- 1

- S upporting Statement for

Information Collection Request

Notice of Rulemaking 

### Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium

- and Heavy

- Duty Engines and Vehicles
EPA ICR Tracking Number 2394.0 3

Office of Transportation and Air Quality

Office of Air and Radiation U.S. Environmental Protection Agency

and

National Highway Traffic Safety Administration U.S. Department of Transportation- 2

-

1. Identification of the Information Collection

1 (a ) Title and Number of the Information Collection

Control of Greenhouse Gas Emissions and Reduction of Fuel Consumption from New Motor Vehicles: Heavy

- Duty Engine and Vehicle Standard s (Renewal), EPA ICR Number 2394.0 3 , OMB Control Number 2060

- 0678.

1(b) Short Characterization

Th e Environmental Protection Agency (EPA) and the National Highway Traffic Saf et y A dministrat ion (NHTSA) issued standards on September 15, 2011, to address greenhouse gas (GHG) emissions and fuel consumption in

the heavy

- duty (HD) trucking sector

. As a result of these standards, HD engine and HD vehicle manufacturers will be subject to new test ing

, reporting

, and recordkeeping requirements . The paperwork and cost b urdens associated with these requirements are identified in this ICR , which is an extension of a currently approved ICR.

Historically, EPA’s approach to regulating the heavy

- dut y trucking sector has been to set standards t hat reduce emissions from a truck’s engine . The agency’s focus on setting standards that reduc e HD engine e missions is due mostly

to the fact that engine s are primarily responsible for emissions of “criteria po llutants,” including carbon monoxide, nitrogen oxides, ozone, and particulate matter.

On May 21, 2010, the President issued a memorandum calling for the Administrators of NHTSA and EPA to

“ immediately begin work on a joint rulemaking under the Clean Ai r Act (CAA) and the Energy Independence and Security Act of 2007 (EISA) to establish fuel efficiency and greenhouse gas emissions standards for c ommercial

m edium

- and h eavy

- d uty o n

- h ighway v ehicles and w ork t rucks beginning with the 2014 model year (MY).” 1

Addressing GHG emissions and the fuel efficiency of heavy

- duty vehicles requires a different approach than the EPA existing HD program

. Specifically, r educing GHG emissions and the fuel consumed by a truck requires increasing the inherent efficiency of the engine and making changes to the vehicle to reduce the amount of work demanded from the engine in order to move the truck

– and its load

– down the road.

As a result, the standards that support the HD National Program address the complete vehicle, through complementary engine and vehicle standards. Consistent with the structure of this program, the testing

, reporting

, labeling and recordkeeping requirements described in this ICR cover heavy

- duty gas and diesel engines, and three regulatory categor ies of heavy

- duty vehicles , including combination tractors, vocational vehicles and heavy

- duty pickup

trucks and vans.

Importantly, the HD National P rogram recognizes that under EPA regulations covering criteria pollutants, heavy

- duty engine and pickup tr uck and van manufacturers already administer extensive emissions testing and reporting programs. EPA and NHTSA fully expect that engine and pickup truck and van manufacturers will ut ilize the ir existing reporting and testing infrastructure to demonstrate compliance with the program’s new fuel consumption and GHG

standards , including those for CO2, N2O and CH4 emissions

.

Under the HD National Program these manufacturers are now subject to CO2 and fuel consumption standard s. As their vehicles are not directly responsible for N2O and CH4 emissions, vocational vehicle chassis and combination tractor manufacturers are not subject to the new standards for these pollutants. To demonstrate compliance with the new

CO2 and fuel c onsumption standards, vocational vehicle chassis and tractor manufacturers will have put in place entirely

new testing programs , reporting , labeling and recordkeeping systems

.

Notably, to streamline the reporting process and reduce industry burden for all manufacturers, EPA and- 3

-

NHTSA established a harmonized approach by which all information for the HD National Program is submitted by

manufacturers through a single databa se syst em. Both EPA and NHTSA have access to data in this data base system, which also help s the A gencies to efficiently review, process, and store the heavy duty data relevant to each agency’s program requirements.

Over the next three years, 1 2 engine manufacturers and 22 vehicle and chassis manufacturers will submit 22 8 applications (24 heavy

- duty pickup truck, 108 heavy

- duty engine, 60 vocational vehicle and 36 combination tractor applications) to certify their products and respond to the information collection activities detailed in the HD National

P rogram

.

The manufacturers regulated under this program must: 1) submit applications to certify vehicles; 2)

submit r eports with early estimates to demonstrate their compliance plans; 3) conduct compliance testing; 4) label certified vehicles; 5) provide final year

- end

- reports with compliance test results; and 6) retain records of information submitted to the agencies , which will be maintained for 8 years . A manufacturer must send an application for a cert ificate of conformity and gain approval by EPA before it can legally introduce any vehicle or engine into commerce in the U.S. To e nsure compliance with the CAA and EISA , EPA and NHTSA will annually

review a manufacturer’s submitted information and compliance test results

. Manufacturer test results will be used by EPA to perform confirmatory testing on a sufficient number of engines and vehicles to confirm manufacturer

- reported

results

. Limited equipment testing and modeling runs will also be perfo rmed by NHTSA to confirm manufacturer test

results.

The testing data submitted by manufacturers is needed for EPA and NHTSA to verify that manufacturers have

selected the proper engine s and vehicle s, and conducted the testing necessary to demonstrate th at their equipment compl ies with the new GHG emission s and fuel consumption standards

.

The first year the program becomes effective is in the calendar year 201 4 . T he se collection activities are estimated to impose annual cost s of $8. 5 million and a labor hour burden of 58,064 hours . In subsequent years, years 2015 and 2016

, ann ual costs and burden hours are estimated at $ 2. 6 million and 32,926 hours, respectively.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

Under Title II of the Clean Air Act (42 U.S.C. 7521 et seq.), EPA is charged with issuing certificates of conformity for motor vehicle designs and engines that comply with applicable emission standards set under section 202(a)(1) of the Act, such as those for CO2, N2O, and CH4 in the final regulation

. This authority was clarified in the Supreme Court’s decision State of Massachusetts v. EPA

, 549 U.S. 497 (2007 ) (holding that greenhouse gases are pollutants under the Clean Air Act)

. Under the statutory aut hority of 49 U.S.C. 32902, NHTSA is mandated to require manufacturers comply with fuel economy and consumption standards.

Specifically, under Section 206(a) of the CAA (42 USC 7521):

“The Administrator shall test, or require to be tested in such manner as he deems appropriate, any new motor vehicle or new motor vehicle engine submitted by a manufacturer to determine whether such vehicle or engine conforms with the regulations prescribe d under §202 of this Act. If such vehicle or engine conforms to such regulations, the Administrator shall issue a certificate of conformity upon such terms, and for such period (not in excess of one year) as he may prescribe.”

In addition to test result s, as part of their application for a certificate of conformity, under CAA §217

, manufacturers are required to pay a n application fee when applying for a vehicle or engine certificate . At this time, the exact costs associated with the heavy

- duty vehicle G HG compliance are not known. The Agency is not modifying its- 4

-

fees provisions in this final rule and is determining how to appropriately address this issue in the future. When EPA

finalizes a cost assessment of its compliance program, it will amend its fees r egulations to include any warranted new

costs.

EPA and NHTSA also establish ed an Average, Banking and Trading (ABT) program, as outlined in 40

CFR Parts 1036.701 and 1037.701, and in 49 CFR Part 535 .7 . E ngine and vehicle manufacturers covered by th is

HD National P rogram have an option to participate in this ABT program

. Th e A gencies ’ ABT program s
, and

others like it

, are designed to enhance compliance flexibility and reduce the burden on affected manufacturers, without compromising the expected e missions benefits derived from EPA’s emissions standards and NHTSA’s fuel consumption standards

.

EPA’s new GHG standards for HD engines and vehicle s amend 40 CFR Part 86 subchapter U with the addition of two new parts : part 1036 (engines) and part 1037 ( v ehicles). The introduction of new parts in the CFR is part of a long

- term plan to migrate all the regulatory provisions related to highway and nonroad en gine

and vehicle emissions to Subchapter U of 40 CFR , which already consists of 40 CFR parts 1000 t hrough 1299. NHTSA’s new fuel consumption standards for HD engines and vehicles amend 49 CFR Parts 523, 534, and 535.

Emission standards, test procedures and compliance provisions for several types of engines already exist in parts 1033 through 1074, an d eventually all regulatory requirements related to heavy

- duty highway engines and vehicles will be placed in these parts. Moving its regulatory provisions to these new parts will allow EPA to publish its regulations in a way that is more organized, reflects updates to various certification and compliance procedures, and provides greater consistency. For now, until this migration is complete, the new HD GHG

standards also have generated amend ments to 49 CFR Parts 523, 534, and 535. Other existing regulations that pertain to controlling emissions from engines and vehicles can be found in 40 CFR Parts 86 and 600. The se regulations are not attached to this st atement due to their length and technical nature.

2(b) Need/Authority for the Collection

T he testing data submitted by manufacturers is needed for EPA and NHTSA to verify that manufacturers have

selected the proper engine s and vehicle s
, and conducted th e testing necessary to demonstrate that their equipment compl ies with the new GHG emission s and fuel consumption standards

.

Under the rule, manufacturers of heavy

- duty pickup trucks and vans will submit “pre

- model year report s ” to satisfy both EPA and NHTSA’s requirements for receiving compliance reports in advance of the model year. These pre

model reports for heavy duty pickup trucks and vans are similar to early model year compliance reports that are required

for light duty vehicles

, and the pre

- production data included in the report should be familiar to manufacturers of heavy duty pickup trucks and vans.

For engines, vocational vehicle cha s sis and combination tractor manufacturers, the agencies are using the

manufacturer’ s applications for certificates of conformity to obtain early model production estimates and related data

. The A gencies treat information submitted in the applications as a manufacturer’s demonstration of providing early complia nce information, similar to the pre

- model year report submitted for heavy

- duty pickup trucks and vans. A summary of that information can be found in Table 4

- 2

.

Once the engines and vehicles have been produced, EPA and NHTSA are using the test data and the data

included in the p re

- model reports and certification applications to support various enforcement actions, such as selective enforcement audits and in

- use compliance testing.

As noted, t he HD National Program offers manufacturers an opportunity to participate in an Average, Banking and Trading (ABT) program and other regulatory flexibilities that allow manufacturers to generate

emission and fuel consumption credits. For manufacturers that choose to participate and take advantage of these
flexibilities, EPA and NHTS A collect data to ensure that allowable emission and fuel consumption credits are- 5

-

properly allocated, traded and applied

. This data is provided in an End of Year or “EOY” production report and compared against production estimates submitted in the pre

- mod el year repor t and certification application s

.

