TOTAL LABOR BURDEN AND COST FOR REPORTING OF U.S. PARENT 

COMPANY AND NAICS CODE: AN AMENDMENT TO THE MANDATORY GHG 

REPORTING RULE 

March 9, 2010
1 

Table of Contents

1. Introduction ...........................................................................................................2

2. Definitions and Instructions for Proposed Data Elements .....................................3

2.1. U.S. Parent Company Name, Physical Address, and Ownership Status .........3

2.1.1. Definition of U.S. Parent Company...........................................................3

2.1.2. Proposed Instruction to Reporters............................................................4

2.2. Primary and Other Applicable North American Industrial Classification 

System (NAICS) codes and Cogeneration ........................................................5

2.2.1. Definition of Primary NAICS Code............................................................5

2.2.2. Proposed Instruction to Reporters on NAICS Code(s) .............................5

2.2.3. Definition of Cogeneration........................................................................6

2.2.4. Proposed Instructions for Reporting Cogeneration...................................6

3. Methodology .........................................................................................................6

3.1. Estimation of Reporting Labor Burden ..............................................................6

3.1.1. Option 1: U.S. Parent Company Name, Address, and Ownership 

Status.........................................................................................................7

3.1.2. Option 2: All U.S. Parent Company Names, Addresses, and 

Percentage of Ownership...........................................................................7

3.1.3. North American Industry Classification System (NAICS) Code(s)..............8

3.1.4. Cogeneration..............................................................................................9

3.2. Estimation of Labor Costs .................................................................................9

3.3. Estimation of the Sector and Facility Universe ................................................10

3.4. Calculation of Total Labor Burden and Total Cost...........................................12

3.4.1 Step 1: Calculate Total Industry Sector Labor Burden, by Labor 

Category...................................................................................................12

3.4.1.1 Option 1: Reporting U.S. Parent Company Information ......................12

3.4.1.2 Option 2: Reporting U.S. Parent Company Information for All 

Ownership Interest..............................................................................12

3.4.1.3 Options 1 and 2: Reporting NAICS code(s) and facility cogeneration.13

3.4.2 Step 2: Calculate Total Industry Sector Cost, by Reporting Year.............14

3.4.3 Step 3: Calculate Total Labor Burden and Total Cost for Sector and 

U.S. ..........................................................................................................15

3.4.4 Step 4: Calculate Total Labor Burden and Total Cost for All Data 

Elements ..................................................................................................15

4. Results................................................................................................................15

 
2 

1. Introduction 

EPA’s Office of Atmospheric Programs has issued a final rule requiring facilities in all sectors of 

the economy to report all greenhouse gas emissions. This rule is applicable only to sources that 

are direct greenhouse gas emitters or fossil fuel suppliers and that emit above defined threshold 

levels to monitor and report emissions.1

This rule, however, does not require facilities to report their sector identification or U.S. parent 

company. As a result, EPA is now proposing a rule requiring that facilities and suppliers to 

report the following additional data fields: the name, physical address, and type of ownership of 

their U.S. parent company, primary and all other applicable NAICS codes, and indication of 

whether or not reported emissions include those from cogeneration. If the reporting entity has 

more than one owner, EPA is also proposing an option whereby facilities and suppliers would 

report the names and addresses of the all their U.S. parent companies as well as provide the 

percent of ownership interest. Through data collected under this proposed rule amendment, EPA 

would gain a better understanding of the aggregate GHG emissions of corporations and specific 

industry sectors. 

The purpose of collecting the name and physical address of the U.S. parent company(s) on the 

annual reporting form for the Mandatory GHG Reporting Rule is to assist in aggregating facilitybased GHG emissions data to the corporate level. This additional data element would allow EPA 

to collect more comprehensive information on corporate GHG emissions and conduct a variety 

of analyses. In addition to collecting information on reporters’ U.S. parent company(s), this 

proposed rule amendment would require facilities and suppliers reporting under the Mandatory 

GHG Reporting Rule to report their primary NAICS code and any other NAICS codes applicable 

to their facility. This information is useful, because it would provide an additional data element 

that can assist EPA to further aggregate and analyze the data collected under the Mandatory 

GHG Reporting Rule at the sector level. EPA is also proposing to require that reporters to 

indicate (by checking yes or no) whether some or all of the GHG emissions they report are from 

a cogeneration unit located at the facility. Information on the types and characteristics of 

facilities that employ cogeneration technologies and the performance of cogeneration units could 

be important to future development of greenhouse gas mitigation strategies. 

