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

EPA I CR 0783. 5 9

C ompliance and Innovative Strategies Division Office of Tran sportation and Air Quality Office of Air and Radiation U.S. Environmental Protection Agency2 Part A SUBMISSION Section 1: Identification Of T he I nformation Collection 1(a) Title A nd Number Of T he Information Collect ion Motor Vehicle Emissions: Revision s to Certification of Alternative Fuels Conversions ; EPA IC R number 0783. 5 9 , OMB control number 2060 - 0 104. 1(b) Short Characterization/Abstract The Environmental Protection Agency is finalizing a rule that is designed to simplifyand lessen the burdens for conversion manufacturers seeking approval to introduce into commerce in the U.S. light - duty vehicles , light - duty trucks , medium - dut y passenger vehicles, and heavy - duty vehicles and engines that have been converted for use of fuels that the original mod els were not designed for, such as from gasoline to liquid propane gas (LPG) or compressed natural gas (CNG) . This ICR covers the light - dut y portion of the rule . Th ese applications are currently administrativelyhandled as a part of EPA’s motor vehicle and engine certification program, covered bythe I CR 0783 series. This ICR addresses the anticipated paperwork burden reduction within the context of the existing baseline from OMB 2060 - 0104 (ICR 0783.54) , which was approved on August 31, 2009. These chang es would start taking effect with 20 1 1 model y ear 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 s ome cases . ICRs normallyhave a three y ear time horizon. T his ICR w ill cover the expected paperwork burden changes for the three y ears after the effective date of the final rule . In formation collected under the previous alternative fuels conversion prog ram consist ed of t est results and related submissions under existi ng procedures for the EPA light - dutyvehicle certification program. A ll information from converter applicants is currently submitted electronicallydirectly to the V erify sy stem. Subject t o confidentiality claims, this information is made available to interested parties upon request. E mission test i nformation is available on the i nternet. The burden analy sis in this ICR differs from the cost analy sis in the preamble to the rule in import ant 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 informatio n, 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 byconverters with testing companies , which include overhead , profit and possiblycompliance elements not counted in the 0783 series . The analy sis in this ICR uses the traditional capital cost, O&M cost, and labo r cost3

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 IC R attempts to generalize the analy sis to the industryas a whole . The existing baseline estimates that certification applications for 36 test groups from five converter respondents are submitted annually . During the proposal pha se of this rule, t he most recent model y ear data available (model y ear 2008) showed 18 light - duty vehicle conversions, and the draft ICR (0783.55) baseline was adjusted accordingly . However, the number of certificates steadilyincreased in 2009 and 2010. In 2010, there were 42 new certificates issued for 7 different conversion manufacturers. Following this upward trend, t his ICR adjusts the baseline to 50 new conversions from 8 con version manufacturer s and calculates industrysavings against that number. T he adjusted baseline also assumes 50 carry over applications. The analy sis also gives the change in the 0783 ICR overall collection with the adjusted baseline after savings . T hese test groups consist of conversion sy stems that applyto a specific certifi ed 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 conver sion program encompasses a diverse range of circumstances. Manyof the tests are currently waived in certain situations. For example, currently , evaporative testing mayor maynot be waived depending o n whether a closed fuel sy stem is used. Exhaust and evaporative emission testing can be waived for dual fueled gasoline/LPG or gasoline/CNG vehicles if the modification doesn’t increase the weight more than 500 pounds and no increase in emissions is expect ed. (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 industrytotal paperwork co st 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 bythe Clean Air Act but wh ich 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 al so, as with other certified vehicles, subject to EPA 's confirmatorytesting program , durabilitydemonstration, Vehicle Emission Control In formation (VECI) labeling, defect and voluntaryemission recall reporting, and other light - dutyrequirements ( all cove red in ICR 0783) . In addition, theyare subject to EPA’s certification fee requirements (ICR 2080; OMB 2060 - 0545) but burden changes in th is 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) vehicles4

