Final

Supporting Statement

for

Information Collection Request

Certification and In-use Testing of Motor Vehicles: 

Revisions to Reduce Light-Duty Vehicle Emissions of Greenhouse Gases: 

Model Years 2017 – 2025

EPA ICR 0783.62

August, 2012

Compliance Division

Office of Transportation and Air Quality

Office of Air and Radiation

U.S. Environmental Protection Agency
Part A

SUBMISSION Section 1: Identification Of The Information Collection

1(a) Title And Number Of The Information Collection

Certification and In-use Testing of Motor Vehicles: Revisions to Reduce Emissions 

of Light-Duty Vehicle Greenhouse Gases, Model Year 2017 - 2025; EPA ICR number 

0783.62, OMB control number 2060-0104.

1(b) Short Characterization/Abstract

Introduction and Short Characterization

The Environmental Protection Agency and the National Highway Traffic and 

Safety Administration are jointly finalizing Light-Duty Vehicle Greenhouse Gas 

Emission Standards and Corporate Average Fuel Economy Standards changes designed 

to decrease emissions of greenhouse gases (GHG) for model year (MY) 2017 to 2025 

light duty vehicles (LDVs). This is an extension of the national GHG program 

rulemaking recently completed for MY 2012 to 2016 (75 FR 25324, May 7, 2010). This 

ICR deals with EPA’s portion of the rule, which concerns EPA’s motor vehicle 

certification and in-use testing programs, covered by the ICR 0783 series. As with the 

ICR on the prior rule, EPA is not aware of, and has not analyzed, any NHTSA-specific 

paperwork burdens in this ICR. The ICR addresses changes to paperwork burdens on 

these programs dealt with in the ICR on the MY 2012 – 2016 final rule (ICR 0783.58), 

which included the cost of upgrading information systems to comply with new 

reporting requirements, and new testing requirements. Other economic impacts, such as 

the industry’s costs of complying with the new standards, are discussed in the cost 

analysis portions of the preamble and Regulatory Impact Analysis associated with the 

regulations. That economic analysis includes "cost markups for manufacturer indirect costs" 

based on multipliers. The individual components of those indirect costs, such as paperwork 

costs, were not specifically addressed.

At OMB’s request, EPA previously disaggregated the 0783 certification ICR 

into separate Information Collections (ICs) for Emissions (also called Certification) and 

Fuel Economy (as well as ICs for DR/VERR defect reporting, IUVP in-use testing, and 

highway motorcycles). As with ICR 0783.58, the burdens in this ICR have been 

allocated to the emissions and IUVP ICs, even though the rule includes changes to 

EPA’s fuel economy regulations and the emissions reporting is done in a CAFEcompatible format.

Some of the changes occur as early as MY 2012, and constitute modifications of 

the prior rule. Other changes will start taking effect with 2017 model year light-duty 

vehicles and will phase in through model year 2025. The core of the rule is to set 

standards for emissions of greenhouse gasses for MY 2017 - 2025, continuing the 

information reporting structure established in the prior rulemaking. Most of the costs 
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associated with the rulemaking therefore involve an assessment of the available 

technology and the costs of using it and as such and are outside the scope of this ICR.

In addition, the standards incorporate assumptions about the extent to which credits 

based on air conditioning improvements will be used for compliance. These and other 

credit and incentive provisions in the rule have to be applied for with the submission of 

information to EPA. All credits and incentives that are alternatives to the normal 

emissions based methods of compliance with the standards will presumptively be used 

because they are less expensive that the normal methods of meeting the standards, even 

when taking the information costs into account. Paperwork burdens of these optional 

credits and incentives should be considered in the context of an overall lowering of the 

manufacturer's costs of compliance with the rule. 

