repair requirements. The requirements and the way in which the analysis 

addresses these requirements are described below. 

 EO 12866 (Regulatory Planning and Review): Six of the 12 regulatory options examined 

in this analysis represent “economically significant regulatory action” because they are 

likely to have an annual effect on the economy of $100 million or more. The annual 

effect is over $100 million for all six of the Scenario 1 options, and for none of the 

Scenario 2 options. Accordingly, this screening analysis evaluates the costs and benefits 

of all of the regulatory options. 

 Paperwork Reduction Act, Unfunded Mandates Reform Act, EO 13132 (Federalism), and 

EO 13175 (“Consultation and Coordination with Indian Tribal Governments”): As 

discussed in Section 4.4, this action does impose recordkeeping but no reporting burden. 

Furthermore, this action is not anticipated to have substantial direct effects on the States, 

on the relationship between the national government and the States, or on the distribution 

of power and responsibilities among the various levels of government (per EO 13132), 

nor have any Tribal implications (per EO 13175). EPA will solicit comments during the 

public comment process. 

 RFA: The RFA generally requires EPA to prepare a regulatory flexibility analysis of any 

rule subject to notice and comment rulemaking requirements unless EPA certifies that the 

rule will not have a SISNOSE. Small entities include small businesses, small 

organizations, and small governmental jurisdictions. Sections 2.3, 2.4, and 2.5 present an 

economic screening analysis that examines the impacts of the proposed revisions on 

small entities. This screening analysis will assist EPA in determining whether any of the 

12 regulatory options will have a significant economic impact on a substantial number of 

small entities. 

 EO 13045 (Protection of Children from Environmental Health & Safety Risks): EO 

13045 applies to any rule that (1) is determined to be “economically significant” as 

defined under EO 12866, and (2) concerns an environmental health or safety risk that 

EPA has reason to believe may have a disproportionate effect on children. If the 

regulatory action meets both criteria, EPA must evaluate the environmental health or 

safety effects of the rule on children, and explain why the regulation is preferable to other 

potentially effective and reasonably feasible alternatives considered by EPA. 
 

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The Scenario 1 regulatory options meet the first requirement for being subject to EO 

13045, because the economic screening analysis determines that six Scenario 1 regulatory 

options may be economically significant as defined by EO 12866. 

While the quantified skin cancer health effects of reducing stratospheric ozone primarily 

occur in adults, exposure to UV radiation during childhood is directly linked to increased 

incidence of skin cancer later in life. According to EPA’s “Guide to Considering 

Children’s Health When Developing EPA Actions” (U.S. EPA, 2006b), a 

disproportionate risk to children occurs either when (1) children are more sensitive to a 

particular pollutant or agent being considered in the rulemaking, or (2) children are more 

likely to be exposed or are likely to be exposed to higher levels of the pollutant or agent 

than adults are. Direct exposure to ODS is not a risk to children, but the environmental 

effects of ODS emissions (i.e., UV radiation) are a health risk for children. Therefore, 

EPA may conclude that this proposed rulemaking is covered by EO 13045. 

If the EPA concludes that this proposed rulemaking is covered by EO 13045, the health 

risk analysis discussed in Section 5.2 (which was conducted using the peer-reviewed 

AHEF model), will meet the “Guide to Considering Children’s Health” objectives for 

both a preliminary children’s health risk analysis and a more detailed risk analysis of 

each proposed regulatory option. 

 EO 13211 (Actions that Significantly Affect Energy Supply, Distribution or Use): This 

rule is not expected to have adverse impacts on energy supply, distribution, or use. On the 

contrary, the regulatory options under consideration are expected to improve the efficient 

operation of refrigeration systems, and result in energy savings. Refrigeration and cooling 

equipment are less energy-efficient when operating with a diminished charge of 

refrigerant. By requiring timely and successful repair of ODS leaks in large refrigeration 

and cooling systems, the regulatory options will decrease the time the affected 

refrigeration and cooling equipment operates inefficiently. 

 EO 12898 (Federal Actions to Address Environmental Justice in Minority Populations 

and Low-Income Populations): EO 12898 requires EPA to consider the impact on 

minority populations and low-income populations. According to EPA guidance, agencies 

are to assess whether minority or low-income populations face a risk or a rate of exposure 

to hazards that are significant and that appreciably exceed the risk or rate to the general 

population or to the appropriate comparison group. Protecting stratospheric ozone by 

reducing emissions of ODS reduces risks of UV radiation for all sectors of the 

U.S. population, with the amount of protection increasing for residents in more northern 

latitudes. As described in Section 6.2, the darker-skinned U.S. population is believed to 

be less at risk from developing cancer from UV radiation than the lighter-skinned 

population, but are still at risk. Income level is not known to affect the risks of UV 

radiation. Because the risk of developing UV-related skin cancer will be reduced by the 
 

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same proportion of all individuals in any particular location, the regulatory options will 

not disproportionately affect the minority or low-income populations. 

8. Conclusions 

Based on this screening analysis, the total expected incremental cost of the rule across all sectors 

is between $86.5 million and $135.6 million under Scenario 1 and $28.5 million and 

$53.2 million under Scenario 2. Scenario 1 costs are greater than the $100 million adverse 

impact threshold for the purposes of EOs 12866 and 13422, while Scenario 2 costs all fall below 

this threshold. Option 5 under Scenario 2 has an expected incremental cost of $38.2 million with 

a total emissions reduction of 316 ODP-weighted tonnes or 1.8 MMTCE. The value of the 

avoided health effects is less than the total incremental cost for all regulatory options. 

The RFA screening analysis found that the revised rule will only significantly impact between 

1,396 and 1,775 small businesses under Scenario 1 and between 336 and 409 small businesses 

under the second scenario for the purposes of the RFA. The regulatory option selected for the 

rule, described in Section 1.2, would result in a total expected annual incremental cost of 

$38.2 million and only significantly impact 353 small businesses. 

Although there are uncertainties associated with several components of this analysis, we believe 

that the assumptions and methodology applied are logical, and that the results derived and 

presented here are reasonably robust. 

Bibliography 

A.D. Little. 2002. Global Comparative Analysis of HFC and Alternative Technologies for 

Refrigeration, Air Conditioning, Foam, Solvent, Aerosol Propellant, and Fire Protection 

Applications. Final Report to the Alliance for Responsible Atmospheric Policy, March 21, 2002. 

Available: http://www.arap.org/adlittle/toc.html. Accessed October 1, 2006. 

AQMD. 2006. Rule 1415 Registration Form. Available: 

http://www.aqmd.gov/prdas/forms/1415form2.doc. Accessed May 15, 2007. 

ARI. 2007. Air Conditioning and Refrigeration Institute (ARI), Statistical Release, February 5, 

2007. 

CFR Title 40, Part 82, Subpart F. 2003. Chapter 1  Environmental Protection Agency. Part 82 

Protection of Stratospheric Ozone. Subpart F: For Group VI Controlled Substances. Available: 

http://www.access.gpo.gov/nara/cfr/waisidx_05/40cfr82_05.html. Accessed May 15, 2007. 
 

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Page 93 

Do Not Cite or Quote 

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Chain Store Guide. 2007. Directory of Supermarket, Grocery & Convenience Store Chains.

Published by Business Guides, Inc. March. 

Clark, D. 2008. Energy efficient and sustainable refrigeration. Available: 

http://www.caterersearch.com/Articles/2008/06/18/321552/energy-efficient-and-sustainablerefrigeration.html. Accessed 7/15/2008. 

EIA. 2006. Commercial Building Energy Consumption Survey (CBECs), Table B30. Cooling 

Energy Sources, Number of Buildings and Floorspace for Non-Mall Buildings, 2003. Energy 

Information Administration. Available: 

http://www.eia.doe.gov/emeu/cbecs/cbecs2003/detailed_tables_2003/2003set6/2003html/b30.ht

ml. Accessed May 15, 2007. 

E.O. 1993. Executive Order 12866 Regulatory Planning and Review. September. Available: 

http://www.epa.gov/fedrgstr/eo/eo12866.htm. Accessed May 15, 2007. 

E.O. 2007. Further Amendment to Executive Order 12866 on Regulatory Planning and Review. 

January. Available: http://www.whitehouse.gov/news/releases/2007/01/20070118.html. 

Accessed May 15, 2007. 

ICF. 1997. Analysis of the Costs and Benefits of Leak Repair Requirements for the Commercial 

Refrigeration and Retail Food Stores. Final report to Office of Air and Radiation, 

U.S. Environmental Protection Agency. February 4. 

IPCC. 2007. Climate Change 2007: Impacts, Adaptation and Vulnerability. Contribution of 

Working Group II to the Fourth Assessment Report of the Intergovernmental Panel on Climate 

Change. 

SCAQMD. 1994. Rule 1415 – Reduction of Refrigerant Emissions from Stationary Refrigerant 

Emissions from Stationary Refrigeration and Air Conditioning Systems. October. Available: 

http://www.arb.ca.gov/DRDB/SC/CURHTML/R1415.HTM. Accessed May 15, 2007. 

SCAQMD. 2004. Data collected under Rule 1415 by the South Coast Air Quality Management 

District. 

SCAQMD. 2005. Data collected under Rule 1415 by the South Coast Air Quality Management 

District. 

Tol, R.S.J. 2005. The marginal damage costs of carbon dioxide emissions: An assessment of the 

uncertainties. Energy Policy 33(16):2064-2074. 
 

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Page 94 

Do Not Cite or Quote 

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U.S. BLS. 2007. Occupational Employment Statistics. Employer Costs for Employee 

Compensation. U.S. Bureau of Labor Statistics, US Department of Labor. Available: 

www.bls.gov/ncs/ect/home. Accessed May 23, 2007. 

U.S. Census Bureau. 2002a. North American Industry Classification System – Revisions for 

2002. Available: http://www.census.gov/epcd/naics02/. Accessed May 15, 2007. 

U.S. Census Bureau. 2002b. Statistics of U.S. Businesses. Available: 

http://www.census.gov/csd/susb/susb.htm. Accessed May 15, 2007. 

U.S. Census Bureau. 2004. Plumbing, Heating and Air-Conditioning Contractors: 2002. 

Construction Industry Series. 2002 Economic Census. Economics and Statistics Administration. 

