| Forms and Instructions/User Guides |
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| Registration and Reporting Instructions using templates or that occurs within systems; with system user guides listed; user guides are instructions for respondents (REQUESTED TO DISPLAY OMB CONTROL NUMBER): |
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| · Engineering Review Template - PDF and *Word (both on webpage at https://www.epa.gov/fuels-registration-reporting-and-compliance-help/template-engineering-reviews-renewable-fuel) |
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| · OTAQ Reg (Registration System) User Guide - resources at https://www.epa.gov/fuels-registration-reporting-and-compliance-help/registration-fuel-programs |
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| · User Guide for DCFUEL in EPA’s Central Data Exchange - resources at https://www.epa.gov/fuels-registration-reporting-and-compliance-help/reporting-fuel-programs |
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| * Engineering Review Submission User Guide - see https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P100VGC7.pdf |
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| * Pathways Screening Tool at https://www.epa.gov/renewable-fuel-standard-program/forms/renewable-fuel-pathway-screening-tool |
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https://www.epa.gov/renewable-fuel-standard-program/how-submit-complete-petition-approved-pathway-renewable-fuel |
| * Pathways Instructions at https://www.epa.gov/renewable-fuel-standard-program/forms/renewable-fuel-pathway-screening-tool and for Submitting a Petition at https://www.epa.gov/renewable-fuel-standard-program/how-submit-complete-petition-approved-pathway-renewable-fuel |
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| * Attest Engagements submitted via system following general fields of prior ATT0101 https://www.epa.gov/fuels-registration-reporting-and-compliance-help/how-submit-attest-engagements |
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| Forms and Form Instructions (Form Number / Name): |
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| · 5900-631 / RFS0107: RIN activity report |
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| · 5900-290 / RFS0602: RFS2 Renewable Fuel Producer Supplemental Report |
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| · 5900-289 / RFS0702: RFS2 Co-products report |
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| · 5900-293 / RFS0801: RFS2 Renewable Biomass Report |
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| · 5900-278 / RFS0902: Production Outlook Report |
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| · 5900-633 / RFS2001: Batch Verification |
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| · 5900-634 / RFS2101: Aggregate RIN Verification |
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| · 5900-635 / RFS2201: On-Site Audit Report |
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| · 5900-636 / RFS2301: List of Potentially Invalid RINs |
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| · 5900-361 / RFS2400: Mass Balance |
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| · 5900-529 / RFS4000: Biointermediates batch reporting |
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| * URF (unified reporting format) - the spreadsheet template where the above forms and instructions are entered |
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| Summary |
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| Type of Respondent |
Total Responses per Year |
Total Hours per Year |
Total Cost per Year (Labor and Non-Labor) |
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| Biointermediate Producers |
16,625 |
13,497 |
$1,541,907 |
|
| RIN Generators (Renewable Fuel Producers) |
16,430 |
8,319 |
$1,066,251 |
|
| Biointermediate Importer |
4,080 |
5,295 |
$1,127,625 |
|
| Third Parties |
10 |
760 |
$186,200 |
* Third parties are counted as respondents, but their responses/hours/$ are assigned |
| GRAND TOTAL |
37,145 |
27,871 |
$3,921,983 |
to the party for whom they do the work. (Purchased service providers.) |
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The exception is QAP providers, whose burden is shown on this line. |
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| TOTAL NUMBER of Respondents: |
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892.00 |
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| Non-Labor Costs* Only - Used for OMB Inventory: |
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2,062,900.00 |
