Supporting Statement for In formation Collection Request
In formation Requirements for Importation of Nonconforming Vehicles (Renewal) EPA I CR 0010.1 2 April 2010

C ompliance and Innovative Strategies Divis ion Office of Transportation and Air Qualit y Office of Air and Radiation U.S. Environmental Protection Agency2 PART A OF THE SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY

1. IDENTIFICATION OF THE INFORMATION COLLECTION (a) TITLE OF THE INFORMATION COLLECTION In formation Requirements for Importation of Nonconforming Vehicles (40CFR Part 85, Subparts P and R) (Renewal) , EPA ICR Number 0010.12, OMB Control Numbe r 2060

- 0095 (b) SHORT CHARACTERIZATION (ABSTRACT) The Clean Air A ct requires motor vehicles and engines imported into the U.S. to conform to applicable emission requirements. This Information Collection Request (I CR) covers importation reporting requirements for light

- dut y vehicle, light

- duty truck, and on - road motorcy cle vehicles and engines. The information collection instruments are Form 3520

- 1 (" Form 1 " ) for initial entry , and Form 3520

- 8 ( " Form 8 " ) for final entry (see below). All heav y - duty on - road and all non - road vehicle and engine importation reporting requirem ents are now covered b y ICR 1723 (OMB 2060

- 0294). The two programs use separate forms, have differing regulatory provisions, and are processed by differing staffs. Most importers are also required to apply for and obtain a certificate of conformit y from EP A; that information burden for the light

- dut y and motorcy cle certification program is covered b y ICR 0783 (OMB 2060

- 0104). There is some program overlap between the present I CR and 0783 because testing for Independent Commercial Importers (ICIs) is report ed both on Form 8, covered by this ICR , and , initially

and in more detail , for certification purposes, via ICR 0783. (Similarly , all importing light

- dut y vehicle and motorcy cle manufacturers, and not just I CI s, use Form 1.) Thus, the certification informat ion burden is covered in ICR 0783 and the (different and less detailed) testing burden for imports subsequent to certification for ICIs in this I CR. The burden of submitting the fee and associated forms is covered b y IC R 2080 (OMB 2060

- 0545). The post

- certification, final

- entry testing burden for light

- dut y vehicle imports falls into two categories. For the category of certified light

- dut y IC Is, a city test (the “FTP” ) is required for every

third vehicle imported under a certificate for the fi rst 300 vehicles imported, and every

fifth the reafter (40 CFR 85.1505). The second light

- duty imports category is “mod an d test” , which applies to vehicles whose original production y ear is six or more prior to the year of importation. E ach such vehicle mu st be modified to meet applicable emissions requirements and tested with the FTP (40 CFR 85.1509). In the first ca tegory , each FTP test will be accompanied by a two

- hour evap orative emissions test , and in both ca tegories , by a highway test in order to comp ute a combined fuel econom y number to comply

with fuel econom y requirements. Form 8 inc ludes spaces for reporting the test results and combined fuel economy for those vehicles that undergo them

. A very3

limited number of nonconforming motorcy cles have been imported in the last t hree ye ars. Most are imported under a provision (40 CFR 85.1505(a)(2)(i)) that allows for no additional testing bey ond the original certification testing. Otherwise, testing requirements are the same as those for light dut y vehicles except that a highway test is not required. Most I CI s contract with a broker to do some of the imports process and a testing laboratory

to perform the necessary tests. The testing lab also performs whatever modifications are necessary to bring the vehicle up to certification standards. The Compliance and Innovative Strategies Division (CI SD) in EPA’s Office of Transportation and Air Quality collects information and requires some recordkeeping to help insure that imported vehicles and engines ar e brought into compliance with federal emission requirements or that they qualify for exemption or exclusion from th em . “Nonconforming” refers to the vehicles and engines that are not constructed to EPA certification standards and therefore must meet va rious additional requirements , such as testing, prior to being certified and available for sale in the U.S. The information is also used by the U .S. Customs Service (Customs), s tate regulatory agencies, businesses, and individuals to verify

whether or not vehicles are in compliance.
In formation collected includes vehicle identification data , U.S. Customs entry statements that such information is correct, and summary emission test results. The information is either stored in a computer database, or re tained in document form. The information is used to monitor compliance of imports and respond to inquiries from the public concerning the compliance status of specific imported vehicles. This information is collected on two forms (attached in I CRAS ) : EP A Form 3520