U.S. EPA. 1999. The Benefits and Costs of the Clean Air Act, 1990 to 2010. EPA-410-R-99-

001. Available: http://www.epa.gov/airprogm/oar/sect812/prospective1.html. Accessed 

December 1, 2007. 

U.S. EPA. 2005a. Regulatory Analysis for the Proposed Revisions to the Oil Pollution 

Prevention Regulation (40 CFR PART 112). Available: 

http://yosemite.epa.gov/ee/epa/riafile.nsf/vwAN/Regulatory%20Analysis%20SPCC.pdf/$File/Re

gulatory%20Analysis%20SPCC.pdf. Accessed May 15, 2007. 

U.S. EPA. 2005b. Regulatory Impact Analysis for the Final Clean Air Interstate Rule. EPA452/R-05-002. Available: http://www.epa.gov/cair/pdfs/finaltech08.pdf. Accessed 12/1/2007. 

U.S. EPA. 2006a. Final Guidance for EPA Rulewriters: Regulatory Flexibility Act as Amended 

by the Small Business Regulatory Enforcement Fairness Act. November 2006. U.S. 

Environmental Protection Agency. Available: 

http://www.epa.gov/sbrefa/documents/rfafinalguidance06.pdf. Accessed May 15, 2007. 

U.S. EPA. 2006b. Guide to Considering Children’s Health When Developing EPA Actions: 

Implementing Executive Order 13045 and EPA’s Policy on Evaluating Health Risks to Children. 

Available: 

http://yosemite.epa.gov/ochp/ochpweb.nsf/content/ADPguide.htm/$File/EPA_ADP_Guide_508.

pdf. Accessed 12/1/2007. 

U.S. EPA. 2006c. Human Health Benefits of Stratospheric Ozone Protection; Peer Reviewed 

Report. Prepared for EPA by ICF Consulting. April 24, 2006. Available: 

http://www.epa.gov/Ozone/science/effects/AHEFDEC2003D3.pdf. Accessed 12/1/2007. 

U.S. EPA. 2006d. Regulatory Impact Analysis for the 2006 Revisions to the National Ambient 

Air Quality Standards for Particulate Matter. Available: http://www.epa.gov/ttn/ecas/ria.html. 

Accessed 12/1/2007. 
 

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U.S. EPA. 2007. Regulatory Impact Analysis of the Proposed Revisions to the National Ambient 

Air Quality Standards for Ground-Level Ozone. EPA-452/R-07-008. Available: 

http://www.epa.gov/ttn/ecas/ria.html. Accessed 12/1/2007. 

U.S. SBA. 2007. U.S. Small Business Administration: Table of Small Business Size Standards 

Matched to North American Industry Classification System Codes. October 1. 
 

 

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Attachment. Economic Analysis Detail Tables1

 

1. Note: Totals may vary slightly due to rounding. 
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Table A.1. Regulatory impact by sector and size category for Option 1 (5% and 10%) under Scenario 1 Sector NAICS code Number of employees

Proposed expected 

cost of compliance per 

size category 

Baseline expected cost 

of compliance 

per size category 

Supermarkets and grocery 445110 < 20 $33,200,000 $7,400,000 stores 20-99 $9,460,000 $2,080,000  100-499 $5,060,000 $1,100,000  500+ $37,900,000 $8,210,000 Totals All entities $85,700,000 $18,800,000 Convenience stores 445120 < 20 $299,000 $86,000  20-99 $13,000 $4,000  100-499 $8,000 $2,000  500+ $37,000 $11,000 Totals All entities $357,000 $103,000 Gas station convenience 447110 < 20 $376,000 $108,000 stores 20-99 $94,000 $27,000  100-499 $113,000 $33,000  500+ $301,000 $87,000 Totals All entities $884,000 $255,000 Warehouse and club 45291 < 20 $266,000 $61,000 supercenters 20-99 $16,000 $4,000  100-499 $42,000 $9,000  500+ $3,000,000 $684,000 Totals All entities $3,330,000 $758,000 Refrigerated warehouse and 49312 < 20 $624,000 $142,000 storage 20-99 $303,000 $69,000  100-499 $143,000 $32,000  500+ $371,000 $85,000 Totals All entities $1,440,000 $328,000 
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Table A.1. Regulatory impact by sector and size category for Option 1 (5% and 10%) under Scenario 1 (coSector NAICS code Number of employees

Proposed expected 

cost of compliance per 

size category 

Baseline expected cost 

of compliance 

per size category 

Refrigerated warehouse farm 49313 < 20 $429,000 $98,000 products 20-99 $116,000 $26,000  100-499 $108,000 $25,000  500+ $147,000 $33,000 Totals All entities $800,000 $182,000 Office building managers 531312 < 20 $90,000 $26,000  20-99 $12,000 $4,000  100-499 $6,000 $2,000  500+ $16,000 $5,000 Totals All entities $124,000 $36,000 Lodging 72 < 20 $7,180,000 $2,070,000  20-99 $1,860,000 $536,000  100-499 $725,000 $209,000  500+ $2,030,000 $585,000 Totals All entities $11,800,000 $3,400,000 Chemical manufacturing 325 < 20 $14,200,000 $5,800,000  20-99 $5,180,000 $2,110,000  100-499 $3,120,000 $1,270,000  500+ $8,330,000 $3,400,000 Totals All entities $30,900,000 $12,600,000 Pharmaceutical 3254 < 20 $2,220,000 $906,000 manufacturing 20-99 $843,000 $343,000  100-499 $567,000 $231,000  500+ $1,220,000 $497,000 Totals All entities $4,850,000 $1,980,000 
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Table A.1. Regulatory impact by sector and size category for Option 1 (5% and 10%) under Scenario 1 (coSector NAICS code Number of employees

Proposed expected 

cost of compliance per 

size category 

Baseline expected cost 

of compliance 

per size category 

Petrochemical 324110 < 20 $292,000 $119,000 manufacturing 20-99 $79,000 $32,000  100-499 $76,000 $31,000  500+ $505,000 $206,000 Totals All entities $952,000 $388,000 Bakeries 3118 < 20 $10,900,000 $4,440,000  20-99 $2,030,000 $828,000  100-499 $607,000 $247,000  500+ $843,000 $343,000 Totals All entities $14,400,000 $5,850,000 Food manufacturing other 311 < 20 $10,600,000 $4,300,000 than bakeries 20-99 $3,770,000 $1,540,000  100-499 $2,050,000 $837,000  500+ $4,300,000 $1,750,000 Totals All entities $20,700,000 $8,430,000 Breweries 31212 < 20 $797,000 $325,000  20-99 $267,000 $109,000  100-499 $65,000 $27,000  500+ $87,000 $36,000 Totals All entities $1,220,000 $496,000 Soft drink manufacturing 312111 < 20 $360,000 $147,000  20-99 $202,000 $82,000  100-499 $199,000 $81,000  500+ $742,000 $302,000 Totals All entities $1,500,000 $613,000 
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Table A.1. Regulatory impact by sector and size category for Option 1 (5% and 10%) under Scenario 1 (coSector NAICS code Number of employees

Proposed expected 

cost of compliance per 

size category 

Baseline expected cost 

of compliance 

per size category 

Bottled water manufacturing 312112 < 20 $494,000 $201,000  20-99 $104,000 $42,000  100-499 $30,000 $12,000  500+ $150,000 $61,000 Totals All entities $777,000 $317,000 Ice manufacturing 312113 < 20 $757,000 $308,000  20-99 $113,000 $46,000  100-499 $23,000 $9,000  500+ $106,000 $43,000 Totals All entities $998,000 $407,000 Ice rinks 713940 < 20 $455,000 $193,000  20-99 $80,000 $34,000  100-499 None None  500+ None None Totals All entities $535,000 $227,000 Elementary and secondary 6111 < 20 $171,000 $49,000 schools 20-99 $180,000 $52,000  100-499 $67,000 $19,000  500+ $17,000 $5,000 Totals All entities $436,000 $126,000 Junior colleges, colleges and 6112, 6113 < 20 $26,000 $7,000 universities 20-99 $12,000 $4,000  100-499 $17,000 $5,000  500+ $35,000 $10,000 Totals All entities $90,000 $26,000 
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Table A.1. Regulatory impact by sector and size category for Option 1 (5% and 10%) under Scenario 1 (coSector NAICS code Number of employees

Proposed expected 

cost of compliance per 

size category 

Baseline expected cost 

of compliance 

per size category 

Hospitals 611 < 20 $27,000 $8,000  20-99 $21,000 $6,000  100-499 $72,000 $21,000  500+ $195,000 $56,000 Totals All entities $316,000 $91,000 Other, not included above All entities $12,600,000 $3,640,000 Note: Totals may vary slightly due to rounding. 
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Table A.2. Regulatory impact by sector and size category for Option 2 (5% and 20%) under Scenario 1 Sector NAICS code Number of employees 

Proposed expected 

cost of compliance 

per size category 

Baseline expected cost 

of compliance 

per size category 

< 20 $27,400,000 $7,400,000 

20-99 $7,720,000 $2,080,000 

100-499 $4,110,000 $1,100,000 

Supermarkets and grocery stores 

445110 

500+ $30,700,000 $8,210,000 

Totals All entities $69,900,000 $18,800,000 

< 20 $299,000 $86,000 

20-99 $13,000 $4,000 

100-499 $8,000 $2,000 

Convenience stores 445120 

500+ $37,000 $11,000 

Totals All entities $357,000 $103,000 

< 20 $376,000 $108,000 

20-99 $94,000 $27,000 

100-499 $113,000 $33,000 

Gas station convenience stores 

447110 

500+ $301,000 $87,000 

Totals All entities $884,000 $255,000 

< 20 $223,000 $61,000 

20-99 $14,000 $4,000 

100-499 $35,000 $9,000 

Warehouse and club supercenters 

45291 

500+ $2,520,000 $684,000 

Totals All entities $2,790,000 $758,000 

< 20 $523,000 $142,000 

20-99 $254,000 $69,000 

100-499 $120,000 $32,000 

Refrigerated warehouse and storage 

49312 

500+ $311,000 $85,000 

Totals All entities $1,210,000 $328,000 
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Table A.2. Regulatory impact by sector and size category for Option 2 (5% and 20%) under Scenario 1 (coSector NAICS code Number of employees 