that are new or relatively new, (2) vehicles within EPA’s definition of useful life but which a re neither new nor relativelynew (“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 opti ons. 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 outsid e useful life vehicles EPA is finalizing a requirement for information submission demonstrating that the conversion is technicallyviable and will not increase emissions. Beginning in model y ear 20 11 or the effective date of these regulations, t he propo sed changes will reduce total costs annua llyon the regulated manufacturers by $ 19 5,735 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 A nd Use of the Coll ection 2(a) Need/Authority For T he Collection Unde r Title II of the Clean Air Act (42 U.S.C. 7521 et seq.), EPA is charged with issuing certificates of conformityfor motor vehicle designs that compl y with applicable emission standards set under sectio n 202(a)(1) of the Act . A manufacturer must have a certificate before vehicles maybe legallyintroduced into commerce. To i nsure compliance with the Act , EPA reviews product information and manufacturer test results; EPA also tests some vehicles to conf irm manufacturer results. Section 203 of the Clean Air Act contains “anti - tampering” provisions prohibiting alteration of OEM vehicle components relevant to the vehicle’s certification under the Act. Regulations at 40 CFR, Part 85, Subpart F , provide exemption for aftermarket conversion sy stems from these tampering prohibitions for those converters complying with the regulations of that Part. Under Subpart F, these exemptions are currently administered through a certification process that is modeled on the OEM certification provisions: converters submit certification requests for engine families, and those that satisfyEPA’s regulations upon review are granted certificates of conformityfor one model y ear. 2(b) Practical Utility

/Users of the Data Th e information collection under the rule would be used to determine whether the new requirements have been complied with bymeans of the revised ce rtification and compliance program . Section 3: Nonduplication, Consultations, and Other Collection Criteria 3 (a) Nonduplication5

The information collection, reporting, and storage provisions of the proposed rule relyto the maximum extent possible on EPA’s existing certification program , while simplify ing that program to reflect the needs of this industry . Efforts have been made to eliminate duplication in this information collection. EPA - CI SD (Compliance and Innovative Strategies Division) is currentlyusing , for light dutyvehicles , a new information management system (Verify ) , under which the manufact urer 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 anysource 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 p ublished on May 26, 2010 , 75 Federal Register 29606 ; a copy can be found at www.regulations.gov un der docket EPA - HQ - OAR - 2009 - 0299 . The draft IC R was placed in the docket. No comments were received. 3 (c) Consulta tions The proposed regulations, including the cost analy sis that is reflected in this ICR, were developed based on experience with similar regulations developed in the past in close consultation with the affected industry . EPA sought and received signif icant input and feedback from the fuel conversion community . In preparing th e proposed rule , EPA made use of consult ations with several converters and an independent test lab working in the regulated industry . Their comments have been considered in developing the burden 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 bythe Clean Air Act ( at 42 USC 7525(a)), emission informa tion is currently submitted on a y earlybasis coinciding with the manufacturer’s “model y ear.” EPA allows applicants to define their own “model y ear”, thus granting some flexibilityin this regard. Major product changes typicallyoccur at the start of a model y ear. For these reasons, a collection frequencylonger than a model y ear is not 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 - ye ar sales volume submission. In addition manyconversion manufacturers will no longer need to renew t heir certificate of conformity ; if the OEM vehicle design is “carried over” to a6

subsequent model y ear, the amount of new information required is substantiallyreduced or eliminated . 3 (e) General Guidelines Manufacturers are required to keep some records for periods longer than three y ears . This requirement stems from the statutoryrequirement that manufacturer s warrant some items f or periods longer than 3 y ears. This information collection activitycomplies with the remaining guidelines in 5 CFR 1320.5 . The proposal makes no changes in the reporting and recordkeeping provisions that impact anyof the guidelines for information c ollections as approved in the ex isting approved collection. 3 (f) Confidentiality In formation submitted bymanufacturers is held as confidential until the specific vehicle to which it pertains is available for purchase. After vehicles are available, mos t 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. P roprietaryinform ation is granted confidentialityin 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 i nformation collection. This collection complies with the PrivacyAct and OMB Circular A - 1 08. Section 4: Respondents and Information Requested 4(a) Respondents/ NA SIC Codes The respondents are potentially involved in the industries shown in the followin g table: Industry 335312 A

336312 336322 336399 454312 485310 Alternative fuel vehicle converters

A North American Industry Classification Sy stem (NAICS) 4 (b) Information Requested7

(i) Data items The information and reporting burden associated with t his 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 ap plication for emission certification prior to production. In termediately aged vehicle converters will submit a testing demonstration without the burdens of the formal certification application process. For vehicles converted outside their useful life , reg ulation will be through an information submission that the conversion is technicallyviable and will not increase emissions. The se reporting formats describe the major aspects of the proposed product line, technical details of the emission control sy stems , and the results of anyrequired tests to indicate compliance with the emissions limitations. The reports and supporting test results are reviewed and, if appropriate, a certificate of conformityis issued , the applicant is notified of possible noncompli ance with anti - tampering provisions, or additional post - production information is requested . New /revised data items: At the time of certification: For all vehicles :

 ex panded conversion test or " demonstration " groups  ex emption from HCHO testing for conversions to CNG and LP G  conversion factors for calculating NMOG for conversions to CNG and LPG  new VECI label requirement describin g test group, mileage, and date  renewal application for certificates for “carry over” test groups is optional For i ntermediate - 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 o f OBD compliance strategy and for intermediate age vehicles an OBD scan tool rep ort 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 verifycompliance. In some cases the proposal would replace the current application and certification process with a notification8