To develop these estimates, EPA reviewed reporting estimates for similar data elements on the 

Toxic Release Inventory’s (TRI) reporting forms and then applied their best professional 

judgment. 

 

1 U.S. EPA. “Mandatory Reporting of Greenhouse Gases.” Federal Register, Proposed Rule. April 10, 2009. 74 

(68): 16448 
3 

2. Definitions and Instructions for Proposed Data Elements 

EPA is proposing two options for collecting U.S. parent company information. Under option 1, 

reporters would be required to provide the name and physical address of their highest-level U.S. 

parent company with the largest ownership interest in the reporting entity as of December 31 of 

the reporting year, while under Option 2 reporters would be required to list the names and 

physical addresses of all of their U.S. parent companies and their percentages of ownership 

interest as of December 31 of the reporting year. 

Under Option 1, the following data elements would be reported: 

• Primary and other applicable North American Industrial Classification System (NAICS) 

Code(s); 

• Cogeneration (indication whether any reported emissions are from a cogeneration unit); 

• U.S. Parent Company Name; 

• U.S. Parent Company Physical Address; and 

• Ownership Status. 

Under Option 2, the following data elements would be reported: 

• Primary and other applicable North American Industrial Classification System (NAICS) 

Code(s); 

• Cogeneration(indication whether any reported emissions are from a cogeneration unit); 

• U.S. Parent Company Name(s); 

• U.S. Parent Company Physical Address(es); 

• Percent of Ownership Interest of each U.S. Parent Company. 

Under Option 2, facilities and suppliers would report the legal names and physical addresses of 

all their U.S. parent companies together with each U.S. parent company’s percentage of 

ownership. 

2.1. U.S. Parent Company Name, Physical Address, and 

Ownership Status 

2.1.1. Definition of U.S. Parent Company

For the purposes of this proposed rule amendment, under Option 1, a reporter’s U.S. parent 

company is the highest-level company, located in the United States, and with the largest 

ownership interest in a reporting entity as of December 31 of the reporting year. Each reporter 

would also be required to indicate one of the following with respect to its ownership status: 

“S”—single ownership (the reporting entity is entirely owned by a single company which 

is not owned by any other company, e.g., it is not a subsidiary or division of another 

company). 
4 

“W”—wholly owned (the reporting entity is entirely owned by a single company which 

is, itself, owned by another company, e.g., it is a subsidiary or division of another 

company). 

“M”—multiple owners (the reporting entity is owned by more than one company). 

Under Option 2, EPA proposes to define parent companies as the highest-level U.S. companies 

with an ownership interest in the reporting entity as of December 31 of the reporting year. 

Facilities and suppliers would be required to report all of their U.S. parent companies regardless 

of the percentage of their ownership stake. Note that this option would not ask for all of the 

owners in an individual corporate structure, only the highest-level parent companies. If a facility 

or supplier has only one parent company, the facility should report that company as having 100 

percent ownership. 

2.1.2. Proposed Instruction to Reporters 

EPA is proposing the following instruction to reporters for the data element US parent company. 

Table 1: Proposed Instruction for Reporters on How to Report U.S. Parent Company(s) 

Reporting Scenario 

How to Report U.S. Parent 

Company Under Option 1 

How to Report U.S. Parent 

Company Under Option 2 

The reporting entity is entirely 

owned by a single U.S. 

company that is not owned by 

any other company. 

• Provide that company’s 

legal name and physical 

address as the U.S. parent 

company. 

• Mark “S” for Single 

Ownership in the associated 

box. 

• Provide that company’s 

legal name and physical 

address as the highest-level 

U.S. parent company. 

• Enter 100% as the percent 

ownership 

The reporting entity is entirely 

owned by a single U.S. 

company which is, itself, 

owned by another company 

(e.g., it is a division or 

subsidiary of a higher-level 

company). 

• Provide the legal name and 

physical address of the 

highest-level company in the 

ownership hierarchy as the 

U.S. parent company. 

• Mark “W” for Wholly 

Owned in the associated 

box. 

• Provide the legal name and 

physical address of the 

highest-level company in the 

ownership hierarchy as the 

U.S. parent company. 

• Enter 100% as the percent 

ownership. 

The reporting entity is owned 

by more than one U.S. 

company (e.g., company A 

owns 40%, company B owns 

35% and company C owns 

25%). 

• Provide the legal name and 

physical address of the 

company with the largest 

ownership interest as the 

U.S. parent company. 

• Mark “M” for Multiple 

Owners. 

• Provide the legal names and 

physical addresses of all of 

the highest-level companies 

with an ownership interest as 

U.S. parent companies. 

• Enter the percent ownership 

of each company. 

