SUPPORTING STATEMENT FOR INFORMATION COLLECTION REQUEST RENEWAL:

MOBILE AIR CONDITIONER RETROFITTING PROGRAM

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection

This ICR is entitled " Mobile Air Conditioner Retrofitting Program (Renewal) ," EPA ICR

Number 1774.06 , and OMB Number 2060

- 0350.

1(b) Short Characterization

T he Significant New Alternatives Pol icy (SNAP) Program , under Section 612 of the Clean Air Act (CAA), enables the Agency to review available substitutes for ozone depleting substances (ODSs) and determine t heir acceptability. The Stratospheric Protection Division (S PD) is responsible for enacting regulations to phase out chemicals that damage the stratosp heric ozone layer and ; therefore

, pose a threat to human health and the environment. Depletion of stratospheric ozone can result in sharp increases in melanoma and non

- melanoma cancers due to increased exposure to ultraviolet

- A (UV

- A) and ultraviolet

- B (UV

- B) radiation, and a higher incidence of cataracts (a leading cause of blindness). Under the SNAP program, companies submit applications of substitutes for ODSs

. After all necessary information is received, SPD ha s 90 days to review the data submitted, and determine if the substitute is acceptable, unacceptable,

or if its use must be restricted. For every submission, SPD reviews factors such as impact on human health and the environment, ozone depleting potential, atmospheric lifetime, global warming potent ial, and flammability. Because m any substitutes are produced for multiple uses,

SPD must determin e what uses are appropriate based on the factors mentioned

. Once SPD makes

a decision of acceptability of a substitute , a Notice is published in t he Federal Re gister listing acceptable substitutes under SNAP

. If the substitute is found unacceptable or use restrictions are required , a notice

- and

- comment rulemak ing is necessary

. A comprehensive list of substitutes, their uses, and any relevant restrictions is main tained for distribution to interested parties.

SPD requires technicians retrofitting motor vehicle air conditioners (M V AC s ) containing ODS

such as CFC

- 12 to use a n approved SNAP substitute and to provide basic information on a label

to be affixed to a visible section of the MVAC

. The label must include the name of the substitute refrigerant, when and by whom the retrofit was performed, environmental and safety information about the substitute refrigerant, and other information. This inf ormation is nee ded so that subsequent technicians working on the M V AC system will be able to service the system properly, decreasing the likelihood of significant refrigerant emissions, cr oss

- contamination and potential

failure of air conditioning systems and refrigerant recovery/recycling equipment. EPA requires that when retrofitting CFC

- 12 MVAC systems with an approved SNAP refrigerant, the

technician must first extract the CFC

- 12, and then ins tall new fittings unique to the new refrigerant.2 EPA estimates that 29 4 technicians will be responsible for providing this information over the next 3 years, at a total cost (labor plus materials) of about $ 1,750 .00

.

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need and Authority for the Collection

The SNAP program reviews p otential alternatives to ozone

- depleting refrigerants used in various sectors, including MVAC s

. W hen chlorofluorocarbons (CFCs), and specifically CFC

- 12, were phased out SPD face d the challenge of identifying acceptable alternative refrigerants t hat

allow ed consumers choice to retrofit CFC

- 12 MVAC systems to use alternatives. EPA notes that

in the U.S. prior t o the 1993 model year all MVAC s used CFC

- 12 and that after 1995 , original equipment manufacturers (OEMs) were producing MVA Cs with HFC

- 134a. EPA esti mates that there are currently , in 2013, about 330,000 automobiles , originally designed to use CFC

- 12 in

their MVAC s , operating in the U.S. Of the automobiles originally designed to use CFC

- 12 in

their MVACs that are expected to be operational during the t hree year term of this ICR , EPA

estimates 294 ( about 0. 1 % ) or less will be retrofitted to use alternative refrigerants between October 31, 2013 and October 30, 2016 (the term of this ICR). The remaining MVAC systems will either (1) continue to op erate without service, (2) continue to operate with minor service including repairs and refilling with available supplies of CFC

- 12, (3) will be recycled or disposed of along with the entire motor vehicle, (4) will cease to function but will not be

retrofi tted, or (5) have already been retrofitted to an acceptable alternative refrigerant and will not be retrofitted again.