- 1

. This form is used by importers who are apply ing for entry into the U.S. of light

- duty vehicle, light

- dut y truck, and motorcy cle vehicles or engines, whether conforming, nonconforming, exempt , or excluded. The form identifies to all parties involved the category of import and the requirements that are appropriate to that category . The form goes from the importer or its agent (broker) to Customs, which stamps the form and forwards it in batch to EPA. EPA gathers the forms in Ann Arbor where t hey

are logged and filed for future reference. The form is posted on EPA’s imports website, http://www.epa.gov/otaq/imports/index.htm

. EPA Form 3520

- 8

. This form is used by I CI s to request “ fin al admission ” of a nonconforming vehicle or engine upon their certification that it has been brought into compliance with Federal emission requirements. The f orm is held for fifteen day s, during which the ICI can not release the vehicle for sale or to its owner . This gives EPA a chance to conduct an y review or oversight, including confirmat ory testing, deemed necessary before the vehicle or engine is released

. The EPA requests a waiver from posting the expiration date of the OMB clearance on these forms. Because Form 1 is used by both Customs, EPA, and importers, repeated uploadings to the imports website and revisions to reflect expiration of the clearance4

deadline, continuation of clearance pending review, and the new expiration date may be burdensome , w ith the existence of revisions inadequately communicated to users

. Form 8 has a limited number of users who in the past have had to be individually contracted to inform them of substantive updates. Posting of Form 8 on the imports website is currentl y unde r consideration . Both forms have been in use for man y ye ars and importers are familiar with their features. The information collection will involve an estimated y earl y 1 2 , 352 respon ses from 12, 0 0 5 respondents at an Operations & Maintenance ( O&M ) cos t of $ 9 0,894 , a capital cost of $ 73,353 , and a labor cost of $ 370,803 (see Table 1 below)

. 2. NEED FOR AND USE OF THE COLLECTION (a) NEED/AUTHORITY FOR THE COLLECTION Joint EPA and Customs regulations at 40 CFR 85.1501 et seq., 19 CFR 12.73 , and 19 CFR 12.74 , promulgated under the authorit y under the Clean Air Act (Sections 203 and 208) , give authorit y for the collection of the information. The collection helps i nsure compliance of imported vehicles and engines with federal emissions requireme nts , which helps meet the Agency

goal of reducing air pollution. Without this information, EPA and Customs officials could not confirm that imported vehicles and engines conform to U.S. emission requirements , and consequentl y would not be able to allow importation or sale of these vehicles and engines. (b) PRACTICAL UTILITY/USERS OF THE DATA T he information on Form 1 and Form 8 is used by Customs and/or Agency personnel to verify that all Federal emission requirements (or exemptions or exclus ions thereto) concerning imported nonconforming light

- dut y motor vehicles and motorcy cles are met. The information is also used to identify and prosecute violators of the regulations and to monitor the program in achieving the objectives of the regulation s. It is also used to answer public inquiries concerning the compliance or exempted or excluded status of particular motor vehicles. Public access to this information is not direct but rather through the EPA ’s imports section and the Automotive I mports He lpline in order to maintain securit y of information protected under the Privacy Act. 3. NON
- DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA (a) NON
- DUPLICATION A search of the Government I nformation Locator Sy stem (GIL S) found no other program or agency

collecting this information. As explained above, Form 1 is necessary to identify , at the point of importation , the applicable category of the vehicle or engine for regulatory