The reporting entity is entirely 

owned by a foreign company. 

• Provide the legal name and 

physical address of the 

foreign company’s highestlevel company based in the 

U.S. as the U.S. parent 

company. 

• Mark “W” for Wholly 

Owned in the associated 

• Provide the legal name and 

physical address of the 

foreign company’s highestlevel company based in the 

U.S. as the U.S. parent 

company. 

• Enter 100% as the percent 

ownership. 
5 

Reporting Scenario 

How to Report U.S. Parent 

Company Under Option 1 

How to Report U.S. Parent 

Company Under Option 2 

box. 

The reporting entity is 

partially owned by a foreign 

company. 

1) If the reporting entity is not 

entirely owned by the foreign 

company, but the foreign 

company has the largest 

ownership interest, then 

provide the legal name and 

physical address of the foreign 

company’s highest-level 

company based in the U.S. as 

the U.S. parent company. 

Mark “M” for Multiple 

Owners in the associated box. 

2) If the foreign company does 

not have the largest ownership 

interest in the reporting entity, 

then provide the name and 

physical address of the 

company with the largest 

ownership interest as the U.S. 

parent company. Mark “M” 

for Multiple Owners in the 

associated box. 

• Provide the legal name and 

physical address of the 

foreign entity’s highestlevel company based in the 

U.S., along with the legal 

names and physical 

addresses of all the other 

companies with an 

ownership Interest, as U.S. 

parent companies. 

• Enter the percent ownership 

of each company. 

 

2.2. Primary and Other Applicable North American Industrial 

Classification System (NAICS) codes and Cogeneration 

2.2.1. Definition of Primary NAICS Code 

For the purposes of this proposed rule amendment, EPA is proposing to define a reporter’s 

primary North American Industry Classification System (NAICS) code as the six-digit code that 

represents the reporter’s primary product/activity/service at the facility, as defined in "North 

American Industry Classification System Manual 2007," available from the U.S. Department of 

Commerce, National Technical Information Service. The primary NAICS code is the principal 

source of revenue. EPA is proposing to define additional NAICS codes as those codes that 

correspond to product(s)/activity(s)/service(s) that provide economic profit, but that are not 

related to the principal source of revenue. 

Proposed Instruction to Reporters on NAICS Code(s) 

EPA is proposing the following instructions to reporters regarding the facility NAICS code: 

Enter the six-digit North American Industry Classification System (NAICS) code that 

most accurately describes the primary product/activity/service at the facility, based on 

value of shipments. A facility may consist of two or more distinct and separate economic 
6 

units that may have different NAICS codes. Provide all other NAICS codes relating to 

product(s)/activity/service(s) that provide economic profit, but that are not related to the 

principal source of revenue for your facility, in order of largest revenue to smallest. For 

additional guidance on how to determine the proper NAICS code(s) go to 

http://www.census.gov/eos/www/naics/. 

Federal facilities should report the NAICS code that most closely represents the activities 

taking place at the site. For example, a federally-owned, fossil-fuel fired electrical power 

plant would be classified as 221112 – electric power generation, fossil fuels. 

2.2.2. Definition of Cogeneration 

For the purposes of this proposal, a facility uses cogeneration if it produces electric energy or 

useful thermal energy for industrial, commercial, or heating or cooling purposes, through the 

sequential [or simultaneous] use of the original fuel energy.

2

2.2.3. Proposed Instructions for Reporting Cogeneration 

Indicate (check box yes or no) whether some or all of the GHG emissions facilities report are 

from a cogeneration (also known as combined heat and power (CHP)) unit located at the facility. 

3. Methodology 

This section presents the methodology used to estimate the unit and total labor burden and costs 

associated with the two proposed options. It includes a description of the information sources 

used to develop estimates of the labor burden and cost of reporting the proposed data elements 

for each option. The total cost of each option is calculated by first combining information on the 

time spent gathering and submitting the information with wage rates appropriate to the category 

of labor performing the task. This “unit” cost is then multiplied by the total number of facilities 

that will be required to provide this information. 

3.1. Estimation of Reporting Labor Burden 

The labor burden estimates (i.e., time needed for respondents to prepare and submit required 

information) presented below are primarily based on EPA’s professional judgment. As in the 

Mandatory GHG Reporting rule, affected entities will report this information on an annual basis. 

It is assumed that more time will be required in the first year of reporting because the reporting 

entity’s staff must familiarize themselves with the requirements, locate, and then enter the 

relevant information into the reporting form. In subsequent years, it is assumed that the 

information filed in the previous year is used to pre-populate each reporter’s web-based reporting 

form. In subsequent years, the reporting entity’s staff will still need to spend time to determine if 

these data elements have changed and revise the pre-populated information, should that be 

necessary. The labor burden for subsequent years is, therefore, less than that of the first year. 

