Final

Supporting Statement

for

Information Collection Request

Motor Vehicle Emissions:

Revisions to Certification of Alternative Fuels Conversions 

EPA ICR 0783.59

Compliance and Innovative Strategies Division

Office of Transportation and Air Quality

Office of Air and Radiation

U.S. Environmental Protection Agency
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Part A SUBMISSION 

Section 1: Identification Of The Information Collection

1(a) Title And Number Of The Information Collection

Motor Vehicle Emissions: Revisions to Certification of Alternative Fuels Conversions;

EPA ICR number 0783.59, OMB control number 2060-0104.

1(b) Short Characterization/Abstract

The Environmental Protection Agency is finalizing a rule that is designed to 

simplify and lessen the burdens for conversion manufacturers seeking approval to introduce 

into commerce in the U.S. light-duty vehicles, light-duty trucks, medium-duty passenger 

vehicles, and heavy-duty vehicles and engines that have been converted for use of fuels 

that the original models were not designed for, such as from gasoline to liquid propane gas 

(LPG) or compressed natural gas (CNG). This ICR covers the light-duty portion of the rule. 

These applications are currently administratively handled as a part of EPA’s motor vehicle 

and engine certification program, covered by the ICR 0783 series. This ICR addresses the 

anticipated paperwork burden reduction within the context of the existing baseline from 

OMB 2060-0104 (ICR 0783.54), which was approved on August 31, 2009.

These changes would start taking effect with 2011 model year light-duty or 

medium-duty vehicles and trucks or upon the effective date of the final rule. Starting then, 

manufacturers will be given expanded options for submitting a simplified notification 

process in some cases. ICRs normally have a three year time horizon. This ICR will cover 

the expected paperwork burden changes for the three years after the effective date of the 

final rule. 

Information collected under the previous alternative fuels conversion program

consisted of test results and related submissions under existing procedures for the EPA 

light-duty vehicle certification program. All information from converter applicants is 

currently submitted electronically directly to the Verify system. Subject to confidentiality

claims, this information is made available to interested parties upon request. Emission test 

information is available on the internet.

The burden analysis in this ICR differs from the cost analysis in the preamble to the 

rule in important respects. First, ICRs are concerned with paperwork burdens, a subset of 

all business costs; this ICR covers the costs and labor hours of providing information to 

EPA, including both the paperwork itself and the costs and labor to develop the 

information, such as testing to provide test results, and facilities to carry out that testing. It 

is not concerned with the costs of compliance in general, nor with general business 

overhead or profits. The preamble, on the other hand, focuses on costs incurred by

conversion manufacturers such as contracts by converters with testing companies, which 

include overhead, profit and possibly compliance elements not counted in the 0783 series. 

The analysis in this ICR uses the traditional capital cost, O&M cost, and labor cost 
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assumptions in this ICR series, so that, for example, facility costs that would be recovered 

as part of a consulting firm's contract are here allocated to capital costs. Second, the 

preamble focuses on the burden for a single converter enterprise of interest, whereas the

ICR attempts to generalize the analysis to the industry as a whole.

The existing baseline estimates that certification applications for 36 test groups 

from five converter respondents are submitted annually. During the proposal phase of this 

rule, the most recent model year data available (model year 2008) showed 18 light-duty

vehicle conversions, and the draft ICR (0783.55) baseline was adjusted accordingly.

However, the number of certificates steadily increased in 2009 and 2010. In 2010, there 

were 42 new certificates issued for 7 different conversion manufacturers. Following this 

upward trend, this ICR adjusts the baseline to 50 new conversions from 8 conversion 

manufacturers and calculates industry savings against that number. The adjusted baseline 

also assumes 50 carryover applications. The analysis also gives the change in the 0783 ICR 

overall collection with the adjusted baseline after savings. 