purposes; Form 8 is necessary to report test results to E PA (where required) and alert it of pending release to the owner. As stated on Form 1, vehicles that5

are primarily

manufactured for use on public roads are also required to file an HS

- 7 Declaration Form to identify the basis for the vehicle’s admission und er the laws administered b y the Department of Transportation (DoT) . EPA had discussions with the D oT in late 2005 that considered whether a combined form would be feasible, and the conclusion was that a single form was not practical at this time because of the unique requirements of each program and the different agencies administering them. (b) PUBLIC NOTICE A Federal Register notice was published, soliciting public comment for this I CR on January 22, 2010 (75 FR 3723). A cop y of the draft S upporting Statement was also placed in the docket. No comments were received. (c) CONSULTATIONS Consultations have been made with ICIs to discuss form revisions , to update burden and cost estimates , and to receive suggestions about the opera tion of the program . The following ICIs were contacted: Auto Enterprises, Inc. 850 N. Rochester Rd. Clawson, MI48017 Rep: Mr. Philip Trupiano Phone: ( 248 ) 723

- 6677 J.K. Technologies , L .L .C. 3500 Sweet Air Street Baltimore, MD 21211 Rep: Mr. Jonath an Weisheit Phone: (410) 366

- 6332 Compliance and Research Services, Inc. 1701 Front Street Plainfield, NJ 07063

- 1066 Rep: Bob DePalma Phone: ( 908 ) 561

- 1824 (d) EFFECTS OF LESS FREQUENT COLLECTION Since reporting is done onl y at the time of initial and “final” entry , the effects of less frequent collection would be to seriously undermine the Agency 's ability to determine whether vehicles being imported meet applicable emission requirements. Consequently , the Agency

would not be ab le to allow entry of vehicles being imported. Therefore, less frequent collection is not feasible.6

(e) GENERAL GUIDELINES This I CR requires that I CI s notify EPA when requesting final admission for vehicles (Form 8) and this may

occasionally result in reporting more often than quarterly if vehicles are tested and ready for sale more frequently

than quarterl y . This requirement is necessary for EPA to have the opportunity to inspect vehicles prior to release from the IC I. If EPA onl y required quarterl y reports, either the I CI would have to hold vehicles and release them on a quarterl y basis or EPA would not likely have the opportunity

to inspect or require confirmatory testing of vehicles imported by the ICI. EPA's regulations require that I CI s retain records for a period of six y ears from the date of entry (40 CFR 85.1507 (a) ). IC Is are responsible for the same emissions warrant ies that appl y to original manufacturers, generall y extending to 8 ye ars or 80,000 miles for major emission control components

. T he Clean Air Act requires that light

- dut y vehicles meet f

ederal emission standards throughout their useful lives , which is defined by the Clean Air Act to be either 10 y ears or 100,000 miles (Sec. 202(d)); these requirements are implement ed through the certification process for ICIs just as they are for original manufacturers. The i mports regulations specify that the useful life period starts from the date that the vehicle is released to the owner by the ICI. The six

- year record retention requirement is the minimum considered consistent with these obligations. ( f) CONFIDENTIALITY Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to policies set forth in Title 40, Chapter 1, Part 2, Subpart B

- Confidentiality of Business Information (CBI) (see CFR 2). The public is not permitted access to information containing personal or organizational identifiers. Thi s collection complies with the Privacy Act of 1974 and OMB Circular A

- 130. (g) SENSITIVE QUESTIONS T here are no sensitive questions. 4. THE RESPONDENTS AND THE INFORMATION REQUESTED (a) RESPONDENTS/NAICS CODES The Li ght

- dut y Vehicle Group and Imports Team of CI SD collect information from individual importers and both small and large companies that import light