Proposed expected 

cost of compliance 

per size category 

Baseline expected cost 

of compliance 

per size category 

< 20 $360,000 $98,000 

20-99 $97,000 $26,000 

100-499 $91,000 $25,000 

Refrigerated warehouse farm products 

49313 

500+ $123,000 $33,000 

Totals All entities $671,000 $182,000 

< 20 $90,000 $26,000 

20-99 $12,000 $4,000 

100-499 $6,000 $2,000 

Office building managers 531312 

500+ $16,000 $5,000 

Totals All entities $124,000 $36,000 

< 20 $7,180,000 $2,070,000 

20-99 $1,860,000 $536,000 

100-499 $725,000 $209,000 

Lodging 72 

500+ $2,030,000 $585,000 

Totals All entities $11,800,000 $3,400,000 

< 20 $12,800,000 $5,800,000 

20-99 $4,650,000 $2,110,000 

100-499 $2,800,000 $1,270,000 

Chemical manufacturing 325 

500+ $7,480,000 $3,400,000 

Totals All entities $27,700,000 $12,600,000 

< 20 $1,990,000 $906,000 

20-99 $756,000 $343,000 

100-499 $509,000 $231,000 

Pharmaceutical manufacturing 

3254 

500+ $1,090,000 $497,000 

Totals All entities $4,350,000 $1,980,000 
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Table A.2. Regulatory impact by sector and size category for Option 2 (5% and 20%) under Scenario 1 (coSector NAICS code Number of employees 

Proposed expected 

cost of compliance 

per size category 

Baseline expected cost 

of compliance 

per size category 

< 20 $262,000 $119,000 

20-99 $71,000 $32,000 

100-499 $69,000 $31,000 

Petrochemical manufacturing 324110 

500+ $453,000 $206,000 

Totals All entities $854,000 $388,000 

< 20 $9,760,000 $4,440,000 

20-99 $1,820,000 $828,000 

100-499 $544,000 $247,000 

Bakeries 3118 

500+ $756,000 $343,000 

Totals All entities $12,900,000 $5,850,000 

< 20 $9,480,000 $4,300,000 

20-99 $3,380,000 $1,540,000 

100-499 $1,840,000 $837,000 

Food manufacturing other than bakeries 

311 

500+ $3,850,000 $1,750,000 

Totals All entities $18,600,000 $8,430,000 

< 20 $715,000 $325,000 

20-99 $240,000 $109,000 

100-499 $59,000 $27,000 

Breweries 31212 

500+ $78,000 $36,000 

Totals All entities $1,090,000 $496,000 

< 20 $323,000 $147,000 

20-99 $181,000 $82,000 

100-499 $179,000 $81,000 

Soft drink manufacturing 312111 

500+ $666,000 $302,000 

Totals All entities $1,350,000 $613,000 
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Table A.2. Regulatory impact by sector and size category for Option 2 (5% and 20%) under Scenario 1 (coSector NAICS code Number of employees 

Proposed expected 

cost of compliance 

per size category 

Baseline expected cost 

of compliance 

per size category 

< 20 $443,000 $201,000 

20-99 $93,000 $42,000 

100-499 $27,000 $12,000 

Bottled water manufacturing 312112 

500+ $135,000 $61,000 

Totals All entities $697,000 $317,000 

< 20 $679,000 $308,000 

20-99 $101,000 $46,000 

100-499 $20,000 $9,000 

Ice manufacturing 312113 

500+ $95,000 $43,000 

Totals All entities $896,000 $407,000 

< 20 $401,000 $193,000 

20-99 $71,000 $34,000 

100-499 None None 

Ice rinks 713940 

500+ None None 

Totals All entities $472,000 $227,000 

< 20 $171,000 $49,000 

20-99 $180,000 $52,000 

100-499 $67,000 $19,000 

Elementary and secondary schools 

6111 

500+ $17,000 $5,000 

Totals All entities $436,000 $126,000 

< 20 $26,000 $7,000 

20-99 $12,000 $4,000 

100-499 $17,000 $5,000 

Junior colleges, colleges and universities 

6112, 6113 

500+ $35,000 $10,000 

Totals All entities $90,000 $26,000 
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Table A.2. Regulatory impact by sector and size category for Option 2 (5% and 20%) under Scenario 1 (coSector NAICS code Number of employees 

Proposed expected 

cost of compliance 

per size category 

Baseline expected cost 

of compliance 

per size category 

< 20 $27,000 $8,000 

20-99 $21,000 $6,000 

100-499 $72,000 $21,000 

Hospitals 611 

500+ $195,000 $56,000 

Totals All entities $316,000 $91,000 Other, not included above All entities $12,600,000 $3,640,000 

Note: Totals may vary slightly due to rounding. 
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Table A.3. Regulatory impact by sector and size category for Option 3 (5% and 30%) under Scenario 1 Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Supermarkets and grocery 445110 < 20 $22,900,000 $7,400,000 stores 20-99 $6,380,000 $2,080,000  100-499 $3,370,000 $1,100,000  500+ $25,000,000 $8,210,000 Totals All entities $57,700,000 $18,800,000 Convenience stores 445120 < 20 $299,000 $86,000  20-99 $13,000 $4,000  100-499 $8,000 $2,000  500+ $37,000 $11,000 Totals All entities $357,000 $103,000 Gas station convenience 447110 < 20 $376,000 $108,000 stores 20-99 $94,000 $27,000  100-499 $113,000 $33,000  500+ $301,000 $87,000 Totals All entities $884,000 $255,000 Warehouse and club 45291 < 20 $190,000 $61,000 supercenters 20-99 $12,000 $4,000  100-499 $30,000 $9,000  500+ $2,140,000 $684,000 Totals All entities $2,370,000 $758,000 Refrigerated warehouse and 49312 < 20 $445,000 $142,000 storage 20-99 $216,000 $69,000  100-499 $102,000 $32,000  500+ $265,000 $85,000 Totals All entities $1,030,000 $328,000 
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Table A.3. Regulatory impact by sector and size category for Option 3 (5% and 30%) under Scenario 1 (coSector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Refrigerated warehouse farm 49313 < 20 $306,000 $98,000 products 20-99 $83,000 $26,000  100-499 $77,000 $25,000  500+ $105,000 $33,000 Totals All entities $571,000 $182,000 Office building managers 531312 < 20 $90,000 $26,000  20-99 $12,000 $4,000  100-499 $6,000 $2,000  500+ $16,000 $5,000 Totals All entities $124,000 $36,000 Lodging 72 < 20 $7,180,000 $2,070,000  20-99 $1,860,000 $536,000  100-499 $725,000 $209,000  500+ $2,030,000 $585,000 Totals All entities $11,800,000 $3,400,000 Chemical manufacturing 325 < 20 $11,700,000 $5,800,000  20-99 $4,250,000 $2,110,000  100-499 $2,560,000 $1,270,000  500+ $6,840,000 $3,400,000 Totals All entities $25,300,000 $12,600,000 Pharmaceutical 3254 < 20 $1,820,000 $906,000 manufacturing 20-99 $692,000 $343,000  100-499 $466,000 $231,000  500+ $1,000,000 $497,000 Totals All entities $3,980,000 $1,980,000 
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Table A.3. Regulatory impact by sector and size category for Option 3 (5% and 30%) under Scenario 1 (coSector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Petrochemical manufacturing 324110 < 20 $240,000 $119,000 

 20-99 $65,000 $32,000 

 100-499 $63,000 $31,000  500+ $414,000 $206,000 Totals All entities $781,000 $388,000 Bakeries 3118 < 20 $8,930,000 $4,440,000  20-99 $1,670,000 $828,000  100-499 $498,000 $247,000  500+ $692,000 $343,000 Totals All entities $11,800,000 $5,850,000 Food manufacturing other 311 < 20 $8,670,000 $4,300,000 than bakeries 20-99 $3,090,000 $1,540,000  100-499 $1,690,000 $837,000  500+ $3,530,000 $1,750,000 Totals All entities $17,000,000 $8,430,000 Breweries 31212 < 20 $654,000 $325,000  20-99 $219,000 $109,000  100-499 $54,000 $27,000  500+ $72,000 $36,000 Totals All entities $999,000 $496,000 Soft drink manufacturing 312111 < 20 $296,000 $147,000  20-99 $166,000 $82,000  100-499 $163,000 $81,000  500+ $609,000 $302,000 Totals All entities $1,230,000 $613,000 
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Table A.3. Regulatory impact by sector and size category for Option 3 (5% and 30%) under Scenario 1 (coSector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Bottled water manufacturing 312112 < 20 $405,000 $201,000  20-99 $85,000 $42,000  100-499 $25,000 $12,000  500+ $123,000 $61,000 Totals All entities $638,000 $317,000 Ice manufacturing 312113 < 20 $621,000 $308,000  20-99 $92,000 $46,000  100-499 $18,000 $9,000  500+ $87,000 $43,000 Totals All entities $819,000 $407,000 Ice rinks 713940 < 20 $361,000 $193,000  20-99 $64,000 $34,000  100-499 None None  500+ None None Totals All entities $425,000 $227,000 Elementary and secondary 6111 < 20 $171,000 $49,000 schools 20-99 $180,000 $52,000  100-499 $67,000 $19,000  500+ $17,000 $5,000 Totals All entities $436,000 $126,000 Junior colleges, colleges and 6112, 6113 < 20 $26,000 $7,000 universities 20-99 $12,000 $4,000  100-499 $17,000 $5,000  500+ $35,000 $10,000 Totals All entities $90,000 $26,000 
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Table A.3. Regulatory impact by sector and size category for Option 3 (5% and 30%) under Scenario 1 (coSector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Hospitals 611 < 20 $27,000 $8,000  20-99 $21,000 $6,000  100-499 $72,000 $21,000  500+ $195,000 $56,000 Totals All entities $316,000 $91,000 Other, not included above All entities $12,600,000 $3,640,000 Note: Totals may vary slightly due to rounding. 
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Table A.4. Regulatory impact by sector and size category for Option 4 (10% and 10%) under Scenario 1 Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Supermarkets and grocery 445110 < 20 $32,700,000 $7,400,000 stores 20-99 $9,330,000 $2,080,000  100-499 $5,010,000 $1,100,000  500+ $37,600,000 $8,210,000 Totals All entities $84,600,000 $18,800,000 Convenience stores 445120 < 20 $270,000 $86,000  20-99 $12,000 $4,000  100-499 $7,000 $2,000  500+ $34,000 $11,000 Totals All entities $322,000 $103,000 Gas station convenience 447110 < 20 $339,000 $108,000 stores 20-99 $85,000 $27,000  100-499 $102,000 $33,000  500+ $271,000 $87,000 Totals All entities $797,000 $255,000 Warehouse and club 45291 < 20 $260,000 $61,000 supercenters 20-99 $16,000 $4,000  100-499 $41,000 $9,000  500+ $2,940,000 $684,000 Totals All entities $3,250,000 $758,000 Refrigerated warehouse and 49312 < 20 $609,000 $142,000 storage 20-99 $296,000 $69,000  100-499 $139,000 $32,000  500+ $363,000 $85,000 Totals All entities $1,410,000 $328,000 
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Table A.4. Regulatory impact by sector and size category for Option 4 (10% and 10%) under Scenario 1 (Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Refrigerated warehouse farm 49313 < 20 $419,000 $98,000 products 20-99 $113,000 $26,000  100-499 $106,000 $25,000  500+ $144,000 $33,000 Totals All entities $782,000 $182,000 Office building managers 531312 < 20 $81,000 $26,000  20-99 $11,000 $4,000  100-499 $5,000 $2,000  500+ $14,000 $5,000 Totals All entities $112,000 $36,000 Lodging 72 < 20 $6,480,000 $2,070,000  20-99 $1,670,000 $536,000  100-499 $654,000 $209,000  500+ $1,830,000 $585,000 Totals All entities $10,600,000 $3,400,000 Chemical manufacturing 325 < 20 $13,900,000 $5,800,000  20-99 $5,050,000 $2,110,000  100-499 $3,040,000 $1,270,000  500+ $8,130,000 $3,400,000 Totals All entities $30,100,000 $12,600,000 Pharmaceutical 3254 < 20 $2,170,000 $906,000 manufacturing 20-99 $822,000 $343,000  100-499 $553,000 $231,000  500+ $1,190,000 $497,000 Totals All entities $4,730,000 $1,980,000 
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Table A.4. Regulatory impact by sector and size category for Option 4 (10% and 10%) under Scenario 1 (Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Petrochemical manufacturing 324110 < 20 $285,000 $119,000 