These test groups consist of conversion systems that apply to a specific certified 

OEM (original equipment manufacturer) vehicle test group, or in some cases combinations 

of OEM test groups. As with OEM certifications, the biggest paperwork cost component 

for converters is testing. However, estimating testing costs under the existing regulations 

has been difficult because the fuel conversion program encompasses a diverse range of 

circumstances. Many of the tests are currently waived in certain situations. For example, 

currently, evaporative testing may or may not be waived depending on whether a closed 

fuel system is used. Exhaust and evaporative emission testing can be waived for dualfueled gasoline/LPG or gasoline/CNG vehicles if the modification doesn’t increase the 

weight more than 500 pounds and no increase in emissions is expected. (Assumptions for 

dealing with these complexities both in the existing program and under the final rule are 

discussed in Section 6.) 

The current baseline program costs applied to 50 new test group applications

estimates an industry total paperwork cost of $380,828. As with the main light-duty

program, this does not include development costs (such as repeated testing needed to 

perfect a conversion kit that can meet emission and OBD standards), which are not directly

mandated by the Clean Air Act but which can be considerable. Other elements of the 

alternative fuels certification process covered by this ICR are listed in Part 4 below, 

including paperwork filing burdens, which are budgeted in the ICR as O&M costs and 

labor hours. Converted vehicles are also, as with other certified vehicles, subject to EPA's

confirmatory testing program, durability demonstration, Vehicle Emission Control 

Information (VECI) labeling, defect and voluntary emission recall reporting, and other 

light-duty requirements (all covered in ICR 0783). In addition, they are subject to EPA’s 

certification fee requirements (ICR 2080; OMB 2060-0545) but burden changes in this 

program is de minimis (the number of fee forms affected is small and will be reflected in 

the next fees ICR renewal). All burden elements in this ICR are in the Emissions 

(Certification) IC. 

The proposed changes will recognize three classes of conversions: to (1) vehicles 
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that are new or relatively new, (2) vehicles within EPA’s definition of useful life but which

are neither new nor relatively new (“intermediate age vehicles”), and (3) vehicles that are 

outside EPA’s definition of useful life. For the newest vehicles, certification will still be 

required, but with some additional flexibilities and expansion of options. Conversion of 

intermediate age vehicles will be not be certified but audited through reporting of a testing 

demonstration that the converted vehicle family still meets emissions standards certified 

for the OEM vehicle family. For conversion of outside useful life vehicles EPA is 

finalizing a requirement for information submission demonstrating that the conversion is 

technically viable and will not increase emissions.

Beginning in model year 2011 or the effective date of these regulations, the 

proposed changes will reduce total costs annually on the regulated manufacturers by

$195,735 in non-labor costs and 23,267 labor hours.

Additional details on the coverage of this ICR are given in Section 2(b), below. 

Section 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 that comply with applicable 

emission standards set under section 202(a)(1) of the Act. A manufacturer must have a 

certificate before vehicles may be legally introduced into commerce. To insure compliance 

with the Act, EPA reviews product information and manufacturer test results; EPA also 

tests some vehicles to confirm manufacturer results. 

Section 203 of the Clean Air Act contains “anti-tampering” provisions prohibiting 

alteration of OEM vehicle components relevant to the vehicle’s certification under the Act. 

Regulations at 40 CFR, Part 85, Subpart F, provide exemption for aftermarket conversion 

systems from these tampering prohibitions for those converters complying with the 

regulations of that Part. Under Subpart F, these exemptions are currently administered 

through a certification process that is modeled on the OEM certification provisions: 

converters submit certification requests for engine families, and those that satisfy EPA’s 

regulations upon review are granted certificates of conformity for one model year. 

2(b) Practical Utility/Users of the Data

The information collection under the rule would be used to determine whether the 

new requirements have been complied with by means of the revised certification and 

compliance program. 

Section 3: Nonduplication, Consultations, and Other Collection Criteria

3(a) Nonduplication
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The information collection, reporting, and storage provisions of the proposed rule 

rely to the maximum extent possible on EPA’s existing certification program, while 

simplifying that program to reflect the needs of this industry.

Efforts have been made to eliminate duplication in this information collection. 