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| *Non-Labor Costs include capital, O&M, and purchased services. For this collection, all are purchased services. |
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| These costs are reflected in the "OMB Inventory." |
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| Burden Calculations |
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| Annual Burden |
Annual Time Burden (hrs) |
Annual Non-Labor Cost ($) |
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| Reporting |
18,251.00 |
965,300.00 |
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| Recordkeeping |
9,620.00 |
1,097,600.00 |
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| Third-Party Disclosure |
- |
- |
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| Total |
27,871.00 |
2,062,900.00 |
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| Annual Respondent Burden and Cost by Type of Party |
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| Table 1 -Biointermediate Producers* - |
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| Information Collection Activity |
Hours and Cost |
Total Hours and Cost |
Forms & Notes |
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| Citation |
Activity |
Standard Industry Mix Hours/ Response |
Clerical Only Hours/ Response |
Purchased Services Hours/ Response |
Total Cost/ Response (dollars) |
Number of Respondents |
Number of Responses per party/
year** |
Total Number of Responses per Year |
Total Hours/ Year |
Total Cost/Year (Labor and Non-Labor) |
$ Non-Labor Costs (Purchased Services) |
|
Reporting Activities |
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|
305.00 |
|
8,255.00 |
10,887.00 |
1,365,777.00 |
|
498,085.00 |
| 80.1416 |
Pathways Petition: new renewable fuels/feedstocks by biointermediate producers - assumes two respondents per year and 24 hours total per respondent petition |
14.00 |
- |
10.00 |
3,822.00 |
2.00 |
1.00 |
2.00 |
48.00 |
7,644.00 |
Screening tool at https://www.epa.gov/renewable-fuel-standard-program/renewable-fuel-pathway-screening-tool; actual submission is CBP and sent via CDX. See how to submit a Complete pathway petition at https://www.epa.gov/renewable-fuel-standard-program/how-submit-complete-petition-approved-pathway-renewable-fuel |
4,900.00 |
| 80.1450(b) and 40 CFR 1090.805 |
Registration: Initial registration of new biointermediate producers - company and facility information |
2.00 |
- |
- |
196.00 |
30.00 |
1.00 |
30.00 |
60.00 |
5,880.00 |
OTAQ REG USER GUIDE |
- |
| 80.1450(b) and 40 CFR 1090.805 |
Registration: Initial registration of new biointermediate producers - detailed description of biointermediates and processes from registrant - 12 hours total / 3 years to annualize |
4.00 |
- |
- |
392.00 |
30.00 |
1.00 |
30.00 |
120.00 |
11,760.00 |
OTAQ REG USER GUIDE |
- |
| 80.1450(b) and 40 CFR 1090.805 |
Registration: Initial registration of new biointermediate producers -engineering review - 66 hours total / 3 years to annualize |
- |
- |
22.00 |
5,390.00 |
30.00 |
1.00 |
30.00 |
660.00 |
161,700.00 |
OTAQ REG USER GUIDE - refer to Table IV as well, as these are submitted by third party engineers on behalf of the respondents. |
161,700.00 |
| 80.1450(d) and 40 CFR 1090.805 |
Registration: Update to existing registrations (should be uncommon since these are new registrants, in case of error, change of address) |
2.00 |
- |
1.00 |
441.00 |
3.00 |
1.00 |
3.00 |
9.00 |
1,323.00 |
OTAQ REG USER GUIDE |
735.00 |
| 80.1450(b) and 80 CFR 1090.805 |
Registration: Set up account in CDX - new biointermediate producer registrants |
1.00 |
- |
- |
98.00 |
30.00 |
1.00 |
30.00 |
30.00 |
2,940.00 |
OTAQ REG USER GUIDE |
- |
| 80.1450 and 80 CFR 1090.805, 80.1476, 80.1479 |
Registration: Updates to existing registrations to associate with third party auditor |
0.50 |
- |
- |
49.00 |
30.00 |
1.00 |
30.00 |
15.00 |
1,470.00 |
OTAQ REG USER GUIDE |
- |
| 80.1450 and 80 CFR 1090.805, 80.1476, 80.1479 |
Registration: Updates to existing registrations to associate with QAP provider |
0.50 |
- |
- |
49.00 |
30.00 |
1.00 |
30.00 |
15.00 |
1,470.00 |
OTAQ REG USER GUIDE |
- |
| 80.1451 |
Reporting: RFS0702 quarterly Co-Products reports for biointermediate producers |
1.00 |
- |
- |
98.00 |
30.00 |
4.00 |
120.00 |
120.00 |
11,760.00 |
RFS0702 |
- |
| 80.1451 |
Reporting: quarterly RFS4000 Biointermediate Batch Reporting for biointermediate producers |
5.00 |
- |
- |
490.00 |
30.00 |
4.00 |
120.00 |
600.00 |
58,800.00 |
RFS4000 |
- |
| 80.1453 |
Generating product transfer documents related to biointermediates |
1.00 |
- |
- |
98.00 |