Throughout the year, manufacturers may also be required to report various submissions to the agencies to comply with other various aspects of the rule. This o ther data collected, such as notification s th at a
manufacturer i ntends to participate in the ABT program or that a vehicle qualifies for an exclusion are ne eded so that the agencies can ensure that manufacturers are complying with the HD National Program’s regulatory provisions. A summary of require d information for compliance is listed in Table s 4

- 1, 4

- 3, and 4

- 5

.

All test and ABT data was received and used by EPA ’s Compliance Division ( CD ) within the Agency’s transportation and air quality office. Other EPA offices and divisions also may access the data to assess the effectiveness

of the HD National program. Information is shared with NHTSA as needed. Non

- confidential portions of the

information submitted to CD are available to and may be used by importers, engine users, environmental groups, members of the public and state and local government organizations.

3. Nonduplication, Consultations and Other Collection Criteria

3(a) Nonduplication This rulemaking contains specific recordkeeping provi sions in 40 CFR 1036.205 and 1037.205, which are

summarized in Table 4

- 8. Because of its specialized (and sometimes confidential ) nature

, and the fact that it is submitted jointly with NHTSA prior to the start of vehicle or engine production, the informat ion collected is not available from any

other source. The agencies developed this rulemaking to build on existing test procedures and reporting structures where possible to prevent duplication

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

An announcement of a public comment period for the renewal of this ICR was published in the Federal Register ( Vol. 79, 53190 on September 8, 2014 ).

3(c) Consultations

EPA did not contact companies for this ICR.

3(d) Effects of Less Frequent Collection

The CAA states that emission certification must be done on a yearly basis (CAA 206(a)(1)), coinciding with the industry's ‘model year’. Major product changes typically occur at the start of a model year. For these reasons, a

collec tion frequency of less than a model year is not possible. However, when an engine or vehicle design is "carried over" to a subsequent model year, the amount of new information requ ired is substantially reduced

. Existing regulations

also call for an end

- o f

- year report, with final production numbers , and the HD National Program conforms to this existing requirement as well.

3(e) General Guidelines

Under sections 1036.250 and 1037.250 of the final regulations, copies of all documents sent to EPA includ ing,

pre

- model reports, certification applications

, ABT, and end

- of

- the

- year report s , must be kept and maintained for eight

years. These records may be stored in any format and on any media, as long as they are organized and can be sent promptly to EPA, i f requested. These recordkeeping requirements stem, in part, from the statutory requirement to warrant some items for long periods of time

. M anufacturers also must comply with requirements to submit to an EPA
audit, and recall vehicles and engines failin g to meet emission standards during their useful lives. Other data, ( such as- 6

-

routine emissions tests, i.e.: test cell temperatures and relative humidity readings, etc.) need to be kept for only one year after a certificate of conformity is issued.

Man ufacturers are required to submit confidential business information such as sales projections and certain sensitive technical descriptions (see section 4(b)(i) for reference). This information is kept confidential in accordance

with the Freedom of Informat ion Act, EPA regulations at 40 CFR Part 2, and class determinations issued by EPA's Office of General Counsel. Also, non

- proprietary information submitted by manufacturers is held as confidential until the specific vehicle or engine to which it pertains is available for purchase. No other general guideline is exceeded by

this information collection.

3(f) Confidentiality

Manufacturers are allowed to assert a claim of confidentiality over information provided to EPA. Confidentiality is provided in accordance with the Freedom of Information Act and EPA regulations at 40 CFR Part 2. For further detail, refer to section 3(e), above.

3(g) Sensitive Questions

No sensitive questions are asked in this information collection. This collection complies with the Privacy

Act and OMB Circular A

- 1 08.

4. Respondents and Information Requested

4(a) Respondents/ NAICS Codes

Respondents are manufacturers of engines and vehicles within the North American Industry Classification System (NAICS) and use the coding structure as defined by NAICS. 336111, 336112, 336120, 541514, 811112, 811198,

336111

, 336112 422720, 454312, 541514, 541690, 811198, 333618, 336510, for Motor Vehicle Manufacturers, Engine and Truck Manufacturers, Commercial Importers of Vehicles a nd Vehicle Components, Alternative Fuel Vehicle Converters and Manufacturers, remanufacturers and importers of locomotives and locomotive engines

.

4(b) Information Requested

All manufacturers are required to provide pre

- model year production and related data in either a pre

model year report or as part of their application for a certificate of conformity. Data included in the p re

- model

year report and application will provide the best estimate of the vehicles and engines that a man ufacturer will produce for the year and are needed to help construct an annual testing plan. Information that manufacturers will include in their pre

- model year reports and certification applications, such a projected production estimates,

are outlined in the sections below

.

NHTSA requires manufacturers to determine equivalent fuel consumption values from CO2 emissions

test results and provide the values along with the applications for certification submitted to EPA

. Manufacturers

will submit the ir pre

- model year reports, applications, test data and related information to EPA electronically via a single database system that NHTSA will access as needed

.

In order to obtain a certificate of conformity, all manufacturers must complete a compliance demonstration, normally consisting of test data showing that their engines or vehicles meet the rule’s emission

standards and other regulatory requirements

. For t esting purposes, manufacturers typically establish either “test groups” or engine and vehicle “families” that share certain design and emissions characteristics

.

Specific criteria for establishing these test groups and families for each regulatory cate gory is outlined

in the rule § 1036.230 (engines) and § 1037.230 ( heavy duty pickup trucks and vans, vocational vehicle s and- 7

-

combination tractors). Within the families and test groups a manufacture establishes , engines and vehicles are selected and subject to actual testing.

In addition to test results and related documents that demonstrate compliance

, an application for a certificate of conformity describe s other key aspects of the manufacturer’s proposed product line , such as controls put in place to reduce GHG emissions , warranty and service information , and emission control

information label s.

All manufacturers also are required to submit end

- of

- year (EOY) production reports that will be used to reconcile pre

- model production estimates wit h final year figures. Manufacturers also must state whether they intend to participate in the Average, Banking and Trading (ABT) program that EPA and NHTSA have developed for each regulatory category. The EOY reports also are necessary for the ABT program since they are a resource for identifying e missions credits and deficits. For manufacturers not participating in ABT, the EOY reports are required to assess compliance. A summary of the data included in an EOY report is listed in Table 4

- 1

. Table 4

- 1

Summ ary of Required Information for End of Year and Final Reports Vehicle family or test group designation and averaging set Vehicle emissions and fuel consumption standards including any alternative standards used Vehicle family FELs Final production volum es Certified test cycles A credit plan identifying the manufacturers actual credit balances, credit flexibilities, credit trades and a credit deficit plan if needed demonstrating how it plans to resolve any credit deficits that might occur for a model ye ar within a period of up to three model years after that deficit has occurred A plan describing the vehicles that were exempted such as for off

- road or small business purposes A plan describing any alternative fueled vehicles that were produced for the model year identifying the approaches used to determinate compliance and the production volumes

In addition, all manufacturers will be required to retain records per the provisions in 40 CFR parts 1036
and 1037, as outlined in Table 4

- 2.- 8

- Table 4

- 2 Key Recordkeeping requirements, HD National Certification Program Records are to be kept for eight years, except routine emission records that are to be kept for only one year.

Information Item *Engine

Manufacturers Vehicle Manufacturers

General records: 1036.205 1037.205

Identification and description of all engines and vehicles for which testing is required

Description of emission control system

Description of test procedures and supporting documents demonstrating compliance

Individual Records: 1036.825 1037.825

Copies of all applications submitted

Test records, instructions and other data provided to or received from other manufacturers (for example: emissions

related engine installation instructions, instructions for air conditioning installation, etc.)

A complete record of all emission tests performed

A complete record of all model inputs

Record and description of each test performed to diagnose engine and vehicle emissions

The rule has an effective date in time for model year s 2015

- 2018 . Under this timeframe, manufacturers

will begin to test and submit their applications and other pre

- production do cuments to EPA and NHTSA in 2015

. The time horizon of this ICR is intended to cover the annualized impacts of the rule at the time that manufacturers initiate their testing and compli ance activities.

( i ) Data Items

In addition to the data items described above, b rief summaries of the new data items the A gency collect s from engine manufacturers and the three regulatory c ategories of the heavy duty truck manufacturers covered by

the rule are provided below. D etailed list s of the se data items are given in Table s 4

- 3 through 4

- 11

.

Heavy Duty Pick Up Trucks and Vans Testing and Certification

The vast majority of heavy duty pickup trucks and vans are designed, manufactured and sol d by manufacturers as complete vehicles, and many of these truck and van models already are certified to vehicle

- based emission standards for criteria pollutants. Further, these heavy duty truck/van models typically are based on higher sales volume light duty truck/van designs and models, which already are subject to GHG emission and

fuel economy standards under the joint light

- duty vehicle program promulgated by EPA and NHTSA in March

2010.

Thus, the HD national certification program closely tracks existing tes t procedures and reporting

program s already in place for vans and pickup truck s. F or example, the test procedures, GHG and fuel- 9

-

consumption standards for heavy duty pickup trucks and vans apply to the complete vehicle , just as similar procedur es and standards apply to complete light duty trucks and vans (there are no separate engine and vehicle requirements, such as those that exist for vocational vehicles and combination tractors)

.

U sing test procedures , reporting and compliance requiremen ts from already established and proven test protocols and programs that are applicable to HD pickup trucks and vans helps to minimize test costs and reporting burdens for this category of the HD National Program. Burdens are further reduced for HD pickup

truck and van manufacturers because manufacturers already have invested in test facilities and equipment for the light duty trucks and vans that they also produce.

Nonetheless, the standards for HD trucks and vans are unique and are expected to create new testing burdens and reporting requirements

. Specifically , EPA and NHTSA have established weight

- based attributes, namely payload and towing capacit y
, which support the GHG emission and fuel consumption limits for this vehicle category. M anufa cturers are required to apply these attributes when establishing vehicle test groups to demonstrate compliance with the CO 2 and fuel consumption standards . These attributes also are factored into the production volume

- weighted calculation of a manufacture r’s annual fleet average compliance requirement.

For demonstrating compliance with the new N2O and CH4 standards , EPA believes that the current test

group concept used by pickup truck and van manufacturers is appropriate because the technologies empl oyed to control N2O and CH4 emissions are generally the same as those used to control criteria pollutants.