EPA-CISD (Compliance and Innovative Strategies Division) is currently using, for lightduty vehicles, a new information management system (Verify), under which the 

manufacturer submission process will occur within a Central Data Exchange (CDX) 

environment that should further help minimize duplication in submissions.

Because of its specialized nature and the fact that product plans and emission 

performance information must be submitted to EPA prior to the start of production, this 

information is not available from any source other than the manufacturer.

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

EPA solicited public comment by means of a Federal Register Notice published on May

26, 2010, 75 Federal Register 29606; a copy can be found at www.regulations.gov under docket 

EPA-HQ-OAR-2009-0299. The draft ICR was placed in the docket. No comments were 

received.

3(c) Consultations

The proposed regulations, including the cost analysis that is reflected in this ICR, 

were developed based on experience with similar regulations developed in the past in close 

consultation with the affected industry. EPA sought and received significant input and 

feedback from the fuel conversion community. 

In preparing the proposed rule, EPA made use of consultations with several 

converters and an independent test lab working in the regulated industry.

Their comments have been considered in developing the burden estimates discussed 

below. EPA wishes to thank them and their colleagues for their assistance in preparing this 

report.

3(d) Effects of Less Frequent Collection

As required by the Clean Air Act ( at 42 USC 7525(a)), emission information is 

currently submitted on a yearly basis coinciding with the manufacturer’s “model year.” 

EPA allows applicants to define their own “model year”, thus granting some flexibility in 

this regard. Major product changes typically occur at the start of a model year. For these 

reasons, a collection frequency longer than a model year is not normally possible. 

However, this rule would replace the annual application process with a one-time submittal 

for intermediate age and outside useful life vehicles, only requiring an end-of-year sales 

volume submission. In addition many conversion manufacturers will no longer need to 

renew their certificate of conformity; if the OEM vehicle design is “carried over” to a 
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subsequent model year, the amount of new information required is substantially reduced or 

eliminated. 

3(e) General Guidelines

Manufacturers are required to keep some records for periods longer than three years.

This requirement stems from the statutory requirement that manufacturers warrant some 

items for periods longer than 3 years. 

This information collection activity complies with the remaining guidelines in 5 

CFR 1320.5. The proposal makes no changes in the reporting and recordkeeping 

provisions that impact any of the guidelines for information collections as approved in the 

existing approved collection.

3(f) Confidentiality

Information submitted by manufacturers is held as confidential until the specific 

vehicle to which it pertains is available for purchase. After vehicles are available, most 

information associated with the manufacturer’s application is available to the public. 

Under section 208 of the Clean Air Act (42 USC 7542(c)) all information, other than trade 

secret processes or methods, must be publicly available. Proprietary information is granted 

confidentiality 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.

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.

Section 4: Respondents and Information Requested

4(a) Respondents/NASIC Codes

The respondents are potentially involved in the industries shown in the following 

table:

Industry 335312A

336312

336322

336399

454312

485310

Alternative fuel vehicle converters

A North American Industry Classification System (NAICS)

4(b) Information Requested
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(i) Data items

The information and reporting burden associated with this rule occurs within the 

context of EPA’s motor vehicle certification and compliance program. Current regulations 

require converters to submit emissions information to EPA in conjunction with this 

program. Converters of newer vehicles must submit an application for emission 

certification prior to production. Intermediately aged vehicle converters will submit a 

testing demonstration without the burdens of the formal certification application process. 

For vehicles converted outside their useful life, regulation will be through an information 

submission that the conversion is technically viable and will not increase emissions. These

reporting formats describe the major aspects of the proposed product line, technical details 

of the emission control systems, and the results of any required tests to indicate compliance 

with the emissions limitations. The reports and supporting test results are reviewed and, if 

appropriate, a certificate of conformity is issued, the applicant is notified of possible 

noncompliance with anti-tampering provisions, or additional post-production information is 

requested. 