30.00 |
260.00 |
7,800.00 |
7,800.00 |
764,400.00 |
CBP |
- |
| 80.1464 |
Attest Engagements for biointermediate producers - primarily purchased services |
2.00 |
- |
45.00 |
11,221.00 |
30.00 |
1.00 |
30.00 |
1,410.00 |
336,630.00 |
Refer to Table IV - Third Parties as well - these are submitted by a third party auditors on behalf of these respondents; how to report attest engagements within system information is here:https://www.epa.gov/fuels-registration-reporting-and-compliance-help/how-submit-attest-engagements |
330,750.00 |
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Recordkeeping Activities |
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105.00 |
|
8,370.00 |
2,610.00 |
176,130.00 |
|
- |
| 80.1453 |
Initial programming of new PTD statements 12 hours total / 3 years to annualize cost |
4.00 |
- |
- |
392.00 |
30.00 |
1.00 |
30.00 |
120.00 |
11,760.00 |
CBP |
- |
| 80.1453 |
Retention of PTDs |
- |
0.25 |
- |
17.75 |
30.00 |
260.00 |
7,800.00 |
1,950.00 |
138,450.00 |
CBP |
- |
| 80.1454 |
General recordkeeping related to biointermediate production and transfers |
- |
1.00 |
- |
71.00 |
30.00 |
12.00 |
360.00 |
360.00 |
25,560.00 |
CBP |
- |
| 80.1478 |
Additional requirements for foreign biointermediate producers, including signed commitments/affirmations |
- |
1.00 |
- |
2.00 |
15.00 |
12.00 |
180.00 |
180.00 |
360.00 |
OTAQ REG USER GUIDE for submission of registration material and CBP |
- |
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| GRAND TOTAL |
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|
410.00 |
|
16,625.00 |
13,497.00 |
1,541,907.00 |
|
498,085.00 |
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| Notes to the Table: |
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*This assumes 30 biointermediate producers, of which 15 are domestic and 15 foreign; and six total pathways petitioners, TOTAL, during the three-year period of this ICR. |
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Hourly burden is divided by three, where appropriate, in order to get annual burden. |
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The final rule ICR greatly overestimated the number of biointermediate producers, because the universe was so difficult to know. During the first three years of this |
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collection, fewer than 10 parties registered as biointermediate producers; far below the then-estimated universe of 240 (200 domestic, 40 foreign). |
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Given that we now have actual registration information and experience with this program, we have adjusted the number to be in line with the known universe and projected growth from it. |
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This renewal anticipates the possibility of additional pathways that may be approved and, with them, an increase in registrants as biointermediate producers. |
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** Assumes 260 days for daily R&R activities. |
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| User Guides, pathways screening tool remain unchanged from those submitted with OMB Control Number 2060-0725. |
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| Annual Respondent Burden and Cost by Type of Party |
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| Table 2 - RIN Generators - Renewable Fuels Producers that Use Biontermediates to Produce Renewable Fuel * |
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| Information Collection Activity |
Hours and Cost |
Total Hours and Cost |
Forms & Notes |
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| Citation |
Activity |
Standard Industry Mix Hours/ Response |
Clerical Only Hours/ Response |
Purchased Services Hours/ Response |
Total Cost/ Response (dollars) |
Number of Respondents |
Number of Responses per party/year** |
Total Number of Responses per Year |
Total Hours/ Year |
Total Cost/Year |
$ Non-Labor Costs - Purchased Services |
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Reporting Activities |
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|
199.00 |
|
8,095.00 |
6,764.00 |
954,226.00 |
|
320,215.00 |
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| 80.1449 |
RFS0902 - Annual Production Outlook Report - form amended to clarify biointermediates, but effort unchanged and number of responses unchanged (accounted for in 2060-0725) |
- |
- |
- |
- |
15.00 |
- |
- |
- |
- |
RFS0902 |
- |
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| 80.1450(b) and 40 CFR 1090.805 |