- duty vehicle, light

- duty truck, and on - road motorcy cle vehicles or engines. The NAICS code for respondents is : 1) 42 3 110, Automobile and Other Motor Vehicle Merchant Wholesalers ; and 2) 441200, Other Motor Vehicle Dealers.7

(b) INFORMATION REQUESTED

(i) Data Items The data requested in reports include:

- vehicle identifi cation number

- vehicle make

- vehicle model

- model y ear of the vehicle

- port of entry

- date of entry

- entry number

- importer name, address and telephone number

- owner name, address, telephone number and SSN or EI N

- emission test results

- applicable EPA certificate of conformit y

- fuel economy

- test date

- modification date

- name of emissions test laboratory

- vehicle storage location

- justification for an exclusion o r exemption, if applicable and records are maintained on:

- documents related to certification, modification, importation, storage, registration or emission testing

- bills of sale, invoices, or purchase agreements

- docu ments providing parts identification data associated with the emission control sy stem

- documents providing evidence of the initiation of the "hold period"

(ii) Respondent Activities To complete the collection, the re spondent would:

- read form instructions

- collect data and complete forms

- conduct required emission testing (I CI s only )

IN FORMAT ION REQUIREMENTS FOR IMPORTATION OF NONCONFORMING MOTOR VEHI CL ES

AND MOTOR VEHI CLE ENGINES ( 40 CFR PART 85 , SUBPARTS P and R ) (Renewal) IN F ORMATION REQUIREMENTS CI TAT ION8

I. ICI requirements

- Reporting

- Applicat ion for final admission 85.1505(a) (certified)

- Reasonable assistance during inspection, 85.1506(c),(g)(4) including c opi es of records or documents 85.1506(b)(2)

- Applicat ion for final admission 85.1509(b) (modification/test)

- Repair and retest 85.1509(g)

- Maintenance i nstructions, attestation, 85.1510(a) parts list

- Altitude compensato r in structions, attestation 85.1510(b)

- Emission warranties, attestation 85.1510(c)

- Emission la

beling, attestation 85.1510(d)

- Fuel econom y labeling, attestation 85.1510(e)

- Gas guzzle r tax forms, attestation 85.1510(f)

- Repl y to notice of suspension or 85.1513(f)(3)(ii), revocation 85.1513(f)(3)(iv) 85.1513(f)(6)

- Request for hearing 85.1513(f)(3)(iii) Recordkeeping

- Certification, mod ification, test, purchase, 85.1507 sale, storage, registration, importation

- Owner s or ultimate purchasers 85.1508(b)

- Maintenance instructions, parts list, 85.1510 altitude compensator instructions, emission warranties, emission labeling, fuel econom y labeling
II. R equirements applying to all importers

- Notification of conditional admission 85.1504(a)

- Request for prior approval (exemption), 85.1511(b),(g) request for extension of exemption

- Request for prior approval (exclusion) 85.1511(c)

- (g )

- Attestations, copy

of paid invoice 85.1512(f)

- Claim of confidentiality 85.1514

5. THE INFORMATION COLLECTED : AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEM ENT (a) AGENCY ACTIVITIES9

Form 1 s are collected as they are received from Customs and, in some cases, from importers or their agents and collected b y the Imports Team ; Form 8 s are collected by the I mports T eam and copies dis tributed to certif ication staff; since late 2005 the data from Form 8 has been entered into the Automated I mports Tracking S ys tem ( AITS )

. After receiving the information, EPA uses it to determine whether vehicles meet EPA requirements and whether to conduct investigations or require confirmatory testing, and retains it in order to respond to public, State government, and Federal government inquires. In addition, IC I applications for certification are now included in the “ Verify ” information sy stem , effective with the 2010 ye ar imports