New/revised data items:

At the time of certification:

For all vehicles: 

 expanded conversion test or "demonstration" groups

 exemption from HCHO testing for conversions to CNG and 

LPG 

 conversion factors for calculating NMOG for conversions to 

CNG and LPG 

 new VECI label requirement describing test group, mileage, 

and date

 renewal application for certificates for “carryover” test groups 

is optional

For intermediate-age and outside useful-life age vehicles (25%):

 online notification and test result report rather than application 

for certification (savings in “paperwork” burden) or 

compliance “demonstration” for outside useful-life conversions

 description of OBD compliance strategy and for intermediateage vehicles an OBD scan tool report rather than current OBD 

test results

(ii) Respondent Activities

While there is no “typical” converter respondent, all converters must describe their 

product and supply test data and other information to verify compliance. In some cases the 

proposal would replace the current application and certification process with a notification 
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and audit process. Applicants for certification submit certification fees, usually “reduced

fees” set at 1% of the estimated retail sales value of the conversion package, including 

labor. Converters or installers of conversion kits must install a second VECI label on 

converted vehicles. Converters must also retain records. These tasks may be repeated for 

each conversion model year, although previous data and information may be “carried 

over” when no changes have occurred. Carryover, intermediate and outside useful-life test 

group manufacturers will continue to be subject to the end-of-model-year sales reporting 

through the same existing Verify reporting module that applies to their new test groups. 

Section 5: The Information Collected—Agency Activities, Collection Methodology, and 

Information Management

5(a) Agency Activities

The test data used by EPA to determine compliance with emissions standards are

derived from vehicle testing done by vehicle converters who report their own test data to 

EPA, and at EPA's National Vehicle and Fuel Emissions Laboratory in Ann Arbor, 

Michigan. EPA staff review applications (or notifications or demonstrations), issue 

certificates, and oversee the program. 

5(b) Collection Methodology and Management

All information from converter applicants will be submitted electronically directly

to the Verify system by the effective date of the new rule. By guidance letter CISD-09-14, 

vehicle converters are required to submit applications for certification through Verify

beginning with the 2010 model year. The rule makes no changes in this reporting system, 

only changing the format and content of some of the information reported within it.

All information received by EPA is subject to review. Data submitted are screened

to determine that the test results insure compliance with emission and fuel economy

standards. Narrative descriptions of the proposed product line are checked to verify that 

the appropriate "worst case" vehicles have been tested. Except for projected sales and a 

very limited amount of proprietary product information, all information is available to the 

public as soon as the vehicle is offered for sale. Emission data are available on the

internet; other information is available upon request under the Freedom of Information Act.

5(c) Small Entity Flexibility

Many conversion manufacturers already enjoy various exemptions and special 

provisions tailored to their small entity status and special business needs in contrast to 

original vehicle manufacturers, such as use of assigned deterioration factors, exemption 

from the manufacturers’ in-use vehicle testing program (IUVP) and availability of reduced 

certification fees. This proposal further extends this flexibility in numerous ways detailed 

in the proposal and summarized in this Supporting Statement. 
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5(d) Collection Schedule

Currently, information must be submitted for each “conversion model year” that a 

manufacturer intends to convert vehicles. Under the final rule, only the newest vehicles 

will be required to renew annually, if a new certificate is desired, but all categories will file 

an end-of-year report (as do light-duty manufacturers). For emissions 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. 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.

Section 6: Estimating the Burden and Cost of the Collection

The following estimates of reduced burden use baselines and methodologies 

developed in the process of continuing updates of the 0783 ICR series, including the last 

renewal (ICR 0783.54), and the greenhouse gasses rule (ICR 2387.01). The reasoning 

behind estimates of decreased burden from the current baseline are given below and 

summarized in Section 6(f). 

6(a) Estimating Respondent Burden (Hours)

As noted above, the number of converter test groups covered by the ICR is subject 

to small number fluctuations as well as a recent upward trend. The baseline in the last 

renewal (ICR 0783.54) was 36 test groups; in the renewal three years before that (ICR 

0783.47) it was 15. Following normal practice, the baseline is here adjusted to reflect the 

most current information available; we predict 50 new light-duty conversion test groups for 

Model Year 2011. The Emissions IC will reflect this adjustment. The discussions below 

compare the burdens on 50 families before and after the proposal. 