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 maybe re peated for each conversion model year, although previous data and information may be “ carried over ” when no changes have occurred. Carry over, intermediate and outside usefu l - life test group manufacturers will continue to be subject to the end - of - model - ye a r sales reporting through the same existing Verifyreporting module that applies to their new test groups. Sectio n 5: The Information Collected

— Agency

Activities, Collection Methodology , and I nformation Management 5(a) AgencyActivities The test data used byEPA to determine compliance with emissions standards are derived from vehicle testing done byvehicle converters who report their own test data to EPA , and at EPA's National Vehicle and Fuel Emissions Labora toryin Ann Arbor, Michigan . EPA staff revie w applications (or notifications or demonstrations), issue certificates, and oversee the program. 5(b) Collection Methodology and Management A ll information from converter applicants will be submitted electronicallydirectly to the V erify sy stem by t he effective date of the new rule . Byguidance letter CISD - 09 - 14, vehicle converters are required to submit applications for certification through Verify beginning with the 2010 model y ear. The rule makes no changes in this reporting sy stem , onlychanging the format and content of some of the information reported within it . All information received byEPA is subject to review . D ata submitted are screened to determine that the test results insure compliance with emission and fuel economy standards. Na rrative descriptions of the proposed product line are checked to verify that the appropriate "worst case" vehicles have been tested . Ex cept for projected sales and a verylimited amount of proprietaryproduct information , all information is available to th e public as soon as the vehicle is offered for sale. Emission d ata are available on the internet; other information is available upon request under the Freedom of Information Act . 5 (c) Small Entity

Flexibility Manyconversion manufacturers already enj oy various exemptions and special provisions tailored to their small entitystatus and special business needs in contrast to original vehicle manufacturers, such as use of assigned deterioration factors , exemption from the manufacturers’ in - use vehicle tes ting program (IUVP) and availabilityof reduced certification fees. This proposal further extends this flexibilityin numerous way s detailed in the proposal and summarized in this Supporting Statement.9

5(d) Collection Schedule Currently , i nformation must be submitted for each “ conversion model year ” that a manufacturer intends to convert vehicles. Under the final rule , onlythe newest vehicles will be required to renew annually , if a new certificate is desired, but all categories will file an end - of

- y ear report (as do light - dut y manufacturers). For emissions purposes, a “ model year ” is statutorilydefined as the annual production period of a manufacturer, as decided bythe Administrator, that includes January1 of that calendar y ear; or that calendar ye ar if the manufacturer does not have an annual production period. If a product is unchanged between model y ears, much of the information can be “ carried over. ” The collection frequencyand burden are determined to a large extent bythe manufacturer ’ s m arketing and product ion 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 la st 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 abo ve, the number of converter test groups covered bythe I CR 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 y ears 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 20 11 . The Emissions IC will reflect this adjustment. The discussions belo w compare the burdens on 50 families before and after the proposal. Within the converter program under the adjusted baseline, t he respondent hours burden decrease for the Li ght - DutyVehicle Emissions In formation Collection reflects reduced labor hours a ssociated with conducting tests and reduced reporting. This is largely due to the broader definition of test groups, since this definition determines how manytests must be conducted. The paperwork reporting burdens in particular are significantlyreduced for intermediate and out side useful - life conversions. As converters are a verysmall 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 4 2 9) , the decrease in burden is corresponding ly 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 redu ced by at least 25 percent. This correspondinglyreduces the labor hours associated with conducting emissions tests (including preparation costs, FTP tests, NMOG tests and HFET tests), OBD compliance reporting , confirmatory testing costs10