The purpose of this Information Collection Request (ICR) is to estimate the burden associated

with the 40 CFR p art 82 subpart G requirem ents that service technicians label MVAC systems with information about new refrigerants when they retrofit a system. It is necessary to assess the time it will take for the service technician to fill out and place the label on the retrofitted air

conditio ner. This label will acknowledge that the retrofitting has been completed, and that the

MVAC no longer use s CFC

- 12

. In addition, the label provides essential information to technicians about the specific refrigerant used in the air conditioning system.

Se ction 612 of the CAA requires EPA to promulgate rules making it unlawful to replace any

ODS with any substitute that the Administrator determines may present adverse effects to human

health or the environment where the Administrator has identified an alter native that (1) reduces the overall risk to human health and the environment, and (2) is currently or potentially available.

EPA is concerned that the existence of several substitutes in this end

- use may increase the likelihood of significant refrigerant c ross

- contamination and potential failure of air conditioning systems and recovery/recycling equipment. In addition, continuing the smooth transition to substitutes strongly depends on the continued purity of the recovered, recycled and/or reclaimed

CFC

- 12 supply.3 2(b) Practical Utility/ Users of the Data

The purpose of the label is to alert service technicians and motor vehic le owners that the MVAC

has been retrofitted to use an acceptable non

- CFC refrigerant. The label will provide essential information to technicians about the specific refrigerant used in the air conditi oning system.

Technicians need this information to avoid service practices that might result in refrigerant cross

contamination and system failure.

3. NON DUPLICATION, CONSU LTATIONS, AND OTHER COLLECTION CRITERIA

3(a) Non duplication

The required label is put on CFC

- 12 air conditioners that are being retrofitted with an acceptable

substitute. The label will be the only required mechanism to indicate the use of a substitute, and therefore will not be duplicative.

3(b) Public Notice Required Prior to ICR Submission to OMB

A Federal Register Notice soliciting public comment was published on 6/20/2013 (78 FR 37220).

No comments were received. EPA will publish a second FR not ice when this ICR is submitted

to OMB for review.

3(c) Consultations

EPA consulted with the following individuals in preparing this ICR renewal:

• Angelo Patti, Chairman of the Interior Climate Control Committee of Society of Automotive Engineers (SAE), regarding the number of air conditioners likely to be

retrofitted.

• War d Atkinson, Suntest Engineering , regarding the number of air conditioners likely to

be retrof itt ed and the cost burden.

• Paul DeGuiseppi, Mobile Air Conditioning Society Worldwide, regarding the percent of air conditioners likely to be retrofitted.

• Fred Sciance, Manager, Environment and Climate Policy General Motors (GM) Public Policy Center

, regar ding the number of R

- 1 2 air conditioners on the road today and the percent likely to be retrofitted

.

EPA received comments from the four individuals listed above. The y are highly supportive of EPA’s effort to ensure the labeling of cars retrofitted from R

- 12 to R

- 134a. The y believe that due to better maintenance and longer lifetimes of vehicles, the number of cars remaining on the road today with R

- 12 may be higher than the number estimated by EPA. Despite varying estimates on the number of cars on the road today using R

- 12, the y all agree with the estimated number of retrofits to be performed and labeled over the next three years.4 Two of the four specifically stated th at the estimated number of cars using R

- 12 on the road today is likely too low; however, they concluded that the estimated number of retrofits is accurate. Angelo Patti, Chairman of the SAE Interior Climate Control Committee stated that

“due to the increas ed age and dwindling value of these remaining vehicles, I believe the estimated number of future retrofits is probably accurate. In other words most of the remaining vehicles will simply not be repaired or retrofit because the cost would be too high relati ve to the

value of the vehicle.” Fred Sciance, GM, concluded, “although there will be many of these vehicles still in service, I concur with your estimate of the number of conversions of R

- 12 systems to alternative refrigerants, since most of these vehicle s would either be serviced with R

12 or left unrepaired.”

The EPA believes the comments received in response to the request for consultation are consistent with the proposal put forward in June 20, 2013 Federal Register notice. Therefore, the

EPA has not changed the conclusions of this Supporting Statement.