Registration: Initial registration or update for renewable fuels producers - company and facility information |
2.00 |
- |
- |
196.00 |
15.00 |
1.00 |
15.00 |
30.00 |
2,940.00 |
OTAQ REG USER GUIDE |
- |
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| 80.1450(b) |
Registration: Initial registration or update to detailed description of renewable fuels processes using biointermediates from registrant - 12 hours total / 3 years to annualize |
4.00 |
- |
- |
392.00 |
15.00 |
1.00 |
15.00 |
60.00 |
5,880.00 |
OTAQ REG USER GUIDE |
- |
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| 80.1450(b) |
Registration: Initial registration or update for renewable fuels producers using biointermediates -engineering review - 66 hours total / 3 years to annualize |
- |
- |
22.00 |
5,390.00 |
15.00 |
1.00 |
15.00 |
330.00 |
80,850.00 |
OTAQ REG USER GUIDE |
80,850.00 |
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| 80.1450(d) |
Registration: Update to existing registrations (should be uncommon since these are new registrants, in case of error, change of address) |
2.00 |
- |
1.00 |
441.00 |
2.00 |
1.00 |
2.00 |
6.00 |
882.00 |
OTAQ REG USER GUIDE |
490.00 |
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| 80.1450(b) and 80 CFR 1090.805 |
Registration: Set up account in CDX - 40 new registrants only |
1.00 |
- |
- |
98.00 |
15.00 |
1.00 |
15.00 |
15.00 |
1,470.00 |
OTAQ REG USER GUIDE |
- |
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| 80.1450 and 80 CFR 1090.805 |
Registration: Updates to existing and new registrations to associate with third party auditor |
0.50 |
- |
- |
49.00 |
15.00 |
1.00 |
15.00 |
7.50 |
735.00 |
OTAQ REG USER GUIDE |
- |
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| 80.1450 and 80 CFR 1090.805 |
Registration: Updates to existing and new registrations to associate with QAP provider |
0.50 |
- |
- |
49.00 |
15.00 |
1.00 |
15.00 |
7.50 |
735.00 |
OTAQ REG USER GUIDE |
- |
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| §80.1451(b) |
Reporting: Quarterly RFS Activity Report (4x/yr.) - burden for 2 new respondents (existing respondents already fill out) |
1.00 |
- |
- |
98.00 |
2.00 |
4.00 |
8.00 |
8.00 |
784.00 |
RFS0107 |
- |
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| §80.1451(b) |
Reporting: Quarterly RFS Renewable Fuel Producer Supplemental Report (4x/year, as needed); producers only - burden for new respondents (existing respondents already fill out) |
0.50 |
- |
- |
49.00 |
15.00 |
4.00 |
60.00 |
30.00 |
2,940.00 |
RFS0602 |
- |
|
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| §80.1451(b) |
Reporting: Quarterly Co-Products Report (4x/year) - burden for new respondents (existing respondents already fill out) |
1.00 |
- |
- |
98.00 |
15.00 |
4.00 |
60.00 |
60.00 |
5,880.00 |
RFS0702 |
- |
|
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| §80.1451(b) |
Reporting: Quarterly Renewable Biomass Report (4x/year) - burden for new respondents (existing respondents already fill out) |
4.00 |
- |
15.00 |
4,067.00 |
15.00 |
4.00 |
60.00 |
1,140.00 |
244,020.00 |
RFS0801 |
55,125.00 |
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| 80.1452 |
Reporting: EMTS transactions |
1.00 |
- |
- |
98.00 |
15.00 |
260.00 |
3,900.00 |
3,900.00 |
382,200.00 |
EMTS Renewable Fuels Standard User's Guide |
- |
|
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| 80.1453 |
Reporting: Generated product transfer documents related to biointermediates (a)(11)(v) |
0.10 |
- |
- |
9.80 |
15.00 |
260.00 |
3,900.00 |
390.00 |
38,220.00 |
CBP |
- |
|
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| 80.1464 |
Attest Engagements for renewable fuel producers who use biointermediates |
2.00 |
- |
50.00 |
12,446.00 |
15.00 |
1.00 |
15.00 |
780.00 |
186,690.00 |
Refer to Table IV - Third Parties as well - these are submitted by a third party auditors on behalf of these respondents; how to report attest engagements within system information is here:https://www.epa.gov/fuels-registration-reporting-and-compliance-help/how-submit-attest-engagements |
183,750.00 |
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Recordkeeping Activities |
|
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|
47.00 |
|
8,335.00 |
1,555.00 |
112,025.00 |
|
- |
|
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| 80.1453 |
Initial programming of new PTD statements |
4.00 |
- |
- |
392.00 |
15.00 |
1.00 |
15.00 |
60.00 |
5,880.00 |
CBP |
- |
|
|
|
| 80.1453 |
Retention of biointermediate PTDs** |
- |
0.25 |
- |
17.75 |
15.00 |
260.00 |
3,900.00 |
975.00 |
69,225.00 |
CBP |
- |
|
|
|
| 80.1453 |
Retention of general PTDs (2 new respondents) (existing respondents already do this)** |
