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Supporting 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 2394.03

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
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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 Standards (Renewal), EPA ICR Number 2394.03, OMB Control Number 2060-0678.

1(b) Short Characterization

The Environmental Protection Agency (EPA) and the National Highway Traffic Safety Administration 

(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 testing, reporting, and recordkeeping requirements. The paperwork and cost burdens 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-duty trucking sector has been to set standards that reduce 

emissions from a truck’s engine. The agency’s focus on setting standards that reduce HD engine emissions is due mostly 

to the fact that engines are primarily responsible for emissions of “criteria pollutants,” 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 Air Act (CAA) and the Energy Independence and 

Security Act of 2007 (EISA) to establish fuel efficiency and greenhouse gas emissions standards for commercial 

medium-and heavy-duty on-highway vehicles and work trucks 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, reducing 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 categories of heavy-duty vehicles, including combination tractors, vocational vehicles and heavy-duty pickup 

trucks and vans.

Importantly, the HD National Program recognizes that under EPA regulations covering criteria pollutants, 

heavy-duty engine and pickup truck 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 utilize their 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 standards. 

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 consumption 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 

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

manufacturers through a single database system. Both EPA and NHTSA have access to data in this database system, 

which also helps the Agencies to efficiently review, process, and store the heavy duty data relevant to each agency’s 

program requirements. 

 

Over the next three years, 12 engine manufacturers and 22 vehicle and chassis manufacturers will submit 228

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 

Program.

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

submit reports 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 certificate of conformity and gain approval by EPA before it can legally introduce any vehicle 

or engine into commerce in the U.S. To ensure 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 performed 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 engines and vehicles, and conducted the testing necessary to demonstrate that their equipment

complies with the new GHG emissions and fuel consumption standards. 

 The first year the program becomes effective is in the calendar year 2014. These collection activities are 

estimated to impose annual costs of $8.5 million and a labor hour burden of 58,064 hours. In subsequent years, years 

2015 and 2016, annual 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 authority 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 prescribed 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 results, as part of their application for a certificate of conformity, under CAA §217, 

manufacturers are required to pay an application fee when applying for a vehicle or engine certificate. At this time, the 

exact costs associated with the heavy-duty vehicle GHG compliance are not known. The Agency is not modifying its 
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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 regulations to include any warranted new 

costs. 

EPA and NHTSA also established 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. Engine and vehicle manufacturers covered by this

HD National Program have an option to participate in this ABT program. The Agencies’ ABT programs, and 

others like it, are designed to enhance compliance flexibility and reduce the burden on affected manufacturers, 

without compromising the expected emissions benefits derived from EPA’s emissions standards and NHTSA’s 

fuel consumption standards. 

EPA’s new GHG standards for HD engines and vehicles amend 40 CFR Part 86 subchapter U with the 

addition of two new parts: part 1036 (engines) and part 1037 (vehicles). 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 through 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, and 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 amendments 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. These

regulations are not attached to this statement due to their length and technical nature. 

2(b) Need/Authority for the Collection

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

selected the proper engines and vehicles, and conducted the testing necessary to demonstrate that their equipment

complies with the new GHG emissions and fuel consumption standards.

Under the rule, manufacturers of heavy-duty pickup trucks and vans will submit “pre-model year reports” to 

satisfy both EPA and NHTSA’s requirements for receiving compliance reports in advance of the model year. These premodel 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 chassis 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 Agencies treat information submitted in the applications as a manufacturer’s demonstration of providing early 

compliance 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 pre-model reports and certification applications to support various enforcement actions, such as 

selective enforcement audits and in-use compliance testing. 

As noted, the 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 NHTSA collect data to ensure that allowable emission and fuel consumption credits are 
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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-model year report and certification applications. 

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 other data collected, such as notifications that a 

manufacturer intends to participate in the ABT program or that a vehicle qualifies for an exclusion are needed so 

that the agencies can ensure that manufacturers are complying with the HD National Program’s regulatory 

provisions. A summary of required information for compliance is listed in Tables 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 provisions 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 information 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 

collection 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 required is substantially reduced. Existing regulations 

also call for an end-of-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 including, 

pre-model reports, certification applications, ABT, and end-of-the-year reports, 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, if requested. These recordkeeping requirements stem, in part, from the statutory requirement to 

warrant some items for long periods of time. Manufacturers also must comply with requirements to submit to an EPA 

audit, and recall vehicles and engines failing to meet emission standards during their useful lives. Other data, (such as 
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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. 