ICRs normally have a three year time horizon. Those portions of this rule that go 

into effect with MY 2017 largely will fall outside the normal time horizon of an ICR, 

other than preparatory work, familiarization, and provisions that go into effect within 

three years of the final rule. This ICR will adjust the burdens authorized in the prior 

ICR covering MY 2012 -2016, where appropriate, and will discuss paperwork burdens that 

may change the authorized level after that without attempting to quantify cost impacts that 

the rule’s cost study itself deems speculative. (In addition, possible reductions in the burden 

after 2017 for some line items should not be counted until they go into effect because doing 

so could potentially cause noncompliance with the authorization prior to that, to the extent 

that the authorization is considered as based on the entire ICR cost analysis and not on 

merely on its aggregate results.) Furthermore, the rule includes a "mid-term evaluation" to 

be completed by 2018, which may provide information for adjustments to the model years 

beyond that. 

In many cases, this ICR cost analysis includes both high and low cost estimates; 

unless otherwise indicated, the burden estimates given below are the high-cost 

estimates. The rule changes will result in new costs (high estimate) of about $1,399,632

annually in capital and operations and maintenance costs with an increase in labor hours

of 5,667 annually on the regulated manufacturers compared to the baseline after the 

prior MY 2012-2016 GHG rule. 

Summary of the MY 2017-2025 GHG Rule’s New Paperwork-Affecting Features

This summary gives necessary background for the estimations given in Part 6. 

Starting with model year 2017, manufacturers will be required to meet 

increasingly stringent greenhouse gas emissions limits through 2025, beyond those 

specified in the prior rule for 2012 to 2016. These limits will be enforced through the 

certification program. As with the existing program, averaging, banking, and trading 

(ABT) will be available; light-duty vehicles (cars), light-duty-trucks, and medium-duty 

passenger vehicles seeking certificates of authority to sell vehicles in the United States 

will be required to submit CO2 test results and other information in support of 

certification applications; and all certified vehicles will be subject to the requirements 

of the In-Use Vehicle Testing Program (IUVP). This ICR considers the costs associated 
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with submitting this information to EPA, including the costs of generating the 

information to be submitted, such as testing costs, and facility and equipment costs to 

conduct the testing. The ICR calculates the changes in the baseline information burden, 

based on changes in the existing GHG program, the major outlines of which were 

established in the prior rule and costed in the prior ICR. 

The prior ICR included new testing costs associated with air conditioning credits 

because the level of credit attainment was included in the compliance standards. It also 

included new IUVP testing costs due to the requirement that the highway fuel 

efficiency test be added for the test fleet. Both of these had a capital cost component for 

the facilities needed to conduct the tests, and there were startup capital costs for N2O 

analyzers and for information system updating. Estimates were also made for the more 

direct burden increases for reporting and recordkeeping, including estimated paperwork 

burdens for the other credits. This ICR incorporates an updated estimate of the costs of 

N2O analyzers, and additional and updated costs for information and familiarization 

with the regulations. 

This rule includes an updated estimate of the number of manufacturers affected 

by the GHG standards, the number of small businesses exempt from the standards, and 

brings in some small volume manufacturers exempted in the prior rule. The prior ICR 

assumed 53 manufacturers, of which 20 were small businesses which are exempt from 

GHG standards, for a total of 33 respondents. The current ICR also assumes 33 

respondents. (EPA is exempting police and emergency vehicles beginning with

MY2012, but the test-group level impact of this, if any, is likewise too limited to 

quantify at this time.) These changes result in adjustments to the prior ICR's testing, 

facility, capital, and general reporting burden estimates. 

The prior MY 2012-2016 rule requires SVMs to make a good faith effort to secure 

credits from other manufacturers, if they are reasonably available, to cover the emissions 

reductions they would have otherwise had to achieve under applicable standards. These 

