DRAFT Supporting Statement for In formation Collection Request Motor Vehicle Emissions: Revisions to Certification of Alternative Fuels Conversions

EPA I CR 0783. 5 5 April 2010

C ompliance and Innovative Strategies Division Office of Transportation and Air Quality Office of Air and Radiation U.S. Environmental Protection Agency2 Part A SUBMISSION Section 1: Identification Of T he I nformation Collection 1(a) Title A nd Number Of T he Information Collect ion Motor Vehicle Emissions: R evisions to Certification of Alternative Fuels Conversions ; EPA IC R number 0783. 5 5 , OMB control number 2060
- 0 104. 1(b) Short Characterization/Abstract The Environmental Protection Agency is proposing changes designed to simplify and lessen the burdens f or manufacturers seeking approval to introduce into commerce in the U.S. light
- dut y vehicles , light
- dut y trucks , medium
- duty passenger vehicles, and heavy
dutyvehicles and engines that have been converted for use of fuels that the original models were not designed for, such as from gasoline to liquid propane gas (LPG) or compressed natural gas (CNG)
. This ICR covers the light
- dutyportion of the proposal. Th ese applications are currently administrativelyhandled as a part of EPA’s motor vehicle and engine certification program, covered bythe I CR 0783 series. This ICR addresses the anticipated paperwork burden reduction of the proposal within the context of the existing baseline from OMB 2060 - 0104 (ICR 0783.54) , which was approved on August 31, 2009. The se changes would start taking effect with 20 1 1 model y ear light
- duty vehicles and trucks or upon the effective date of the final rule
. Starting then , manufacturers will be given expanded options for submitting simplified applications. IC Rs normallyhave a three year time horizon. T his ICR w ill cover the expected paperwork burden changes for the three y ears after the effective date of the final rule
. In formation collected under the existing alternative fuels conversion program consists of t est results an d related submissions under existi ng procedures for the EPA light
dutyvehicle certification program. A ll information from converter applicants is currently submitted electronically directly to the V erify sy stem. Subject to confidentialityclaims, this i nformation is made available to interested parties upon request. E mission test i nformation is available on the i nternet. The burden analy sis in this ICR differs from the cost analy sis in the preamble to the proposed rule in important respects. First, IC Rs are concerned with paperwork burdens , a subset of all business costs : this IC R covers the costs and labor hours of providing information to EPA, including both the paperwork itself and the costs and labor to develop the information, such as testing to p rovide test results, and facilities to carryout that testing. It is not concerned with the costs of compliance in general, nor with general business overhead or profits. The preamble, on the other hand, focuses on costs incurred in developing conversions that complywith the Clean Air Act and subsequent certification applications through contracts byconverters with testing companies , which include overhead and profit elements not counted in the 0783 series
. The analysis in this ICR uses the traditional c apital cost, O&M cost, and labor cost assumptions in this ICR series, so3