However, by applying weight

- based attributes to establish CO2 and fuel consumption standards for HD pickup trucks and vans, EPA and NHTSA expect that, manufacturers will find it in their best interest to test multiple vehicle configurations with a given test group to accurately estimate the fleet average CO2 emission

levels . Ultimately these additional tests and estimates are necessary to d emonstrate compliance

.

EPA is requiring manufacturers to meet the air conditioning leakage standard. To demonstrate compliance, the

vehicle manufacturer must c alculate the percent leakage rate of the hydrofluorocarbon (HFC) emissions from the air conditioning system by dividing the total leakage rate in grams per year by the refrigerant capacity as specified in 40 CFR 1037.115(c). The agency has adopted a test procedure for determining leakage rate that is consistent with the one adopted for L ight Duty GHG, and therefore familiar to the HD pickup truck and van manufacturers.

Table 4

- 3 Required Information for pre

- model year reports Heavy

- duty Pickup Truck and Van Manufacturers

A list of each unique vehicle configuration included in the manufacturer’s fleet describing the make and model designations, attribute based

- values (GVWR, GCWR, Curb Weight and drive configurations) and standards The emission and fuel consumption fleet average standard derived from the unique vehicle configurations The estimated vehicle configuration, test group and fleet production volumes

E xpected CO2, N2O, CH4, and HFC emissions and fuel consumption test group results and fleet average performance A statement declaring whether the manufacturer w ill use fixed or increasing standards; acknowledging that once selected, the decision cannot be reversed and the manufacturer must continue to comply with the same alternative for subsequent model years A statement declaring whether the manufacturer choos es to comply voluntarily with NHTSA’s fuel consumption standards for model years 2015 through 2018 . The manufacturers must acknowledge that once selected, the decision cannot be reversed and the manufacturer will continue to comply with the fuel consumpti on standards for subsequent model years;

The list of Class 2b

- 3 cab

- complete vehicles and the method use to certify, as vocational vehicles and engines, or as complete pickups and vans identifying the most similar complete vehicles used to derive the targ et standards and performance test results- 10

-

The list of Class 2b

- 3 incomplete vehicles and the method use to certify, as vocational vehicles and engines, or as complete pickups and vans identifying the most similar complete vehicles used to derive the targe t standards and performance test results The list of Class 4 and 5 incomplete and complete vehicles and the method use to certify, as vocational vehicles and engines, or as complete pickups and vans identifying the most similar complete vehicles used to d erive the target standards and performance test results List of loose engines included in the heavy

- duty pickup and van category and the list of vehicles used to derive target

standards Copy of any notices a vehicle manufacturer sends to the engine manuf acturer to notify the engine manufacturers that their engines are subject to emissions and fuel consumption standards and that it intends to use their engines in

excluded vehicles A credit plan identifying the manufacturers estimated credit balances, planned credit flexibilities (i.e., credit balances, planned credit trading, innovative, advanced and early credits and etc.) and if needed a credit deficit plan demonstrating how it plans to resolve any credit deficits that might occur for a model year wi thin a period of up to three model years after that deficit has occurred

For the purposes of this ICR, the t est data accompanying these applications will include results from coast down and chassis tests. HD pickup trucks and vans also are subject to n ew HFC leakage, N2O, and CH4 standards and their applications will need to demonstrate how they are meeting the standards. The new testing requirement costs are identified as the following in Tables 6

- 4 and 6

- 5:

Test/Gather CO2, N2O, CH4, and HFC emission data on test vehicles

Coastdown test Analyze CO2, N2O, CH4, and HFC data to determine compliance

As shown in Table s 6

- 4 and 6

- 5

, based on these estimates, EPA and NHTSA expect to receive a total of 24 applications for certificates of conformity each year from the heavy

- duty pickup truck and van regulatory

category. Unlike the other regulatory categories discussed below , the manufacturers of heavy

- duty pickup trucks and vans have recordkeeping systems in place for the existing criteria pollutant requirements, thus the agencies did not include a recordkeeping burden in this ICR. The requirements to develop the application for certification are identified as the following in Tables 6

- 4 and 6

- 5 :

Review of reg ulations Information technology upgrade to track GHG emissions (CO2, N2O, CH4, and HFC) within the existing systems Prepare and submit certification application (including carryover applications)

Collect and submit data for ADFE model Prepare and review GHG compliance plan End of year and f inal production reports

Engine Manufacturers

For engine manufacturers, the information and reporting burden associated with the National HD Program occur within the context of EPA’s existing engine certification program for controlling criteria pollut ants. In constructing a program to address GHG pollutants, EPA has bui lt upon this existing infrastructure, thus creating minimal new certification testing and reporting requirements for engine

manufacturers. For example, the agencies developed the GHG certification by building on the existing criteria pollutant certification template.

Also as an example, EPA believes that the selection criteria used to determine criteria pollutant engine families are equally applicable for defining CO2 emissions perfo rmance, and that having two distinct family designations per engine (one for criteria pollutants and one for CO2) would be overly burdensome without- 11

-

adding any benefit. Consequently the rule directs engine manufacturers to use the same selection criteria, as outlined in 40 CFR Part 86, Subpart N, to define a single engine family designation for both criteria pollutant

and GHG emissions.

The requirements for engine manufacturers ’ application for certification are listed in Tables 4

- 4 and 4

- 5

. The maj ority of these requirements will be reported to the agency through the HD engine certification template provided to manufacturers.- 12

- Table 4

- 4 Engine Manufacturers

Section 1036.205

Description of engine families as related to requirements for GHG standards, including CO2, CH4 and N2O, as applicable

Description of emission control system, including auxiliary

- emission control devices to be installed on production vehicles

Description of test engin es selected for testing and rationale for selection

Description of test procedures and equipment, including alternate tests if applicable

Instructions for Engine Installation

Describe Label Information

Engine placement (combination tractors, vocational vehicles )

Intent to participate in Average, Banking & Trading and/or other available emissions credit programs

Family Certification Limits

Family Emission Limits

Statement of Compliance

Good

- faith estimates of U.S. production volumes

End of Year (EOY) production reports

Amendment to certification application

Name of U.S.

- based service agent

Table 4

- 5

Summary of Additional Information Required for Compliance

- Engines

Submission Applies to Required Submissions

Date EPA Regulation

Reference NHTSA

Regulation

Reference

Small business exemptions Engine manufacturers meeting the

Small Business Administration (SBA) size criteria of a small

business as described in 13 CFR

121.201. Before introducing any

excluded vehicle into U.S.

for commerce §1036.150 §535.8

Incentives for early

introduction The provisions apply with respect

to tractors and vocational vehicles produced in model years before

2014 EPA must be notified

before the manufacturer

submits it s applications

for certificates of conformity §1036.150 §535.8

Voluntary compliance for

NHTSA

standards Engine manufacturers seeking early

compliance in model years 2014 to

2016. NHSAT must be notified

before the manufacturer

submits it s applications

for certificates of conformity NA §535.8- 13

-

Model year

2014 N2O

standards. Manufacturers that choose to show

compliance with the MY 2014 N2O standards requesting to use an engineering analysis EPA must be notified

before the manufacturer

submits it s applications

for certificates of conformity §103 6.150 NA

Exemption

from EOY

reports Manufactures with surplus credits

at the end of the model year 90

- days after the calendar year ends §1036.730 §535.8

Alternative engine

standards Engine manufacturers not able to

comply with 1036.104 and wanting

to use the alternative engine

standard. EPA and NHTSA must be

notified before the

manufacturer submits it s applications for certificates of conformity §1036.150 §535.8

Alternate phase

- in Engine manufacturers that want to

comply with alternate phase in

standard s. EPA and NHTSA must be

notified before the

manufacturer submits it s applications for certificates of conformity §1036.150 §535.8

The existing HD criteria pollutant program requires engine labels per 40 CFR 86.007

- 35(a)(3) . The GHG rule requires the addition of one identification requirement to the existing label, as listed in Table 4

- 6.



### Table 4

- 6 Key labeling requirements, HD National Certification Program

Information Item Engine

Manufacturers

Engine Labels: 1036.135

Label your engines as described in 40 CFR 86.007

- 35(a)(3)

Additional Engine GHG Labeling: 1036.135

Identify the emission control system. Use terms and

abbreviations as described in 40 CFR 1068.45 or other applicable conventions. 1068.85

Identify any limitations on your certification. For example, if you certify heavy heavy

- duty engines to the CO2 standards using only transient cycle testing, include the statement

“VOCATIONAL VEHICLES ONLY”. 1036.135

You may ask us to approve modified labeling requirements in this part 1036 if you show that it is necessary or appropriate. We will approve your request if your alternate label is consistent with the requirements of this part. We may also specify modifie d labeling requirement to be consistent with the intent of 40 CFR part 1037. 1036.135

Further, tests used today to demonstrate compliance with criteria pollutants also include provisions for- 14

-

measuring GHGs, and in the rule , compliance with NHTSA’s fu el consumption standards and with EPA’s GHG

standards is established with these same tests, the Heavy Duty Federal Test Procedure (FTP) and Supplemental Engine Test (SET). However, depending on the type of vehicle in which the engine would be placed,

manu facturers are required to identify relevant test results (steady state, transient or steady state and transient test results) in their certification application. The agencies calculated the burden of these activities in Tables 6

- 6

and 6

- 7 as the “Testing/G athering emission data on test vehicles” and “Analyze data to determine compliance”

costs.

In addition, engine manufacturers are required to report CH4 and N2O at the time of certification. Although CH4 emissions can be accurately measured using existin g engine tests and equipment

, manufacturers typically do not have the equipment to measure N2O emissions. In the first year of the program, manufacturers have the option of directly measur ing N2O or submitting a compliance statement based on good engineer ing judgment

. As shown in Table 6

- 6, t he ICR assumes that engine manufacturers will test and report N2O emissions in the first year of the program and has identified this cost as “N2O Analyzer Investment

. ”

With the exception of these new certification requirements for heavy duty engines, the existing compliance structure that engine manufacturers use for criteria pollutants is also valid for demonstrating compliance with the GHG regulations. Specifically, engine manufacturers may utilize the emissions

, warranty and service programs already in place for CO2, CH4 and N2O as outlined in 40 CFR Part 86.