- |
0.25 |
- |
17.75 |
2.00 |
260.00 |
520.00 |
130.00 |
9,230.00 |
CBP |
- |
|
|
|
| 80.1454 |
General recordkeeping related to RF production and transfers (15 new respondents) (existing respondents already do this)** |
- |
0.10 |
- |
7.10 |
15.00 |
260.00 |
3,900.00 |
390.00 |
27,690.00 |
CBP |
- |
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| GRAND TOTAL |
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|
246.00 |
|
16,430.00 |
8,319.00 |
1,066,251.00 |
|
320,215.00 |
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* Assumes 15 RIN Generators, who are renewable fuels producers, during the three year period of this ICR. Of this total, |
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This is fewer than the 90 respondents estimated with the final rule. In fact fewer than 10 have participated in the first three years of this collection. |
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Hourly burden is divided by three, where appropriate, to get annual burden. |
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** Assumes 260 business days for daily R&R activities. |
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| User Guides and pathways screening tool remain unchanged from those submitted with OMB Control Number 2060-0725. |
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| Annual Respondent Burden and Cost by Type of Party |
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| Table III - Recordkeeping by Biontermediate Importers* |
|
| Information Collection Activity |
Hours and Cost |
Total Hours and Cost |
Forms & Notes |
|
| Citation |
Activity |
Standard Industry Mix Hours/ Response |
Clerical Only Hours/ Response |
Purchased Services Hours/ Response |
Total Cost/ Response (dollars) |
Number of Respondents |
Number of Responses per party/year** |
Total Number of Responses per Year |
Total Hours/ Year |
Total Cost/Year |
$ Non-Labor Costs - Purchased Services |
|
Reporting Activity |
|
|
|
|
- |
|
- |
- |
- |
|
- |
| None. |
None for these respondents. |
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|
Recordkeeping Activity |
|
|
|
|
30.00 |
|
4,080.00 |
5,295.00 |
1,127,625.00 |
|
1,058,400.00 |
| 80.1453 |
Retain product transfer documents from biointermediate producer |
- |
0.25 |
- |
17.75 |
15.00 |
260.00 |
3,900.00 |
975.00 |
69,225.00 |
CBP |
- |
| 80.1478 |
Acquire independent volume certification, retain and give to RF producer and biointermediate producer - assume two instances per month, all purchased service |
- |
- |
24.00 |
5,880.00 |
15.00 |
12.00 |
180.00 |
4,320.00 |
1,058,400.00 |
CBP |
1,058,400.00 |
| GRAND TOTAL |
|
|
|
|
30.00 |
|
4,080.00 |
5,295.00 |
1,127,625.00 |
|
1,058,400.00 |
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| Notes to the Table: |
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| * Assumes 15 existing importers who will import biointermediates. |
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| ** Assumes 260 business days in a year. |
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| Annual Respondent Burden and Cost by Type of Party |
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| Table 4 - QAP Providers & Other Third Parties: assumes 20 Auditors, 10 Third Party Engineers and Two (2) QAP Providers, for a total of 32 Third Parties |
|
| Information Collection Activity |
Hours and Cost |
Total Hours and Cost |
Forms & Notes |
|
| Citation |
Activity |
Standard Industry Mix Hours/ Response |
Clerical Only Hours/ Response |
Purchased Services Hours/ Response |
Total Cost/ Response (dollars) |
Number of Respondents |
Number of Responses per party/year |
Total Number of Responses per Year |
Total Hours/ Year |
Total Cost/Year |
$ Non-Labor Only Portion of Column K - All Purchased Services for this Table |
|
Reporting Activities |
|
|
|
|
112.00 |
|
8.00 |
600.00 |
147,000.00 |
|
147,000.00 |
| 80.1450 and subpart I of 40 CFR part 1090 |
Overhead, basic information - new registrants - assumes most already registered; cost of registration is borne by primary party as part of the purchase of services - all third parties - cost and hours attributed to parties on Tables I & II |
- |
- |
- |
- |
32.00 |
- |
- |
- |
- |
OTAQ REG USER GUIDE; cost attributed to party who pays for service in Tables I-III |
- |
| 80.1450 and subpart I of 40 CFR part 1090 |
Set up account in CDX, EMTS - new registrants only, assumes 10% of total new |
- |
- |
- |
- |
3.00 |
- |
- |
- |
- |
OTAQ REG USER GUIDE; cost attributed to party who pays for service in Tables I-II |
- |
| 80.1450(b) and 40 CFR 1090.805 |