that, for example, facilitycosts that would be recovered as part of a consulting firm's contract are here allocated to capital costs. Second, the preamble focuses on the burden for a single converter enterprise of interest ( and generalizes this to four such enterprises ) . This IC R attempts to generalize the analy sis to the industryas a whole
. Third, the ICR does not cover development costs associated with compliance with the Clean Air Act, but onlythe paperwork
- related costs once such a conversion has been achieved to the point where the converter submits an application for certification. The existing baseline estimates that certification applications for 36 test groups from five converter respondents are submitted annually
. The most recent model y ear data available (model y ear 2008) shows 18 light
- duty vehicle conversions. This ICR adjusts the baseline to 18 conversions and calculates industry savings against that number. The anal ys is also gives the change in the 0783 ICR overall collection
. T hese test groups consist of conversion kits that apply to a specific certified OEM (original equipment manufacturer) vehicle engine family , or in some cases group of families . As with OEM c ertifications, the biggest paperwork cost component for converters is testing. However, estimating testing costs under the existing regulations has been difficult because the alt. fuel converter program encompasses a diverse range of circumstances. Manyof the tests are currently waived in certain situations. For example, currently , evaporative testing mayor maynot be waived depending on whether a closed fuel sy stem is used. Exhaust and evaporative emission testing can be waived for dual
fueled gasoline/L PG or gasoline/CNG vehicles if the modification doesn’t increase the weight more than 500 pounds and no increase in emissions is expected. (Assumptions for dealing with these complexities both in the existing program and under the proposal are discussed in Section 6.) The current baseline applied to 18 test groups estimates an industrytotal paperwork cost of $ 137,856 . As with the main light
- duty program, this does not include development costs (such as repeated testing needed to perfect a conversion kit that can meet emission and OBD standards ), which are not directly mandated bythe Clean Air Act but which can be considerable
. Other elements of the alt. fuels certification process covered bythis I CR are listed in Part 4 below , including paperwork filin g burdens, which are budgeted in the IC R as O&M costs and labor hours
. Converted vehicles are also, as with other certified vehicles, subject to EPA 's confirmatorytesting program , durabilitydemonstration, Vehicle Emission Control Information (VECI) label ing, defect and voluntaryemission recall reporting, and other light
- dutyrequirements ( all covered in ICR 0783)
. In addition, theyare subject to EPA’s certification fee requirements (ICR2080; OMB 2060
- 0545) but burden changes in th is program is de minimi s (the number of fee forms affected is small and will be reflected in the next fees ICR renewal)
. All burden elements in this ICR are in the Emissions (Certification) IC . The proposed changes will recognize three classes of conversions: to (1) vehicles that are new or relatively new, (2) vehicles within EPA’s definition of useful life but which are neither new nor relativelynew (“intermediate life vehicles”), and (3) vehicles that are outside EPA’s definition of useful life. For the newest vehicles , ce rtification will still be4

required, but with some additional flexibilities and expansion of options. Conversion of intermediate life vehicles will be not be certified but audited through reporting of a simplified testing demonstration that the converted v ehicle famil y still meets emissions standards certified for the OEM vehicle famil y . For conversion of outside useful life vehicles EPA intends to finalize a single demonstration requirement but is seeking comment on three options
. Beginning in model y ea r 20 11 or the effective date of these regulations, t he proposed changes will reduce total costs annua llyon the regulated manufacturers by $ 50,667 in non
- labor costs and 7,073 labor hours. Additional details on the coverage of this ICR are given in Sect ion 2 (b), below. Section 2: Need For A nd Use of the Collection 2(a) Need/Authority For T he Collection Unde r Title II of the Clean Air Act (42 U.S.C. 7521 et seq.), EPA is charged with issuing certificates of conformityfor motor vehicle designs that compl y with applicable emission standards set under section 202(a)(1) of the Act
. A manufacturer must have a certificate before vehicles maybe legallyintroduced into commerce. To i nsure compliance with the Act , EPA reviews product information and manuf acturer test results; EPA also tests some vehicles to confirm manufacturer results. Section 203 of the Clean Air Act contains “anti
- tampering” provisions prohibiting alteration of OEM vehicle components relevant to the vehicle’s certification under the Act. Regulations at 40 CFR, Part 85, Subpart F , provide exemption for aftermarket conversion sy stems from these tampering prohibitions for those converters complying with the regulations of that Part. Under Subpart F, these exemptions are currently admin istered through a certification process that is modeled on the OEM certification provisions: converters submit certification requests for engine families, and those that satisfyEPA’s regulations upon review are granted certificates of conformityfor one m odel y ear. 2(b) Practical Utility

/Users of the Data The information collection under the rule would be used to determine whether the new requirements have been complied with bymeans of the revised ce rtification and compliance program . Section 3: Non duplication, Consultations, and Other Collection Criteria 3 (a) Nonduplication The information collection, reporting, and storage provisions of the proposed rule relyto the maximum extent possible on EPA’s existing certification program , while simplify ing that program to reflect the needs of this industry
.5