. (b) COLLECTION METHODOLOGY AND MANAGEMENT Form 1 is available in fillable .pdf form downloadable from EPA's imports website. Form 8 has recently

been converted to fillable and posting at the same site is under consideration . For

ms are submitted to EPA by the importer or its agent or Customs after being filled out at the port of entry in the case of Form 1 and by the importer or its agent in the case of Form 8. Both Customs and CI SD use the information to determine if vehicles mee t EPA requirements. CI SD retains information in the AITS and document form in order to respond to public, State government, and Federal government inquires, which are handled b y CISD staff. (c) SMALL ENTITY FLEXIBILITY Small entities that ar e required to submit information to EPA have been doing so by completing and submitting EPA paper forms. EPA regulations provide, as an alternative, for submi ssion of imports data electronicall y (e.g. 40 CFR 85.1505(a), 85.1509(b) & (c)). Under EPA guidan ce (CCD

- 02

- 04; ( http://www.epa.gov/otaq/cert/dearmfr/ dearmfr.htm ) , IC Is qualify per se as small volume manufacturers entitled to the special provisions available to all certify ing small manufacturers under EPA’s certification regulatio ns. As stated above, I CI certification activities are now conducted electronically via “ Verify ”

. Form 8s are currently submitted electronicall y as email attachments or in paper form. (d) COLLECTION SCH EDULE The information is not subject to a collection schedule, but is collected at the time of vehicle entry

and when the vehicle is ready for final admission by

EPA. 6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION (a) ESTIMATING RESPOND ENT BURDEN (HOURS) See the table below . Each form is estimated to take 0.5 hours to complete. Completing required post

- certification testing is estimated at 28 hours per test. There is no requirement for importers to keep copies of Form 1. Extra rec ordkeeping for Form 8s10

were formerl y estimated at an additional 0.5 hour per form; however, these recordkeeping burdens are more appropriately attributed to the certification ICR, which will be adjusted accordingl y during the next renewal. There is no reco rdkeeping burden associated with Form 8 other than adding it to the existing records for the certified family

. (b) ESTIMATING RESPONDENT COSTS (i) Labor Costs Labor costs are considered to be more closel y approximated by the motor vehicle manufacturing industry , NAI CS 336100, than retail and wholesale trades in vehicles that do not involve testing and modification. Rates for engineering managers, mechanical engineers, and secretaries (except legal, medical, and executive) are from the May 2 008 National Industry

- Specific Occupational Employ ment and Wage Estimates (http://www.bls.gov/oes/2008/may /naics4_336100.htm , accessed December 10 , 200 9 ). With a 160% overhead multiplier, these are $8 7.30 , $ 60.40 , and $3 0.50 , respectivel y. Test labor costs are $55.82 per hour based on ICR 0783.54. (ii) Operations and Maintenance (O&M) Costs Operations and maintenance costs appl y onl y to Form 8 and were calculated based on responses received from the I CI s contacted. The Operations and Maintenance cost for reporting ordinaril y involves a purchase of services from a broker who complete a package of importation forms (including those of other agencies) and file s them with both Customs and EPA . This cost is estimated as a component of overall broker activities to import a vehicle or engine, and incorporates a $2 per form paperwork cost for broker form handling within overall broker activities , and a $3 per form mailing cost for Form 8s

. O& M costs associated with testing are much less than those for c ertification vehicles; post

- certification vehicles do not have mileage accumulation or durability demonstration requirements or consequent vehicle depreciation; vehicle preparation is minimal. O&M testing costs are estimated at $651 per vehicle. Costs ass ociated with modification of vehicles necessary

to bring them up to certification standards are excluded: they are not reported on the imports forms, they vary widel y depending on the vehicle being imported, and they

therefore can not be predicted or accounted from one y ear to another; finally , they

are analogous to, for example, the costs of catal yt ic converters and other emissions control technologies that original manufacturers are required to install in vehicles in order to comply with the Clean Air Act , and which are not included in the certification paperwork burden. (iii) Capital/Startup vs. Operations and Maintenance (O&M) Costs11 Capital/Startup vs. Operation and Maintenance (O&M) Costs