SVMs are otherwise exempt from the CO2 standards. Eligible manufacturers are SVMs 

having vehicle sales of less than 5,000 per year (three-year rolling average) in the U.S. There 

are currently three manufacturers that qualify under this definition. The high cost estimate for 

purposes of the reporting requirements assessment assumes five and the low, three. Under 

the MY 2017-2025 final rule, SVMs can petition EPA by July 30, 2013 for alternative 

standards that would go into effect beginning MY 2017. This petition requires submission of 

detailed supporting information that imposes a new information collection burden. The 

analysis assumes all three or five will submit this information. The first petition and ruling 

could be followed by an indeterminate number of additional petitions and standards in 

subsequent years covering model years through 2025. This burden is reduced by the fact that 

the submission is similar to those required in support of similar alternatives already required 

beginning prior to 2017 by NHTSA for CAFE, and the European Union. It is also reduced by 

the fact that the application and the standards that result can cover up to five model years. 
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EPA requested comments on and is finalizing extending the SVM standards 

eligibility to manufacturers that are able to demonstrate that they are operationally 

independent from their parent company. EPA received only supportive comments regarding 

extending SVM alternative standards to manufacturers able to demonstrate operational 

independence. EPA knows of only one likely respondent for the operational independence 

criteria EPA and therefore does not expect the criteria to be widely used. For this ICR, EPA

estimates that a low of one and a high of two manufacturers will apply for SVM standards 

under the operational independence provisions. EPA has included an estimate of the burden 

associated with applying for operational independence determination and have increased the 

total estimate of manufacturers eligible for SVM standards from 3 to 5 manufacturers to 4 to 

7 manufacturers.

Much of the rule that affects reporting deals with modifications to the credit and 

incentive provisions of the prior rule. Manufacturers choose between 1) tailpipe 

attainment of CO2 emissions standards without credits or incentives, and 2) application 

and qualification for use of one or more of the available optional credits and incentives. 

The rule makes a distinction between incentives, the AC credit, and other credits, where 

the AC credit is incorporated into the fleet emission standards because the extent to 

which it is achievable industry wide was considered calculable, whereas in the other 

cases it was not. In the case of AC, the calculation is in terms of vehicle numbers under 

an econometric model rather than manufacturers and test groups relevant to the 

paperwork burden. The provisions that are modified or new are summarized below: 

1) Overcompliance and undercompliance credits, debits, trading and transfers are 

unchanged, except that a carry forward of more than five years (to 2021) is added for 

credits that were earned during the initial MY 2010 – 2016 period. 

2) Air conditioning improvement tests: the previous CO2 credits for emissions, 

refrigerant leakage, and global warming improvements remain. EPA is incorporating air 

conditioning improvements in its CO2 standards, leaving manufacturers the option of 

achieving those standards by applying for the credit or by other means. Therefore, there 

is no assumption about how many manufacturers will apply for the credit; the full amount of 

the achievable reduction is incorporated in the standard, and manufacturers can achieve that 

reduction however they wish. The analysis in the previous ICR that assumed most or all 

manufacturers will apply for the credit is maintained in this ICR. Minor changes in the 

leakage credit showing are accounted for in the "familiarization" burden estimate. The 

possible need for some manufacturers to upgrade their refrigerant storage facilities and 

charging stations on the assembly line in order to comply with the CO2 emissions standards 

to the extent that they incorporate assumptions about use of alternative refrigerants, is 

regarded as a cost of compliance rather than reporting. 

EPA is also finalizing changes to the test procedures used for optional A/C credits. 

EPA is replacing the Idle Test with a new “AC17” test procedure beginning in MY 2017. 

The AC17 test procedure is optional prior to MY 2017. Beginning in MY 2020, 
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manufacturers will also need to use AC17 testing to demonstrate that the A/C efficiencyimproving technologies or systems on which the desired credits are based are indeed 

reducing CO2 emissions and fuel consumption. The AC17 test is more expensive from a 

testing and paperwork standpoint but only applies to "platforms", a smaller class than 

"test groups" so that, depending on the number of platforms tested, it could either 

increase or decrease the testing burden associated with the A/C credit. In response to 

manufacturer comments, EPA adopted some relatively minor technical changes that EPA 

agrees will make performance of the test more efficient, with no appreciable effect on test 

accuracy including provisions relating to: the points during the test when cell solar lamps are 

turned on; establishing a specification for test cell wind speed; and a simplific The AC17 

test is reflected in an increased range of the high and low estimates for this paperwork 

cost item in this ICR, while the underlying cost assumptions for AC testing are retained. 