 20-99 $77,000 $32,000 

 100-499 $74,000 $31,000  500+ $492,000 $206,000 Totals All entities $928,000 $388,000 Bakeries 3118 < 20 $10,600,000 $4,440,000  20-99 $1,980,000 $828,000  100-499 $592,000 $247,000  500+ $822,000 $343,000 Totals All entities $14,000,000 $5,850,000 Food manufacturing other 311 < 20 $10,300,000 $4,300,000 than bakeries 20-99 $3,680,000 $1,540,000  100-499 $2,000,000 $837,000  500+ $4,190,000 $1,750,000 Totals All entities $20,200,000 $8,430,000 Breweries 31212 < 20 $777,000 $325,000  20-99 $261,000 $109,000  100-499 $64,000 $27,000  500+ $85,000 $36,000 Totals All entities $1,190,000 $496,000 Soft drink manufacturing 312111 < 20 $351,000 $147,000  20-99 $197,000 $82,000  100-499 $194,000 $81,000  500+ $724,000 $302,000 Totals All entities $1,470,000 $613,000 
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Table A.4. Regulatory impact by sector and size category for Option 4 (10% and 10%) under Scenario 1 (Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Bottled water manufacturing 312112 < 20 $481,000 $201,000  20-99 $101,000 $42,000  100-499 $29,000 $12,000  500+ $146,000 $61,000 Totals All entities $758,000 $317,000 Ice manufacturing 312113 < 20 $738,000 $308,000  20-99 $110,000 $46,000  100-499 $22,000 $9,000  500+ $104,000 $43,000 Totals All entities $974,000 $407,000 Ice rinks 713940 < 20 $448,000 $193,000  20-99 $79,000 $34,000  100-499 None None  500+ None None Totals All entities $527,000 $227,000 Elementary and secondary 6111 < 20 $155,000 $49,000 schools 20-99 $163,000 $52,000  100-499 $60,000 $19,000  500+ $16,000 $5,000 Totals All entities $393,000 $126,000 Junior colleges, colleges and 6112, 6113 < 20 $23,000 $7,000 universities 20-99 $11,000 $4,000  100-499 $16,000 $5,000  500+ $31,000 $10,000 Totals All entities $81,000 $26,000 
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Table A.4. Regulatory impact by sector and size category for Option 4 (10% and 10%) under Scenario 1 (Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Hospitals 611 < 20 $25,000 $8,000  20-99 $19,000 $6,000  100-499 $65,000 $21,000  500+ $176,000 $56,000 Totals All entities $285,000 $91,000 Other, not included above All entities $11,400,000 $3,640,000 Note: Totals may vary slightly due to rounding. 
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Table A.5. Regulatory impact by sector and size category for Option 5 (10% and 20%) under Scenario 1 Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Supermarkets and grocery 445110 < 20 $26,900,000 $7,400,000 stores 20-99 $7,600,000 $2,080,000  100-499 $4,050,000 $1,100,000  500+ $30,300,000 $8,210,000 Totals All entities $68,800,000 $18,800,000 Convenience stores 445120 < 20 $270,000 $86,000  20-99 $12,000 $4,000  100-499 $7,000 $2,000  500+ $34,000 $11,000 Totals All entities $322,000 $103,000 Gas station convenience 447110 < 20 $339,000 $108,000 stores 20-99 $85,000 $27,000  100-499 $102,000 $33,000  500+ $271,000 $87,000 Totals All entities $797,000 $255,000 Warehouse and club 45291 < 20 $217,000 $61,000 supercenters 20-99 $13,000 $4,000  100-499 $34,000 $9,000  500+ $2,450,000 $684,000 Totals All entities $2,710,000 $758,000 Refrigerated warehouse and 49312 < 20 $509,000 $142,000 storage 20-99 $247,000 $69,000  100-499 $116,000 $32,000  500+ $303,000 $85,000 Totals All entities $1,170,000 $328,000 
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Table A.5. Regulatory impact by sector and size category for Option 5 (10% and 20%) under Scenario 1 (Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Refrigerated warehouse farm 49313 < 20 $350,000 $98,000 products 20-99 $94,000 $26,000  100-499 $88,000 $25,000  500+ $120,000 $33,000 Totals All entities $653,000 $182,000 Office building managers 531312 < 20 $81,000 $26,000  20-99 $11,000 $4,000  100-499 $5,000 $2,000  500+ $14,000 $5,000 Totals All entities $112,000 $36,000 Lodging 72 < 20 $6,480,000 $2,070,000  20-99 $1,670,000 $536,000  100-499 $654,000 $209,000  500+ $1,830,000 $585,000 Totals All entities $10,600,000 $3,400,000 Chemical manufacturing 325 < 20 $12,400,000 $5,800,000  20-99 $4,520,000 $2,110,000  100-499 $2,720,000 $1,270,000  500+ $7,270,000 $3,400,000 Totals All entities $26,900,000 $12,600,000 Pharmaceutical 3254 < 20 $1,940,000 $906,000 manufacturing 20-99 $735,000 $343,000  100-499 $495,000 $231,000  500+ $1,060,000 $497,000 Totals All entities $4,230,000 $1,980,000 
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Table A.5. Regulatory impact by sector and size category for Option 5 (10% and 20%) under Scenario 1 (Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Petrochemical manufacturing 324110 < 20 $255,000 $119,000 