Differences in estimated total labor burden under Options 1 and 2 are based on differences in the 

task of collecting and reporting information on the U.S. parent company (s) required under the 

 

2

40 CFR 72.2 
7 

two options. The labor burden under Option 1 requires the name and physical address of the U.S. 

parent company with the largest ownership interest be reported, while Option 2 requires the 

name(s) and physical address(es) of all U.S. parent companies to be reported, together with each 

U.S. parent companies’ percentage of ownership and a ranking of these percentages. 

Note that while the derivation of Labor Costs is outlined in Section 3.2, the total facility cost 

associated with each data element is presented with the labor burden in Sections 3.1.1 through 

3.1.3 below. 

3.1.1. Option 1: U.S. Parent Company Name, Address, and Ownership Status 

It is assumed that the reporting entity’s staff will obtain information on their highest-level U.S. 

parent company from elsewhere in the company by requesting the information via in-person 

request or a telephone call, or personally checking files available to the staff involved with 

reporting. Once obtained, the information will be entered into the web-based electronic 

reporting form and then reviewed as part of an overall review of the submission. Under Option 

1, the amount of time required to gather and provide corporate parent information to EPA is 

estimated to be 40 minutes per facility in the first year and 30 minutes per facility in subsequent 

years. Specifically, identifying the highest parent company legal name and physical address is 

estimated to require 20 minutes in the first and subsequent years, while determining and 

recording the type of ownership is estimated to take 20 minutes in the first year and 10 minutes 

in subsequent years. It is assumed a significant proportion of a facility’s effort in this 

investigation process will be determining its type of ownership (i.e. whether singly-, wholly-, or 

multiply-owned) in order to then record the appropriate ownership status category checkbox. The 

burden of recording this information in the ownership category checkbox is expected to be only a 

small fraction of the total estimated burden associated with determining ownership. The total 

cost per facility under Option 1 is $40.15 in the first year and $30.11 in subsequent years. 

3.1.2. Option 2: All U.S. Parent Company Names, Addresses, and Percentage of 

Ownership 

It is assumed that the reporting entity’s staff will obtain this information from elsewhere in the 

company by requesting the information via in-person request or a telephone call, or personally 

checking files available to the staff elsewhere in the company. Once obtained, the information 

will be entered into the electronic reporting form and then reviewed as part of an overall review 

of the submission. The amount of time required to provide this information is proportional to the 

number of owners: it is assumed that the reporting entity’s staff will spend the same reporting 

time for each additional U.S. parent company legal name and physical address as they do for a 

single U.S. parent company. To obtain information on percentage of ownership interest, staff are 

assumed either to consult with internal sources (e.g., legal or financial staff) or to call outside 

information sources, such as Dun and Bradstreet. Note that for electric utilities, the reporting 
8 

entity has already had to report this information to the Energy Information Administration on 

Form 860, so staff may already possess information on percentage ownership.3

Although reporting entities do not have to report their ownership status under Option 2, they will 

still need to determine their ownership structure in order to identify and rank by ownership all 

U.S. parent companies. The amount of time required to determine ownership structure and 

provide name and addresses is estimated to be 40 minutes per reporting entity in the first year 

and 30 minutes per reporting entity in subsequent years. Specifically, identifying the highest 

parent company legal name and physical address is estimated to require 20 minutes in the first 

and subsequent years, while determining and recording the type of ownership is estimated to take 

20 minutes in the first year and 10 minutes in subsequent years. It is assumed a significant 

proportion of a facility’s effort in this investigation process will be determining its type of 

ownership (i.e. whether singly-, wholly-, or multiply-owned) in order to then rank its parent 

companies by percent ownership. 

Based on ownership information from the electric utility industry, it is estimated that facilities 

and suppliers with multiple owners will have to gather and report U.S. parent company 

information for an average of three owners.

4

 Reporting additional U.S. parent company legal 

names and physical addresses will require an additional 20 minutes per parent in the first year 

and 20 minutes per parent in subsequent years beyond the time spent to collect the information 

for the first U.S. parent company. 

An additional 5 minutes will be required to report and rank percent of corporate ownership for 

facilities with multiple owners in the first year and subsequent years. The total average cost per 

facility under Option 2 is $40.80 in the first year and $30.77 in subsequent years. 