As a consequence, with the exception of their initial investment in N2O test equipment, and the time involved in acquiring experience to operate this equipment, the burden associated with submitting engine certification applications, EOY reports and other data is minimal. This information will simply be integrated into the existing data already submitted to EPA. This ICR assumes and reflects the cost burden to report this new information for 12 heavy

- duty engine manufacturers that on average will submit nine applications each, for a total of 108 engine certification applications. The requirements to develop the application for certification are identified as the following in Tables 6

- 6 and 6

- 7 :

Review of regulations Prepare and submit certification applic ation (including carryover applications) Prepare and review GHG compliance plan End of year and final production reports
Store, file and maintain records

Vocational V ehicles and Combination Tractors

Unlike the engine and pickup truck and van segments o f the HD truck sector, fuel consumption and

emissions from vocational vehicles and combination tractors have been largely unregulated, and EPA recognizes

that the HD N ational P rogram presents these segments with several new testing, reporting

, recordkeepin g , and labeling requirements , as shown in Table s 4

- 7 through 4

- 11

. The reporting requirements for the application for certification are covered in the HD GHG Vehicle application for certification template.

Table 4

- 7 Required Information for Certification Applications Vocational Vehicle Chassis and Tractor Manufacturers (553.8) A description of the vehicle family’s specifications and other basic parameters of the vehicle’s design and emission controls

. List the fuel type on which the vehicles are designed to operate (for example, ultra low

- sulfur diesel fuel). An explanation of how the emission control system operates. As applicable, describe in detail all system components for controlling greenhouse gas and evaporative emissions, including all auxiliary emission control devices (AECDs) and all fuel

system components will be installed on any production vehicle. Identify the part number of each component you describe. Treat as separate AECDs any devices that modulate or activate differently from each other. For vehicles subject to air conditioning standards, include: (1) Th e refrigerant leakage rates (leak scores).- 15

-

(2) The refrigerant capacity of the air conditioning systems. (3) The corporate name of the final installer of the air conditioning system. A description of any vehicles selected for testing and the reasons for selecting them. A description of any test equipment and procedures that were used, including any special or alternate test procedures used (see § 1037.501). A description of how any emission

- data vehicle was operated before testing, including the duty c ycle and the number of vehicle operating miles used to stabilize emission levels. Explain why this method of service accumulation was selected. Include a description of any scheduled maintenance performed. A list of the specifications of any test fuel u sed to show that it falls within the required ranges specified in 40 CFR part 1065. Identification of the vehicle family’s useful life. The maintenance instructions and warranty statement that will be provided to the ultimate purchaser of each new vehic le (see §§ 1037.120 and 1037.125). A description of the vehicle’s emission control information label (see § 1037.135). Identify the emission standards or family emission limits ( FEL ) s to which you are certifying vehicles in the vehicle family.

For famil ies containing multiple subfamilies, this means that you must identify multiple CO 2 FELs. For example, you may identify the highest and lowest FELs to which any of your subfamilies will be certified and also list all possible FELs in between (which will be in 1 g/ton

- mile increments). Where applicable, identify the vehicle family’s deterioration factors and describe how they were developed. Present any emission test data used for determining the deterioration factors (see §1037.241(c)).

Where applicable, state that you operated your emission

- data vehicles as described in the application (including the test procedures, test parameters, and test fuels) to show you meet the requirements of this part. Present evaporative test data to show your veh icles meet the evaporative emission standards specified in subpart B of this part, if applicable. Report all valid test results from emission

- data vehicles and indicate whether there are test results from invalid tests or from any other tests of the emiss ion

- data vehicle, whether or not they were conducted according to the test procedures of subpart F of this part. You may be required to report these additional test results. You may be asked to send other information to confirm the validity of test data. Report modeling results for ten configurations. Include modeling inputs and detailed descriptions of how they were derived. Unless otherwise specified, include the configuration with the highest modeling result, the lowest modeling result, and the

conf igurations with the highest projected sales. A description of all adjustable operating parameters (see § 1037.115), including production tolerances. It is not necessary to include parameters that do not affect emissions covered by the application. Incl ude the following in your description of each

parameter: (1) The nominal or recommended setting. (2) The intended physically adjustable range. (3) The limits or stops used to establish adjustable ranges. (4) Information showing why the limits, stops, or other means of inhibiting adjustment are effective in preventing adjustment of parameters on in

- use vehicles to settings outside the intended physically adjustable ranges. A statement that unconditionally certifies that all the vehicles in the vehicle family comply with the requirements of the

Clean Air Act.

Good

- faith estimates of U.S.

- directed production volumes by subfamily. You may be required to describe the basis of your

estimates.

Other information, such as information required by § 1037.725 if participating in the ABT program. Other applicable information, such as information specified in this part or 40 CFR part 1068 related to requests for exemptions. Name an agent for service locate d in the United States. Service on this agent constitutes service on the manufacturer or any of the manufacturer’s officers or employees for any action by EPA or otherwise by the United States related to the requirements of these regulations.- 16

- Table 4

- 8 : Key Information Items Requested: HD National Certification Program

Vehicle Manufacturers

Section 103 7 .205

Description of vehicle families as related to requirements for GHG standards, including CO2 and HFC , as applicable

Description of emission control system, including auxiliary

- emission control devices to be installed on production vehicles

Description of test vehicles selected for testing and rationale for selection

Description of test procedures and equipment, including alternate tests if applicable

Describe Label Information

Intent to participate in Average, Banking & Trading and/or other available emissions credit programs

Family Emission Limits

Statement of Compliance

Good

- faith estimates of U.S. production volumes

End of Year (EOY) production reports

Amendment to certification application

Name of U.S.

- based service agent

Table 4

- 9

Summary of Additional Information Required for Compliance

– Vocational Vehicles

Submission Applies to Required Submissions

Date EPA Regulation

Reference NHTSA

Regulation

Reference

Small business exemptions Vehicle manufacturers meeting

the Small Business Administration (SBA) size

criteria of a small business as

described in 13 CFR 121.201. Before introducing any

excluded vehicle into U.S.

commerce §1037.150 §535.8

Incentives for early

introduction The provisions apply with

respect to tractors and vocational vehicles produced in model years before 2014 EPA must be notified

before the manufacturer submits its applications for certificates of conformity §1037.150 §535.8

Voluntary compliance for

NHTSA

standards Vehicle manufacturers seeking

early compliance in model years

2014 to 2016. NH TSA must be notified

before the manufacturer submits its applications for certificates of conformity NA §535.8

Approval of

alternate

methods to determine drag

coefficients Tractors meeting § 1037.106 EPA must be notified

before the manufacturer

submits its applications for certificates of conformity §1037.150 §535.8

Off

- road exemption Manufacturers wanting to

exclude tractors from vehicle

standards EPA must be notified

before the manufacturer submits its applications for certificates of conformity §1037.150 §535.8- 17

-

Vocational

Tractor Manufacturers wanting to

reclassify tractor as vocational tractors making them applicable

to vocational vehicle standards EPA must be notified

before the manufacturer submits it applications for certificates of conformity §1037.150 §535.8

Exemption from EOY reports Manufactures with surplus

credits at the end of the model

year 90

- days after the calendar year ends §1037.730 §535.8

Table 4

- 10 Summary of Additional Information Required for Compliance

– Tractors

Submission Applies to Required

Submissions Date EPA Regulation

Reference NHTSA

Regulation

Reference

Small business exemptions Vehicle or engine manufacturers meeting the

Small Business Administration (SBA) size criteria of a small

business as described in 13

CFR 121.201. Before introducing any

excluded vehicle into

U.S. commerce §1037.150 §535.8

Incentives for early

introduction The provisions apply with respect to tractors and vocational vehicles produced in model years before 2014 EPA must be notified

before the

manufacturer submits it applications for

certificates of conformity §1037.150 §535.8

Air condition leakage exemption for

vocational vehicles Vocational Vehicles excluded from § 1037.115 EPA must be notified

before the

manufacturer submits it applications for

certificates of conformity §1037.150 §535.8

Model year 2014 N 2 O

standards. Manufacturers that choose to show compliance with the MY

2014 N 2 O standards requesting to use an engineering analysis EPA must be notified

before the

manufacturer submits it applications for

certificates of conformity §1037.150 §535.8

Exemption for electric

vehicles All electric vehicles are deemed

to have zero exhaust emissions

of CO 2 , CH 4 , and N 2 O End of December prior to model year §1037.150 §535. 8

Off

- road exemption Manufacturers wanting to

exclude vocational vehicles

from vehicle standards EPA must be notified

before the

manufacturer submits it applications for

certificates of conformity §1037.150 §535.8

Exemption from EOY

reports Manufactures with surplus

credits at the end of the model

year 90

- days after the calendar year ends §1037.730 §535.8- 18

- 

### Table 4

- 11 Key labeling requirements, HD National Certification Program

Information Item Vehicle

Manufacturers

Vehicle Labels: 1037.135

Assign each vehicle a unique identification number and permanently affix, engrave, or stamp it on the vehicle in a legible way. The vehicle identification number (VIN) serves this purpose. 1037.135

At the time of manufacture, affix a permanent and legible label identifying

each vehicle. 1037.135

The label must include information contained in 1037.135(c). 1037.135

You may add information to the emission control information label to identify other emission standards that the vehicle meets or does not meet (su ch as European standards). You may also add other information to ensure that the vehicle will be properly maintained and used. 1037.135

You may ask us to approve modified labeling requirements in this part 1037 if you show that it is necessary or appropriate. We will approve your request if your alternate label is consistent with the requirements of this part. 1037.135

Additional Vehicle GHG Labeling:

The original vehicle manufacturer of an off

- road vocational vehicle must apply a removable la bel meeting the requirements of 40 CFR 1068.45 that identifies the corporate name of the original manufacturer and states that the vehicle is exempt under the provisions of § 1037.620. The name of the certifying manufacturer must also be on the label or, a lternatively, on the bill of lading that accompanies the vehicles during shipment. The original manufacturer may not apply a permanent emission control information label identifying the vehicle's eventual status as a certified vehicle. 1037.615

You must i nclude the following additional statement on the vehicle’s
emission control information label for a vocational tractor under §1037.135:

“THIS VEHICLE WAS CERTIFIED AS A VOCATIONAL TRACTOR

UNDER 40 CFR 1037.630.”. 1037.630

The requirements to develop the application for certification are identified as the following in Tables 6

- 8 through 6

- 11:

Review of reg ulation s and guidance document Prepare and submit certification application (including carryover applications) Labeling requirements Final year producti on and ABT update
Store, file, and maintain records

For both these vehicle categories, the CO2 and fuel consumption standards focus on reductions that can

be achieved primarily through changes to vehicle systems, such as tires , and some modifications to vehicle design. Both the fuel consumption and CO2 standards are expressed in terms of moving a ton of freight over

one mile : the fu e l consumption standard is represented as gallons of fuel used to move one ton of freight (pay load) 1000 mile s , or gal/ 1000 ton

- mile ; and the CO2 vehicle standards are represented as grams of CO2 per

ton

- mile. Neither vocational vehicles nor combination tractors are subject to N2O or CH4 emission standards,- 19

-

but tractors equipped with air condition ing are subject to HFC leakage standards.