(including shipmen t costs), and paperwork reporting and recordkeeping costs associated with preparing this information in anyof the required form ats and submitting it to EPA for review and saving it for possible submission to EPA upon request. In termediate age and outside useful life conversion test groups are estimated to achieve an additional 80 percent reduction in paperwork reporting for those qualify ing . The ICR includes a minor startup cost for implementing new labeling requirements. All labor hours associated with startup costs are treated as capital/startup costs, so they are inc lu ded under that heading, following EPA guidance (EPA ICR Handbook, Rev. 11/05, p. A 31). 6(b) Estimating Respondent Costs (i) Estimating labor costs Labor costs for testing follow the te sting labor cost assumptions of I CR 0783. 54 and average out to $5 9.07 per hour across management, technical, and secretarial categories . This figure, which was initiallybased on the fees rule cost studyof EPA laboratoryexpenses, matches verycloselywit h an analy sis based on r ates for engineering managers, mechanical engineers, and secretaries (except legal, medical, and executive) from the May 2005 BLS National Industry - Specific Occupational Employ ment and Wage Estimates (http://www.bls.gov/oes/current/naics4_336100.htm , accessed August 22, 2006). With a 160% overhead multiplier, these are $81.38, $49.71, and $33.57, respectivel y . The next renewal of the ICR will likely

update this figure. (ii) Estimating Operations and Maintenance Costs Operation a nd Maintenance costs are the non - labor costs associated with conducting the new tests that are anticipated for the full model y ear after the effective date of the new regulations . The O&M costs for conducting emissions tests follow the assumptions in prio r IC Rs in this series, with an improved figure for NMOG and HCHO analysis, totaling about $4,000 per vehicle, with another $3,600 for OBD compliance (about $50 for intermediate age OBD scan tool test) and $2,000 for each confirmatorytest . The estimate al so includes O&M items for evaporative emissions testing, a nd reporting and recordkeeping , with the baseline total coming to about $10,000 per activity(test group). Applied to the industry , the baseline O&M cost is $ 3 80,828 annually . The revised regulation reduces this figure by $ 1 95,735 , to $ 1 85,093 . 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 y ear conversions being certified or by the respondent converters after the effective date of the final rule . S tartup costs are included for redes ign of the VECIlabel . This burden is an add - on to well established reporting requirements: manufacturers alread y submit similar label data to EPA.11

Once the new label templates are in place, we anticipate no increase in burden for th is startup item . Thi s part of the estimate costs new analy sis 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 I CR series estimat es capital costs associated with the t esting requirements. Because manufacturers vary widel y in their existing testing facilities, their excess capacities, their work shift arrangements and availabilities, the real estate cost and land availabilities for h ypothetical expansions, and their contractual arrangements with other testing facilities, CI SD has for man y ye ar 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 t esting increment. This cost is then allocated over ten y ears 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 tes ts a year. While most converters work through contractors whose contract costs do not break down costs in this manner, for consistency the anal ys is in the Certification I C series 0783 is continued here. Primarily due to the reduction in the number of te st 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 economycompliance programs are primarilyadministered by EPA’s Compliance and Innovative Strategies Division and LaboratoryOperations Division. Approximately47.5 full time employ ee equivalents are directlyinvolved in the combined emission and fuel economylight - duty , motorcycle, and other , secondary programs; their cost is approximately$5.9 million, including benefits but not overhead. EPA also participates in a program wherebythe agencycontracts with an organization that provides qualified persons to perform duties for the a gencythat are not performed byEPA employ ees. The cost associated with these persons who work directlyon these programs is approximately$0.23 million, excluding overhead. Overhead percentage for the entire division is approximately16.9%, y ielding an estimated total agencylabor cost of $7.17 million. The total non - capital costs for the light - dutyand motorcy cle programs, including direct and indirect labor, operations and maintenance, and overhead, is estimated as $11.14 million for FY 2007. Im ple mentation of the new alternative fuels rule will b e carried out byexisting staff . Other ongoing database management, oversight, and certification activities are part of the fuel economyand emissions program Agency baseline. All EPA labor estimates are b ased on Office of Personnel Management draft annual payrates effective January , 200 8 , with a 1.6 multiplier for overhead based on EPA’s latest fees cost allocation study (1.37 indirect program cost overhead times 1.16 overall EPA overhead) . This estimate does not include Agencyburdens incurred prior to the effective date of the rule, such as costs of developing the rule and preliminary consultations with converters .12

6(d) Estimating the Respondent Universe and Total Burden and Costs From the above dis cussion the following total burden and cost estimates can be calculated. (Due to the diverse nature of the converter industry , there is no typical or average respondent. ) 6(e) Bottom L ine Burden Hours and Cost (i) Respondent Tall y [a] Overall Emiss ions I C This analy sis is against the Emissions I C baseline in I CR 0783.54. EPA has another recent rulemaking (Revisions to Reduce Emissions of Greenhouse Gases; EPA I CR 2387.01 ) which will result in other changes . [1] Existing authorization RESPONDENT S 35 BURDEN HOURS 362,033 LABOR COST $6,308,800 OPERATI