3.1.3. North American Industry Classification System (NAICS) Code(s) 

It is assumed that the reporting entity’s staff will obtain their NAICS code(s) from elsewhere in 

the company by requesting the information via in-person request or a telephone call, or 

themselves checking files available to the staff elsewhere in the company. Once obtained, the 

information will be entered into the electronic reporting form and then reviewed as part of an 

overall review of the submission. All facilities and suppliers are required to report at least one 

NAICS code that corresponds to the facility’s principal revenue-generating operations, i.e. the 

facility’s primary NAICS code. From an analysis of NAICS code reporting to the TRI program, 

over 99% of reporters listed 3 or fewer NAICS codes.5 Therefore, for the purposes of estimating 

the potential costs of this rulemaking, it is assumed that 3 NAICS codes will be reported per 

facility. The amount of time required for the facility to provide information for additional 

NAICS codes is proportional to the number of NAICS codes: each additional code is assumed to 

 

3 This data is collected in EIA Form 860, Schedule 4, and made publically available in the Annual Electric 

Generator Report database. http://www.eia.doe.gov/cneaf/electricity/page/eia860.html

4

Ibid. 

5

99.5% of TRI reporters in all reporting years provided 3 or fewer NAICS codes. In RY2008, 98.9% of TRI 

reporters provided 3 or fewer NAICS codes. Source: TRI Public Data Releases. 

http://www.epa.gov/TRI/tridata/index.htm#pdr
9 

require the same reporting time as the primary NAICS code. The amount of time required at each 

facility to provide primary and other applicable NAICS code is estimated to be 10 minutes per 

NAICS code in the first year and 2.5 minutes per NAICS code in subsequent years. In total, the 

amount of time to report three NAICS codes is expected to be 30 minutes in the first year and 7.5 

minutes in subsequent years. The total average cost per facility is $30.11 in the first year and $ 

7.53 in subsequent years. 

3.1.4. Cogeneration 

It is assumed that the reporting entity’s staff would determine whether any of its reported 

emissions are from a cogeneration unit by making a phone call, checking files, or making an inperson information request. The amount of time required to determine whether any of its 

reported emissions are from a cogeneration unit is estimated to be 10 minutes per facility in the 

first year and 2.5 minutes per facility in subsequent years. The total average cost per facility is 

$10.04 in the first year and $ 2.51 in subsequent years. 

3.2. Estimation of Labor Costs 

The personnel responsible for reporting the required information in the proposed rule are likely 

to vary by industry sector and/or by facility and supplier. Table 2 provides estimates of the 

expected personnel titles, labor categories, and loaded hourly wage rates used in the Mandatory 

GHG Reporting Rule Regulatory Impact Analysis.6Loaded hourly wage rates represent the total 

cost to the facility per hour of labor, accounting for costs beyond the hourly rate paid to the 

employee such as fringe benefits and overhead. 

To reflect that management, legal and technical staff will be involved in reporting the required 

data elements; a blended management/legal wage rate was created from the average of hourly 

wage rates of management and legal staff. A similar blended technical wage rate was calculated 

from the average of certain technical staff job classifications. An overall weighted wage rate was 

then developed based on estimates from the TRI program for similar data element reporting at 

similar facilities. According to the TRI estimates, management and legal staff are estimated to 

be involved in approximately 0.8% of the reporting effort, while technical staff are likely to be 

needed for the remaining 99.2%. Using these proportions, the weighted loaded wage rate, i.e., 

the blended labor rate, used in this analysis is $60.22 per hour. 

 

6 U.S. EPA, 2009. Regulatory Impact Analysis for the Mandatory Reporting of Greenhouse Gas Emissions Final 

Rule (GHG Reporting). September. 
10 

Table 2: Loaded Hourly Wage Rates of Facility Staff Involved in GHG Reporting 

Personnel Type Hourly Wage Rate 

Management Personnel 

 electricity manager $88.79

 refinery manager $101.31

 industrial manager $71.03

 lawyer $101.00

Blended Management and Legal 

Wage Rate 

$90.53

Technical 

 electricity engineer/technician $60.84

 refinery engineer/technician $63.89

 industrial engineer/technician $55.20

Blended Technical Wage Rate $59.98

Percent reporting by Management 

and Legal Personnel 0.8%

Percent reporting by Technical 

Personnel 99.2%

Blended Labor Rate $60.22

3.3. Estimation of the Sector and Facility Universe 

Every facility and supplier subject to the Mandatory Greenhouse Gas Reporting rule would also 

be required to report on the additional data elements covered under this rulemaking. Table 3 lists 

the 27 industries affected by the Mandatory Greenhouse Gas Reporting Rule and provides counts 