Within the converter program under the adjusted baseline, the respondent hours 

burden decrease for the Light-Duty Vehicle Emissions Information Collection reflects 

reduced labor hours associated with conducting tests and reduced reporting. This is largely

due to the broader definition of test groups, since this definition determines how many tests 

must be conducted. The paperwork reporting burdens in particular are significantly reduced 

for intermediate and outside useful-life conversions. As converters are a very small subset 

of the current light-duty baseline (prior to this ICR, 36 out of 427 families, after this ICR, 

50 reduced to 38 out of 429), the decrease in burden is correspondingly small; but for 

vehicle converters the hour savings are significant (from 41,802 hours down to 18,535

hours, a savings of over 45% (23,267 hours).

In particular, the number of test groups requiring any reporting under this rule is 

estimated to be reduced by at least 25 percent. This correspondingly reduces the labor 

hours associated with conducting emissions tests (including preparation costs, FTP tests, 

NMOG tests and HFET tests), OBD compliance reporting, confirmatory testing costs 
10

(including shipment costs), and paperwork reporting and recordkeeping costs associated 

with preparing this information in any of the required formats and submitting it to EPA for 

review and saving it for possible submission to EPA upon request. Intermediate age and 

outside useful life conversion test groups are estimated to achieve an additional 80 percent 

reduction in paperwork reporting for those qualifying.

The ICR includes a minor startup cost for implementing new labeling requirements. 

All labor hours associated with startup costs are treated as capital/startup costs, so they are 

included under that heading, following EPA guidance (EPA ICR Handbook, Rev. 11/05, p. A31). 

6(b) Estimating Respondent Costs

(i) Estimating labor costs

Labor costs for testing follow the testing labor cost assumptions of ICR 0783.54 and 

average out to $59.07 per hour across management, technical, and secretarial categories. This 

figure, which was initially based on the fees rule cost study of EPA laboratory expenses, 

matches very closely with an analysis based on rates for engineering managers, mechanical 

engineers, and secretaries (except legal, medical, and executive) from the May 2005 BLS 

National Industry-Specific Occupational Employment and Wage Estimates 

(http://www.bls.gov/oes/current/naics4_336100.htm , accessed August 22, 2006). With a 160% 

overhead multiplier, these are $81.38, $49.71, and $33.57, respectively. The next renewal of the 

ICR will likely update this figure. 

(ii) Estimating Operations and Maintenance Costs

Operation and Maintenance costs are the non-labor costs associated with conducting 

the new tests that are anticipated for the full model year after the effective date of the new 

regulations. The O&M costs for conducting emissions tests follow the assumptions in prior 

ICRs in this series, with an improved figure for NMOG and HCHO analysis, totaling about 

$4,000 per vehicle, with another $3,600 for OBD compliance (about $50 for intermediateage OBD scan tool test) and $2,000 for each confirmatory test. The estimate also includes 

O&M items for evaporative emissions testing, and reporting and recordkeeping, with the 

baseline total coming to about $10,000 per activity (test group). Applied to the industry, 

the baseline O&M cost is $380,828 annually. The revised regulation reduces this figure by

$195,735, to $185,093. This is primarily due to 1) reduction in the number of test groups 

by at least 25%; and 2) savings of $1,750 in NMOG and HCHO testing per test group.

(iii) Start-up and Other Capital Costs

“Startup” costs are one-time costs to implement the new requirements in the proposal that 

are applicable to the next model year conversions being certified or by the respondent converters 

after the effective date of the final rule. 