EPA received comments from manufacturers raising concerns regarding the 

number of AC 17 test that would be required. In response to these concerns, EPA has 

taken several steps in the final rule to clarify how a manufacturer will be able to use the 

AC17 to demonstrate the effectiveness of its different A/C systems and technologies while 

minimizing the number of tests that it will need to perform. In general, EPA believes that it 

is appropriate to limit the number of vehicles a manufacturer must test in any given model 

year to no more than one vehicle from each platform that generates credits (and CAFE 

improvement values) during each model year. EPA is also clarifying the definition of 

“platform” in addition to more clearly limiting testing to one test per platform per year, and 

believes we have addressed the manufacturers’ concerns about unreasonable test burdens. 

Finally, in order to further minimize the number of tests that will be required for A/C 

efficiency credit purposes, instead of requiring replicate testing in all cases, EPA will allow a 

manufacturer to submit data from as few as one AC17 test for each instance in which testing 

is required. 

3) Off-cycle credits are continued, but with a simplified approval process for some of 

the relevant technologies (defined technologies qualify for the credits given adequate 

penetration of the manufacturer's fleet subject to a combined manufacturer fleet credit 

cap and with minimum penetration requirements for certain technologies) starting with 

MY 2014 and altered eligibility criteria in other cases beginning in MY 2012. The 

default off-cycle credit requires running three 5-cycle tests with and without the 

technology along with an engineering analysis to support the credit application; an 

alternative demonstration methodology can be requested based on submission of 

supporting information. The MY 2017-2025 final rule adds a list of defined 

technologies that are pre-approved for credits starting with MY 2014, with 

manufacturer fleet-wide caps on the amount of the credit. For the MY 2012 – 2016 

period, there are changes in the criteria and possible additional or alternative tests. 

Applying for the credit is presumably less burdensome from a compliance standpoint 

than not qualifying for the credit, for those who choose to qualify. Off-cycle 

components generating credits are subject to all in-use requirements, including 

durability testing, defect reporting, warranty, and recall. Assumption about the class of 

manufacturers and number of tests that would fall under each variant are unwarranted at 

this time. A step-by-step review process for 2012 on is spelled out to qualify and apply 
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for these credits. 

4) Various new incentive multipliers are added for electric vehicles (EVs), plug-in hybrid 

electric vehicles (PHEVs), fuel cell vehicles (FCVs) and natural gas vehicles, for MY 2017 

through 2021 that would allow each of these vehicles to “count” as more than one vehicle in 

the manufacturer’s compliance calculation (The 0 gram per mile compliance value incentive 

from the prior rule is continued, but without the production cap for MY2017 – 2021. For 

MY 2022 through 2025, EPA is finalizing that the 0 grams per mile compliance incentive 

will apply up to a per-company cumulative production cap threshold for those model years.) 

Since the credit in all these cases is based on production figures that are reported anyway as 

part of the end-of-year report, the small paperwork burden addressed in the prior ICR is

small. However, new data would need to be submitted for production over a manufacturer's 

cap, if any, in order to calculate the GHG compliance level taking into account upstream 

emissions. This ICR considers the production caps for the period up to 2016 unlikely to be 

exceeded.

5) Incentive for Game Changing Technologies: a new CO2 credit in the GHG program for 

manufacturers that employ significant quantities of hybridization on full size pickup trucks, 

by including a per-vehicle CO2 credit available for mild and strong hybrid electric vehicles 

(HEVs). The credit requires a showing of market penetration. EPA is also finalizing a 

performance-based incentive CO2 emissions credit for full size pickup trucks that achieve a 

significant CO2 reduction through technologies other than hybrid systems. Both begin with 

MY 2017. The main paperwork burden associated with these provisions is showing that the 

vehicles in question qualify, which is a simple matter of definition, and showing that the 

market penetration requirements (a minimum percentage of a manufacturer’s full-size pickup 

trucks) have been met, which is a matter of sales records, which are already reported, or that 

performance fits the criteria based on testing that is required anyway. 