of the number of reporting facilities in each sector.7 

For Option 2, it was necessary to estimate the number of facilities and suppliers in each sector 

that have more than one owner, and thus more than one U.S. parent company. The electric utility 

sector, with its complex ownership structures, includes reporters with multiple owners. Table 4 

shows the distribution of the number of U.S. parent companies for reported operating electric 

generators in 2007 estimated to meet Mandatory GHG Reporting rule requirements. In the other 

industry sectors subject to the Mandatory GHG Reporting Rule, data are not readily available to 

estimate the number of facilities with more than one corporate owner. While joint venture 

ownership is not uncommon in other sectors, no evidence has been found to quantify the 

frequency of multiple facility ownership in other sectors subject to the Mandatory GHG 

Reporting Rule. Therefore, for the purposes of this analysis it is assumed that no facilities in 

other industries have more than one U.S. parent company. 

 

7 U.S. EPA. 2009 “Final Mandatory Greenhouse Gas Reporting Rule: Overview.” Powerpoint Presentation. October 

5. 
11 

Table 3: Estimated Number of Facilities Required to Report GHG Emissions, by Industry Sector 

Table 4: Electric Utility Sector Facility Ownership for Plants expected to be subject to the 

Mandatory GHG Reporting Rule 

Number of 

Owners 

Number of 

Plants 

Percent of Total 

Plants 

Percent of 

Facilities with 

Multiple Owners 

1 1,280 87.07% 

2 121 8.23% 63.68%

3 29 1.97% 15.26%

4 15 1.02% 7.89%

5 8 0.54% 4.21%

6 7 0.48% 3.68%

7 2 0.14% 1.05%

8 3 0.20% 1.58%

9 1 0.07% 0.53%

10 0 0.00% 0.00%

11 0 0.00% 0.00%

12 2 0.14% 1.05%

13 1 0.07% 0.53%

14 1 0.07% 0.53%

15 0 0.00% 0.00%

16 2 0.14% 1.05%

Major Industries 

Number of 

Facilities 

Other Industries 

Number of 

Facilities 

Stationary Combustion 3,000 Cement 107 

Landfills 2,551 Lime 89 

Natural Gas Suppliers 1,502 Petrochemical 80 

Electricity Generation 1,108 Glass 55 

Pulp and Paper 425 Nitric Acid 45 

Petroleum Product Suppliers 315 Hydrogen 41 

GHG Suppliers 167 Ammonia 23 

Petroleum Refineries 150 Phosphoric Acid 14 

Iron and Steel 121 Aluminum 14 

Other 529 CO2 Suppliers 13 

Total 9,868 Lead 13 

Ferroalloy 9 

Titanium oxide 8 

Zinc 5 

Soda Ash 5 

Adipic Acid 4 

HCFC-22 3 

Silicon Carbide 1 
12 

Table 5: Average Number of Corporate Owners of Facilities in the Electric Utility Sector 

Average number of owners 

across all utilities 

Average number of 

owners across utilities 

with multiple owners 

1.3 3.2 

3.4. Calculation of Total Labor Burden and Total Cost 

To calculate the total labor burden and total cost of reporting the required data elements under 

the proposed rule amendment, the analysis is divided into the following four steps for each 

option. Note that steps 2 - 4 are identical for data elements under both Options 1 and 2. Total 

labor burden and cost are derived separately for the first year of reporting and for subsequent 

reporting years. 

3.4.1 Step 1: Calculate Total Industry Sector Labor Burden, by Labor Category 

3.4.1.1 Option 1: Reporting U.S. Parent Company Information 

To calculate the total amount of time required in the first year, the number of reporting facilities 

in each sector was multiplied by the total first year burden for each labor category. The same 

calculation is made for subsequent year burden. These calculations were completed for all 

reporting sectors. 

Industry Sector Labor Burden (s,l, y) = Bly x Ns

Ns = Estimated number of facilities in a given sector (s) 

Bl,y= Hourly blended labor category burden (l) for a given reporting year (y) under Option 1, 

where 

l = blended proportion of expected management, legal and technical labor, and 

y= First Year or Subsequent Years 

For example: 

Industry Sector Labor Burden (Cement, First Year) = (Estimated Number of Facilities in the 

Cement Sector) x (Blended labor burden in First Reporting Year). 

As burden is estimated in minutes, calculated industry burden is divided by 60 to convert to an 

hourly burden total for each sector. 