Startup costs are included for redesign of the VECI label. This burden is an add-on to 

well established reporting requirements: manufacturers already submit similar label data to EPA. 
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Once the new label templates are in place, we anticipate no increase in burden for this startup 

item. This part of the estimate costs new analysis and coding for 50 test groups, reduced to 38

by the new rule. This is a small item, less than $10,000 for the industry, and is annualized and 

discounted at 7% in the cost estimate. 

Second this ICR series estimates capital costs associated with the testing requirements. 

Because manufacturers vary widely in their existing testing facilities, their excess capacities, 

their work shift arrangements and availabilities, the real estate cost and land availabilities for 

hypothetical expansions, and their contractual arrangements with other testing facilities, CISD 

has for many year now used the approximation that a facility capable of performing 750 

FTP/HFET tests per year costs $4,000,000 and allocated this cost to each testing increment. This 

cost is then allocated over ten years and discounted at 7%. This methodology is considered 

conservative, because it assumes no excess capacity. Similarly, evaporative facilities are costed 

at $3,000,000 to conduct 900 evaporative tests a year. While most converters work through 

contractors whose contract costs do not break down costs in this manner, for consistency the 

analysis in the Certification IC series 0783 is continued here. 

Primarily due to the reduction in the number of test groups (slightly offset by the new 

labeling startup) he total non-depreciated capital costs for the conversion program of $318,333 

are reduced by $146,400 to $171,933.

6(c) Estimating Agency Burden

The emission and fuel economy compliance programs are primarily administered by

EPA’s Compliance and Innovative Strategies Division and Laboratory Operations Division. 

Approximately 47.5 full time employee equivalents are directly involved in the combined 

emission and fuel economy light-duty, motorcycle, and other, secondary programs; their 

cost is approximately $5.9 million, including benefits but not overhead. EPA also 

participates in a program whereby the agency contracts with an organization that provides 

qualified persons to perform duties for the agency that are not performed by EPA 

employees. The cost associated with these persons who work directly on these programs is 

approximately $0.23 million, excluding overhead. Overhead percentage for the entire 

division is approximately 16.9%, yielding an estimated total agency labor cost of $7.17 

million. The total non-capital costs for the light-duty and motorcycle programs, including 

direct and indirect labor, operations and maintenance, and overhead, is estimated as $11.14 

million for FY 2007. 

Implementation of the new alternative fuels rule will be carried out by existing staff.

Other ongoing database management, oversight, and certification activities are part of the 

fuel economy and emissions program Agency baseline. All EPA labor estimates are based 

on Office of Personnel Management draft annual pay rates effective January, 2008, with a 

1.6 multiplier for overhead based on EPA’s latest fees cost allocation study (1.37 indirect 

program cost overhead times 1.16 overall EPA overhead). This estimate does not include 

Agency burdens incurred prior to the effective date of the rule, such as costs of developing 

the rule and preliminary consultations with converters. 
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6(d) Estimating the Respondent Universe and Total Burden and Costs

From the above discussion the following total burden and cost estimates can be 

calculated. (Due to the diverse nature of the converter industry, there is no typical or 

average respondent.)

6(e) Bottom Line Burden Hours and Cost

(i) Respondent Tally

[a] Overall Emissions IC

This analysis is against the Emissions IC baseline in ICR 0783.54. EPA has another 

recent rulemaking (Revisions to Reduce Emissions of Greenhouse Gases; EPA ICR 2387.01) 

which will result in other changes.