3(d) Effects Of Less Frequent Collection

This ICR asks for information to be collected just once per MVAC retrofit.

3(e) General Guidelines

This ICR follows all of OMB’s general guidelines for information collections.

3(f) Confidentiality

This ICR does not ask for any information that would be considered confidential.

3(g) Sensitive Questions

This ICR does not ask any questions concerning sexuality, religious beliefs, or other matters

usuall y considered private.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents and SIC Codes

The following is a list of Standard Industrial Classification (SIC) codes and associated industries that may retrofit a MVAC and therefore may be affe cted by information collection requirements

covered under this ICR. Also listed are the corresponding North American Industry Classification System (NAICS) codes available at http://www.census.gov/epcd/www/naics.html.

SIC code : Type of Industry and NAICS code : 551 New and used car dealers (NAICS code 441110)

554 Gas service stations (NAICS codes 447110 and 447190)5 7532 Top and body repair shops (NAICS code 811121)

7538 General automotive repair shops (NAICS code 811111)

7539 Automotive repair shops not elsewhere classified, including air conditioning and radiator specialty shops (NAICS code 811198)

4(b) Information Requested

The Agency will not standardize the label, but rather allow the industry to devise a format that

accommodates information abo ut the refrigerants on the market. Unique fittings are necessary for different refrigerants in order to avoid cross contamination, as is the use of different colored labels for each refrigerant. EPA work s with refrigerant developers to eliminate the risk o f duplication. The person conducting the retrofit must apply a label that contains the following

information to the MVAC in the engine compartment:

• The name and address of the technician and the company performing the retrofit

,

• The d ate of the retrofit,

• The trade name, charge amount, and, when applicable, the numerical designation of the refrigerant as determined under the latest version of Standard 34 of the American Society of Heating, Refrigerating, and Air

- conditioning Engi neers ( ASHRAE), Inc.,

• The type, manufacture r, and amount of lubricant used,

• If the refrigerant is or contains an ozone

- depleting substan ce, the phrase "ozone depleter",

• If the refrigerant displays flammability limits as measured according to latest version of

Sta ndard E681 of the American Society for Testing and Materials (ASTM) International, the statement "This refrigerant is FLAMMABLE. Take appropriate precautions."

5. THE INFORMATION COLLECTED

– AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT

The Agency has not develop ed a format for the label and does not collect and compile the information provided on the label.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden

EPA has not developed a standard label, but rather the manufacturers have the opportunity to produce unique labels to accompany their refrigerant. Much of the information required on the

labels ca n be printed with the labels, thereby lessening the burden on the individual service shops, many of which are small businesses. These labels may also contain information about the specific fittings the service technician should use, with the subject refrig erant, to minimize the potential for cross

- contamination due to several alternative refrigerant products on the market

. EPA work s closely with industry in carrying out these labeling requirements

. Proper labelin g result s in considerable savings to industry and the public, since it greatly reduce s the chance of6 refrigerant contamination. There are now 16 alternative refrigerants on the market listed under the SNAP program as acceptable replacements for CFC

- 12 for MVAC. However, only 13 of

these alternative r efrigerants are acceptable for retrofitting MVAC s

. Considerable costs would accrue if refrigerants were contaminated (mixed), including the costs to repair systems which failed as a result and the costs to recover, separate, reclaim and/or dispose of conta minated refrigerant.

To estimate the total number of retrofits to occur by October 30, 2016 , the date this ICR will expire, the Agency analyzed publicly ava ilable data from the U.S. Department of Transportation, Bureau of Transportation Statistics, regarding vehicle sales per year. EPA assumed that the penetration of air conditioning in these vehicles rose linearly from 70% in 1970 to 98% in 1998

and remained at 98% thereafter. EPA assumed that 100% of the MVACs were designed for

CFC

- 12 for years 197 0 through 1991, 67% for 1992, 33% for 1993, and 0% thereafter. EPA

assumed the lifetime of service of an air conditioner follows a Poisson distribution with an average lifetime of 12 years. Using this method, EPA estimates that ther e are currently approxim ately 33 0,000 MVAC s , originally designed to use CFC

- 12, operating in the U.S. EPA estimates that in 2014, 2015 and 2016 the number of cars originally designed to use CFC