3.4.1.2 Option 2: Reporting U.S. Parent Company Information for All Ownership 

Interest 

To calculate the total amount of time required in the first year, the number of reporting facilities 

in each sector was multiplied by the total first year labor burden to report one corporate parent 

for each labor category. The same calculation is made for subsequent year labor burden. These 

calculations were completed for all reporting sectors. In this analysis, only electric utilities are 

expected to report multiple owners. For the electric utility sector, an incremental burden of 

reporting more than one corporate parent is added to the proportion of reporting facilities and 

suppliers with multiple corporate owners.
13 

Industry Sector Labor Burden (s,l, y) = (Bly x Ns x po ) + ((Bly +Oly+(Aly x (Nm-1)) x Ns x pm)

Ns = Estimated number of facilities in a given sector (s) 

Nm= Estimated average number of corporate owners for facilities with multiple parents

po = Proportion of facilities with one corporate owner 

pm = Proportion of facilities with more than one corporate owner 

Bl,y = Hourly blended labor category burden (l) for a given reporting year (y) needed to report 

corporate parent name and address for one ultimate parent, where 

l = blended proportion of expected management, legal and technical labor, and 

y = First Year or Subsequent Years 

Ol,y = Hourly blended labor category burden (l) for a given reporting year (y) needed to 

report percent of ownership, where 

l = blended proportion of expected management, legal and technical labor, and 

y = First Year or Subsequent Years 

Al,y = Incremental hourly blended labor category burden (l) for a given reporting year (y) 

needed to report multiple corporate parent names and addresses beyond the first parent, 

where 

l = blended proportion of expected Management and Technical labor, and 

y = First Year or Subsequent Years 

For example, 

Industry Sector Labor Burden (Electric Utilities, First Year) = [(Estimated labor burden to 

report one corporate owner) x (Estimated number of facilities in the Electric Utility Sector) x 

(Estimated proportion of facilities with one corporate parent in the Electric Utility 

Sector)]+[((Estimated labor burden to report one corporate owner) + (Estimated labor burden to 

report percent ownership)+ (Estimated time to report multiple corporate owners beyond the first 

reported owner)) x (Estimated number of facilities in the Electric Utility Sector) x (Estimated 

proportion of facilities with more than one corporate owner in the Electric Utility Sector)] 

As labor burden is estimated in minutes, calculated industry labor burden is divided by 60 to 

convert to an hourly labor burden total for each sector. 

3.4.1.3 Options 1 and 2: Reporting NAICS code(s) and facility cogeneration 

The calculation of labor burden for reporting NAICS codes and facility cogeneration elements is 

identical for Options 1 and 2. To calculate the total amount of time required in the first year, the 

number of reporting facilities in each sector was multiplied by the total first year burden for each 

labor category. The same calculation is made for subsequent year burden. These calculations 

were completed for all reporting sectors. 

Industry Sector Labor Burden (s,l, y) = Bly x Ns

Ns = Estimated number of facilities in a given sector (s) 

Bl,y= Hourly blended labor category burden (l) for a given reporting year (y), where 

l = blended proportion of expected management, legal and technical labor, and 

y= First Year or Subsequent Years 

For example: 
14 

Industry Sector Labor Burden (Cement, First Year) = (Estimated Number of Facilities in the 

Cement Sector) x (Blended labor burden in First Reporting Year). 

As burden is estimated in minutes, calculated industry burden is divided by 60 to convert to an 

hourly burden total for each sector. 

3.4.2 Step 2: Calculate Total Industry Sector Cost, by Reporting Year

To calculate the total cost in the first year under Options 1 and 2, reporting labor burden 

calculated in Step 1 was multiplied by the first year loaded weighted hourly wage rate. The same 

calculation is made for subsequent year burden. These calculations were completed for all 

reporting sectors. 

Under Option 1, the complete calculation of Industry Cost follows the equation below: 

Industry Cost (s, l, y) = Bly x Ns x Rl

Ns = Estimated number of facilities in a given sector (s) 

Bl,y = Hourly Blended Burden (l) for a given reporting year (y), where 

l = blended labor burden, and 

y= First Year or Subsequent Years 

Rl=Average Loaded Weighted Hourly Wage Rate (l) 

For example: 

Industry Cost (Landfill, Subsequent Years) = (Estimated Labor Burden under Option 1 for the 

Landfill Industry in Subsequent Years) x (Average Loaded Weighted Hourly Wage Rate). 