Efforts have been made to eliminate duplication in this information collection. EPA - CI SD (Compliance and Innovative Strategies Division) is currentlyusing , for light
dutyvehicles , a new inform ation management system (Verify ) , under which the manufacturer submission process will occur within a Central Data Exchange (CDX) environment that should further help minimize duplication in submissions
. Because of its specialized nature and the fact th at product plans and emission performance information must be submitted to EPA prior to the start of production, this information is not available from anysource other than the manufacturer. 3(b) Public Notice Prior to ICR Submission to OMB EPA solici ted public comment by means of a Federal Register Notice published on

____ , 2010 ,

__ Federal Register

___ ; a cop y can be found at _____________ . The draft ICR was placed in the docket. 3 (c) Consultations The proposed regulations, including the cost a naly sis that is reflected in this ICR, were developed based on experience with similar regulations developed in the past in close consultation with the affected industry
. In designing this proposal EPA sought and received significant input and feedback fr om the fuel conversion community
. In preparing th e proposed rule , EPA made use of consult ations with several converters and an independent test lab working in the regulated industry: Their comments have been considered in developing the burden estim ates discussed below. EPA wishes to thank them and their colleagues for their assistance in preparing this report. 3(d) Effects of Less Frequent Collection A s required bythe Clean Air Act (42 USC 7525(a)), emission information is currently submitted on a y earlybasis coinciding with the manufacturer ’ s “ model y ear. ” EPA allows applicants to define their own “ model y ear ” , thus granting some flexibility in this regard. Major product changes typicallyoccur at the start of a model y ear. For these reasons, a collection frequencylonger than a model y ear is not possible normallypossible
. However, this rule would replace the annual application and compliance process with a one - time submittal for intermediate and outside useful life vehicles. Furthermore , fo r new and relativelynew vehicles, when a vehicle design is “ carried over ” to a subsequent model year, the amount of new information required is substantiallyreduced. 3 (e) General Guidelines Manufacturers are required to keep some records for periods longer than three y ears6

This requirement stems from the statutoryrequirement that manufacturer s warrant some items for periods longer than 3 y ears. This information collection activitycomplies with the remaining guidelines in 5 CFR 1320.5 . The propo sal makes no changes in the reporting and recordkeeping provisions that impact anyof the guidelines for information collections as approved in the ex isting approved collection. 3 (f) Confidentiality In formation submitted bymanufacturers is held as conf idential until the specific vehicle to which it pertains is available for purchase. After vehicles are available, most information associated with the manufacturer/importer ’ s application is available to the public. Under section 208 of the Clean Air Act (42 USC 7542 (c) ) all information, other than trade secret processes or methods, must be publicly available. P roprietaryinformation is granted confidentiality in accordance with the Freedom of Information Act, EPA regulations at 40 CFR Part 2, and class d eterminations issued byEPA ’ s Office of General Counsel. 3(g) Sensitive Questions No sensitive questions are asked in this information collection. This collection complies with the PrivacyAct and OMB Circular A
- 1 08. Section 4: Respondents and Informa tion Requested 4(a) Respondents/ NA SIC Codes The respondents are potentially involved in the industries shown in the following table: Industry 335312 A

336312 336322 336399 454312 485310 Alternative fuel vehicle converters

A North American Industry Clas sification Sy stem (NAICS) 4 (b) Information Requested (i) Data items The information and reporting burden associated with this rule occurs within the context of EPA’s motor vehicle certification and compliance program. Current regulations7

require conv erters to submit emissions information to EPA in conjunction with this program. Converters of newer vehicles must submit an application for emission certification prior to production. In termediately aged vehicle converters will submit a simplified testin g demonstration without the burdens of the formal certification application process. For vehicles converted outside their useful life , regulation will be through an information submission that the conversion is technicallyviable and will not increase emis sions. The se reporting formats describe the major aspects of the proposed product line, technical details of the emission control systems, and the results of anyrequired tests to indicate compliance with the emissions limitations. The reports and suppor ting test results are reviewed and, if appropriate, a certificate of conformityis issued , the applicant is notified of possible noncompliance with anti
- tampering provisions, or additional post
production information is requested
. New /revised data item s: At the time of certification: For all vehicles :