- 12 will decrease to 170,000, 84,000 and 40,000, respectively. Of these, EPA estimates that 0.1% will be retrofitted annually to use alternative refrigerants between October 2013 and September 2016. Therefore, EPA estimates that in 2014, 2015 and 2016 the numbers of MVACs to be retrofitted are 170, 84 and 40, respectively; resulting in a tot al of 294 MVAC retrofits between October 31,

2013 and October 30, 2016 (the term after this ICR). The remaining MVACs either (1) will continue to operate without service, (2) will continue to operate with minor service including refilling with available supplies of CFC

- 12, (3) will be disposed or recycled along with the entire motor vehicle, (4) will cease to function but will not be retrofitted due to economic reasons, or (5) have already been retrofitted to an alternative refrigerant and will not be retrofitted again.

EPA estimates the time to complete and apply the required label at 5 minutes per MVAC

.

6(b) Estimating Respondent Costs

EPA estimates the cost per label to be $0.10.

EPA estimates the time to complete and apply the label at 5 minutes per MVAC

. Based on recent consultation with the industry, EPA uses an estimate of $70 per hour loaded labor rate (include s: wages paid to the technician, benefits including paid leave, health insurance, retirement saving s and legally required benefits, and overhead, including office space, furniture, equipment and computers, supplies and other business expenses). Thus the lo aded labor cost per response is approximately $5.83.

6(c) Estimating Agency Burden And Cost

The data required on the label is not submitted to the EPA; therefore, the Agency burden and

cost is zero.7 6(d) Estimating the Respondent Universe and Total Burd en and Costs

The U.S. Department of Labor statistics indicate there will be an average total of 787,000 automotive service technicians and mechanics (SOC Code Number 49

- 3023) in the U.S. during the years this ICR will be active. EPA estimates that no more technicians than the total number of MVACs retrofitted over the 3 years of this ICR will be responsible for retrofitting. If each of the 294 MVACs is retrofitted by a different technician, then approximately .037% of technicians will be responsible for re trofitting over the three

- year term of this ICR.

EPA estimates the time to complete and apply the label at 5 minutes per MVAC, making the total burden 24.5 hours (8 hours per year). At an estimated average labor rate of $70 per hour,

the overall cost asso ciated with the burden hours is $1,7 15 ($5 6 0 per year). The cost for designing, typesetting, printing and distributing 294 labels is estimated at $0.10 per label for a total of about $30 ($10 per year). Adding the labor and capital costs together yiel ds a total cost burden of $1,745 .00 ($570 per year)

.

6(e) Bottom Line Burden Hours And Cost Tables

As indicated in 6(c), there is no burden or cost to the Agency; therefore, the bottom

- line burden hours and costs are equivalent to the respondent burden hours and costs:

burden hours: 8 hours per year

burden costs: direct: $10 per year

labor: $57 0 per year

6(f) Reasons for Change in Burden

Based on the decline of CFC

- 12 MVACs in service today

, EPA estimates a continued reduction

in the number of CFC

- 12 MVACs retrofits will occur during the next three years. After 1994, new cars in the US were no longer sold with CFC

- 12 MVACs

. Thus, t he number of operating

cars with CFC

- 12 MVACs has decrea sed since the last ICR renewal

. With fewer cars with CFC

12 MVACs, there will be fewer retrofits with substitute refrigerant s and subject to this ICR

.

6(g) Burden Statement

The annual public reporting and record keeping burden for this collection of information is estimated to average 5 minutes per response. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the tim e needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable in structions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose8 the information. An agency may not conduct or spo nsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Dock et

ID No. EPA

- HQ

- OAR

- 20 13

- 0402 , which is available for online viewing at www.regulations.gov, or in person viewing at the EPA Docket Center (EPA/DC), WJC West, Room 3334 , 1301 Constitution Avenue, NW, Washington, D.C. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the

Air and Radiation Docket is (202) 566

- 1742 . An electronic version of the public docket is available at www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronic ally. When in the system, select “search,” then key in the Docket ID Number identified above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, A ttention: Desk Officer for EPA. Please include the EPA Docket ID

Number EPA

- HQ

- OAR

- 2013

- 0402 and OMB Control Number 2060

- 0350 in any correspondence.