NG COST $5,929,702 CAPI TALIZED COST $2,256,127 TOTAL NON - LABOR COST $8,185,829 [2] After final rule RESPONDENTS 3 8 BURDEN HOURS 350,830 LABOR COST $ 5,612,,466 OPERATI

NG COST $ 5 ,848,800 CAPI TALIZED CO ST $ 2, 247,926 TOTAL NON - LABOR COST $ 8, 096,726 [3] Change in burden BURDEN HOURS - 11,203 LABOR COST - $696,334 OPERATI

NG COST - $ 80,920 CAPI TALIZED COST - $8, 201 TOTAL NON - LABOR COST - $ 89,103 [b] Alternative Fuels Converters [1] Existing baseline13

RESPONDE NTS 5 FAMILIES 36 BURDEN HOURS 29,738 LABOR COST $ 1,756,606 OPERATI

NG COST $ 241,566 CAPI TALIZED COST $ 32,630 TOTAL NON - LABOR COST $ 274,196 [2] After final rule RESPONDENTS 8 FAMILIES (75% OF 50 ) 38 BURDEN HOURS 18, 5 35 LABOR COST $ 1,060,272 OPERATI

NG COST $ 160,664 CAPI TALIZED COST $ 24,429 TOTAL NON - LABOR COST $ 185,093 [3] Change in b urden BURDEN HOURS - 11,203 LABOR COST - $ 696,334 OPERATI

NG COST - $ 80,920 CAPI TALIZED COST - $ 8, 201 TOTAL NON - LABOR COST - $89,103 [4] Reduc tion in b urden applied to 50 families without final rule changes BURDEN HOURS - 23,267 LABOR COST - $ 1,408,994 OPERATI

NG COST - $ 174,845 CAPI TALIZED COST - $ 20,890 TOTAL NON - LABOR COST - $ 195,735 (ii) Agency

Tally EMPL OYEES 47.5 CONTRACT L ABOR COST $0.27 million COST $11.1 millio n 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 c osts and labor hours associated14

with implementing the new program s detai led 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 rul e: approximately 18,535 hours per ye ar, 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 - dut y baseline , notwithstanding application of program costs to an increased number of manufacturers and test groups . The annual costs and hours for information collection activities bya given manufacturer under anyof the options in this proposed rule depend upon manufacturer - specific variables, such as the number of different test groups and the number of vehicles tested. The estimated number of likelyrespondent manufacturers is 8 . The responses will be submitted annually and occasionally as a part of the existing EPA certification program . Burden me ans the total time, effort, or financial resources expended bypersons 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 utili ze technologyand sy stems for the purposes of collecting, validating, and verify ing information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to comply with anypreviouslyapplicable instruction s and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency maynot conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currentlyvalid OMB control number. The OMB control numbers for EPA ’ s regulations are listed in 40 CFR Part 9 . To comment on the Agency 's need for this information , the accuracyof the provided burden estimates, and anysuggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this rule, which includes th i s I CR, under Docket ID n umber EPA - HQ - OAR - 200 9 - 0299 . Submit anycomments related to the ICR for this proposed rule to EPA and OMB. Submit y our comments, identified by Docket ID No. EPA - HQ - OAR - 200 9 - 0299 , by one of the following methods: • www.regulations.gov: Follow the on - line instructions for submitting comments. • Fax: (202) 566 - 1741. • Mail: Environmental Protection Agency , EPA Docket Center (EPA/DC), Air and Radiation Docket, Mail Code 6102T, 1200 Pennsy lvania Avenue, N.W., Washington, DC 20460, Attention Dock et ID No. EPA - HQ - OAR - 200 9 - 0299 . In addition, please mail a copyof y our comments on the information collection provisions to the Office of Information and RegulatoryAffairs, 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, 130115 Constitution Ave., NW, Washington, DC., Attention Docket ID No. OAR 200 9 - 0299 . Such deliveries are onlyaccepted during the Docket’s normal hours of operation, and special arrangements should be made for deliveries of boxed information Docket ID No. EPA - HQ - OAR - 200 9 - 0299 , is available for public viewing at the Air And Radiation Docket in the EPA Docket Center (EPA/D C), 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., Mondaythrough Friday , excluding legal holiday s. The telephone number for the Reading Room is (202) 566 - 17 44, 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 .