 20-99 $69,000 $32,000 

 100-499 $67,000 $31,000  500+ $440,000 $206,000 Totals All entities $830,000 $388,000 Bakeries 3118 < 20 $9,490,000 $4,440,000  20-99 $1,770,000 $828,000  100-499 $529,000 $247,000  500+ $735,000 $343,000 Totals All entities $12,500,000 $5,850,000 Food manufacturing other 311 < 20 $9,210,000 $4,300,000 than bakeries 20-99 $3,290,000 $1,540,000  100-499 $1,790,000 $837,000  500+ $3,750,000 $1,750,000 Totals All entities $18,000,000 $8,430,000 Breweries 31212 < 20 $695,000 $325,000  20-99 $233,000 $109,000  100-499 $57,000 $27,000  500+ $76,000 $36,000 Totals All entities $1,060,000 $496,000 Soft drink manufacturing 312111 < 20 $314,000 $147,000  20-99 $176,000 $82,000  100-499 $174,000 $81,000  500+ $647,000 $302,000 Totals All entities $1,310,000 $613,000 
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Table A.5. Regulatory impact by sector and size category for Option 5 (10% and 20%) under Scenario 1 (Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Bottled water manufacturing 312112 < 20 $431,000 $201,000  20-99 $90,000 $42,000  100-499 $26,000 $12,000  500+ $131,000 $61,000 Totals All entities $678,000 $317,000 Ice manufacturing 312113 < 20 $660,000 $308,000  20-99 $98,000 $46,000  100-499 $20,000 $9,000  500+ $93,000 $43,000 Totals All entities $871,000 $407,000 Ice rinks 713940 < 20 $394,000 $193,000  20-99 $70,000 $34,000  100-499 None None  500+ None None Totals All entities $464,000 $227,000 Elementary and secondary 6111 < 20 $155,000 $49,000 schools 20-99 $163,000 $52,000  100-499 $60,000 $19,000  500+ $16,000 $5,000 Totals All entities $393,000 $126,000 Junior colleges, colleges and 6112, 6113 < 20 $23,000 $7,000 universities 20-99 $11,000 $4,000  100-499 $16,000 $5,000  500+ $31,000 $10,000 Totals All entities $81,000 $26,000 
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Table A.5. Regulatory impact by sector and size category for Option 5 (10% and 20%) under Scenario 1 (Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Hospitals 611 < 20 $25,000 $8,000  20-99 $19,000 $6,000  100-499 $65,000 $21,000  500+ $176,000 $56,000 Totals All entities $285,000 $91,000 Other, not included above All entities $11,400,000 $3,640,000 Note: Totals may vary slightly due to rounding. 
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Table A.6. Regulatory impact by sector and size category for Option 6 (10% and 30%) under Scenario 1 Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Supermarkets and grocery 445110 < 20 $22,300,000 $7,400,000 stores 20-99 $6,260,000 $2,080,000  100-499 $3,320,000 $1,100,000  500+ $24,700,000 $8,210,000 Totals All entities $56,600,000 $18,800,000 Convenience stores 445120 < 20 $270,000 $86,000  20-99 $12,000 $4,000  100-499 $7,000 $2,000  500+ $34,000 $11,000 Totals All entities $322,000 $103,000 Gas station convenience 447110 < 20 $339,000 $108,000 stores 20-99 $85,000 $27,000  100-499 $102,000 $33,000  500+ $271,000 $87,000 Totals All entities $797,000 $255,000 Warehouse and club 45291 < 20 $183,000 $61,000 supercenters 20-99 $11,000 $4,000  100-499 $29,000 $9,000  500+ $2,070,000 $684,000 Totals All entities $2,300,000 $758,000 Refrigerated warehouse and 49312 < 20 $431,000 $142,000 storage 20-99 $209,000 $69,000  100-499 $98,000 $32,000  500+ $256,000 $85,000 Totals All entities $994,000 $328,000 
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Table A.6. Regulatory impact by sector and size category for Option 6 (10% and 30%) under Scenario 1 (Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Refrigerated warehouse farm 49313 < 20 $296,000 $98,000 products 20-99 $80,000 $26,000  100-499 $75,000 $25,000  500+ $101,000 $33,000 Totals All entities $552,000 $182,000 Office building managers 531312 < 20 $81,000 $26,000  20-99 $11,000 $4,000  100-499 $5,000 $2,000  500+ $14,000 $5,000 Totals All entities $112,000 $36,000 Lodging 72 < 20 $6,480,000 $2,070,000  20-99 $1,670,000 $536,000  100-499 $654,000 $209,000  500+ $1,830,000 $585,000 Totals All entities $10,600,000 $3,400,000 Chemical manufacturing 325 < 20 $11,300,000 $5,800,000  20-99 $4,120,000 $2,110,000  100-499 $2,480,000 $1,270,000  500+ $6,630,000 $3,400,000 Totals All entities $24,600,000 $12,600,000 Pharmaceutical 3254 < 20 $1,770,000 $906,000 manufacturing 20-99 $671,000 $343,000  100-499 $452,000 $231,000  500+ $971,000 $497,000 Totals All entities $3,860,000 $1,980,000 
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Table A.6. Regulatory impact by sector and size category for Option 6 (10% and 30%) under Scenario 1 (Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Petrochemical manufacturing 324110 < 20 $232,000 $119,000 

 20-99 $63,000 $32,000 

 100-499 $61,000 $31,000  500+ $402,000 $206,000 Totals All entities $758,000 $388,000 Bakeries 3118 < 20 $8,660,000 $4,440,000  20-99 $1,620,000 $828,000  100-499 $483,000 $247,000  500+ $671,000 $343,000 Totals All entities $11,400,000 $5,850,000 Food manufacturing other 311 < 20 $8,410,000 $4,300,000 than bakeries 20-99 $3,000,000 $1,540,000  100-499 $1,630,000 $837,000  500+ $3,420,000 $1,750,000 Totals All entities $16,500,000 $8,430,000 Breweries 31212 < 20 $634,000 $325,000  20-99 $213,000 $109,000  100-499 $52,000 $27,000  500+ $69,000 $36,000 Totals All entities $968,000 $496,000 Soft drink manufacturing 312111 < 20 $287,000 $147,000  20-99 $161,000 $82,000  100-499 $158,000 $81,000  500+ $591,000 $302,000 Totals All entities $1,200,000 $613,000 
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Table A.6. Regulatory impact by sector and size category for Option 6 (10% and 30%) under Scenario 1 (Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Bottled water manufacturing 312112 < 20 $393,000 $201,000  20-99 $83,000 $42,000  100-499 $24,000 $12,000  500+ $119,000 $61,000 Totals All entities $619,000 $317,000 Ice manufacturing 312113 < 20 $602,000 $308,000  20-99 $90,000 $46,000  100-499 $18,000 $9,000  500+ $85,000 $43,000 Totals All entities $795,000 $407,000 Ice rinks 713940 < 20 $355,000 $193,000  20-99 $63,000 $34,000  100-499 None None  500+ None None Totals All entities $417,000 $227,000 Elementary and secondary 6111 < 20 $155,000 $49,000 schools 20-99 $163,000 $52,000  100-499 $60,000 $19,000  500+ $16,000 $5,000 Totals All entities $393,000 $126,000 

6112, 6113 < 20 $23,000 $7,000 

 20-99 $11,000 $4,000 

Junior colleges, colleges and universities 

 100-499 $16,000 $5,000 

 500+ $31,000 $10,000 Totals All entities $81,000 $26,000 
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Table A.6. Regulatory impact by sector and size category for Option 6 (10% and 30%) under Scenario 1 (Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Hospitals 611 < 20 $25,000 $8,000  20-99 $19,000 $6,000  100-499 $65,000 $21,000  500+ $176,000 $56,000 Totals All entities $285,000 $91,000 Other, not included above All entities $11,400,000 $3,640,000 Note: Totals may vary slightly due to rounding. 
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Table A.7. Regulatory impact by sector and size category for Option 1 (5% and 10%) under Scenario 2 Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Supermarkets and grocery 445110 < 20 $19,500,000 $7,400,000 stores 20-99 $5,560,000 $2,080,000  100-499 $2,980,000 $1,100,000  500+ $22,400,000 $8,210,000 Totals All entities $50,400,000 $18,800,000 Convenience stores 445120 < 20 $167,000 $86,000  20-99 $7,000 $4,000  100-499 $4,000 $2,000  500+ $21,000 $11,000 Totals All entities $200,000 $103,000 Gas station convenience 447110 < 20 $210,000 $108,000 stores 20-99 $53,000 $27,000  100-499 $63,000 $33,000  500+ $168,000 $87,000 Totals All entities $494,000 $255,000 Warehouse and club 45291 < 20 $156,000 $61,000 supercenters 20-99 $10,000 $4,000  100-499 $24,000 $9,000  500+ $1,760,000 $684,000 Totals All entities $1,950,000 $758,000 Refrigerated warehouse and 49312 < 20 $365,000 $142,000 storage 20-99 $177,000 $69,000  100-499 $83,000 $32,000  500+ $217,000 $85,000 Totals All entities $843,000 $328,000 
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Table A.7. Regulatory impact by sector and size category for Option 1 (5% and 10%) under Scenario 2 (coSector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Refrigerated warehouse farm 49313 < 20 $251,000 $98,000 products 20-99 $68,000 $26,000  100-499 $63,000 $25,000  500+ $86,000 $33,000 Totals All entities $468,000 $182,000 Office building managers 531312 < 20 $50,000 $26,000  20-99 $7,000 $4,000  100-499 $3,000 $2,000  500+ $9,000 $5,000 Totals All entities $69,000 $36,000 Lodging 72 < 20 $4,020,000 $2,070,000  20-99 $1,040,000 $536,000  100-499 $405,000 $209,000  500+ $1,130,000 $585,000 Totals All entities $6,590,000 $3,400,000 Chemical manufacturing 325 < 20 $8,100,000 $5,800,000  20-99 $2,950,000 $2,110,000  100-499 $1,780,000 $1,270,000  500+ $4,740,000 $3,400,000 Totals All entities $17,600,000 $12,600,000 Pharmaceutical 3254 < 20 $1,260,000 $906,000 manufacturing 20-99 $479,000 $343,000  100-499 $323,000 $231,000  500+ $694,000 $497,000 Totals All entities $2,760,000 $1,980,000 
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Table A.7. Regulatory impact by sector and size category for Option 1 (5% and 10%) under Scenario 2 (coSector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Petrochemical manufacturing 324110 < 20 $166,000 $119,000 

 20-99 $45,000 $32,000 

 100-499 $43,000 $31,000  500+ $287,000 $206,000 Totals All entities $542,000 $388,000 Bakeries 3118 < 20 $6,190,000 $4,440,000  20-99 $1,160,000 $828,000  100-499 $345,000 $247,000  500+ $479,000 $343,000 Totals All entities $8,170,000 $5,850,000 

311 < 20 $6,010,000 $4,300,000 

 20-99 $2,140,000 $1,540,000 

Food manufacturing other than bakeries 

 100-499 $1,170,000 $837,000 

 500+ $2,440,000 $1,750,000 Totals All entities $11,800,000 $8,430,000 Breweries 31212 < 20 $453,000 $325,000 

 20-99 $152,000 $109,000  100-499 $37,000 $27,000  500+ $50,000 $36,000 Totals All entities $692,000 $496,000 Soft drink manufacturing 312111 < 20 $205,000 $147,000  20-99 $115,000 $82,000  100-499 $113,000 $81,000  500+ $422,000 $302,000 Totals All entities $855,000 $613,000 
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Table A.7. Regulatory impact by sector and size category for Option 1 (5% and 10%) under Scenario 2 (coSector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Bottled water manufacturing 312112 < 20 $281,000 $201,000  20-99 $59,000 $42,000  100-499 $17,000 $12,000  500+ $85,000 $61,000 Totals All entities $442,000 $317,000 Ice manufacturing 312113 < 20 $431,000 $308,000  20-99 $64,000 $46,000  100-499 $13,000 $9,000  500+ $61,000 $43,000 Totals All entities $568,000 $407,000 Ice rinks 713940 < 20 $259,000 $193,000  20-99 $46,000 $34,000  100-499 None None  500+ None None Totals All entities $305,000 $227,000 Elementary and secondary 6111 < 20 $96,000 $49,000 schools 20-99 $101,000 $52,000  100-499 $37,000 $19,000  500+ $10,000 $5,000 Totals All entities $244,000 $126,000 