 ex panded conversion test or " demonstration " groups  ex emption from HCHO testing for conversions to CNG and LP G  conversion factors for calculating NMOG for conversions to CNG and LPG  new VECI label requirement describin g test group, mileage, and date For intermediate
- age and outside useful
- life age vehicles (25%)

 online notification and test result report rather than application for certification (savings in “paperwork” burden) or compliance “demon stration” for outside useful
- life conversions  description of OBD compliance strategyor OBD demonstration rather than current OBD test results (ii) Respondent Activities While there is no “ typical ” converter respondent, all converters must describe the ir product and supplytest data and other information to verifycompliance. In some cases the proposal would replace the current application and certification process with a notification and audit process. Applicants for certification submit certification fees, usually“reduced fees” set at 1% of the estimated retail sales value of the conversion package, including labor. Converters or installers of conversion kits must install a second VECI label on converted vehicles. Converters must also retain records. These tasks a re repeated for each model y ear, although ty picallyprevious data and information can be “ carried over ” when no significant changes have occurred. Sectio n 5: The Information Collected

— Agency

Activities, Collection Methodology , and I nformat ion Management8

5(a) AgencyActivities The test data used byEPA to determine compliance with emissions standards are derived from vehicle testing done byvehicle converters who report their own test data to EPA , and at EPA's National Vehicle and Fuel Emissio ns Labora toryin Ann Arbor, Michigan
. EPA staff review applications (or notifications or demonstrations), issue certificates, and oversee the program. 5(b) Collection Methodology and Management A ll information from converter applicants will be submi tted electronicallydirectly to the V erify sy stem by the effective date of the new rule
. Byguidance letter CISD
- 09 - 14, vehicle converters are required to submit applications for certification through Verify beginning with the 2010 model y ear. The rule ma kes no changes in this reporting sy stem , onlychanging the format and content of some of the information reported within it
. All information received byEPA is subject to review
. D ata submitted are screened to determine that the test results insure com pliance with emission and fuel economy standards. Narrative descriptions of the proposed product line are checked to verifythat the appropriate "worst case" vehicles have been tested
. Ex cept for projected sales and a verylimited amount of proprietarypr oduct information , all information is available to the public as soon as the vehicle is offered for sale. Emission d ata are available on the internet; other information is available upon request under the Freedom of Information Act
. 5 (c) Small Entity

Fle xibility Converters alreadyenjoy various exemptions and special provisions tailored to their small entitystatus and special business needs in contrast to original vehicle manufacturers, such as use of assigned deterioration factors , exemption from the manufacturers’ in
- use vehicle testing program (IUVP) and availability of reduced certification fees. This proposal further extends this flexibilityin numerous ways detailed in the proposal and summarized in this Supporting Statement. 5(d) Collection S chedule Currently , i nformation must be submitted for each “ model y ear ” that a manufacturer intends to convert vehicles. Under the proposal, onlythe newest vehicles will be required to renew annually , but all categories will file an end
- of
- ye ar report (a s do light
- duty manufacturers). For emissions purposes, a “ model y ear ” is statutorilydefined as the annual production period of a manufacturer, as decided bythe Administrator, that includes January 1 of that calendar y ear; or that calendar y ear if the m anufacturer does not have an annual production period. If a product is unchanged between model y ears, much of the information can be “ carried over. ” The collection frequencyand burden are determined to a large extent bythe manufacturer ’ s marketing and product ion plans.9

