Draft Supporting Statement for In formation Collection Request EPA ’ s Li ght

- Duty In
- Use Vehicle Testing Program (Renewal)

EPA I CR 0222.0 9
OMB Control No: 2060

- 0086

August, 2010 Compliance and Innovative Strategies Division Office o f Transportation and Air Quality Office of Air and Radiation U.S. Environmental Protection Agency

Part A SUBMI SSI ON2

Section 1: I dentification of the Information Collection 1(a) Title and Number of the Information Collection EPA’s Li ght

- Duty In
- Use Vehicle Testing Program (Renewal) , EPA I CR Number 0222.0 9 , OMB Control Number 2060

- 0086. This I CR was formerly titled “EPA’ s I n - Use Vehicle and Engine Testing Programs .” This renewal includes only the light

- duty

vehicle portion of the prior I CR. The h eavy - duty and off

- road vehicle and engine programs will henceforth be included in the I CR 1684, OMB 2060
- 0287. 1(b) Short Characterization/Abstract The Environmental Protection Agency (EPA), Office of Transportation and Air Quality , Compliance and Inn ovative Strategies Division , conducts an integrated motor vehicle and engine emission compliance program. Motor vehicles and engines are first evaluated as prototy pes prior to production; those designs that meet applicable criteria are licensed for introd uction into commerce. EPA also has discretion to conduct assembly line testing of new vehicles and engines as well as to test emissions of in

- use vehicles and engines . This I nformation Collection Request covers inquiries directed at the owners/lessees of in

- use light

- duty motor vehicles to see if their specific vehicles are suitable for an EPA in

- use testing investigation and the paperwork burdens attendant upon election to participate
. The prior I CR had a light

- duty vehicle component and a heavy

- duty

and nonroad component. This I CR renews only the light

- duty

portion. The light

- duty program can be broken down into three closely

- related headings
. The first is t he surveillance testing program , with the possibility of an add

- on compliance testing phase. O nly three compliance phase s have been conducted in the last five ye ars, but it remains an information collection in this request. The second is a small ongoing program testing the functioning of onboard diagnostics (O B D) sy stem s on in

- use vehicles , which i s simply additional testing on a subset of vehicles already recruited for the surveillance program
. Finally , budget permitting, there are other occasional one - time “special investigations” spot - check tests of vehicles to address specific issues. An example of a special investigation might be procurement of a class of vehicles to test compatibility with a particular portable emissions monitoring (PEM) unit
. Special investigations are similar to testing of th e portion of surveillance classes has have been sel ected to addres s a s pecific informational need. B ecause they use the same procurement sy stem as the surveillance and OBD programs, these special investigations should be accounted for in this collection request, although the number of such tests will vary
. Li ght

- duty testing ty

pically includes standard emissions test cy cles and standard OBD tests performed at EPA’s facility in Ann Arbor . The primary purpose of these programs is informational: to give EPA and manufacturer engineers intelligence regarding emissions performance for in

- use vehicles. Manufacturers are involved at every step of the ongoing light

duty program s : they

are informed of the surveillance tests, can be present during vehicle preparation and testing, are given test results, and partici pate in post

- failure investigations. The3

testing supplements information from the manufacturers’ own discretionary in

- use testing programs as well as the mandatory reporting under the manufacturers’ In - Use Vehicle Program (IUVP) under 40 CFR 184 5

– 1847. The light

- duty program entail two formalized information collections. Participation in the information collections , as well as the vehicle evaluation, is strictly voluntary
. (The actual solicitation of information is conducted by EPA ’ s contractor, URS , at its Michigan Procurement Facility
. ) First, 25 to 50 owners/lessees of the vehicles of interest who are within about 70 miles of Ann Arbor are randomly selected from the owner list of vehicles obtained from the Michigan Secretary of State and sent a letter with a card and return envelope to accept or decline the invitation to participat e (Attachments I I, I II, and I V)
. After a suitable time for response, all positive respondents are considered for inclusion and called in order from the list. If the owner/l essee is reached and willing, a telephone questionnaire is conducted that asks about a half