6) N2O and CH4 Flexibility: A new provision allows CO2 credits to be used to satisfy the 

NO2 and CH4 emissions caps contained in the prior rule for those manufacturers choosing to 

comply using the CO2-equivalent standard option, which allows manufacturers to fold all 2-

cycle weighted N2O and CH4 emissions, on a CO2-equivalent basis, along with CO2 into their 

CO2 emissions fleet average compliance level. This has no effect on the testing cost. 

Additional details on the coverage of this ICR are given in Section 4(b), below. 

Section 2: Need For And Use of the Collection

2(a) Need/Authority For The Collection

Under Title II of the Clean Air Act (42 U.S.C. 7521 et seq.), EPA is charged 

with issuing certificates of conformity for motor vehicle designs that comply with 

applicable emission standards set under section 202(a)(1) of the Act, such as those for 

CO2, N2O, and CH4 in the final regulation. (This authority was clarified in the 

Supreme Court’s decision State of Massachusetts v. EPA, 127 S. Ct. 1438 (2007)). 

Section 202(a)(1) states that ‘‘the Administrator shall by regulation prescribe (and from time 
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to time revise) [...] standards applicable to the emission of any air pollutant from any class or 

classes of new motor vehicles [...], which in his judgment cause, or contribute to, air 

pollution which may reasonably be anticipated to endanger public health or welfare.’’ The 

Administrator has found that the elevated concentrations of a group of six GHGs in the 

atmosphere may reasonably be anticipated to endanger public health and welfare, and that 

emissions of GHGs from new motor vehicles and new motor vehicle engines contribute to 

this air pollution

A manufacturer must have a certificate before vehicles may be legally 

introduced into commerce. To insure compliance with the Act, EPA reviews product 

information and manufacturer test results; EPA also tests some vehicles to confirm 

manufacturer results. Information is also shared with other agencies: the Internal 

Revenue Service for “gas guzzler” taxes and NHTSA for CAFE and GHG requirements.

Other elements of the legal and regulatory background relating to the need and 

authority for the final rule are discussed in the preamble to the rule. 

Under Section 206(a) of the Clean Air Act (42 U.S.C. 7525) “... The 

Administrator shall test ... any new motor vehicle ... submitted by a manufacturer ... If 

such vehicle ... conforms ... the Administrator shall issue a certificate of conformity.” 

While EPA has delegated a substantial portion of the process of calculating and 

reporting emissions and fuel economy results to the manufacturers, the test results upon 

which labels are based are subject to EPA confirmatory testing. Such confirmation 

testing makes sure that results from different manufacturers can be accurately used for 

comparison.

The regulations dealing with LDV and LDT emission control can be found in 40 

CFR Parts 85 and 86. The regulations dealing with reporting fuel economy information 

are in 40 CFR Part 600. The regulations are not attached to this statement due to their 

length and technical nature. 

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

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

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

2(b) Practical Utility/Users of the Data

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

new GHG requirements have been complied with by means of the certification and inuse testing programs.

Section 3: Nonduplication, Consultations, and Other Collection Criteria

3(a) Nonduplication

The compliance process for both manufacturers and EPA builds on existing 

practice wherever possible, and manufacturers can use a single data set to satisfy both 
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GHG and Corporate Average Fuel Economy (CAFE) testing and reporting 

requirements. The EPA and NHTSA programs replicate the compliance protocols 

established under the prior rule. The certification, testing, reporting, and associated 

compliance activities track current practices and are thus familiar to manufacturers. As 

is the case under the 2012-2016 program, EPA and NHTSA have designed a 

coordinated compliance approach for 2017-2025 such that the compliance mechanisms 

for both GHG and CAFE standards are consistent and non-duplicative. The information 

collection, reporting, and storage provisions of the rule rely on EPA’s existing 

certification and in-use programs and on EPA’s fuel economy reporting system that is 

used by NHTSA in developing and administering CAFE standards. As discussed at 

length in the preamble to the final rule, this is a joint rulemaking by NHTSA and EPA, 

a format which has a maximum degree of coordination between the two similar 

programs addressing GHGs and fuel economy. NHTSA is regulating fuel economy, 

whereas EPA is regulating GHG emissions. The statutory mandates for the two 

agencies are different, and this results in a certain degree of difference in two programs 

that nonetheless share a great deal in approach and structure. 