Manufacturers 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 Information 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-108.

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 and 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 premodel 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 manufacturer 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 their 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 testing 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 category is outlined 

in the rule §1036.230 (engines) and §1037.230 (heavy duty pickup trucks and vans, vocational vehicles and 
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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 describes 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 labels. 

All manufacturers also are required to submit end-of-year (EOY) production reports that will be used to 

reconcile pre-model production estimates with 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 emissions 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

Summary 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 volumes

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 year 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.
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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: emissionsrelated 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 years 2015 - 2018. Under this timeframe, manufacturers 

will begin to test and submit their applications and other pre-production documents 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 compliance activities. 

(i) Data Items

In addition to the data items described above, brief summaries of the new data items the Agency collects

from engine manufacturers and the three regulatory categories of the heavy duty truck manufacturers covered by 

the rule are provided below. Detailed lists of these data items are given in Tables 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 test procedures and reporting 

programs already in place for vans and pickup trucks. For example, the test procedures, GHG and fuel 
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consumption standards for heavy duty pickup trucks and vans apply to the complete vehicle, just as similar 

procedures 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). 

Using test procedures, reporting and compliance requirements 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 capacity, which support the GHG emission and fuel consumption limits for this 

vehicle category. Manufacturers are required to apply these attributes when establishing vehicle test groups to 

demonstrate compliance with the CO2 and fuel consumption standards. These attributes also are factored into 

the production volume-weighted calculation of a manufacturer’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 employed 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 demonstrate compliance. 

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

vehicle manufacturer must calculate 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 Light 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

Expected CO2, N2O, CH4, and HFC emissions and fuel consumption test group results and fleet average performance

A statement declaring whether the manufacturer will 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 chooses 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 consumption 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 target standards and 

performance test results
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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 target 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 derive 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 manufacturer 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 within a period of up to 

three model years after that deficit has occurred

For the purposes of this ICR, the test data accompanying these applications will include results from 

coast down and chassis tests. HD pickup trucks and vans also are subject to new 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 Tables 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 regulations

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 final 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 

pollutants. In constructing a program to address GHG pollutants, EPA has built 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 performance, and that having two distinct family 

designations per engine (one for criteria pollutants and one for CO2) would be overly burdensome without 
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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 majority of these requirements will be reported to the agency through the HD engine certification template 

provided to manufacturers. 
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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 engines 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 its 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 its applications 

for certificates of 

conformity

NA §535.8
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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 its applications 

for certificates of 

conformity

§1036.150 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 its

applications for 

certificates of conformity

§1036.150 §535.8

Alternate 

phase-in

Engine manufacturers that want to 

comply with alternate phase in 

standards.

EPA and NHTSA must be 

notified before the 

manufacturer submits its

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 modified 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 
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measuring GHGs, and in the rule, compliance with NHTSA’s fuel 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, 

manufacturers 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/Gathering 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 existing 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 measuring N2O or submitting a compliance statement based on good engineering 

judgment. As shown in Table 6-6, the 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 application (including carryover applications)

Prepare and review GHG compliance plan

End of year and final production reports

Store, file and maintain records

Vocational Vehicles and Combination Tractors

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

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

that the HD National Program presents these segments with several new testing, reporting, recordkeeping, and 

labeling requirements, as shown in Tables 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 fuelsystem 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) The 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 cycle 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 used 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 vehicle (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 families containing multiple subfamilies, this means that you must identify multiple CO2 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 vehicles 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 emission-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 

configurations 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. Include 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 located 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 1037.205 

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.

NHTSA 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 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 

applications for 

certificates of 

conformity

§1037.150 §535.8

Exemption for electric 

vehicles

All electric vehicles are deemed 

to have zero exhaust emissions 

of CO2, CH4, and N2O

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 

(such 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 label 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, alternatively, 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 include 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 regulations and guidance document

Prepare and submit certification application (including carryover applications)

Labeling requirements

Final year production 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 fuel consumption standard is represented as gallons of fuel used to move one ton of freight

(payload) 1000 miles, 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 conditioning 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 demonstrate compliance with the new GHG standards. Under the rule, 

manufacturers evaluate and report CO2 emissions and fuel consumption through a simulation of the ir vehicles

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 data 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/transmission/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 preprogrammed 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. 

Manufacturers will however, be required to test their vehicles, collect data and input at least two key 

data elements (based on testing) prior to running 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 “CdA”) of a truck. 