- dozen questions concerning vehicle condition and ma intenance (see A ttachment V). The first three who successfully complete the telephone questionnaire provide the v ehicles for the surveillance class. If there are any test failures in the first three, then two more are recruited in the same manner. A dditional groups of potential participants will be contacted if necessary until the required three or five vehicles have been obtained. In formation collected is used to insure that vehicles procured meet relevant criteria. For example, the vehicle should not have been tampered with or have other overt problems
. Special testing investigations and particular vehicle ty pes may have additional or alternative criteria. Those who elect to participate are asked if they are willing to bring in their maintenance records for copying when they deliver their vehicle s . Doing so is voluntary and has no effect on eligibility . At the time of delivery , participants go over the telephone questionnaire answers and sign a notarized statement that the answers are correct. They sign for either URS ’s cash incentive or a loaner car agreement, and a URS test agreement. Upon delivering their ve hicle, they sign a vehicle release. As part of the surveillance process, EPA attempts to determine the cause of any test failures. Post

- test “special maintenance” involves close examination of the vehicle, nearly alway s with manufacturer participation. T his may produce relevant information about the cause of the failure. Surveillance test data are also supplemented with information from manufacturer application test data, EPA confirmatory test rest results, defect reports, service bulletins, CARB (Califo rnia Air Resources Board) warranty reports, state In spection/Maintenance (I /M) information, manufacturer service technician bulletins, and the results of the manufacturers’ IU VP tests submitted to EPA and their own in

- use testing results . Manufacturers/imp orters are involved in the process from the outset, and receiv e all test results, including test failures. The process of identifying problems is collaborative and cooperative in nearly all cases. I f EPA believes that a recall is indicated, and the manufa cturer/importer agrees that EPA's conclusion is valid, it will agree to conduct a voluntary recall. However, if questions remain , EPA has procedures in place to run the compliance t est phase with continued manuf acturer involvement. Even at this stage the inferences are inform ational rather than statistical: to identify , based on4

engineering judgment , the appropriate population to which the problem applies, identify the cause of the problem, resolve issues regarding the testing protocols and results, etc. T he process has not been adversarial in recent y ears. There have only been three compliance class es in the last five y ears, and th ey

were or are being amicably resolved without any

recall. B ased on information gathered from all sources , EPA can make an administrative finding mandating recall and repair of in

- use vehicles if it determines that “a substantial number” of vehicles in a class or category do not comply

with the emissions requirements as a result of its own in

- use testing program. In reality , s uch a determination will be based on information from a variety of sources that may

or may not include EPA in

- use testing. Such findings are subject to the Administrative Procedures Act and are reviewable in court under the “substantial evidence” test (5 U SC 706(2)(E)), which is restated in the “substantial evidence” standard in the Clean Air Act for ordering recalls. Procurement of light duty vehicles for a compliance testing phase is similar to that for the surveillance phase , except that EPA may ma ke several attempts to contact an owner/lessee by telephone or mail; participants in the surveillance phase are screened out. Inthe last fiscal y ear an estimated 185 vehicle in

- use testing actions were conducted by EPA , counting OBD add

- ons as separate act ions . Adding an allowance for about 25 special investigation vehicles (the number is expected to vary from y ear to y ear) and the possibility of a co nfirmatory class, the estimate here is 210 procured vehicle actions , corresponding to 3673 contacts and 164 telephone interview and /or other followup participant contacts
. Assuming that 4, 285 r espondents spend an average of 7.3 minutes, this collection imposes a burden of 521 hours annually . This collection has no recordkeeping requirements
. Section 2: Need for and Use of the Collection 2(a) Need/Authority

for the Collection Under Title I I of the Clean Air Act, (42 U.S.C. 7521 et seq.), manufacturers of motor vehicles and engines are required to design and build vehicles which will comply with emission standards throughout their useful lives. ( " Useful life " is de fined by statute and regulation; it varies by ty pe of vehicle or engine .) Pursuant to se ction Clean Air Act section 207 (c) (42 USC 7541, see Attachment I ), EPA is responsible for monitoring compl iance and investigating possible noncompliance with emi ssion standards. Inorder to fulfill this function, it is necessary for EPA to test actual " in

- use " vehicles; these vehicles must be obtained from their owners/lessees. As part of the procuremen t process, EPA must determine that the vehicle is within the useful life and that it has been “ properly maintained and used ” . I n order to do this, EPA must make a limited inquiry of the owner/lessees who are willing to participate; see Attachment V for an example telephone questionnaire. 2(b) Practical Utility