Under Option 2, the calculation of Industry Cost follows the equation below: 

Industry Cost (s, l, y) = [(Blyc x Ns x po ) + ((Bly +Oly+(Aly x (Nm-1)) x Ns x pm)] x Rl 

Ns = Estimated number of facilities and suppliers in a given sector (s) 

Nm= Estimated average number of multiple U.S parent companies

po = Proportion of facilities and suppliers with one U.S. parent company 

pm = Proportion of facilities and suppliers with more than one U.S. parent company 

Bl,y = Hourly blended labor category burden (l) for a given reporting year (y) needed to report 

corporate parent name and address for one U.S. parent company, where 

l = blended proportion of expected management, legal and technical labor, and 

y = First Year or Subsequent Years 

Ol,y = Hourly blended labor category burden (l) for a given reporting year (y) needed to 

report percent of ownership, where 

l = blended proportion of expected management, legal and technical labor, and 

y = First Year or Subsequent Years 

Al,y = Incremental hourly blended labor category burden (l) for a given reporting year (y) 

needed to report multiple U.S. parent company names and addresses beyond the first 

parent, where 

l = blended proportion of expected Management and Technical labor, and 

y = First Year or Subsequent Years 
15 

Rl=Average Loaded Weighted Hourly Wage Rate (l) 

Alternatively, 

Industry Cost (Electric Utilities, Subsequent Years) = (Estimated Labor Burden under Option 2 

for the Electric Utility Industry in Subsequent Years) x (Average Loaded Weighted Hourly 

Wage Rate). 

3.4.3 Step 3: Calculate Total Labor Burden and Total Cost for Sector and U.S. 

To calculate the total labor burden incurred under each option by sector, labor hours are summed 

for each sector for the first and subsequent years separately. The total labor burden is the sum of 

all industry sector labor burden estimates. The same calculation is made to estimate total cost. 

Total Labor Burden = ∑∑s lBlyNs

In other words, 

Total Labor Burden = Σ (Total Industry Sector Labor Burden) over all sectors for either the first 

or subsequent reporting years. 

To calculate the total cost incurred by sector, cost estimates are summed for each industry sector. 

Total Cost = ∑∑s l

ly sRl B N

In other words, 

Total Cost = Σ (Total Industry Cost) over all sectors. 

3.4.4 Step 4: Calculate Total Labor Burden and Total Cost for All Data Elements

In both Options 1 and 2, the total labor burden is calculated as the sum of the total labor burden 

estimates for all required data elements. Likewise, the total cost for the data elements is 

calculated as the sum of the individual cost estimates for each data element. These calculations 

are made separately for first and subsequent reporting years. 

4. Results

Tables 6 and 7 present the total labor burden and cost associated with the data elements required 

by the proposed rule is presented separately by data elements, reporting year, and option. Total 

overall labor burden and cost estimates for reporting all data elements proposed in the first year 

of reporting and for all subsequent reporting years under Option 1 are presented in Table 6, and 

total overall labor burden and cost estimates for reporting all data elements in the first year of 

reporting and for all subsequent reporting years under Option 2 are presented in Table 7. 
16 

Specifically, approximately 9,900 facilities will incur roughly 13,200 hours and $792,000 overall 

under Option 1 in the first year and roughly 6,600 hours and $396,000 under Option 1 in 

subsequent years. Approximately 9,900 facilities will incur roughly 13,300 hours and $799,000 

under Option 2 in the first year and roughly 6,700 hours and $403,000 under Option 2 in 

subsequent years. On a per facility basis, costs amounts to approximately $80 per facility in the 

first year and $40 per facility in subsequent years under Option 1 and $81 per facility in the first 

year and $41 per facility in subsequent years under Option 2. 

Table 6: Estimated Total Labor Burden and Total Cost under Option 1 

 

Total Labor 

Burden (hours) Total Cost 

First Reporting Year 

Parent Company Name, Address, 

and Ownership Status 

6,579 $396,162

Facility NAICS Code(s) and 

Cogeneration 

6,579 $396,162

All Data Elements 13,157 $792,324

Subsequent Reporting Years 

Parent Company Name, Address, 

and Ownership Status 

4,934 $297,091

Facility NAICS Code(s) and 

Cogeneration 

1,645 $99,040

All Data Elements 6,578 $396,132

Table 7: Estimated Total Labor Burden and Total Cost under Option 2 

 

Total Labor 

Burden (hours) Total Cost 

First Reporting Year 

Parent Company Name, Address, 

and Percent Ownership 

6,686 $402,630

Facility NAICS Code(s) and 

Cogeneration 

6,579 $396,162

All Data Elements 13,265 $798,792

Subsequent Reporting Years 

Parent Company Name, Address, 

and Percent Ownership 

5,041 $303,589

Facility NAICS Code(s) and 

Cogeneration 

1,645 $99,040

All Data Elements 6,686 $402,630