To help reduce testing and reporting burdens on vocational vehicle chassis and combination tractor manufacturers, EPA has developed a truck simulation model, the Greenhouse gas Emissions Model (GEM)

. The GEM was developed for manufacturers to demonstrat e compliance with the new GHG standards. Under the rule, manufacturers evaluate and report CO2 emissions and fuel consumption through a simulation of the ir vehicle s using GEM

. GEM is directly available to vocational vehicle chassis and combination tractor manufacturers as a

download from the internet , at no cost . Outputs from the GEM model also generate summary d ata that can be integrated

into the application for a certificate of conformity.

EPA has programmed the GEM with two sets of predefined parameters; one set of parameters for

vocational vehicles , and a second set of parameters for combination tractors

. Values for these predefined parameters are detailed in the rule , and include several key vehicle characteristics common to the vocational

vehicle and combination tractor configurations subject to CO2 and fuel consumption limits

.

These characteristics include vehicle frontal area dimensions; total and payload weight; engine/transmissio n/wheel inertia, accessory load, axle base, tire radius, and engine fuel map, among others. Additional predefined inputs, unique to combination tractors, such as trailer tire coefficient of rolling resistance (Crr), also are included.

These preprogramm ed inputs substantially reduce the testing burden on manufacturers of vocational

vehicle chassis and combination tractors. For example, the GEM provides an alternative to chassis and other tests traditionally performed in a laboratory or on the road.

M anufacturers w ill however, be required to test their vehicles

, collect data and input at least two key

data elements (based on testing) prior to run ning GEM. As discussed below, these two inputs are : 1) the coefficient of rolling resistance (Crr) of the vehicle’s steer and drive tires; and (for combination tractors) 2) the aerodynamic drag (expressed as the vehicle’s coefficient of drag area or “ Cd A ” ) of a truck

.

Additional inputs needed to run the GE M include b asic information, such as manufacturer name , vehicle family and configuration

, and model year

.

The new testing requirement costs are identified as the following in Tables 6

- 8 through 6

- 11:

Tire testing Tractor coefficient of drag testing (us ing coastdown, wind tunnel, and CFD) Collect, input data for the Greenhouse Gas Emissions Model (GEM), and run model Analyze data to determine compliance

Tire Rolling Resistance

Both vocational vehicle chassis and combination tractor manufacturers will need to determine the rolling resistance of a vehicle’s steer and drive tires from either their tire suppliers or by testing the tires using the test method adopted by the International Organization for Standardiz ation, ISO 28580:2009.

Specifically, the ISO test must be conducted on three tire samples within each tire model one time each to account for some production variability. Details for conducting the ISO test are specified in the rule ( §1037.520(c) ). In summary, t he average of the three tests would be the rolling resistance coefficient value for use as an input into the GEM. Whether tested in

- house, or contracted out, this ICR assumes a cost of $300 for

each tire model tested. The ICR further assumes t hat each manufacturer ( vocational vehicle chassis and combination tractor) will need to test 10 tire models for each vehicle family or certification application that is

submitted for the first year of certification

. In subsequent years, the manufacturers will be able to carry

- over tire test results so the agencies assumed one new tire will be tested for each application for each manufacturer.- 20

-

Although the results of the tire tests do not need to be submitted as part of the certification application,

the Crr is needed to run GEM and demonstrate compliance with the rule’s CO2 and fuel consumption standards.

Test results are to be maintained for 8 years, as required under ( §1037.825 ).

Aerodynamic Assessment

In addition to providing inputs on the rollin g resistance of their steer and drive tires, c ombination tractor

manufacturers must also establish the GEM inputs for the aerodynamic drag

– expressed as the coefficient of drag or “ Cd A ”

– of their vehicles. Vocational vehicle chassis manufacturers are not subject to this requirement to test and establish drag for their vehicles.

Manufacturers must determine a combination tractor’s Cd A through testing, which then is to be used as an input into the GEM. Under the rule, manufacturers may choose from test methods to assess the aerodynamics of their vehicle and establish appropriate Cd A value s. These test methods include coastdown testing, wind tunnel testing and computational fluid dynamics.

To estimate the cost associated with testing combination tracto rs to establish a Cd A

, p rocedures for conducting coastdown tests are specified in ( §1037.520(b) ) of the rule; procedures for conducting wind tunnel testing can be found in ( §1037.521(c) ) of the rule. Detailed guidance on the role of computational fluid dy namics in establishing a Cd A for specific tractor models can be found in ( §1037.521(d) ).

Importantly, tractor manufacturers must conduct coastdown testing on at least one truck. Based on the Cd A established from coastdown testing, manufacturers have the option of developing a n adjustment factor that can be applied to assess the aerodynamic drag of other trucks. If a manufacturer chooses to develop this adjustment factor, it

must also conduct alt ernate aerodynamic testing on the same truck that was subject to the coastdown test. The rule also provides guidance on using the coastdown and alternate aerodynamic test results (from the same truck) to establish this adjustment factor (§1037.521(a))

.

As stated, at this time the agencies recognize that manufacturers may not have the facilities or onsite expertise necessary to conduct either coast down or alternate aerodynamic testing in house. Consequently, the ICR assumes that manufacturers will work with testing contractors that possess the expertise and facilities to meet the rule’s testing requirements

.

Further

, the c ontract costs (operations and maintenance, or “O&M”) presented in Table 6

- 10 assume that tractor manufacturers will choose to derive and apply a n adjustment factor to establish the Cd A for their trucks. As specified in the rule, this factor can only be used in conjunction with actual alternate aerodynamic tests conducted on vehicles that

are selected to represent specific vehicle families.

Thus, as shown in Table 6

- 10

, testing burden s for tractor manufacturers are presented as O&M costs, based on

the assum ption that manufacturers will contract out the testing

– coastdown and wind tunnel

- ne eded to establish the

Cd A for their vehicles, and subsequently to run the GEM.

Tractor manufacturers also will have option s for includ ing other parameters in the GEM, if their

vehicles are equipped with technologies to reduce idling, lower vehicle weight and limit speed.

Although this data is not reported as a GEM input , at the time of certification, tractor manufacturers

also will be required to outline the design of their air conditio ning systems used in cabs, and an HFC leakage score. Test procedures for establishing an HFC leakage score are detailed in §1037.115(c).

The ICR assumes that 15 vocational vehicle chassis manufacturers, on average, will identify four

vehicle families and that the agencies will receive a total of 60 applications for certificates of conformity from- 21

-

this regulatory category.

The agencies expect to receive an additional 36 applications from manufacturers of combination tractors (on average nine application s from four manufacturers). The four tractor manufacturers also manufacture the

vocational vehicles accounted for in the ICR.

However, these manufacturers operate distinctly different truck divisions and based on significant

differences in vehicle desi gn, the agencies expect to receive a total of 96 applications for certificates of conformity from the vocational vehicle and tractor categories.

( ii ) Respondent Activities

The type s of activities a manufacturer would do to certify an engine or vehicle family are as follows:

Review the regulations and guidance document
Prepare and submit pre

- model year reports or related production data for certification applications Develop engine o r vehicle “test” or “ family ” groups Test engines and vehicles for compliance with emission and fuel consumption standards

Gather and analyze test results

Collect inputs and run GEM , as needed Submit the Application for Certification

Label certified vehic les Prepare and submit carryover applications Prepare GHG compliance plan and reports , as needed Prepare and submit End of Year Production reports
Store, file and maintain records

5. The Information Collected

-- Agency Activities, Collection Methodology, and Information Management

5(a) Agency Activities

As part of the implementation of the certification programs, EPA and NHTSA officials carry out the following

activities:

Review and interpret regulations, provide guidance

Review certification applica tions for completeness and accuracy Verify that the correct engines and vehicles have been selected and tested Answer questions from manufacturers and the public Issue appropriate certificates of conformity Periodically perform maintenance or enhance the database Make data available to the public Analyze and manage requests for confidentiality Determining if "carry over" of data from a previous model year is appropriate or if new testing will be required

Review End

- of

- Year production reports
Store, file and maintain data

5(b) Collection Methodology and Management

EPA and NHTSA currently make extensive use of computers in collecting information from vehicle manufacturers. Essentially all applications for certification and related product descriptions, test results, ABT and end of

year reports, etc. will be submitted electronically through a single point of entry to a database that both EPA and NHTSA- 22

-

can access. Once the data is received, the information is uploaded, monitored and reviewed for completeness by EPA

and NHTSA

.

The public can access non

- confidential portions of the certification applications and test data by contacting CD or through the Certification Information Center at http://www.epa.gov/otaq/certdata.htm

.

5(c) Small Entity Flexibility

As discussed in the preamble of the regulation, the respondent class for this rule is defined to exclude those manufacturers who would fall into the definition of small business entities, except for a once

- per

- year declaration of

small business status.

5(d) Collection Schedule

Information must be submitted prior to and after the end o f each “model year” that a manufacturer intends to build (or import) vehicles. For emissions and fuel consumption purposes, a “model year” is statutorily defined as the annual production period of a manufacturer, as decided by the Administrator, that

incl udes January 1 of that calendar year; or that calendar year if the manufacturer does not have an annual production period.

Du ring the model year, the results of such additional fuel consumption and greenhouse gases tests as the

manufacturer conducts a re also reported to EPA and NHTSA . After the end of the model year fleet

- wide greenhouse gasses emissions are reported. If a product is unchanged between model years, much of the

information can be “carried over.” The collection frequency and burden are d etermined to a large extent by the manufacturer’s marketing and product ion plans. However, as required by law, some submission is required for each model year’s production.

6. Estimating the Burden and Cost of the Collection

Tables 6

- 4 , 6

- 6 , 6

- 8 , and 6

- 10 at the end of this section provide details on collections costs in the first year of program implementation

. The first year the program becomes effective is in the calendar year 2014. Tables 6

- 5 , 6

- 7 , 6

- 9

and 6

- 11 represent costs in years two and thr ee of the program. These tables represent burdens and costs for

manufacturers of HD engine s and the three new vehicle categories covered by the HD National Program.

6(a) Estimating Respondent Burden

Burden estimates were taken from the previous ICRs and adjusted to reflect EPA experience in these and other similar programs.