/Users of the Data5

EPA needs the information from the vehicle owner/lessee to determine that the vehicle is within its “ useful life ” and that it has been “ properly maintained and used. ” EPA ’ s C ompliance and I nnovative Strategies Division, Office of Transportation and Air Quality , is the prime user of this information. Manufacturers whose models are being tested receive a copy of the file on the vehicle to be tested, identified by a “vehicle contro l number.” Manufacturers are informed of pre

test maintenance and test dates and receive all test results. They also participate in post

- test “special maintenance” to investigate failures. Section 3: Nonduplication, Consultations, and Other Collection Cr iteria 3(a)Nonduplication The information obtained from the vehicle owner/lessee is unique to that specific vehicle; it is not obtainable from any other source. There is no information available, in either public or private databases, that will adequa tely serve the program purposes. (Some vehicle maintenance information, such as warranty repairs and scheduled maintenance done at dealers’ outlets, is available from manufacturers and commercial automotive data services, and such information may be suppli ed by

manufacturers in their own interests or as queried by EPA. However, it is not a substitute for owners ’ /lessees ’ own records. ) Additionally , there are no other similar government programs which would allow sharing of data. 3(b) Public Notice Prior t o I CR Submission to OMB EPA solicited public comment by means of a Federal Register Notice published on

_____ , 20 10 ,

__ Federal Register

_____ . 3 ( c) Consultations Inpreparing this I CR, EPA consulted with Ms. Kim Cieslak and John White , URS Michi gan Procurement Facility , (734) 214

- 4568. ( URS is EPA ’ s contractor that procures and maintains in

- use passenger cars and light duty trucks.) Ms. Cieslak mails out the procurement letters and conducts the telephone interviews; she was asked to monitor h ow much time the interviews required. She determined the average to be 20 minutes. John White is her supervisor. The two went over how the program operates from start to end. 3(d) Effects of Less Frequent Collection In formation is collected only once per vehicle evaluation; less frequent collection is not possible. 3 (e) General Guidelines This information collection activity complies with the requirements of 5 CFR6

1320.5(d)(2). 3 (f) Confidentiality In formation gathered from light

- duty respon dents is stored in contractor files . These paper records, including names and social security numbers needed for those who accept pay ment over $600 in lieu of loaner cars , are completely segregated from test results, which are separately handled and stored by EPA. Respondent information is handled and stored exclusively by the contractors URS
. Itis not available to the public. Non

- personal information (such as maintenance record data ) may occasionally

be queried by

EPA staff, who convey

the request to URS , who in turn retrieve the information from respondent files and answer the EPA query
. Test results are tracked by vehicle control number and are shared with manuf acturers by

email automatically ; they are available to the public. This information collecti on complies with the Privacy Act of 1974 and OMB Circular A

- 130. 3(g) Sensitive Questions No sensitive questions are asked in this information collection. Section 4. Respondents and Information Requested 4(a) Respondents/SI C & NAI CS Codes The re spondents are individual vehicle owners/lessees of any regulated vehicle or engine regulated by

EPA under the Clean Air Act (No N AI CS code)
. 4 (b) I nformation Requested (i) Data items Respondents who receive EPA ’ s initial request (see Attachments I I and III and I V ) are asked to supply

the following information on a card via a postage paid return envelope; participation is entirely

voluntary : Do they own/lease the desired vehicle ; verify the m ake and model Current odometer reading Are they the original owner/lessee Transmission ty

pe Are they interested in participating; how EPA should contact them
. Those who indicate they

wish to be considered for participation are asked for additional information: Has the odometer malfunctioned and, if so, for how l ong was it inoperative7

Has the vehi cle cataly st ever been replaced Do they have maintenance records; would they al low EPA to review and copy them There are no recordkeeping requirements associated with this collection. (ii) Respondent Activities Resp onses to the request for participation and information collection are strictly voluntary
. Those wishing to participate are asked to fill out a postage

- paid information card. Some are then contacted by

telephone to obtain the additional information liste d above. Vehicles that will be evaluated are brought to EPA ’ s facility for testing. T he owners/lessees receive either a cash incentive for each day EPA keeps the vehicle or a lesser cash incentive and a late model loaner car with a full tank of gas and un limited mileage for the duration of the testing, which may take two to three weeks. Most of the information requested is known by the owner/lessee; some information might have to be obtained by

simple vehicle or engine inspection or by reference to main tenance records (if available). Section 5: The Information Collected

-- Agency Activities, Collection Methodology , and In formation Management 5(a) Agency