O& M Capital/Startup (unamortized) Capital/Startup (am ortized) Total Dep. Cap + O&M Filing Form 3520

- 1 $0 0 $0 $0 Form 3520

- 8 $1,056 0 $0 $0 Testing Form 3520

- 8 Regular ICI $62,496 $358,400 $51,028 $113,524 Mod and Test $27,342 $156,800 $22,325 $49,667 Total $90 ,894 $515,200 $73,353 $164,247
( iv ) Capital/Start
- up Costs Consistent with I CR 0783, a capital cost of $4,000,000 for a test facility capable of conducting 750 combined FTP and highway tests p er year has been allocated on a per

test basis. Following ICR 2387.01, which is the L ig ht Dut y Greenhouse Gases rule ICR, this is allocated 0.7 to the FTP portion. For ICIs, these test facility costs will in most cases be covered b y contractual costs betwe en the importer and a testing laboratory

. As mentioned above, these costs listed here are not initial certification costs but the post

certification test costs for additional imported vehicles. As with other ICRs, these capital costs are annualized an d subject to 7% interest depreciation but are considered to be on

going rather than startup capital costs in the sense that as facilities are depreciated they are continuall y being replaced. ( c) ESTIMATING AGENCY BURDEN AND COST The i mports pr ogram is administered by EPA's Compliance and Innovative Strategies Division (CI SD ). Fort y percent of one F ull Time Equivalent employ ees (FTE), GS 12 / 3 ; twenty percent of one Senior Environmental Employ ment (SEE) Program employ ee (the SEE Program is an employ ment program for older workers authorized by the Environmental Programs assistance Act, passed by Congress in l984, and provides employ ment opportunities to s enior citizens age 55 and over); and a portion of the work assignment under a government contract are allocated to i mports activities. Government cost is based on a GS

- 12 , step 3 salary for professional engineers ($ 63 , 341 per year) obtained from the Office of Personal Management 2009 Salary Table; and $ 15.53 per hour for SEE emplo yees, with a 1. 6 multiplier for overhead applied to both , y ielding $40,538 and Based on the 200 6 GS pay schedule, EPA estimates an hourl y $ 34.35 for the FTE, then multiplies the hourly rates by the standard government benefits multiplication factor of 1.6, at a cost of $ 45,728 , and a cost of $ 9,939 for the SEE ; $ 106,000 is estimated for the contractor

. The contractor estimate is based upon the work assignment rather than an estimate of hours. An estimated total agency cost of $ 161,66712

per year is therefore allocated to i mports activities. These activities include both on - road imports (this I CR) and nonroad imports (ICR 1723; OMB 2060

- 0320). An estimated 90% of these activities currently involve on

- road imports; consequently , $ 145,500 is the estimate for the agency

co st for purposes of this ICR

. (d) Estimating the Respondent Universe and Total Burden and Costs In the previous renewal w e estimated that 1 2,000 Form 1 s are submitted annually , averaging one respondent per form, and 352 Form 8s from five I CI s, based on a hand count of Form 8s received in 2005 and 2006 , plus an estimate based on actual and projected imports from one high

- volume importer covering four original production ye ars . The total number of respon ses was therefore estimated as 12, 352

. The estimated number of respondents was 12,005. Both estimates are approximate and variable . For Form 1, our information is that Customs does not require every importer subject to the regulations at 19 CFR 12.73 to fill out the form; furthermore, the fo rms that are forwarded to us by Customs or by

importers may not represent every

form that is filled out. For Form 8, the number of ICI s is small, the number of engine families certified is small, and the number of vehicle imports within an engine family

can vary widel y. All these factors add up to produce significant "small number fluctuations". In 2005 there were 21 IC I families , including one high

- volume importer that greatl y multiplied the number of FTP tests employ ed. In 2008 there were 10 families, and without the high