6(b) Estimating Respondent Costs

( i ) Estimating labor costs

To estimate labor costs, EPA used the Bureau of Labor Statistics’ National Industry

- specific Occupational Wage Estimates ( 2009) for the Manufacturing Industry ( NAICS 31

- 33 ) , Transportation Equipment Manufacturing Subsector (NAICS 336) and the Professional, Scientific, and Technical Services Sector (NAICS 54). These rates were increased by a factor of 2.1 to a ccount for benefits and overhead. The specific rates used are listed below in Table 6

- 1

. These are mean hourly rates.- 23

- Table 6

- 1

Labor Costs Estimates

Occupation Mean Hourly Rate (BLS) Mean Hourly Rate (Including benefits and Overhead)

Mechanical Engineers $ 39.16 $ 82

. 24

Engineering Managers $50.71 $10 6

. 50

Test Cell Operator $ 23.05 $ 48

. 4 0

Lawyers $ 65

. 81 $ 138

. 20
Secretaries, Except Legal, Medical and Executive $14.95 $31.39

(ii) Estimating Capital

, Operations and Maintenance Costs

Operations and Maintenance costs include the non

- labor costs associated with conducting new tests that are proposed for the model year 2014 and after. Costs are for contracted laboratory time, the use of test equipment, vehicle and engine parts, fuel and other supplies.

The agencies expect that manufacturers of vocational vehicle chassis and combination tractors will contract with testing firms for most of their testing. Under the regulations, both these manufacturers need to establish a

coefficient of rolling resistance (Crr) for the tires they will specify for vehicles to demonstrate compliance with the new GHG and fuel standards. In addition, tractor manufacturers need to test vehicles for a coefficient of drag, or a Cd A , also

needed to demonstrat e compliance.

Based on contract costs for running tests to establish Crr (ISO 28580) and Cd (coastdown and wind tunnel),

these test costs amount to a total of $180,000 for vocational vehicles and $ 1.33 million ( $337,320 for Crr testing and $ 992,680 for Cd A testing) for tractors. As listed in Tables 6

- 8 through 6

- 11 below, these values estimate that each of the

15 vocational vehicle manufacturers will test 40 tires and each of the four tractor manufacturers will test 90 tires. The

costs also include ae rodynamic testing of vehicles which consist of one coastdown test, ten wind tunnel tests, ten full computational fluid dynamics (CFD) models, and 81 CFD iterations for each of the four tractor manufacturers.

(iii) Capital/Start Up Costs

Startup costs are one

- time costs to implement the new requirements in the rule that normally are applicable to the first year of the program , of which becomes effective is in the calendar year 2014. These startup costs fall into three categories. First, a re costs associated with information managemen t. Second, are start up costs associated with acquiring test equipment. Third, are costs associated with equipment to generate vehicle labels.

For all manufacturers

, the rule’s electronic reporting requirem ents will generate first

- year start up costs for programming computer systems so that certification and related data can be submitted to EPA /NHTSA in the necessary formats. Since heavy

- duty pickup truck, van and engine manufacturers already have computer systems and processes in place for reporting similar certificatio n data, this start up cost is not so significant

. Tables 6

- 4 and 6

- 6 r eflect start

- u p costs for pickup truck/van manufacturers and engine manufacturers respectively

.

The ICR assumes that in addition to software and programming costs, vocational vehicle chassis and

combination tractor manufacturers will incur additional first

- year start up costs for the purchase of hardware

systems that will be dedicated to processing, reporting and storing records related to the rule’s requirements

. These bu rdens are detailed in Tables 6

- 8 and 6

- 10

.

Manufacturers of vocational vehicle chassi s and tractors also will incur costs for the purchase of labeling equipment and a system for applying labels to their vehicles (pickup truck, van and engine manufacturers already label their equipment. The final rule requires these manufacturers to develop labels that will allow field inspectors to identify- 24

-

whether a vehicle is certified. Detai ls specifying the convention and information to be included on these labels has been published in §1037.135 of the regulations and is shown in Table 4

- 11 with the complete labeling requirements for

vehicles . See Table s 6

- 8 and 6

- 10 for estimated costs for acquiring labeling equipment.

As indicated in Table 6

- 6

, engine manufacturers will incur additional start up costs for the purchase of equipment to measure N2O

. The se costs assum e that 12 engine manufacturers purchase two N2O analyzers at $ 31,500

each

, for a total investment of $ 756,000.

6(c) Estimating Agency Burden

6(c) Estimating Agency Burden

Environmental Protection Agency (EPA)

Existing heavy duty certification and compliance programs are administered by EPA’s Compliance Division ( CD ). CD works closely with the Agency’s Testing and Advanced Technology Division (TATD ) to establish and implement testing programs that enable the Agency to ensure compliance with its mobile source emissions standards. Together CD a nd TATD have identified resources that are needed to support the National HD program, including FTE (full time equivalent) and information system upgrades.

Implementation of the HD GHG standards will be carried out in part by existing staff, but will rely primarily on the hiring of 10 new FTE. These new FTE will be split between developing and conducting HD test related activities

-- both in the field and out of EPA’s National Vehicle and Fuel Emissions Laboratory

-- as well reviewing certification

ap plications, evaluating test and related technical documents, and tracking credit programs.

We project 400 hours per week of staff time at $80 per hour (loaded to include benefits and overhead) will be expended by the agency to manage compliance related to the new GHG emission and fuel consumption standards. This comes to 20,800 hours or $ 1.664 million per year to oversee the requirements of the programs associated with this ICR. These labor estimates are based on Office of Personnel Management labor r ates effective January 201 1 , with a 2.1 multiplier used to account for benefits and overhead.

In addition to FTE costs, the Agency will need to develop a HD engine and vehicle compliance information

system. Th is system will serve as a singl e point of e ntry for manufacturers to submit and EPA t o collect emissions and fuel economy compliance information

. Both EPA and NHTSA will have access to this database system

. EPA

estimates it will incur a one

- time development cost of $1 million and ongoing, annu alized support costs of $150,000 for this database system

. Therefore, the total EPA cost is $2,814,000 per year for this rule as found in Table 6

- 3

Department of Transportation, National Highway Traffic Safety Administration (NHTSA)

NHTSA has an existing consumer average fuel economy program to increase the fuel economy performance of passenger cars and light trucks. The agency administers this program in conjunction with EPA and has four divisions in various program offices responsible for carry ing out the activities of the program. These divisions include the CAFE rulemaking, enforcement and regulatory analysis divisions and the Office of the Chief Counsel. NHTSA is developing and plans to support its fuel consumption program for heavy

- duty tr ucks as a part of its existing infrastructure for its LD CAFE program.

The agency plans to administer the HD program in the same manner it has historically done for the LD CAFE program. For both programs, manufacturers start the program each model year by submitting preliminary information in advance of the model year demonstrating their ability to comply with standards based on the test results of candidate makes and models. The information is used by EPA to conduct confirmatory testing and NHTSA condu cts random audit verifications. Manufacturers continue to test the majority of their fleets throughout the model year and then submit final reports after the model year ends to EPA. EPA verifies manufactures final demonstration results and submits the- 25

-

fi ndings to NHTSA. NHTSA determines compliance with its standards using a credits balancing system and imposes fines if necessary.

Administering the HD program for NHTSA will require using 8 persons on its existing staff and hiring two new

FTEs. One FTE will be an engineer and serve as the HD program’s project manager for rulemaking activities and the second will be a program analyst responsible for tracking credits and carrying out enforcement activities.

NHTSA expects to expend 43.8 hours per week o f staff time at cost of $80 per hour (loaded to include benefits and overhead) to manage its compliance activities (98 percent of the total hours) for and fuel consumption standards. In total, NHTSA calculates that it will use 2,279 hours or $ 182,368 per year to oversee the requirements of the programs associated with this ICR. These labor estimates are based on Office of Personnel Management labor rates effective January 2010, with a 2.1 multiplier used to account for benefits and overhead.

NHTSA will also incur cost for helping EPA maintain its compliance information database system. The final rule establishes a harmonized approach for the HD program by which manufacturers will submit compliance report s directly through the EPA system as the single p oint of entry for all GHG emission and fuel consumption information required for this national program . As a result, EPA will need to create access to its database system for NHTSA

. NHTSA estimates that annual costs for contributing to maintain the EPA d atabase in housing its fuel consumption information and ensure proper access to the data will cost approximately $80,000 per year. This soft estimate is based upon NHTSA’s experience with a web

- based system of comparable size and complexity. However, no costs are assigned on NHTSA’s part to enhance the system to meet our business requirements for this rule. EPA has agreed to assume all of these costs. Therefore, the total NHTSA cost is $262,368 per year for this rule as found in Table 6

- 3

.

6(d) Estimating the Respondent Universe and Total Burden and Costs

6(d)(1) Certification Estimates

There are 1 2 companies in this sector which manufacture on

- highway heavy

- duty engines and 15 companies

that manufacture vehicles that will be required to meet the proposed new greenhouse gas emission standards. Notably, although EPA has established distinct standards for the three vehicle categories covered by this rul e: 1) heavy duty pickup trucks/vans ; 2) vocational vehicles ; and 3) combination tractors

-- m any manufacturers are producing vehicles in more than one of these categories , and thus will be required to submit multiple certification applications.

In total, EPA projects that related to the HD Natio nal Program, it will receive 2 2 8 applications for certification,

as follows:

Engine Manufacturers Engine manufacturers and heavy

- duty truck and van manufacturers are currently regulated by EPA and are already familiar with EPA regulations

, policies and certification program . Under the proposed reg ulations, engine manufacturers will not be required to submit new certification applications, but will need to add CO2, N2O and CH4 test
information and results to their applications

. EPA expects that it will receive approximately 108 such amended applications from engine manufacturers in the future.

HD Pick u

p Trucks and Vans Although subject to regulation for non

- GHG emissions in the past, h eavy duty truck and van manufacturers

ha ve not been required to submit certification applications for GHG emissions and fuel consumption limits. To comply with the proposed new CO2, N2O and CH4 emission and fuel consumption standards, EPA expects to receive 24 certification applications from he avy duty truck and van manufacturers.

Vocational V

ehicle Chassis and Combination Tractors

F rom vocational vehicle chassis manufacturers EPA expects to receive 60 applications and from combination- 26

-

tractor manufacturers the Agency estimates it may receive 3 6 applications for certification in the first year and 32 applications in following years as we do not expect every manufacturer to produce tractors in each of the nine subcategories

.

Table 6

- 2 below, summarizes t he labor, start up a nd operations and maintenance costs associated with meeting the proposed GHG and fuel consumption standards. Tables 6

- 4 through 6

- 11 detail costs for the four categories of vehicle manufacturers affected by the proposal. These tables can be found startin g on page 30

.