Section 6: Estimating the Burden and Cost of the Collection The following estimates of reduced burden use baselines and methodologies developed in the process of continuing updates of the 0783 ICR series, including the last renewal (I CR 0783. 54 ), and the proposed greenhouse gasses rule (ICR 0783.56). The reasoning behind estimates of decreased burden from the current baseline are given below and summarized in Section 6(f). 6(a) Estimating Respondent Burden (Hours) As noted above, the number of converter test groups covered by the I CR is subject to small number fluctuations. The baseline in the last renewal (ICR 0783.54) was 36 test groups; in the renewal three y ears before that (ICR 0783.47) it was 15. Following normal practice, th e baseline is here adjusted to reflect the most current information available; we count 18 light
- duty conversion test groups for Model Year 2008. The Emissions IC will reflect this adjustment. The discussions below compare the burdens on 18 families before and after the proposal. Within the converter program under the adjusted baseline, t he respondent hours burden decrease for the Li ght
- DutyVehicle Emissions In formation Collection reflects reduced labor hours associated with conducting tests and reduced reporting. This is largely due to the broader definition of test groups, since this definition determines how many tests must be conducted. The paperwork reporting burdens in particular are significantly reduced for intermediate and out of useful life con versions. As converters are a very small subset of the current light
- dut y baseline (currently 18 out of 427 test groups/engine families), the decrease in burden is correspondinglysmall; but for vehicle converters the hour savings are significant (from 1 4, 869 hours down to 7,796 hours, a savings of over 4 0%). In particular, the number of test groups requiring any reporting under this rule is estimated to be reduced by25 percent. This correspondingly reduces the labor hours associated with conducting emi ssions tests (including preparation costs, FTP tests, NMOG tests and HFET tests), OBD compliance reporting , confirmatorytesting costs (including shipment costs), and paperwork reporting and recordkeeping costs associated with preparing this information in an y of the required form ats and submitting it to EPA for review and saving it for possible submission to EPA upon request. In termediate and bey ond useful life conversion test groups are estimated to achieve an additional 80 percent reduction in paperwork reporting for those qualify ing
. The ICR includes a minor startup cost for implementing new labeling requirements. All labor hours associated with startup costs are treated as capital/startup costs, so they are inc lu ded under that heading, following EPA guidance (EPA ICR Handbook, Rev. 11/05, p. A
31). 6(b) Estimating Respondent Costs (i) Estimating labor costs10

Labor costs for testing follow the testing labor cost assumptions of I CR 0783. 54 and average out to $5 9.07 per hour across management, technical , and secretarial categories
. This figure, which was initiallybased on the fees rule cost study of EPA laboratoryexpenses, matches verycloselywith an analy sis based on r ates for engineering managers, mechanical engineers, and secretaries (except legal, medical, and executive) from the May 2005 BLS National Industry
- Specific Occupational Employ ment and Wage Estimates (http://www.bls.gov/oes/current/naics4_336100.htm , accessed August 22, 2006). With a 160% overhead multiplier, these are $81.38, $49.71, and $33.57, respectivel y . The labor cost anal ys is may be updated for the final I CR. (ii) Estimating Capital and Operations and Maintenance Costs Operation and Maintenance costs are the non
- labor costs associated with conducting the new tests that are an ticipated for the full model y ear after the effective date of the new regulations
. The O&M costs for conducting emissions tests follow the assumptions in prior IC Rs in this series, with an improved figure for NMOG and HCHO analysis, totaling about $4,000 per vehicle, with another $3,600 for OBD compliance and $2,000 for each confirmatorytest. The estimate also includes O&M items for evaporative emissions testing, a nd reporting and recordkeeping , with the baseline total coming to about $10,000 per activity (test group). Applied to the industry , the baseline O&M cost is $121,541 annually
. The proposal reduces this figure by $44, 650 , down to $7 6,891 . This is primarily due to 1) reduction in the number of test groups by25%; and 2) savings of $1,750 in NMOG a nd HCHO testing per test group. (iii) Start - up Costs “Startup” costs are one - time costs to implement the new requirements in the proposal that are applicable to the next model y ear conversions being certified or by the respondent converters after the effective date of the final rule
. These startup burdens fall into two categories. First are startup costs to redesign the VECI label
. This burden is an add
- on to well established reporting requirements: manufacturers alread y submit similar label data t o EPA. Once the new label templates are in place, we anticipate no increase in burden for th is startup item
. This part of the estimate costs new analy sis and coding for 18 test groups, reduced to 14 by the new rule
. This is a small item, less than $10,00 0 for the industry , and is annualized and discounted at 7% in the cost estimate. Second are capital costs associated with the t esting requirements. Because manufacturers vary widel y in their existing testing facilities, their excess capacities, their wo rk shift arrangements and availabilities, the real estate cost and land availabilities for hy pothetical expansions, and their contractual arrangements with other testing facilities, CI SD has for many ye ar now used the approximation that a facility capable of performing 750 FTP/HFET tests per ye ar costs $4,000,000 and allocated this cost to each testing increment. This cost is then allocated over ten ye ars and discounted at 7%. This methodology is considered conservative, because it assumes no excess capacit y. Similarly , evaporative facilities are costed at $3,000,000 to conduct 900 evaporative tests a year. While most converters work through contractors whose contract11