Activities Agency staff ty pically have no involvement in gathering the information, as that task is done by an EPA contractor. However, on occasion, staff are required to answer specific questions that arise during the information gathering process. Agency staff do review the final telephone questionnaire for completeness as well as potential issues re levant to the vehicle being evaluated. Agency

staff select the vehicle class to be tested, view test results, and participate in discussions with manufacturers relating to the testing preparations and results. 5(b) Collection Methodology and Management In formation is obtained via mailed res ponses and telephone interviews; it is stored on paper in a vehicle file. The information is reviewed to see if the specific vehicle or engine meets the criteria for evaluation. The file is ty pically maintained for five ye ars and then destroy ed Due to the limited amount of information collected and its very limited use, electr onic storage and processing are not employ ed. 5(c) Small Entity

Flexibility8

The information requested is completely voluntary

and imposes no mandatory burden on any respondent. The information collected is the minimum necessary to assure that vehicles meet the criteria for evaluation. Therefore, there can be no process which reduces the burden on small entities. 5(d) Collection Schedule In formation is collected on a continuous basis. The number of solicitations mailed out in a given time frame is a function of available test capacity and how difficult a particular vehicle ty pe is to procure. Section 6.Estimating the Burden and Cost of the Collection 6(a) Estimating Respondent Burden As explained above, EPA ’ s contractor estimated that each telephone interview takes approximately

20 minutes on average. Subsequent information

- related burdens for participants (such as reviewing and att esting to the telephone questionnaire answers and supplying maintenance records voluntarily ) upon delivery

of light

- duty

vehicles, is estimated at 40 minutes. We estimate that the initial contact burden ( by postcard and letter) to averages 5 minutes. 6(b ) Estimating Respondent Costs (i) Estimating labor costs. The is no ty

pical individual owner/lessee; they represent the average person who acquires or owns a vehicle or engine
. For this analy sis we assume a cost of $21.68 per hour, based on the mean an nual income for people 25 y ears and older in 1965, from the U.S. Census Bureau, Current Population Survey , 2006 Annual Social and Economic Supplement ( http://pubdb3.census.gov/macro /032006/perinc/new03_001.htm , accessed August 5, 2010). The annual labor cost is therefore $11,295. (ii) Estimating Capital and Operations and Maintenance Costs This collection has no capital, operations or maintenance costs. ( iii) Start

- up Costs This collection has no start

- up costs. 6(c) Estimating Agency

Burden EPA uses contractor employ ees to collect essentially all the information covered by this information collection request. The most recent annual contractor costs for the light duty test ing9

component was approximately $ 697,000 plus $70,000 for the OBD portion

. An estimated 1.5 EPA employ ees oversee the programs at an annual cost of $150,000. The total estimated Agency cost is $ 917,000 per y ear . 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 as presented below. 6(e) Bottom Line Burden Hours and Cost (i) Respondent Tally Program Vehicles/

Engines In itial

Contacts Burden @

5 min ea.(min) Participant

Contacts Burden @

60 min ea (min) LD Surveillance 150 3673 18365 150 9000 LD Confirmatory 0 0 0 0 0 OBD Surveillance 35 0 0 0 0 Special 25 612 3061 14 840 Total 210 4285 2 1 426 164 9840 Total burden (hrs) 521
There are n o respondent operating, capital, or startup costs associated with this collection. (ii) Agency

tally EMPL OYEES 1 .5 (directly involved in information collection) COST $ 150,000 6(f) Reasons for change in burden The changes in burden , a decreas e of 90 responses and 98 hours, are entirely due to separation of the heavy

- duty and nonroad in

- use testing programs into a separate I CR
. 6(g) Burden Statement The annual public reporting and recordkeeping burden for this collection of information is estimated to average approximately 521 hours per ye ar; 7.30 minutes on average for each owner/lessee who receives a solicitation to participate. This estimate includes the time to review the solicitation material, complete the reply correspondence , compl ete the telephone questionnaire for the subset contacted , and complete paperwork for delivery and p ickup of10

participating vehicles and for monetary compensation
. Participation is completely voluntary
. Burden means the total time, effort, or financial reso urces 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 sy stems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to comply with any previously

applicable instructions and requirements; train personnel to be abl e to respond to a collection of information; search data sources; complete and review the collection or sponsor, and a person is not required to respond to, a collection of information unless it display s a currently valid OMB control number. The OMB contr ol numbers for EPA ’ s regulation are listed in 40 CFR part 9 and 48 CFR chapter 15. 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 I CR under Docket I D Number EPA