6(e) Bottom Line Burden Hours and Cost Tables

(i) Respondent Tally

Bottom

- line burden and cost estimates for the first three years of the HD National Program are shown in the

table below . The table shows industry totals and values for each respondent by category by year

. T here is no burden on the respondents in years 2012

- 2013. The burden in the table represents the burden incurred beginning in year 2014, when the program becomes effective. The Summary of ICR Burden table in ROCI S includes the annualized values of

225 for the Annual Number of Responses, 41,305 hours of Annual Time Burden, and $1,458,333 in Annual Cost Burden (Capital and O&M Costs).

Table 6

- 2 Total Estimated Respondent Burden a nd Cost Summary

Manufacturer Program Number of

Respondents Number of

Responses Total Hours

Per Year Labor Costs Annual Capital

Costs Annual O&M

Costs Total Annual

Capital and

O&M Costs Total Labor,

Capital, and

O&M Costs

2014

Engine Testing &

Certification 12 108 2,970 $ 243,025 $756,000 $0 $756,000 $ 999,025

HD Truck/Van Testing &

Certification 3 24 9,852 $ 808,385 $75,000 $0 $75,000 $ 883,385

Vocational Vehicle Testing &

Certification 15 60 12,480 $1,014,925 $750,000 $180,000 $930,000 $ 1,944,925

Combination Tractor

Certification 4 36 32,762 $ 2,329,168 $1,000,000 $1,330,000 $2,330,000 $ 4,659,168

2015

Engine Testing &

Certification 12 108 2,538 $ 204,877 $0 $0 $0 $ 204,877

HD Truck/Van Testing &

Certification 3 24 4,086 $339,189 $0 $0 $0 $ 339,189

Vocational Vehicle Testing &

Certification 15 60 9,900 $ 809,689 $0 $18,000 $18,000 $ 827,689

Combination Tractor

Certification 4 32 16,402 $ 1,108,711 $0 $124,000 $124,000 $ 1,232,711

2016 Engine Testing &

Certification 12 108 2,538 $ 204,877 $0 $0 $0 $ 204,877

HD Truck/Van Testing &

Certification 3 24 4,086 $ 339,189 $0 $0 $0 $ 339,189- 27

-

Vocational Vehicle Testing &

Certification 15 60 9,900 $ 809,689 $0 $18,000 $18,000 $ 827,689

Combination Tractor

Certification 4 32 16,402 $1,108,711 $0 $124,000 $124,000 $ 1,232,711

2014

- 2016 TOTALS

2014 Total 228 58,064 $ 4,395,503 $ 2,581,000 $ 1,510,000 $ 4,091,000 $ 8,486,503

2015 Total 224 32,926 $ 2,462,466 $

- $ 142,000 $ 142,000 $ 2,604,466

2016 Total 224 32,926 $ 2,462,466 $

- $ 142,000 $ 142,000 $ 2,604,466

Three Year Total 34 676 123,916 $9,320,435 $2,581,000 $ 1,794,000 $4,375,000 $13,695,435

Annualized Burden 34 225 41,305 $3,106,812 $860,333 $598,000 $1,458,333 $ 4,565,145

(ii) The Tally for the Agenc ies

Table 6

- 3

Total Estimated Agency Burden a nd Cost Summary

Program Number of

Applications Number of

Activities Total

Hours

Per Year Total Labor Cost

Per Year Total Annual

Capital Costs Total Annual

O&M Costs Total Costs

EPA Emissions

Certification 2 2 5 10 20,800 $1,664,000 $1,000,000 $150,000 $2,814,000

DOT Fuel Consumption 2 2 5 10 2,279 $18 2,368 0 $80,000 $262,368

EPA & DOT

TOTALS 2 2 5 20 23,079 $ 1

, 846 ,368 $1,000,000 $230,000 $ 3,076,368

6(f) Reasons for change in burden

There is no change of hours in the total estimated burden compared with the ICR currently approved by OMB.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average
1,707 hours per respon dent , or 2 55 hours per application . 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 time neede d 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 exis ting ways to comply with any previously applicable 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 disclo se the information. An agency may not conduct or sponsor, 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 ( OMB

Control No. 2060

- 0678 )

.

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 t his ICR under Docket ID Number EPA

- HQ

- OAR

- 2010

- 1062 , which is available for online viewing at www.regulations.gov , or in person viewing at the Air and Radiation Docket and Information Center in- 28

-

the EPA Docket Cent er (EPA/DC), EPA 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 (2 02) 566

- 1744, and the telephon e number for the Air and

Radiation Docket and Information Center 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, acc ess the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically. When in the system, select “search,” then key in the Docket ID Number identified above. Also, you can send c omments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C.
20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OAR

- 2010

- 0 1 62 and

OMB Control Number 2060

- NEW in any correspondence.- 29

- Table 6

- 4 Annual Respondent Burden and Cost, 2 014 (Year 1) Heavy

- Duty Pickup Trucks and Vans Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium

- and Heavy

- Duty Engines and Vehicles

Hours and cost per application Total hours and cost

Information
Collection Activity Engineer

@82.24

/hr Manager

@ $106.50

/hr Legal

@ $138.20

/hr Test Cell

Operator
@ $48.40

/hr Clerical

@ $31.39/

hr Respond

. hr/yr Labor

Cost/yr Capital

Startup
Cost *Applications

/ respondent Number

of Respon. Total

hr/yr Total

Cost/yr

Review of regs and guidance

document 10 4 3 4 0 21 1,857 0 8.0 3 504 44,558

Test/Gather

emission data on

test vehicles (dyno) 12 4 0 8 0 24 1,800 0 30.0 3 2,160 162,007 Test Cost (Coast Down) 10 2 0 2 0 14 1,132 0 30.0 3 1,260 101,898 Analyze data to

determine compliance 16 4 2 2 0 24 2,115 0 8.0 3 576 50,761

Information Technology Upgrade 25,000 3 75,000 Prepare and

submit
certification application 16 24 6 4 16 66 5,397 8.0 3 1,584 129,525

Collect and
Submit Data for

ADFE model 65 15 0 10 2 92 7,490 0 8.0 3 2,208 179,757 Prepare &
Review GHG Compliance Plan 9 8 1 0 1 19 1,762 0 8.0 3 456 42,282

End

- of

Year/Final

Production Reports 20 10 8 0 8 46 4,067 0 8.0 3 1,104 97,596 Total per respondent 1,748 700 160 460 216 3,284 269,462 25,000 8 3 3,284 $294,462

Total for the industry 5,244 2,100 480 1,380 648 9,852 808,385 75,000 24 3 9,852 $883,385

*Three manufacturers are expected to submit 8 certification applications each (4 HD truck families and 4 HD van families) and conduc t coastdown and dyno testing on 30 vehicles among their different models- 30

- Table 6

- 5 Annual Respondent Burden and Cost, 2015

- 2016 (Ye ars2 & 3)

Heavy

- Duty Pickup Trucks and Vans Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium

- and Heavy

- Duty Engines and Vehicles

Hours and cost per application Total hours and cost

Information
Collection Activity Engineer

@82.24/

hr Manager

@ $106.50/

hr Legal

@ $138.20

/hr Test Cell

Operator
@ $48.40/hr Clerical

@ $31.39/

hr Respon.

hr/yr Labor

Cost/yr *Applications

/ respondent Number

of Respon. Total

hr/yr Total

Cost/yr

Review of regs and guidance

document 2 1 0 1 0 4 319 8.0 3 96 7,665

Test/Gather

emission data on

test vehicles (dyno) 12 4 0 8 0 24 1,800 7.0 3 504 37,802 Test Cost (Coast Down) 10 2 0 2 0 14 1,132 7.0 3 294 23,776 Analyze data to

determine compliance 16 4 2 2 0 24 2,115 8.0 3 576 50,761 Prepare and

submit "carryover" application 8 12 3 4 10 37 2,858 8.0 3 888 68,592 Prepare and

submit

certification applications 2 1 1 2 2 7 446 8.0 3 168 10,714 Prepare &
Review GHG Compliance Plan 9 8 1 0 1 19 1,762 8.0 3 456 42,282

End

- of

Year/Final

Production Reports 20 10 8 0 8 46 4,067 8.0 3 1,104 97,596 Total per respondent 610 326 116 142 168 1,362 113,063 8 3 1,362

Total for the industry 1,830 978 348 426 504 4,086 339,189 24 3 4,086 $339,189 In years 2 and 3 of program implementation, manufacturers will only be required to run coastdown and dyno tests on newly intr oduced vehicles- 31

- T able 6

- 6 Annual Respondent Burden and Cost, 2014 (YEAR 1)

Medium

- and Heavy

- Duty Engine Manufacturers
Greenhouse Gas Emi s sions Standards and Fuel Efficiency Standards for Medium

- and Heavy

- Duty Engines & Vehicles Hours and cost per application Total hours and cost

Information
Collection Activity Engineer

@82.24/

hr Manager

@ $106.50/hr Legal @

$138.20/

hr Test Cell

Operator @$48.40/

hr Clerical

@ $31.39/hr Respon.

hr/yr Labor

Cost/yr Capital

Startup
Cost O & M

Cost *Applications

/ respondent Number

of Respon. Total

hr/yr Total

Cost/yr

Review of regs and guidance

document 4 1 0 0 0 5 435 0 0 9.0 12 540 47,030 Testing/Gathe ring emission

data on test

vehicles 1 0 0 2 0 3 179 0 0 9.0 12 324 19,336 N2O Analyzer

Investment 0 0 0 0 0 0 0 31,500 0 2.0 12 0 756,000 Analyze data

to determine compliance 1 1 0 0 0 2 189 0 0 9.0 12 216 20,384 Prepare and

submit

certification application 1 1 1 1 1 5 383 0 0 9.0 12 486 ( 540) 41,313 Preparing and submitting "carry over" applications 1 1 0 0 0 2 189 0 0 9.0 12 216 20,384 Prepare &
Review GHG Compliance

Plan 2 2 0 0 0 4 377 0 0 9.0 12 432 40,768

Final Year

Production Update 4 1 0 0 0 5 435 0 0 9.0 12 540 47,030 Store, file and

maintain

records 0 0 0 0 2 2 63 0 0 9.0 12 216 6,780 Total per respondent 126 63 9 23 27 248 $20,252.07 31,500 0 9 12 248 $0

Total for the industry 1,512 756 108 270 324 2,970 $243,025 756,000 $0 108 12 2,970 ( 3024 ) $999,025 *Twelve manufacturers are expected to submit 9 certificat i on applications- 32

- Table 6

- 7 Annual Respondent Burden and Cost, 2015

- 2016 (YEARS 2&3)

Medium

- and Heavy

- Duty Engine Manufacturers
Greenhouse Gas Emis s ions Standards and Fuel Efficiency Standards for Medium