costs do not break down costs in this manner, for consistency the analy sis in the Certifica tion IC series is continued here. Primarily due to the reduction in the number of test groups (slightly offset by the new labeling startup) he total non - depreciated capital costs for the conversion program of $114,600 are reduced by

$45,417 to $69,183
. 6(c) Estimating Agency Burden The emission and fuel economycompliance programs are primarilyadministered by EPA’s Compliance and Innovative Strategies Division and LaboratoryOperations Division. Approximately47.5 full time employ ee equivalents a re directlyinvolved in the combined emission and fuel economylight
- duty , motorcycle, and other , secondary programs; their cost is approximately$5.9 million, including benefits but not overhead. EPA also participates in a program whereby the agencycont racts with an organization that provides qualified persons to perform duties for the agencythat are not performed byEPA employ ees. The cost associated with these persons who work directly on these programs is approximately$0.23 million, excluding overh ead. Overhead percentage for the entire division is approximately16.9%, y ielding an estimated total agencylabor cost of $7.17 million. The total non
- capital costs for the light
- dutyand motorcy cle programs, including direct and indirect labor, operatio ns and maintenance, and overhead, is estimated as $11.14 million for FY 2007. Im plementation of the new alternative fuels rule will b e carried out byexisting staff
. Other ongoing database management, oversight, and certification activities are part of the fuel economyand emissions program Agency baseline. All EPA labor estimates are based on Office of Personnel Management draft annual payrates effective January , 200 8 , with a 1.6 multiplier for overhead based on EPA’s latest fees cost allocation study (1.37 indirect program cost overhead times 1.16 overall EPA overhead)
. This estimate does not include Agencyburdens incurred prior to the effective date of the rule, such as costs of developing the rule and preliminary consultations with converters . 6 (d) Estimating the Respondent Universe and Total Burden and Costs From the above discussion the following total burden and cost estimates can be calculated. (Due to the diverse nature of the converter industry , there is no typical or average respondent. ) 6(e) Bottom L ine Burden Hours and Cost (i) Respondent Tall y [a] Overall Emissions I C This analy sis is against the Emissions I C baseline in I CR 0783.54. EPA has another rulemaking underway

(Revisions to Reduce Emissions of Greenhouse Gases; EPA IC R 0783.56)12

which will result in other changes
. [1] Existing authorization RESPONDENTS 35 BURDEN HOURS 362,033 LABOR COST $6,308,800 OPERATI

NG COST $5,929,702 CAPI TALIZED COST $2,256,127 TOTAL NON - LABOR COST $8,185,829 [2] After proposal RESPONDENTS 3 5 BURDEN HOURS 34 0,091 LABOR COST $ 5,054,396 OPERATI

NG COST $ 5,763,511 CAPI TALIZED COST $ 2,2 33,795 TOTAL NON - LABOR COST $ 7,997,306 [3] Reduc tion in b urden BURDEN HOURS - 21,997 LABOR COST - $1,254,404 OPERATI

NG COST - $166,191 CAPI TALIZED COST - $ 22,332 TOTA L NON - LABOR COST - $188,523 [b] Alternative Fuels Converters [1] Existing baseline RESPONDENTS 5 FAMILIES 36 BURDEN HOURS 29,738 LABOR COST $1,756,606 OPERATI

NG COST $243,082 CAPI TALIZED COST $32,63 0 TOTAL NON - LABOR COST $275,71 2 [2] After p roposal RES PONDENTS 5 FAMILIES (75% OF 18) 14 BURDEN HOURS 7,796 LABOR COST $ 502,20213