- HQ
- OAR
- 20 10
- 0 690 , which is available for online viewing at www.regulations.gov , or in perso n viewing at the EPA Docket Center, EPA/DC, EPA West, Room 3334, 1301 Constitution Ave., NW., Washington, DC. The Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday , excluding legal holiday s. The telephone number for the Public Reading Room is (202) 566

– 1744. 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 sy stem, select “search,” then key

in the Docket I D Number identified above. Also, y ou 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 I D Number EPA
- HQ
- OAR
- 20 10
- 0 690 and OMB Control Number 2060

- 0086 in any correspondence.11 Attachment I Legal Authority

42 USC 7541.
- Compliance by vehicles and engines in actual use * * * * * (c) Nonconforming vehicles; plan for remedying nonconformity ; instructions for maintenance and use; label or tag Effective with r espect to vehicles and engines manufactured during model y ears beginning more than 60 day s after December 31, 1970

- (1) I f the Administrator determines that a substantial number of any class or category

of vehicles or engines, although properly maintain ed and used, do not conform to the regulations prescribed under section 7521 of this title, when in actual use throughout their useful life (as determined under section 7521(d) of this title), he shall immediately notify the manufacturer thereof of such no nconformity , and he shall require the manufacturer to submit a plan for remedying the nonconformity

of the vehicles or engines with respect to which such notification is given. The plan shall provide that the nonconformity of any such vehicles or engines w hich are properly used and maintained will be remedied at the expense of the manufacturer. I f the manufacturer disagrees with such determination of nonconformity and so advises the Administrator, the Administrator shall afford the manufacturer and o ther interested persons an opportunity to present their views and evidence in support thereof at a public hearing. Unless, as a result of such hearing the Administrator withdraws such determination of nonconformity , he shall, within 60 day s after the compl etion of such hearing, order the manufacturer to provide prompt notification of such nonconformity

in accordance with paragraph (2). * * * * *12 Attachment I I Sample Solicitation L etter (EPA) Dear Vehicle Owner: The Environmental Protection Agency and URS (under contract to EPA) are conducting an important program to help control air pollution, which involves analy zing vehicle exhaust emissions. You may

be able to contribute significantly toward this program and be rewarded for yo ur coopera tion. I f y our vehicle qualifies, we will offer y ou a number of incentives to participate: 1. The use of a late

- model, fully insured loaner car with a full tank of fuel, and $20.00 per day

. 2. If y ou do not wish to use the loaner vehicle, y ou will receive $50.00 per day

. 3. Your vehicle will be returned with a full tank of fuel. The testing will be conducted in EPA's National Vehicle and Fuel Emissions L aboratory (formerly known as the Motor Vehicle Emissions L aboratory ) in Ann Arbor. Your vehicle will pro bably accumulate less than 300 miles under simulated driving conditions. No unusual operations will be performed on y our vehicle and it will be fully insured for the entire test period, which will take approximately one to four weeks. Please complete and return the enclosed reply card in the prepaid envelope to URS as soon as possible, even if y ou choose not to participate. I f y ou are willing to participate, a representative of URS will be in touch with y ou to ask questions about y our vehicle. The enclo sed information sheet answers some questions people often ask about this program. I f y ou want to participate in this program or have any additional questions, please feel free to call URS toll free at ( 866 ) 665 - 122 8 . Some is available between 8 AM and 4 P M or leave a message for a return call. You can also call me at (734) 214

- 4851. I will be happy to answer any questions y ou may

have related to this program . We look forward to receiving y our reply card or a telephone call very soon. Sincerely ,

Lyn n S ohacki Environmental Engineer Compliance and Innovative Strategies Division EPA Motor Vehicle Emissions L aboratory

2565 Ply mouth Road Ann Arbor, MI4810513 Attachment I II Sample Solicitation L etter (EPA’s Contractor)
Dear Vehicle Owner: EG&G Inc. is u nder contract with the United States Environmental Protection Agency to obtain privately owned vehicles for the test program explained in the enclosed message and to perform routine maintenance and inspection procedures on the selected candidate vehicles. Additionally, it is our responsibility to provide you with the incentives which have been authorized by the Environmental Protection Agency. We hope you will join us in this important project. Please complete and return the enclosed card in the prepaid envelope. If you have any questions, an unlisted telephone number, or if it may be difficult to reach you by telephone, we would appreciate your calling us toll free at ( 866 ) 6 65 - 1228
. Sincerely,