- and Heavy

- Duty Engines & Vehicles Hours and cost per application Total hours and cost

Information
Collection Activity Engineer

@82.24/

hr Manager

@ $106.50/

hr Legal

@ $138.20

/hr Test Cell

Operator @$48.40/

hr Clerical@

$31.39/hr Respon se

hr/yr Labor

Cost/yr Capital

Startup
Cost O & M

Cost(1) Applications/

respondent (2) Number of

Respon. Total

hr/yr Total

Cost/yr

Review of regs and guidance

document 2 1 0 0 0 3 271 0 0 9.0 12 324 29,266 Testing/Gatherin g emission data on test engines 1 0 0 2 0 3 179 0 0 9.0 12 324 19,336 Analyze data to

determine compliance 1 1 0 0 0 2 189 0 0 9.0 12 216 20,384 Prepare and

submit
certification application 1 1 1 1 1 5 383 0 0 9.0 12 486 41,313 Preparing and submitting "carry over" applications 1 1 0 0 0 2 189 0 0 9.0 12 216 20,384 Prepare &
Review GHG Compliance

Plan 1 1 0 0 0 2 189 0 0 9.0 12 216 20,384

Final Year

Production Update 4 1 0 0 0 5 435 0 0 9.0 12 540 47,030 Store, file and

maintain records 0 0 0 0 2 2 63 0 0 9.0 12 216 6,780 Total per respondent 99 54 9 23 27 212 $17,073.09 0 0 9 12 212 17,073

Total for the industry 1,188 648 108 270 324 2,538 $204,877 0 $0 108 12 2,538 $204,877- 33

- Table 6

- 8 Annual Respondent Burden and Cost, 2014 (YEAR 1)

Class 3

- 8 Vocational Vehicles
Greenhouse Gas Emi s sions Standards and Fuel Efficiency Standards for Medium

- and Heavy

- Duty Engines & Vehicles Hours and cost per application Total hours and cost

Information
Collection Activity Engineer

@82.24 /hr Manager @

$106.50/hr Legal @

$138.20/hr Clerical@

$31.39/hr Respon se

hr/yr Labor

Cost/yr Capital

Startup
Cost **O & M

Cost *Applications/

respondent Number of

Respon. Total

hr/yr Total

Cost/yr

Review of regs and guidance

document 20 6 2 0 28 2,560 0 0 4.0 15 1,680 153,612

Tire Tes ting (ISO28580) 2 1 3 271 12,000 40.0 15 1,800 342,588 Collect, Input
GEM Data & Run

Model 20 4 0 0 24 2,071 0 0 4.0 15 1,440 124,248 Analyze data to

determine compliance 10 4 1 0 15 1,387 0 0 4.0 15 900 83,196 Prepare and

submit

certification application 16 2 2 4 24 1,931 25,000 0 4.0 15 1,440 490,848 Labeling Requirements 8 3 2 4 17 1,379 25,000 0 4.0 15 1,020 457,763

Final Year

Production Update 40 4 0 8 52 3,504 0 0 4.0 15 3,120 210,233 Store, file,

maintain records 10 4 0 4 18 1,374 0 0 4.0 15 1,080 82,438 Total per respondent 576 148 28 80 832 $67,661.68 50,000 12,000 4 15 832 $129,662

Total for the industry 8,640 2,220 420 1,200 12,480 $1,014,925 750,000 $180,000 60 15 12,480 $1,944,925 *Based on 15 manufacturers, each submitting an average 4 applications for certificates of conformity to cover production of t heir Class 3, 4, 5, 6, 7 and 8 vocational trucks

** The O& M cost reflects each manufacturer testing 10 tires per application at a cost of $300 per tire ($300 * 4 applications * 10 tires= $12,000) for a total of 600 tires for the industry

.- 34

- Table 6

- 9 Annual Respondent Burden and Cost, 2015

- 2016 (YEARS 2&3)

Class 3

- 8 Vocational Vehicles
Greenhouse Gas Emis s ions Standards and Fuel Efficiency Standards for Medium

- and Heavy

- Duty Engines & Vehicles Hours and cost per application Total hours and cost

Information Collection Activity Engineer @82.24/

hr Manager

@ $106.50/

hr Legal @

$138.20/

hr Clerical

@ $31.39/

hr Respon.

hr/yr Labor

Cost/yr O & M

Cost *Applications/

respondent Number of

Respon. Total hr/yr Total Cost/yr

Review of regs and guidance document 8 3 1 0 12 1,116 0 4.0 15 720 66,937 Tire Testing (ISO28580) 2 1 3 271 300 4.0 15 180 34,259

Collec t, Input GEM Data

& Run Model 20 4 0 0 24 2,071 0 4.0 15 1,440 124,248 Analyze data to determine compliance 10 4 1 0 15 1,387 0 4.0 15 900 83,196 Prepar e and submit "carryover" application 16 2 2 4 24 1,931 0 4.0 15 1,440 115,848 Labeling Requirements 8 3 2 4 17 1,379 0 4.0 15 1,020 82,763

Final Year Production Update 40 4 0 8 52 3,967 0 4.0 15 3,120 238,001 Store, file, maintain

records 10 4 0 4 18 1,374 0 4.0 15 1,080 82,438 Total per respondent 456 100 24 80 660 53,979 $ 1,200.00 4 15 660 55,179

Total for the industry 6,840 1,500 360 1,200 9,900 $809,689 $18,000 60 15 9,900 $827,689 *Based on 15 manufacturers, each submitting an average 4 applications for certificates of conformity to cover production of t heir Class 3, 4, 5, 6, 7 and 8 vocational trucks
** The O&M cost reflects that each manufacturer will be able to carry

- over tire test results and estimates that each will test 1 new tire per certification at a cost of $300 per tire , for a total of 60 new tires each year for the industry

.- 35

- Table 6

- 10 Annual Respondent Burden and Cost, 2014 (YEAR 1)

Class 7

- 8 Combination Tractors Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium

- and Heavy

- Duty Engines and Vehicles Hours and cost per application Total hours and cost

Information Collection Activity Engineer @70.67/hr Manager

@ $106.49/hr Legal @

$138.2/hr Clerical@

$31.39/hr Respon.

hr/yr Labor

Cost/yr Capital

Startup Cost (1) O & M

Cost (2) Applications/

respondent (3) Number of

Respon. Total

hr/yr Total

Cost/yr

Review of regs and guidance document 10 10 5 0 25 2,463 0 0 9.0 4 900 88,654
Test tractors for Cd (coefficient of drag)

- Coast Down Testing 12 3 15 1,168 0 15,000 1.0 4 60 64,670

- Wind Tunnel Testing 8 2 10 778 0 20,000 10.0 4 400 831,134

- Cfd (initial drawing) 8 4 12 991 0 5,000 10.0 4 480 239,653

- Cfd (layers) 2 1 3 195 0 500 81.0 4 810 225,046 Tire Testing 0

- ISO 28580 6 2 8 637 0 300 90.0 4 2,880 337,320

Collect Data & Run
GEM 51 10 8 69 4,920 9.0 4 2,484 177,127 Labeling Requirements 40 8 6 500 554 20,203 100,000 0 1.0 4 2,444 480,812 Prepare & submit certification application 40 20 10 70 6,339 150,000 0 1.0 4 2,520 625,354

End

- of

- year Production Report 225 45 20 10 300 23,771 0 0 9.0 4 10,800 855,745 ABT, Emissions Credit Report 100 15 8 6 129 9,958 0 0 9.0 4 4,644 358,498 Store, file, maintain

records 80 20 10 40 150 10,421 0 0 9.0 4 5,400 375,156 Total per respondent 5,788 796 531 1,076 8,191 $ 81,843.06 $ 250,000 $ 40,800 9 4 8,191 Total for the industry 23,152 3,182 2,124 4,304 32,762 2,329,168 1,000,000 1,330,000 36 4 32,762 $4,659,168 (1) Capital start up costs include upgrades in information and management system to record and report test data to EPA (2) Operations & Maintenance Costs include contract costs for running coast down and wind tunnel tests (3) Four manufacturers will submit 9 applications for certification; conduct 1 coast down test; 10 wind tunnel tests; 10 initial Cfd drawings; 81 Cfd layers . Each manu facturer will test 10 tires per application
for a total of 360 tire s test ed for the industry

.- 36

- Table 6

- 11 Annual Respondent Burden and Cost, 2015

- 2016 (YEAR 2&3)

Class 7

- 8 Combination Tractors Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium

- and Heavy

- Duty Engines and Vehicles

Hours and cost per application Total hours and cost

Information Collection Activity Engineer @70.67/hr Manager @

$106.49/hr Legal @

$138.20/hr Clerical@

$31.39/hr Respon se

hr /yr Labor

Cost/yr *O & M

Cost Applications/

respondent Number of

Respon Total

hr/yr Total

Cost/yr Review of regs and guidance document 6 4 2 0 12 1,126 0 8.0 4 384 36,044
Tes t tractors for Cd (coefficient of drag)

- Coast Down Testing 0 0 0 0 0 0 15,000 0.0 4 0 0

- Wind Tunnel Testing 8 2 10 778 20,000 1.0 4 40 83,113

- Cfd (initial drawing) 8 4 12 991 5,000 1.0 4 48 23,965

- Cfd (layers) 2 1 3 195 500 9.0 4 90 25,005 Tire Testing 0 0

- ISO 28580 6 2 8 637 300 5.0 4 160 18,740

Collect Data & Run GEM 51 10 8 69 4,920 8.0 4 2,208 157,446

Lab eling Requirements 10 4 3 80 97 4,058 0 8.0 4 3,104 129,871

Pre pare & submit certification application, including carryover apps 40 20 10 70 6,339 0 8.0 4 2,240 202,835

End

- of

- year Production Report 80 5 2 10 97 6,776 0 8.0 4 3,104 216,843

ABT , Emissions Credit Report 60 15 4 6 85 6,579 0 8.0 4 2,720 210,518 Store, file, maintain records 20 10 2 40 72 4,010 0 8.0 4 2,304 128,330

Tot al per respondent 2,200 565 184 1,152 4,101 $ 36,410.22 8 4 Total for the industry 8,800 2,258 736 4,608 16,402 $ 1,108,711 $ 124,000 32 4 16,402 $1,232,711 * Operations & Maintenance Costs include contract costs for running coast down and wind tunnel tests

. The O&M cost reflects that each manufacturer will be able to carry

- over tire test results and

estimates that each will test 1 new tire per application at a cost of $300 per tire , for a total of 32 new tires each year for the industry.