Additional inputs needed to run the GEM include basic 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 (using 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, the 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 that 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 rolling resistance of their steer and drive tires, combination tractor 

manufacturers must also establish the GEM inputs for the aerodynamic drag – expressed as the coefficient of 

drag or “CdA” – 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 CdA 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 CdA values. These test methods include coastdown testing, wind tunnel testing and 

computational fluid dynamics.

To estimate the cost associated with testing combination tractors to establish a CdA, procedures 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 dynamics in establishing a CdA 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 CdA

established from coastdown testing, manufacturers have the option of developing an 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 alternate 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 contract costs (operations and maintenance, or “O&M”) presented in Table 6-10 assume that tractor 

manufacturers will choose to derive and apply an adjustment factor to establish the CdA 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 burdens for tractor manufacturers are presented as O&M costs, based on 

the assumption that manufacturers will contract out the testing – coastdown and wind tunnel - needed to establish the 

CdA for their vehicles, and subsequently to run the GEM. 

Tractor manufacturers also will have options for including 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 conditioning 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 applications 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 design, 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 types 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 or 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 vehicles

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 applications 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 of 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 

includes January 1 of that calendar year; or that calendar year if the manufacturer does not have an annual 

production period. 

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

manufacturer conducts are 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 determined to a large extent by the 

manufacturer’s marketing and production 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 three of the program. These tables represent burdens and costs for 

manufacturers of HD engines 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 account 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 $106.50

Test Cell Operator $23.05 $48.40

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 CdA, also 

needed to demonstrate 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 CdA 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 aerodynamic 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, are costs associated with information management. 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 requirements 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 certification data, this start up cost is not so significant.

Tables 6-4 and 6-6 reflect start-up 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 burdens are detailed in Tables 6-8 and 6-10. 

Manufacturers of vocational vehicle chassis 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. Details 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 Tables 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. These costs assume 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 and 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 

applications, 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 rates effective January 2011, 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. This system will serve as a single point of entry for manufacturers to submit and EPA to 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, annualized 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 carrying 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 trucks 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 conducts 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-

findings 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 of 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 reports 

directly through the EPA system as the single point 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 database 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 12 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 rule: 1) heavy duty 

pickup trucks/vans; 2) vocational vehicles; and 3) combination tractors -- many 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 National Program, it will receive 228 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 regulations, 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 Pickup Trucks and Vans

Although subject to regulation for non-GHG emissions in the past, heavy duty truck and van manufacturers 

have 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 heavy duty truck and van manufacturers. 

Vocational Vehicle Chassis and Combination Tractors

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

tractor manufacturers the Agency estimates it may receive 36 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 the labor, start up and 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 starting 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. There 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 ROCIS 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 and 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 Agencies

Table 6-3

Total Estimated Agency Burden and 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

225 10 20,800 $1,664,000 $1,000,000 $150,000 $2,814,000

DOT Fuel 

Consumption

225 10 2,279 $182,368 0 $80,000 $262,368

EPA & DOT 

TOTALS

225 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 respondent, or 255 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 needed to review instructions; develop, acquire, install, and utilize technology and systems for the 

purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and 

providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; 

train personnel to be able to respond to a collection of information; search data sources; complete and review the 

collection of information; and transmit or otherwise disclose the information. An agency 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 this 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 Center (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 (202) 566-1744, and the telephone 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, access 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 comments 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-2010-0162 and 

OMB Control Number 2060-NEW in any correspondence.
-29-

Table 6-4

Annual Respondent Burden and Cost, 2014 (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-ofYear/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 conduct coastdown 

and dyno testing on 30 vehicles among their different models
-30-

Table 6-5

Annual Respondent Burden and Cost, 2015-2016 (Years2 & 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-ofYear/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 introduced vehicles 
-31-

Table 6-6

Annual Respondent Burden and Cost, 2014 (YEAR 1)

Medium- and Heavy-Duty Engine Manufacturers

Greenhouse Gas Emissions 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 certification applications 
-32-

Table 6-7

Annual Respondent Burden and Cost, 2015-2016 (YEARS 2&3)

Medium- and Heavy-Duty Engine Manufacturers

Greenhouse Gas Emissions 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

Response 

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 Emissions 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

Response 

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 Testing 

(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 their 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 Emissions 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

Collect, 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

Prepare 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 their 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 manufacturer will test 10 tires per application 

for a total of 360 tires tested 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

Response 

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

Test 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

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

Prepare & 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

Total 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.