6112, 6113 < 20 $14,000 $7,000 

 20-99 $7,000 $4,000 

Junior colleges, colleges and universities 

 100-499 $10,000 $5,000 

 500+ $19,000 $10,000 Totals All entities $50,000 $26,000 
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Table A.7. Regulatory impact by sector and size category for Option 1 (5% and 10%) under Scenario 2 (coSector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Hospitals 611 < 20 $15,000 $8,000  20-99 $12,000 $6,000  100-499 $40,000 $21,000  500+ $109,000 $56,000 Totals All entities $177,000 $91,000 Other, not included above All entities $7,060,000 $3,640,000 Note: Totals may vary slightly due to rounding. 
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Table A.8. Regulatory impact by sector and size category for Option 2 (5% and 20%) under Scenario 2 Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Supermarkets and grocery 445110 < 20 $16,400,000 $7,400,000 stores 20-99 $4,630,000 $2,080,000  100-499 $2,470,000 $1,100,000  500+ $18,500,000 $8,210,000 Totals All entities $41,900,000 $18,800,000 Convenience stores 445120 < 20 $167,000 $86,000  20-99 $7,000 $4,000  100-499 $4,000 $2,000  500+ $21,000 $11,000 Totals All entities $200,000 $103,000 Gas station convenience 447110 < 20 $210,000 $108,000 stores 20-99 $53,000 $27,000  100-499 $63,000 $33,000  500+ $168,000 $87,000 Totals All entities $494,000 $255,000 Warehouse and club 45291 < 20 $132,000 $61,000 supercenters 20-99 $8,000 $4,000  100-499 $21,000 $9,000  500+ $1,500,000 $684,000 Totals All entities $1,660,000 $758,000 Refrigerated warehouse and 49312 < 20 $311,000 $142,000 storage 20-99 $151,000 $69,000  100-499 $71,000 $32,000  500+ $185,000 $85,000 Totals All entities $717,000 $328,000 
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Table A.8. Regulatory impact by sector and size category for Option 2 (5% and 20%) under Scenario 2 (coSector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Refrigerated warehouse farm 49313 < 20 $214,000 $98,000 products 20-99 $58,000 $26,000  100-499 $54,000 $25,000  500+ $73,000 $33,000 Totals All entities $398,000 $182,000 Office building managers 531312 < 20 $50,000 $26,000  20-99 $7,000 $4,000  100-499 $3,000 $2,000  500+ $9,000 $5,000 Totals All entities $69,000 $36,000 Lodging 72 < 20 $4,020,000 $2,070,000  20-99 $1,040,000 $536,000  100-499 $405,000 $209,000  500+ $1,130,000 $585,000 Totals All entities $6,590,000 $3,400,000 Chemical manufacturing 325 < 20 $7,490,000 $5,800,000  20-99 $2,720,000 $2,110,000  100-499 $1,640,000 $1,270,000  500+ $4,380,000 $3,400,000 Totals All entities $16,200,000 $12,600,000 Pharmaceutical 3254 < 20 $1,170,000 $906,000 manufacturing 20-99 $443,000 $343,000  100-499 $298,000 $231,000  500+ $641,000 $497,000 Totals All entities $2,550,000 $1,980,000 
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Table A.8. Regulatory impact by sector and size category for Option 2 (5% and 20%) under Scenario 2 (coSector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Petrochemical manufacturing 324110 < 20 $153,000 $119,000 

 20-99 $42,000 $32,000 

 100-499 $40,000 $31,000  500+ $265,000 $206,000 Totals All entities $501,000 $388,000 Bakeries 3118 < 20 $5,720,000 $4,440,000  20-99 $1,070,000 $828,000  100-499 $319,000 $247,000  500+ $443,000 $343,000 Totals All entities $7,550,000 $5,850,000 

311 < 20 $5,550,000 $4,300,000 

 20-99 $1,980,000 $1,540,000 

Food manufacturing other than bakeries 

 100-499 $1,080,000 $837,000 

 500+ $2,260,000 $1,750,000 Totals All entities $10,900,000 $8,430,000 Breweries 31212 < 20 $419,000 $325,000 

 20-99 $141,000 $109,000  100-499 $34,000 $27,000  500+ $46,000 $36,000 Totals All entities $640,000 $496,000 Soft drink manufacturing 312111 < 20 $189,000 $147,000  20-99 $106,000 $82,000  100-499 $105,000 $81,000  500+ $390,000 $302,000 Totals All entities $790,000 $613,000 
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Table A.8. Regulatory impact by sector and size category for Option 2 (5% and 20%) under Scenario 2 (coSector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Bottled water manufacturing 312112 < 20 $260,000 $201,000  20-99 $55,000 $42,000  100-499 $16,000 $12,000  500+ $79,000 $61,000 Totals All entities $409,000 $317,000 Ice manufacturing 312113 < 20 $398,000 $308,000  20-99 $59,000 $46,000  100-499 $12,000 $9,000  500+ $56,000 $43,000 Totals All entities $525,000 $407,000 Ice rinks 713940 < 20 $237,000 $193,000  20-99 $42,000 $34,000  100-499 None None  500+ None None Totals All entities $279,000 $227,000 Elementary and secondary 6111 < 20 $96,000 $49,000 schools 20-99 $101,000 $52,000  100-499 $37,000 $19,000  500+ $10,000 $5,000 Totals All entities $244,000 $126,000 

6112, 6113 < 20 $14,000 $7,000 

 20-99 $7,000 $4,000 

Junior colleges, colleges and universities 

 100-499 $10,000 $5,000 

 500+ $19,000 $10,000 Totals All entities $50,000 $26,000 
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Table A.8. Regulatory impact by sector and size category for Option 2 (5% and 20%) under Scenario 2 (coSector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Hospitals 611 < 20 $15,000 $8,000  20-99 $12,000 $6,000  100-499 $40,000 $21,000  500+ $109,000 $56,000 Totals All entities $177,000 $91,000 Other, not included above All entities $7,060,000 $3,640,000 Note: Totals may vary slightly due to rounding. 
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Table A.9. Regulatory impact by sector and size category for Option 3 (5% and 30%) under Scenario 2 Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Supermarkets and grocery 445110 < 20 $13,900,000 $7,400,000 stores 20-99 $3,890,000 $2,080,000  100-499 $2,060,000 $1,100,000  500+ $15,300,000 $8,210,000 Totals All entities $35,200,000 $18,800,000 Convenience stores 445120 < 20 $167,000 $86,000  20-99 $7,000 $4,000  100-499 $4,000 $2,000  500+ $21,000 $11,000 Totals All entities $200,000 $103,000 Gas station convenience 447110 < 20 $210,000 $108,000 stores 20-99 $53,000 $27,000  100-499 $63,000 $33,000  500+ $168,000 $87,000 Totals All entities $494,000 $255,000 Warehouse and club 45291 < 20 $114,000 $61,000 supercenters 20-99 $7,000 $4,000  100-499 $18,000 $9,000  500+ $1,290,000 $684,000 Totals All entities $1,430,000 $758,000 Refrigerated warehouse and 49312 < 20 $267,000 $142,000 storage 20-99 $130,000 $69,000  100-499 $61,000 $32,000  500+ $159,000 $85,000 Totals All entities $617,000 $328,000 
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Table A.9. Regulatory impact by sector and size category for Option 3 (5% and 30%) under Scenario 2 (coSector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Refrigerated warehouse farm 49313 < 20 $184,000 $98,000 products 20-99 $50,000 $26,000  100-499 $46,000 $25,000  500+ $63,000 $33,000 Totals All entities $343,000 $182,000 Office building managers 531312 < 20 $50,000 $26,000  20-99 $7,000 $4,000  100-499 $3,000 $2,000  500+ $9,000 $5,000 Totals All entities $69,000 $36,000 Lodging 72 < 20 $4,020,000 $2,070,000  20-99 $1,040,000 $536,000  100-499 $405,000 $209,000  500+ $1,130,000 $585,000 Totals All entities $6,590,000 $3,400,000 Chemical manufacturing 325 < 20 $7,000,000 $5,800,000  20-99 $2,550,000 $2,110,000  100-499 $1,530,000 $1,270,000  500+ $4,100,000 $3,400,000 Totals All entities $15,200,000 $12,600,000 Pharmaceutical 3254 < 20 $1,090,000 $906,000 manufacturing 20-99 $414,000 $343,000  100-499 $279,000 $231,000  500+ $600,000 $497,000 Totals All entities $2,390,000 $1,980,000 
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Table A.9. Regulatory impact by sector and size category for Option 3 (5% and 30%) under Scenario 2 (coSector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Petrochemical manufacturing 324110 < 20 $144,000 $119,000 

 20-99 $39,000 $32,000 

 100-499 $38,000 $31,000  500+ $248,000 $206,000 Totals All entities $468,000 $388,000 Bakeries 3118 < 20 $5,350,000 $4,440,000  20-99 $999,000 $828,000  100-499 $298,000 $247,000  500+ $414,000 $343,000 Totals All entities $7,060,000 $5,850,000 

311 < 20 $5,190,000 $4,300,000 

 20-99 $1,850,000 $1,540,000 

Food manufacturing other than bakeries 

 100-499 $1,010,000 $837,000 

 500+ $2,110,000 $1,750,000 Totals All entities $10,200,000 $8,430,000 Breweries 31212 < 20 $392,000 $325,000 

 20-99 $131,000 $109,000  100-499 $32,000 $27,000  500+ $43,000 $36,000 Totals All entities $598,000 $496,000 Soft drink manufacturing 312111 < 20 $177,000 $147,000  20-99 $99,000 $82,000  100-499 $98,000 $81,000  500+ $365,000 $302,000 Totals All entities $739,000 $613,000 
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Table A.9. Regulatory impact by sector and size category for Option 3 (5% and 30%) under Scenario 2 (coSector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Bottled water manufacturing 312112 < 20 $243,000 $201,000  20-99 $51,000 $42,000  100-499 $15,000 $12,000  500+ $74,000 $61,000 Totals All entities $382,000 $317,000 Ice manufacturing 312113 < 20 $372,000 $308,000  20-99 $55,000 $46,000  100-499 $11,000 $9,000  500+ $52,000 $43,000 Totals All entities $491,000 $407,000 Ice rinks 713940 < 20 $219,000 $193,000  20-99 $39,000 $34,000  100-499 None None  500+ None None Totals All entities $258,000 $227,000 Elementary and secondary 6111 < 20 $96,000 $49,000 schools 20-99 $101,000 $52,000  100-499 $37,000 $19,000  500+ $10,000 $5,000 Totals All entities $244,000 $126,000 