Registration: Initial registration of new biointermediate producers -engineering review - submitted on behalf of respondents on Tables I and II - costs and hours attributed to parties on Tables I & II |
- |
- |
- |
- |
30.00 |
- |
- |
- |
- |
OTAQ REG USER GUIDE; cost attributed to party who pays for service in Tables I-II |
- |
| 80.1464 and Subpart S of 40 CFR part 1090 |
Reporting: perform and submit attest engagement on behalf of clients - submitted on behalf of respondents on Tables I and II - costs and hours are attributed to parties on Tables I & II |
- |
- |
- |
- |
45.00 |
- |
- |
- |
- |
ATT0102 and "free form report" (CBP); cost attributed to party who pays for service in Tables I-II |
- |
| 80.1451(g) |
Reporting: perform QAP function on behalf of clients; reporting burden for biointermediates |
- |
- |
75.00 |
18,375.00 |
2.00 |
4.00 |
8.00 |
600.00 |
147,000.00 |
QAP forms 2001, 2101, 2201, 2301, 2400 - submitted by QAP providers on behalf of parties listed in Tables I-II, but collection burden is appropriately assigned to QAP provider |
147,000.00 |
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|
Recordkeeping Activities |
|
|
|
|
94.00 |
|
2.00 |
160.00 |
39,200.00 |
|
39,200.00 |
| 80.1454 |
Retain records related to registration and engineering review - costs and hours are attributed to parties on Tables I & II |
- |
- |
- |
- |
45.00 |
- |
- |
- |
- |
CBP; cost attributed to party wh opays for services in Tables I-II |
- |
| 80.1464 |
Retain records related to attest engagement - costs and hours are attributed to parties on Tables I & II |
- |
- |
- |
- |
45.00 |
- |
- |
- |
- |
CBP; cost attributed to party wh opays for services in Tables I-II |
- |
| 80.1469 |
Retain records related to QAP - costs and hours are attributed to parties on Tables I & II |
- |
- |
80.00 |
19,600.00 |
2.00 |
1.00 |
2.00 |
160.00 |
39,200.00 |
CBP; QAP providers on behalf of parties listed in Tables I-II, but burden assigned to QAP provider |
39,200.00 |
| 80.1478 |
Independent third parties who do volume certification for biointermediate importer - costs and hours attributed to parties on Table III |
- |
- |
- |
- |
2.00 |
- |
- |
- |
- |
CBP; cost attributed to party who pays for services in Table III |
- |
| GRAND TOTAL |
|
|
|
|
206.00 |
|
10.00 |
760.00 |
186,200.00 |
|
186,200.00 |
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| Notes to the Table: |
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| Only QAP providers have an hourly and dollar amount assigned, because they are regulated parties with reporting duties. |
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| For other third parties, the hourly and dollar amount is assigned to the party for whom they perform the service and whom they bill for such services. |
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| Labor Costs |
| Labor Type |
Labor Cost/hour |
Labor + Overhead/ houra |
Portion attributed/hour |
Employer Cost/hour |
| Managerial (CEO - 11-1011) |
124.47 |
249 |
0.05 |
12.45 |
| Professional/Technical (Refinery Operators - 51-8093) |
44.35 |
89 |
0.7 |
62.3 |
| Clerical (Administrative Assistants 43-6010) |
35.42 |
71 |
0.2 |
14.2 |
| Legal (Lawyer 23-1011) |
84.84 |
170 |
0.05 |
8.5 |
| Total Employer Cost/hour |
98 |
| Purchased Servicesb |
245 |
| a Overhead is calculated to be equal to the cost of labor. |
| b The cost of purchased services (for example, cost of attest auditors) is calculated at 2.5 times the Total Employer Cost. |
| (we had use 2.0 previously, but increased the factor to 2.5 times the total employer cost in response to industry feedback on similar ICRs) |
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| For these estimates, the most recently available Bureau of Labor Statistics, May 2023 figures, were used as follows: |
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| For CEOs, mean compensation of 124.47 was used; see: https://www.bls.gov/oes/current/oes111011.htm (accessed 2.25.2025). |
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| For professional/technical, compesation of 44.35, using entry for Petroleum and Coal Product Manufacturing, see: https://www.bls.gov/oes/current/oes518093.htm (accessed 2.25.2025). |
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| For clerical, mean compensation of 35.42 was used, see: https://www.bls.gov/oes/current/oes436011.htm (accessed 2.25.2025). |
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| For legal, mean compensation of 84.84 was used, see https://www.bls.gov/oes/current/oes231011.htm (accessed 2.25.2025). |
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