John H. White Program Manager14 Attachment IV Examp le Return Card2008 GM LDT 8GMXT06.2382 Control #N160/N161RXX

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1 Attachment V Example Telephone Questionnaire TELEPHONE QUESTIONNAIRE OMB No. 2060
- 0086 For Surveillance Class N - 160/N - 1 61 Expires (02/08/2011) VEHI CL E CONTROLNUMBER DATE ADMI NI STERED BY OWNER'S NAME STREET ADDRESS CI TY STATE ZIP (CAL L NUMBER BELOW THAT I S MARKED WI TH AN "X") TELEPHONE (Home) / / (Busines s) / / BEST TI ME TO CAL L "WE ARE AUTHORI ZED BY FEDERAL LAW TO COLLECT THIS INFORMATION. WHILE YOU ARE NOT REQUI RED TO RESPOND, YOUR COOPERATI ON I S NEEDED TO M AKE THE RESUL TS OF THI S I NVESTI GATI ON VALID." DATE OF CONTACT _______________________ TI ME OF CONTACT __________________ IN DI VI DUAL CONTACTED_______________________________________________________ TO BE COMPL ETED ___________________ DATE AND TI ME OF CO MPL ETI ON___________ You have been selected from a list of vehicle owners living in the Detroit/Ann Ann Arbor metropolitan area to participate in a study of vehicle emissions being conducted by the U.S. Environmental Protection Agency
. EPA is authorized b y law to conduct this study and to offer incentives to y ou for y our cooperation should y ou decide to participate. Your participation in this program is strictly voluntary
. The accuracy

of the information that y ou provide is important. The information th at y ou provide will be used by EPA along with emission results from your vehicle to determine whether the automobile manufacturer has complied with clean air standards established by Congress. The test results from y our vehicle will not be used by EPA to take action against you. Your cooperation will help EPA's efforts to control air pollution due to motor vehicle emissions.2008 GM LDT 8GMXT06.2382 Control #N160/N161RXX

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2 Public reporting burden for this collection of information is estimated to vary from 1 to 60 minutes per response, with an av erage of 2 0 minutes per response, including time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding the burden estimat e or any other aspect of this collection of information, including suggestions for reducing this burden, to Chief, Information Policy Branch, PM

- 223, U.S. Environmental Protection Agency ,40l M St., S.W. Washington, DC. 20460; and to the Office of Information and Regulatory Affairs, Office of Management and Budget, Washington, DC. 20503.2008 GM LDT 8GMXT06.2382 Control #N160/N161RXX

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3 These are the conditions of the program:

- we ask that y ou bring y our vehicle into our testing facility where y ou will receive either a cash incentive for each day

we k eep y our vehicle or a late model loaner car which will have a full tank of gas and unlimited mileage. This vehicle is yours to use without charge for the duration of the testing, which may

take approximately

2 to 3 weeks. During this time, we will be per forming a series of tests on y our vehicle to measure vehicle emissions. At the time the vehicle is delivered to us for testing, you will be required to sign an affidavit stating that the answers to the questions you will be asked are true and accurate to the best of yo ur knowledge. We will provide y ou the following incentives for participating in our program:

- If y our vehicle is accepted into the program, a full tank of gas and a cash incentive will be awarded. You will be receive $20 per day for each d ay

y our vehicle is at NVFEL, and the use of a fully

- insured loan car; or $50 per day for every day y our vehicle is at NVFEL in lieu of a loan car. However, if y our vehicle is rejected after y ou bring it to the lab, but before y ou leave, y ou will receive a $20 pay

ment. The compensation will be based upon whole day s, beginning with the day y our vehicle arrives. I t will end one day

after y ou are notified y our vehicle is ready for return. The maintenance performed on y our vehicle will depend on program requi rements. You will be given a list of any parts that are replaced. Are y ou willing to participate? YES NO If y ou are not, may

we ask why

not? ______________________________________________2008 GM LDT 8GMXT06.2382 Control #N160/N161RXX

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4 FOR “ URS PERSONNEL ” ONLY SENTENCES I