[1] Existing authorization

RESPONDENTS 35

BURDEN HOURS 362,033

LABOR COST $6,308,800

OPERATING COST $5,929,702

CAPITALIZED COST $2,256,127

TOTAL NON-LABOR COST $8,185,829

[2] After final rule

RESPONDENTS 38

BURDEN HOURS 350,830

LABOR COST $5,612,,466

OPERATING COST $5,848,800

CAPITALIZED COST $2,247,926

TOTAL NON-LABOR COST $8,096,726

[3] Change in burden

BURDEN HOURS -11,203

LABOR COST -$696,334

OPERATING COST -$80,920

CAPITALIZED COST -$8,201

TOTAL NON-LABOR COST -$89,103

[b] Alternative Fuels Converters

[1] Existing baseline
13

RESPONDENTS 5

FAMILIES 36

BURDEN HOURS 29,738

LABOR COST $1,756,606

OPERATING COST $241,566

CAPITALIZED COST $32,630

TOTAL NON-LABOR COST $274,196

[2] After final rule

RESPONDENTS 8

FAMILIES (75% OF 50) 38

BURDEN HOURS 18,535

LABOR COST $1,060,272

OPERATING COST $160,664

CAPITALIZED COST $24,429

TOTAL NON-LABOR COST $185,093

[3] Change in burden

BURDEN HOURS -11,203 

LABOR COST -$696,334

OPERATING COST -$80,920

CAPITALIZED COST -$8,201

TOTAL NON-LABOR COST -$89,103

[4] Reduction in burden applied to 50 families without final rule changes

BURDEN HOURS -23,267

LABOR COST -$1,408,994

OPERATING COST -$174,845

CAPITALIZED COST -$20,890

TOTAL NON-LABOR COST -$195,735

(ii) Agency Tally

EMPLOYEES 47.5

CONTRACT LABOR COST $0.27 million

COST $11.1 million

6(f) Reasons for change in burden

The burden change is from changes in the baseline number of test groups, a 

reduction in the number of test groups after accounting for this baseline change, and 

reductions in the capital and operations and maintenance costs and labor hours associated 
14

with implementing the new programs detailed above.

6(g) Burden Statement

The table in Section 6(e)(i)[b][2] presents the total estimated burden for the alternative 

fuels conversion light-duty program after the final rule: approximately 18,535 hours per year, 

with total annual capitalized and O&M costs estimated at $185,093. These represent a savings of 

11,203 hours and $89,103 over the existing alternative fuels light-duty baseline, notwithstanding 

application of program costs to an increased number of manufacturers and test groups. The 

annual costs and hours for information collection activities by a given manufacturer under 

any of the options in this proposed rule depend upon manufacturer-specific variables, such 

as the number of different test groups and the number of vehicles tested. The estimated 

number of likely respondent manufacturers is 8. The responses will be submitted annually

and occasionally as a part of the existing EPA certification program. 

Burden means the total time, effort, or financial resources expended 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.

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 

rule, which includes this ICR, under Docket ID number EPA-HQ-OAR-2009-0299. Submit 

any comments related to the ICR for this proposed rule to EPA and OMB. Submit your 

comments, identified by Docket ID No. EPA-HQ-OAR-2009-0299, by one of the following 

methods:

• www.regulations.gov: Follow the on-line instructions for submitting 

comments.

• Fax: (202) 566-1741. 

• Mail: Environmental Protection Agency, EPA Docket Center (EPA/DC), Air 

and Radiation Docket, Mail Code 6102T, 1200 Pennsylvania Avenue, N.W., 

Washington, DC 20460, Attention Docket ID No. EPA-HQ-OAR-2009-0299. 

In addition, please mail a copy of your comments on the information 

collection provisions to the Office of Information and Regulatory Affairs, 

Office of Management and Budget (OMB), Attn: Desk Officer for EPA, 725 

7th St. NW., Washington, DC 20503.”

• Hand Delivery: Docket Center, (EPA/DC) EPA West, Room B102, 1301 
15

Constitution Ave., NW, Washington, DC., Attention Docket ID No. OAR2009-0299. Such deliveries are only accepted during the Docket’s normal 

hours of operation, and special arrangements should be made for deliveries 

of boxed information 

Docket ID No. EPA-HQ-OAR-2009-0299, is available for public viewing at the Air And 

Radiation Docket in the EPA Docket Center (EPA/DC), EPA West, Room B102, 1301 

Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room 

is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. 

The telephone number for the Reading Room is (202) 566-1744, and the telephone number 

for the Air and Radiation Docket is also (202) 566-1744. An electronic version of the 

public docket is available through EPA Dockets (EDOCKET) at www.regulations.gov.