6112, 6113 < 20 $14,000 $7,000 

 20-99 $7,000 $4,000 

Junior colleges, colleges and universities 

 100-499 $10,000 $5,000 

 500+ $19,000 $10,000 Totals All entities $50,000 $26,000 
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Table A.9. Regulatory impact by sector and size category for Option 3 (5% and 30%) under Scenario 2 (coSector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Hospitals 611 < 20 $15,000 $8,000  20-99 $12,000 $6,000  100-499 $40,000 $21,000  500+ $109,000 $56,000 Totals All entities $177,000 $91,000 Other, not included above All entities $7,060,000 $3,640,000 Note: Totals may vary slightly due to rounding. 
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Table A.10. Regulatory impact by sector and size category for Option 4 (10% and 10%) under Scenario 2 Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Supermarkets and grocery 445110 < 20 $32,700,000 $7,400,000 stores 20-99 $9,330,000 $2,080,000  100-499 $5,010,000 $1,100,000  500+ $37,600,000 $8,210,000 Totals All entities $84,600,000 $18,800,000 Convenience stores 445120 < 20 $270,000 $86,000  20-99 $12,000 $4,000  100-499 $7,000 $2,000  500+ $34,000 $11,000 Totals All entities $322,000 $103,000 Gas station convenience 447110 < 20 $339,000 $108,000 stores 20-99 $85,000 $27,000  100-499 $102,000 $33,000  500+ $271,000 $87,000 Totals All entities $797,000 $255,000 

45291 < 20 $260,000 $61,000 

 20-99 $16,000 $4,000 

Warehouse and club supercenters 

 100-499 $41,000 $9,000 

 500+ $2,940,000 $684,000 Totals All entities $3,250,000 $758,000 

49312 < 20 $609,000 $142,000 

 20-99 $296,000 $69,000 

Refrigerated warehouse and storage 

 100-499 $139,000 $32,000 

 500+ $363,000 $85,000 Totals All entities $1,410,000 $328,000 
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Table A.10. Regulatory impact by sector and size category for Option 4 (10% and 10%) under Scenario 2 Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Refrigerated warehouse farm 49313 < 20 $419,000 $98,000 products 20-99 $113,000 $26,000  100-499 $106,000 $25,000  500+ $144,000 $33,000 Totals All entities $782,000 $182,000 Office building managers 531312 < 20 $81,000 $26,000  20-99 $11,000 $4,000  100-499 $5,000 $2,000  500+ $14,000 $5,000 Totals All entities $112,000 $36,000 Lodging 72 < 20 $6,480,000 $2,070,000  20-99 $1,670,000 $536,000  100-499 $654,000 $209,000  500+ $1,830,000 $585,000 Totals All entities $10,600,000 $3,400,000 Chemical manufacturing 325 < 20 $13,900,000 $5,800,000  20-99 $5,050,000 $2,110,000  100-499 $3,040,000 $1,270,000  500+ $8,130,000 $3,400,000 Totals All entities $30,100,000 $12,600,000 

3254 < 20 $2,170,000 $906,000 

 20-99 $822,000 $343,000 

Pharmaceutical manufacturing 

 100-499 $553,000 $231,000 

 500+ $1,190,000 $497,000 Totals All entities $4,730,000 $1,980,000 
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Table A.10. Regulatory impact by sector and size category for Option 4 (10% and 10%) under Scenario 2 Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Petrochemical manufacturing 324110 < 20 $285,000 $119,000 

 20-99 $77,000 $32,000 

 100-499 $74,000 $31,000  500+ $492,000 $206,000 Totals All entities $928,000 $388,000 Bakeries 3118 < 20 $10,600,000 $4,440,000  20-99 $1,980,000 $828,000  100-499 $592,000 $247,000  500+ $822,000 $343,000 Totals All entities $14,000,000 $5,850,000 

311 < 20 $10,300,000 $4,300,000 

 20-99 $3,680,000 $1,540,000 

Food manufacturing other than bakeries 

 100-499 $2,000,000 $837,000 

 500+ $4,190,000 $1,750,000 Totals All entities $20,200,000 $8,430,000 Breweries 31212 < 20 $777,000 $325,000 

 20-99 $261,000 $109,000  100-499 $64,000 $27,000  500+ $85,000 $36,000 Totals All entities $1,190,000 $496,000 Soft drink manufacturing 312111 < 20 $351,000 $147,000  20-99 $197,000 $82,000  100-499 $194,000 $81,000  500+ $724,000 $302,000 Totals All entities $1,470,000 $613,000 
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Table A.10. Regulatory impact by sector and size category for Option 4 (10% and 10%) under Scenario 2 Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Bottled water manufacturing 312112 < 20 $481,000 $201,000  20-99 $101,000 $42,000  100-499 $29,000 $12,000  500+ $146,000 $61,000 Totals All entities $758,000 $317,000 Ice manufacturing 312113 < 20 $738,000 $308,000  20-99 $110,000 $46,000  100-499 $22,000 $9,000  500+ $104,000 $43,000 Totals All entities $974,000 $407,000 Ice rinks 713940 < 20 $448,000 $193,000  20-99 $79,000 $34,000  100-499 None None  500+ None None Totals All entities $527,000 $227,000 Elementary and secondary 6111 < 20 $155,000 $49,000 schools 20-99 $163,000 $52,000  100-499 $60,000 $19,000  500+ $16,000 $5,000 Totals All entities $393,000 $126,000 

6112, 6113 < 20 $23,000 $7,000 

 20-99 $11,000 $4,000 

Junior colleges, colleges and universities 

 100-499 $16,000 $5,000 

 500+ $31,000 $10,000 Totals All entities $81,000 $26,000 
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Table A.10. Regulatory impact by sector and size category for Option 4 (10% and 10%) under Scenario 2 Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Hospitals 611 < 20 $25,000 $8,000  20-99 $19,000 $6,000  100-499 $65,000 $21,000  500+ $176,000 $56,000 Totals All entities $285,000 $91,000 Other, not included above All entities $11,400,000 $3,640,000 Note: Totals may vary slightly due to rounding. 
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Table A.11. Regulatory impact by sector and size category for Option 5 (10% and 20%) under Scenario 2 Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Supermarkets and grocery 445110 < 20 $16,100,000 $7,400,000 stores 20-99 $4,570,000 $2,080,000  100-499 $2,440,000 $1,100,000  500+ $18,300,000 $8,210,000 Totals All entities $41,400,000 $18,800,000 Convenience stores 445120 < 20 $153,000 $86,000  20-99 $7,000 $4,000  100-499 $4,000 $2,000  500+ $19,000 $11,000 Totals All entities $183,000 $103,000 Gas station convenience 447110 < 20 $193,000 $108,000 stores 20-99 $48,000 $27,000  100-499 $58,000 $33,000  500+ $154,000 $87,000 Totals All entities $453,000 $255,000 Warehouse and club 45291 < 20 $129,000 $61,000 supercenters 20-99 $8,000 $4,000  100-499 $20,000 $9,000  500+ $1,460,000 $684,000 Totals All entities $1,620,000 $758,000 Refrigerated warehouse and 49312 < 20 $304,000 $142,000 storage 20-99 $148,000 $69,000  100-499 $69,000 $32,000  500+ $181,000 $85,000 Totals All entities $702,000 $328,000 
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Table A.11. Regulatory impact by sector and size category for Option 5 (10% and 20%) under Scenario 2 Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Refrigerated warehouse farm 49313 < 20 $209,000 $98,000 products 20-99 $56,000 $26,000  100-499 $53,000 $25,000  500+ $72,000 $33,000 Totals All entities $390,000 $182,000 Office building managers 531312 < 20 $46,000 $26,000  20-99 $6,000 $4,000  100-499 $3,000 $2,000  500+ $8,000 $5,000 Totals All entities $64,000 $36,000 Lodging 72 < 20 $3,690,000 $2,070,000  20-99 $952,000 $536,000  100-499 $372,000 $209,000  500+ $1,040,000 $585,000 Totals All entities $6,050,000 $3,400,000 Chemical manufacturing 325 < 20 $7,320,000 $5,800,000  20-99 $2,660,000 $2,110,000  100-499 $1,600,000 $1,270,000  500+ $4,280,000 $3,400,000 Totals All entities $15,900,000 $12,600,000 Pharmaceutical 3254 < 20 $1,140,000 $906,000 manufacturing 20-99 $433,000 $343,000  100-499 $292,000 $231,000  500+ $627,000 $497,000 Totals All entities $2,490,000 $1,980,000 
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Table A.11. Regulatory impact by sector and size category for Option 5 (10% and 20%) under Scenario 2 Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Petrochemical manufacturing 324110 < 20 $150,000 $119,000 

 20-99 $41,000 $32,000 

 100-499 $39,000 $31,000  500+ $259,000 $206,000 Totals All entities $489,000 $388,000 Bakeries 3118 < 20 $5,600,000 $4,440,000  20-99 $1,040,000 $828,000  100-499 $312,000 $247,000  500+ $433,000 $343,000 Totals All entities $7,390,000 $5,850,000 Food manufacturing other 311 < 20 $5,430,000 $4,300,000 than bakeries 20-99 $1,940,000 $1,540,000  100-499 $1,060,000 $837,000  500+ $2,210,000 $1,750,000 Totals All entities $10,600,000 $8,430,000 Breweries 31212 < 20 $409,000 $325,000  20-99 $137,000 $109,000  100-499 $34,000 $27,000  500+ $45,000 $36,000 Totals All entities $625,000 $496,000 Soft drink manufacturing 312111 < 20 $185,000 $147,000  20-99 $104,000 $82,000  100-499 $102,000 $81,000  500+ $381,000 $302,000 Totals All entities $773,000 $613,000 
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Table A.11. Regulatory impact by sector and size category for Option 5 (10% and 20%) under Scenario 2 Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Bottled water manufacturing 312112 < 20 $254,000 $201,000  20-99 $53,000 $42,000  100-499 $15,000 $12,000  500+ $77,000 $61,000 Totals All entities $400,000 $317,000 Ice manufacturing 312113 < 20 $389,000 $308,000  20-99 $58,000 $46,000  100-499 $12,000 $9,000  500+ $55,000 $43,000 Totals All entities $513,000 $407,000 Ice rinks 713940 < 20 $234,000 $193,000  20-99 $41,000 $34,000  100-499 None None  500+ None None Totals All entities $275,000 $227,000 Elementary and secondary 6111 < 20 $88,000 $49,000 schools 20-99 $92,000 $52,000  100-499 $34,000 $19,000  500+ $9,000 $5,000 Totals All entities $224,000 $126,000 