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

EPA solicited public comment by means of the Federal Register Notice of the 

proposed rule, published on December 1, 2011, 76 Federal Register 74854; a copy can also 

be found at http://www.epa.gov/otaq/climate/regulations.htm. The draft ICR was placed in 

the docket. 

3(c) Consultations

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

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

consultation with the affected industry. As for the MY 2012-2016 rulemaking, 

collaboration with California Air Resources Board (CARB) and with industry and other 

stakeholders has been a key element in developing the agencies’ rules. Throughout the 

development of this rule, EPA met extensively with individual manufacturers, groups of 

manufacturers, industrial trade associations, industry professional organizations, and 

other stakeholders. Their comments have been reflected in the burden estimates 

discussed below. 

3(d) Effects of Less Frequent Collection

As required by the Clean Air Act (42 USC 7525(a)), emission and fuel economy 

information is submitted on a yearly basis coinciding with the manufacturer’s “model 

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

flexibility in this regard. Major product changes typically occur at the start of a model 

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

However, when a vehicle design is “carried over” to a subsequent model year, the 

amount of new information required is substantially reduced. Some information is also 

to be submitted during the model year, including model-level GHG testing results, 
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analogous to model-level fuel economy results, which are necessary because 

certification data are collected on a test group basis which does not allow for fleet total 

GHG emissions and fuel economy calculations on a model level basis. Likewise, 

existing regulations require an end-of-year report, with final production numbers, and 

the new requirements would be conformed to this existing requirement as well. In-use 

testing is currently required at low- and high-mileage intervals after a model year 

vehicle has entered commerce, and the final rule's provisions bearing on in-use testing 

conform to the current program. 

3(e) General Guidelines

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

years. This requirement stems from the statutory requirement that manufacturers 

warrant some items for periods longer than 3 years.

This information collection activity complies with the remaining guidelines in 5 

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

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

approved collection.

3(f) Confidentiality

Information submitted by manufacturers is held as confidential until the specific 

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

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

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

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

is granted confidentiality in accordance with the Freedom of Information Act, EPA 

regulations at 40 CFR Part 2, and class determinations issued by EPA’s Office of 

General Counsel.

3(g) Sensitive Questions

No sensitive questions are asked in this information collection. This collection 

complies with the Privacy Act and OMB Circular A-108.

Section 4: Respondents and Information Requested

4(a) Respondents/NASIC Codes

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

table:
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Category NAICS Codes AExamples of Potentially Regulated Entities

Industry 336111

336112

Motor vehicle manufacturers.

Industry 335312

336312

336399

811198

Alternative fuel vehicle converters 

Industry 811111

811112

811198

423110

Commercial Importers of Vehicles and Vehicle 

Components B

A North American Industry Classification System (NAICS)

B We are currently unaware of any independent commercial importers (ICIs); as the rule

would defer small businesses these ICIs would not be regulated at this time.

4(b) Information Requested

(i) Data items

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

context of EPA’s motor vehicle certification program and the manufacturers’ in-use 

testing program (IUVP). Current regulations require manufacturers to submit emissions 

information to EPA in conjunction with these two programs (Information Collections). 

Manufacturers must submit an application for emission certification prior to production. 

The application describes the major aspects of the proposed product line, technical 

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

with the emissions and GHG limitations. The application and supporting test results are 

reviewed and, if appropriate, a certificate of conformity is issued. Subsequently, lowand high-mileage vehicles in use are tested for emissions by manufacturers and the 

results of those tests reported to EPA. 