N CAPI T AL LETTERS ARE I NSTRUCTI ONS TO THE CL ERK AND ARE NOT I

NTENDED TO BE READ TO THE OWNER. IF RESPONSE I S POSI TI VE : For the purpose of this study , Iam going to ask y ou some questions about y our vehicle's maintenance and usage history
. Please have your main tenance records in front of you for reference during the following questions. You should answer these questions to the best of yo ur knowledge and indicate when y ou are not sure of something. 1. a. What is the engine family of y our vehicle? The engine f amily can be found on a Vehicle Emission Control I nformation decal located underside of the hood. The engine family should start with: 8 G M / / Owner is unable to locate. / / Owner located. EF# ________________________________________ / / Engine family

located when vehicle arrived at the Lab. ENGI NE FAMI LY Engine Family

must be = 8GMXT06.2382 b. What is the vehicle identification number? __________

_____________ c. What is the model of y our vehicle? _________________ d. What kind of transmission does y our vehicle have?: AUTOMATI C MANUAL OTHER If other, describe:_________________________________________________________
e. Is y our vehicle air conditioned? YES NO f. What mileage is indicated on y our odometer? ____________________2008 GM LDT 8GMXT06.2382 Control #N160/N161RXX

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5 Has the odometer ever not functioned properly ? YES NO If y es, approximately

how long (months/miles) was it inoperable?

________________ CONSULT EPA FOR ELIGIBILITY IF THE RESPONSE IS "YES" to f. 2. Has y our vehicle ’ s cataly st ever been replaced or removed? YES / / NO / / If yes, CALL EO. 3. a) Have y ou kept records of the main tenance and repairs performed on y our vehicle? YES / / NO / / b) To prepare for testing, the glove box and trunk will need to be opened during by URS and EPA personnel. Frequently , records pertaining to the vehicle's maintenance history are foun d in the vehicle. Will y ou allow all records (those provided by y ou and those found) to be reviewed and duplicated? YES / / NO / / 4. EPA needs to share y our maintenance records with the manufacturer to correctly test the vehicle. Do y ou agree to this? YES / / NO / / IF RECORDS ARE AVAILABLE, INFORM OWNER THAT: It is important that they are brought to the lab for review and duplication. 5. Have y ou ever used any fuel other than that recommended by the manufacturer in y our vehicle? YES / / NO / / If Yes, what have y ou used?

___________________________________________________________ How often have y ou used it?2008 GM LDT 8GMXT06.2382 Control #N160/N161RXX

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6 ___________________________________________________________ When was the last time y ou used it?__________________

____________________________________ 6. Has y our vehicle: a) Been in an accident? YES / / NO / / b) Had any

engine repairs? YES / / NO / / c) Any vehicle modifications? YES / / NO / / If “y es” to any

of the above, pl ease describe:

____________________ _______________________________________________________

___________________________________________________________________________

______________________ Has y our vehicle had any : DATE: d) Body work? YES / / NO / /

________________ e) Gla ss repair or replacement? YES / / NO / /

________________ f) Paintwork or detailing? YES / / NO / /

________________ g) Other? YES / / NO / / _________________ If “y es” to d

– g above, please describe:

___________________________________________ ________________________________

___________________________________________________________________________

___________________________________________________________________________

__________________________________________________________________________ _

____________________________________________ IF “YES” TO ANY d) THROUGH f ) ABOVE AND DATE IS LESS THAN 6 MONTHS FROM THE TIME OF THIS QUESTIONNAIRE, THIS VEHICLE SHOULD BE PUT ON HOLD. g) New tires? YES / / NO / / Date and mileage of the mos t recent tire installed? Date_________ Mileage___________ HAS IT BEEN LESS THAN 6 MONTHS AND/OR 6,000 MILES SINCE A TIRE REPLACEMENT? IF YES, THIS VEHICLE SHOULD BE PUT ON HOLD .2008 GM LDT 8GMXT06.2382 Control #N160/N161RXX

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7 If a replacement part was installed, was it an original manufacturer par t? Yes No What was the approximate cost of the work done ? Do y ou have any

documentation of the work that was done? ( NOTE TO URS : IF THE ANSWER TO A NY OF QUESTIONS a) THRU g) IS “YES”, PLEASE CONSUL T WITH EPA STAF F BEFORE ACCEPTING T HIS VEHICLE.) 7. I s y our vehicle equipped with a trailer hitch ? Yes ____ No ____ Was the hitch installed by : dealer other How much total weight has been hauled?: trailer + cargo = _________________________________________

____ ( IF YES, CONSULT WITH EPA STAFF BEFORE ACCEPTING THIS VEHICLE.) INFORM THE OWNER THAT : 1) All valuables should be removed from the vehicle (including those in the glove box) prior to bringing the vehicle to the lab.