6112, 6113 < 20 $13,000 $7,000 

 20-99 $6,000 $4,000 

Junior colleges, colleges and universities 

 100-499 $9,000 $5,000 

 500+ $18,000 $10,000 Totals All entities $46,000 $26,000 
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Table A.11. Regulatory impact by sector and size category for Option 5 (10% and 20%) under Scenario 2 Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Hospitals 611 < 20 $14,000 $8,000  20-99 $11,000 $6,000  100-499 $37,000 $21,000  500+ $100,000 $56,000 Totals All entities $162,000 $91,000 Other, not included above All entities $6,480,000 $3,640,000 Note: Totals may vary slightly due to rounding. 
Stratus Consulting Attachm

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Table A.12. Regulatory impact by sector and size category for Option 6 (10% and 30%) under Scenario 2 Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Supermarkets and grocery 445110 < 20 $13,600,000 $7,400,000 stores 20-99 $3,830,000 $2,080,000  100-499 $2,030,000 $1,100,000  500+ $15,200,000 $8,210,000 Totals All entities $34,700,000 $18,800,000 Convenience stores 445120 < 20 $153,000 $86,000  20-99 $7,000 $4,000  100-499 $4,000 $2,000  500+ $19,000 $11,000 Totals All entities $183,000 $103,000 Gas station convenience 447110 < 20 $193,000 $108,000 stores 20-99 $48,000 $27,000  100-499 $58,000 $33,000  500+ $154,000 $87,000 Totals All entities $453,000 $255,000 Warehouse and club 45291 < 20 $111,000 $61,000 supercenters 20-99 $7,000 $4,000  100-499 $17,000 $9,000  500+ $1,250,000 $684,000 Totals All entities $1,390,000 $758,000 Refrigerated warehouse and 49312 < 20 $261,000 $142,000 storage 20-99 $127,000 $69,000  100-499 $60,000 $32,000  500+ $155,000 $85,000 Totals All entities $602,000 $328,000 
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Table A.12. Regulatory impact by sector and size category for Option 6 (10% and 30%) under Scenario 2 Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Refrigerated warehouse farm 49313 < 20 $179,000 $98,000 products 20-99 $48,000 $26,000  100-499 $45,000 $25,000  500+ $61,000 $33,000 Totals All entities $334,000 $182,000 Office building managers 531312 < 20 $46,000 $26,000  20-99 $6,000 $4,000  100-499 $3,000 $2,000  500+ $8,000 $5,000 Totals All entities $64,000 $36,000 Lodging 72 < 20 $3,690,000 $2,070,000  20-99 $952,000 $536,000  100-499 $372,000 $209,000  500+ $1,040,000 $585,000 Totals All entities $6,050,000 $3,400,000 Chemical manufacturing 325 < 20 $6,830,000 $5,800,000  20-99 $2,490,000 $2,110,000  100-499 $1,500,000 $1,270,000  500+ $4,000,000 $3,400,000 Totals All entities $14,800,000 $12,600,000 Pharmaceutical 3254 < 20 $1,070,000 $906,000 manufacturing 20-99 $405,000 $343,000  100-499 $272,000 $231,000  500+ $585,000 $497,000 Totals All entities $2,330,000 $1,980,000 
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Table A.12. Regulatory impact by sector and size category for Option 6 (10% and 30%) under Scenario 2 Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Petrochemical manufacturing 324110 < 20 $140,000 $119,000 

 20-99 $38,000 $32,000 

 100-499 $37,000 $31,000  500+ $242,000 $206,000 Totals All entities $457,000 $388,000 Bakeries 3118 < 20 $5,220,000 $4,440,000  20-99 $975,000 $828,000  100-499 $291,000 $247,000  500+ $405,000 $343,000 Totals All entities $6,900,000 $5,850,000 

311 < 20 $5,070,000 $4,300,000 

 20-99 $1,810,000 $1,540,000 

Food manufacturing other than bakeries 

 100-499 $986,000 $837,000 

 500+ $2,060,000 $1,750,000 Totals All entities $9,930,000 $8,430,000 Breweries 31212 < 20 $382,000 $325,000 

 20-99 $128,000 $109,000  100-499 $31,000 $27,000  500+ $42,000 $36,000 Totals All entities $584,000 $496,000 Soft drink manufacturing 312111 < 20 $173,000 $147,000  20-99 $97,000 $82,000  100-499 $96,000 $81,000  500+ $356,000 $302,000 Totals All entities $721,000 $613,000 
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Table A.12. Regulatory impact by sector and size category for Option 6 (10% and 30%) under Scenario 2 Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Bottled water manufacturing 312112 < 20 $237,000 $201,000  20-99 $50,000 $42,000  100-499 $14,000 $12,000  500+ $72,000 $61,000 Totals All entities $373,000 $317,000 Ice manufacturing 312113 < 20 $363,000 $308,000  20-99 $54,000 $46,000  100-499 $11,000 $9,000  500+ $51,000 $43,000 Totals All entities $479,000 $407,000 Ice rinks 713940 < 20 $216,000 $193,000  20-99 $38,000 $34,000  100-499 None None  500+ None None Totals All entities $254,000 $227,000 Elementary and secondary 6111 < 20 $88,000 $49,000 schools 20-99 $92,000 $52,000  100-499 $34,000 $19,000  500+ $9,000 $5,000 Totals All entities $224,000 $126,000 

6112, 6113 < 20 $13,000 $7,000 

 20-99 $6,000 $4,000 

Junior colleges, colleges and universities 

 100-499 $9,000 $5,000 

 500+ $18,000 $10,000 Totals All entities $46,000 $26,000 
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Table A.12. Regulatory impact by sector and size category for Option 6 (10% and 30%) under Scenario 2 Sector NAICS code Number of employees

Proposed expected 

cost of compliance 

per size category 

Baseline expected 

cost of compliance 

per size category 

Hospitals 611 < 20 $14,000 $8,000  20-99 $11,000 $6,000  100-499 $37,000 $21,000  500+ $100,000 $56,000 Totals All entities $162,000 $91,000 Other, not included above All entities $6,480,000 $3,640,000 Note: Totals may vary slightly due to rounding. 
 

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Table A.13. Cost effectiveness of options for proposed regulation 

under Scenario 1 ($/GWP-weighted tonne) 

Equipment 

Allowable 

annual 

leak rate 

Cost 

(million dollars)

Benefit 

(MMTCE) 

Cost 

effectiveness 

($/MTCE) 

CC 10% $35.8 0.5 $68 

 5% $41.5 0.6 $73 

CR 30% $32.9 0.8 $40 

 20% $45.8 1.2 $39 

 10% $62.5 1.5 $43 

IPR 30% $17.8 0.1 $161 

 20% $23.7 0.3 $78 

 10% $31.6 0.5 $68 

Table A.14. Cost effectiveness of options for proposed regulation 

under Scenario 2 ($/GWP-weighted tonne) 

Equipment 

Allowable 

annual 

leak rate 

Cost 

(million dollars)

Benefit 

(MMTCE) 

Cost 

effectiveness 

($/MTCE) 

CC 10% $13.1 0.5 $28 

 5% $15.8 0.5 $31 

CR 30% $14.2 0.8 $19 

 20% $21.3 1.1 $19 

 10% $30.3 1.4 $22 

IPR 30% $1.2 0.0 $73 

 20% $3.8 0.2 $18 

 10% $7.1 0.4 $20 
 

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Table A.15. Incremental cost effectiveness of options for proposed 

regulation under Scenario 1 

Equipment 

Allowable 

annual leak 

rate 

Incremental 

cost (million 

dollars) 

Benefit 

(MMTCE) 

Incremental cost 

effectiveness 

($/MTCE) 

CC 10% $41.5 0.5 $79 

 5% $5.7 0.0 $138 

CR 30% $32.9 0.8 $40 

 20% $12.9 0.4 $37 

 10% $16.7 0.3 $59 

IPR 30% $17.8 0.1 $161 

 20% $5.9 0.2 $30 

 10% $7.9 0.2 $49 

Table A.16. Incremental cost effectiveness of options for proposed 

regulation under Scenario 2 

Equipment 

Allowable 

annual leak 

rate 

Incremental 

cost (million 

dollars) 

Benefit 

(MMTCE) 

Incremental cost 

effectiveness 

($/MTCE) 

CC 10% $15.8 0.5 $33 

 5% $2.7 0.0 $66 

CR 30% $14.2 0.8 $19 

 20% $7.2 0.3 $21 

 10% $9.0 0.3 $33 

IPR 30% $1.2 0.0 $73 

 20% $2.6 0.2 $14 

 10% $3.3 0.2 $21 
 

Stratus Consulting Attachment (Draft, 10/23/2009) 

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Table A.17. Cost effectiveness of options for proposed 

regulation under Scenario 1 

Option 

Cost 

(million 

dollars) 

Benefit 

(MMTCE) 

Cost 

effectiveness 

($/MTCE) 

1 (5% and 10%) $135.6 2.5 $54 

2 (5% and 20%) $111.0 2.1 $54 

3 (5% and 30%) $92.2 1.5 $61 

4 (10% and 10%) $129.9 2.5 $53 

5 (10% and 20%) $105.3 2.0 $52 

6 (10% and 30%) $86.5 1.5 $59 

Table A.18. Cost effectiveness of options for proposed 

regulation under Scenario 2 

Option 

Cost (million 

dollars) 

Benefit 

(MMTCE) 

Cost 

effectiveness 

($/MTCE) 

1 (5% and 10%) $53.2 2.3 $24 

2 (5% and 20%) $40.9 1.8 $22 

3 (5% and 30%) $31.1 1.3 $24 

4 (10% and 10%) $50.5 2.2 $23 

5 (10% and 20%) $38.2 1.8 $21 

6 (10% and 30%) $28.5 1.2 $23 
STRATUS CONSULTING

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