The data items in the GHG program were summarized in the prior ICR. The 

basic outline of the model year submission scheme is restated here for convenience ; for 

additional details on the prior rule, see the Supporting Statement for ICR 0783.58):

Before the beginning of each model year:

GHG compliance plan including projected use of credits 

provisions.

At the time of certification:

CO2 and CH4 emissions test results for each test group being 

certified.
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Engineering evaluation indicating that common calibration approaches 

will be utilized at high altitude.

N2O measurement results or compliance showing for each test 

group.

During the model year, after certification:

CO2 emissions test results for model types. (The models for which 

results are reported is considered to be coextensive with those 

already reported for CAFE fuel economy purposes.)

AC/CO2 test for models representing percentages of the 

applicant’s production volume, starting in 2014.

After the model year: 

End of model year GHG emissions report for CO2, including the 

final fleet average standard, all values required to calculate the fleet 

average standard, the actual fleet average CO2 that was achieved, all 

values required to calculate the actual fleet average, the number of 

credits generated or debits incurred, all the values required to calculate 

the credits or debits, and the resulting balance of credits or debits. 

Report of credit transactions. 

During in-use testing:

Results of the highway fuel economy test (HFET) along with the 

currently-reported FTP results for each tested vehicle.

The current rule makes the following additions to the data items that are

reflected in this ICR:

Small Volume Manufacturers (less than 5,000 units per year sold in the U.S.) 

must submit a request for alternative CO2 standards or else comply with the regular 

standards. The ICR assumes that eligible SVMs will request alternative standards. The 

data items are as follows:

EPA requires that SVMs seeking an alternative standard provide the following 

information as part of their petition for SVM standards:

Vehicle Model and Fleet Information

• MYs that the application covers – up to 5 MYs. Sufficient information must be 

provided to establish alternative standards for each year

• Vehicle models and sales projections by model for each MY

• Description of models (vehicle type, mass, power, footprint, expected pricing)
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• Description of powertrain 

• Production cycle for each model including new vehicle model introductions

• Vehicle footprint based targets and projected fleet average standard under primary 

program by model year

Technology Evaluation

• CO2 reduction technologies employed or expected to be on the vehicle model(s) for 

the applicable model years, including effectiveness and cost information

– Including A/C and potential off-cycle technologies

• Evaluation of vehicles produced by other manufacturers similar to those produced by 

the petitioning SVM and certified in MYs 2012-2013 (or latest two MYs for later 

applications) for each vehicle model including CO2 results and any A/C credits 

generated by the models

– Similar vehicles must be selected based on vehicle type, horsepower, mass, 

power-to-weight, vehicle footprint, vehicle price range, and other relevant 

factors as explained by the SVM

• Discussion of CO2 reducing technologies employed on vehicles offered by the 

manufacturer outside of the U.S. market but not in the U.S., including why those 

vehicles/technologies are not being introduced in the U.S. market as a way of 

reducing overall fleet CO2 levels

• Evaluation of technologies projected by EPA as technologies likely to be used to 

meet the 2012-2016 and 2017-2025 standards that are not projected to be fully 

utilized by the petitioning manufacturer and explanation of reasons for not using the 

technologies, including relevant cost information

SVM Projected Standards

• The most stringent CO2 level estimated by the SVM to be feasible and appropriate by 

model and MY and the technological basis for the estimate

• For each MY, projection of the lowest fleet average CO2 production mix of vehicle 

models and discussion demonstrating that these projections are reasonable

• A copy of any applications submitted to NHTSA for MY 2012 and later alternative 

standards

Eligibility

U.S. sales for previous three model years and projections for production volumes over 

the time period covered by the application
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Complete information on ownership structure in cases where SVM has ties to other 

manufacturers with U.S. vehicle sales

New SVMs intending to enter the market in 2017 – 2025 have additional reporting 

requirements:

evidence that the company intends to enter the U.S. market within the time frame of 

the MY2017-2025 SVM standards. Such evidence would include documentation of 

work underway to establish a dealer network, appropriate financing and marketing 

plans, and evidence the company is working to meet other federal vehicle 

requirements such as other EPA emissions standards and NHTSA vehicle safety 

standards. 