OPERATI

NG COST $76,891 CAPI TALIZED COST $ 10,298 TOTAL NON - LABOR COST $ 87,189 [3] Reduction in b urden BURDEN HOURS - 21,942 LABOR COST - $1, 254,404 OPERATI

NG COST - $ 166,191 CAPI TALIZE D COST - $ 22,332 TOTAL NON - LABOR COST - $1 88,523 [4] Reduc tion in b urden applied to a hy pothetical pre - proposal 1 8 family baseline BURDEN HOURS - 7,073 LABOR COST - $376,101 OPERATI

NG COST - $44,650 CAPI TALIZED COST - $6, 017 TOTAL NON - LABOR COST - $ 50,667 (ii ) Agency

Tally EMPL OYEES 47.5 CONTRACT L ABOR COST $0.27 million COST $11.1 million 6(f) Reasons for change in burden The burden change is from changes in the baseline number of test groups and reductions in the capital and operations and maintenance c osts and labor hours associated with implementing the new program s detai led in this draft ICR
. 6(g) Burden Statement The table in Section 6(e ) ( i )[b] [2] presents the total estimated burden for the alternative fuels conversion light
- duty program after th e proposed rule: approximately 7,796 hours per ye ar, with total annual capitalized and O&M costs estimated at $ 87,189 . These represent a savings of 21,942 hours and $1 88,523 over the existing alternative fuels light
- dut y baseline. The annual costs and hour s for information collection activities bya given manufacturer under anyof the options in this proposed rule depend upon manufacturer
- specific variables, such as the number of different test groups and the number of vehicles tested. The estimated number of likelyrespondent manufacturers is 5 . The responses will be submitted annually and occasionally as a part of the existing EPA certification program . Burden means the total time, effort, or financial resources expended bypersons to14

generate, maint ain, retain, or disclose or provide information to or for a Federal agency
. This includes the time needed to review instructions; develop, acquire, install, and utilize technologyand sy stems for the purposes of collecting, validating, and verify ing infor mation, processing and maintaining information, and disclosing and providing information; adjust the existing way s to comply with any previouslyapplicable instructions 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 disclose the information. An agency maynot conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currentlyvalid OMB control number. The OMB control numbers for EPA ’ s regulations are listed in 40 CFR Part 9 . To comment on the Agency 's need for this information, the accuracyof the provided burden estimates, and anysuggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this rule, which includes th i s I CR, under Docket ID number EPA
- HQ - OAR - 200 9 - 0299 . Submit anycomments related to the ICR for this proposed rul e to EPA and OMB. Submit y our comments, identified by Docket ID No. EPA
- HQ - OAR - 200 9 - 0299 , by one of the following methods: • www.regulations.gov: Follow the on
- line instructions for submitting comments. • Fax: (202) 566
- 1741. • Mail: Environmen tal Protection Agency , EPA Docket Center (EPA/DC), Air and Radiation Docket, Mail Code 6102T, 1200 Pennsy lvania Avenue, N.W., Washington, DC 20460, Attention Docket ID No. EPA
- HQ - OAR - 200 9 - 0299 . In addition, please mail a copyof y our comments on th e information collection provisions to the Office of Information and Regulatory Affairs, Office of Management and Budget (OMB), Attn: Desk Officer for EPA, 725 7th St. NW., Washington, DC 20503.” • Hand Delivery : Docket Center, (EPA/DC) EPA West , Room B102, 1301 Constitution Ave., NW, Washington, DC., Attention Docket ID No. OAR
200 9 - 0299 . Such deliveries are onlyaccepted during the Docket’s normal hours of operation, and special arrangements should be made for deliveries of boxed i nformation Docket ID No. EPA
- HQ - OAR - 200 9 - 0299 , is available for public viewing at the Air And Radiation Docket in the EPA Docket Center (EPA/DC), EPA West, Room B102, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Cente r Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday , excluding legal holiday s. The telephone number for the Reading Room is (202) 566
- 1744, and the telephone number for the Air and Radiation Docket is also (202) 566
- 1744. An electronic version of the public docket is available through EPA Dockets (EDOCKET) at www.regulations.gov
.