- volume importer. Consequently , to insure that EPA has the authority to accommodate the possible level of forms and tests needed under the collection authorization, we have retained the numbers of forms and tests from the previous renewal. For each engine famil y, one imported vehicle is used for certification testing; therefore, while the forms count does not decrease, the testing responses is decreased b y the number of import engine families. For model year 2005, 21 ICI engine families were certified; the count of 300 regular ICIs was reduced by 11 to total 289 vehicles subject to post

- certification testing; every third vehicle results in an estimate of 96 tests; the total of 52 mod & test vehicles was reduced b y 10 certification vehicl es; the remaining 42 are subject to tests. (e) Bottom Line Burden Hours and Cost (i) Respondent Tally Respondents 12,005 Respon ses 12,352 Burden Hours 9, 350 Labor Cost $ 37 0,80 3 Operating Cost $9 0 ,8 94 Capital Cost $ 515,200 Capital Cost (Annualized , discounted) $73,35313

Total (Annualized) $5 35, 0 5 0

(ii) Agency Tally Employ ees 2 Employ ee Labor Cost $ 50,100 Contract Labor C ost $95,400 Total Cost $ 145,500 (f ) R easons For Change In Burden Thi s I CR follows the burden hours assumptions of the previous renewal for filling out the forms themselves, as well as the testing cost elements. The previous Supportin g Statement and Federal Register notices reported depreciated capital costs consistent with the treatment in all other ICRs dealing with similar testing costs, but the authorized burden requested was mistakenly based on un

- depreciated capital costs; correc ting this results in a large reduction in the request without a change in the underl yi ng program. O ther changes in bu r den reflect minor improvements to the hour and cost estimates for these elements to reflect information obtained for similar elements in i ntervening ICRs. This has resulted in an increase in O&M costs, a decrease in capital costs , and a decrease in hours associated with FTP tests. The agency and importer labor cost s have been updated with more recent cost figures for government and industry . The agency contract cost for the imports program is down over $50,000 from the previous report. ( g ) BURDEN STATEMENT Public reporting burden for this collection is estimated to average 45.4 minutes per response . Burden means the total tim e, 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 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 an y previously

applicable instructions and requirement s; 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 display s a currentl y valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR p art 9 and 48 CFR Chapter 15. To comment on the Agency 's need for this informa tion, the accuracy of the provided burden estimates, and an y suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA

- HQ

- OAR

- 200 9

- 0 982. Submit any

comments related to the I CR for this rule to EPA and OMB. Submit y our comments, identified by

Docket ID No. EPA

- HQ

- OAR

- 2009

- 0982, by on e of the14

following methods: www.regulations.gov : Foll ow the on

- line instructions for submitting comments.
F ax: (202) 566

- 1741

. M ail: 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 Docket ID No. EPA

- HQ

- OAR

- 2009

- 098 2 . I n addition, please mail a copyof y our 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 3334 , 1301 Constitution Ave., NW, Washington, DC., Attention Docket ID No. EPA

- HQ

- OAR

2009

- 0982 . 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 Number EPA

- HQ

- OAR

- 200 9

- 0982, is available for public viewing at the Air and Radiation Docket in the EPA Docket center (EPA/DC), EPA West, Room B10 2, 1301 Constitution Avenue, NW, Washington, D.C. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telepho ne number for the Air and Radiation Docket and Information Center is also (202) 566

- 174 4

. An electronic version of the public docket is available at www.regulations.gov

.

.15

Table 1: Annual Respondent Burden and Cost
-- Information Req uirements for Importation of Nonconforming Vehicles (40CFR Part 85, Subparts P and R) (Renewal)

Burden Item Number

Activities Hours per

Activity Total Hours Labor Filing Form 3520

- 1 12,000 0.5 6,000 $183,000 Form 3520

- 8 352 0.5 176 $10,630 Testi ng Form 3520

- 8 Regular ICI 96 23 2,208 $123,251 Mod and Test 42 23 966 $53,922 Total 12,352 0.5 9350 $370,803