In addition, EPA requires that manufacturers seeking an operational independence 

determination to become eligible for SVM alternative standards provide information 

demonstrating that they meet the following criteria:

1. No financial or other support of economic value was provided by related 

manufacturers for purposes of design, parts procurement, R&D and production 

facilities and operation. Any other transactions with related manufacturers must be 

conducted under normal commercial arrangements like those conducted with other 

parties. Any such transactions shall be at competitive pricing rates to the 

manufacturer. 

2. The applicant maintains separate and independent research and development, testing, 

and manufacturing/production facilities.

3. The applicant does not use any vehicle engines, powertrains, or platforms developed 

or produced by related manufacturers.

4. Patents are not held jointly with related manufacturers. 

5. The applicant maintains separate business administration, legal, purchasing, sales, 

and marketing departments as well as autonomous decision making on commercial 

matters. 

6. Overlap of Board of Directors is limited to 25 percent with no sharing of top 

operational management, including president, chief executive officer (CEO), chief 

financial officer (CFO), and chief operating officer (COO), and provided that no 

individual overlapping director or combination of overlapping directors exercises 

exclusive management control over either or both companies.

7. Parts or components supply agreements between related companies must be 

established through open market process and to the extent that manufacturer sells 
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parts/components to non-related auto manufacturers, it does so through the open 

market at competitive pricing.

Manufacturer applying for operational independence must provide an attest engagement from 

an independent auditor verifying the accuracy of the information provided in the application. 

After EPA approval, the manufacturer will be required to report within 60 days any material 

changes to the information provided in the application for the operational independence 

determination. 

(ii) Respondent Activities

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

product and supply test data and other information to verify compliance, including the 

test data and reports added by this rule. After certification, additional fuel economy 

tests are conducted and the results reported to EPA for base engines within the test 

group. After the end of the model year a calculated fleet average greenhouse gas 

emissions will be calculated and reported and credits, debits, and trades described. As 

now, high mileage and low mileage in-use vehicles are procured by manufacturers and 

tested for emissions, including the testing added by the prior rule. EPA also conducts a 

limited number of “confirmatory tests” to monitor manufacturer results, and this will 

continue as before with inclusion of testing for GHGs. This requires test vehicles to be 

shipped to EPA’s laboratory. Manufacturers must also retain records. These tasks are 

repeated for each model year, although typically previous data and information can be 

“carried over” when no significant changes have occurred. If, during the course of a 

model year a product change is made (a “running change”), EPA must be notified. 

Under some circumstances additional test data may be required. Manufacturer activities 

also include the post-certification, end of model year, and IUVP actions discussed in 

Section 4(b)(i). 

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

Information Management

5(a) Agency Activities

The test data used by EPA to determine compliance with GHGs and other 

emissions and fuel economy standards are derived from vehicle testing done by vehicle 

manufacturers who report their own test data to EPA, and at EPA's National Vehicle 

and Fuel Emissions Laboratory in Ann Arbor, Michigan. Each year, EPA provides fuel 

economy data to the Department of Energy (DOE), NHTSA, and the Internal Revenue 

Service (IRS) so that they can administer their fuel economy-related programs. DOE 

publishes the annual fuel economy label values in the annual Fuel Economy Guide and 

on the fuel economy web site at http://www.fueleconomy.gov. NHTSA receives the 

manufacturers' fleet average fuel economy from EPA, and determines if manufacturers 

are complying with the CAFE standards. EPA provides IRS with the fuel economy data 

for vehicles that may be subject to the Gas Guzzler tax penalty. The IRS is responsible 
16

for collecting those taxes from manufacturers.

5(b) Collection Methodology and Management

EPA currently makes extensive use of computers in collecting information from 

vehicle manufacturers. Essentially all routine information (test results and vehicle 

descriptions in applications for certification and subsequent model tests, IUVP data, 

end-of-year reports, credits and ABT reports, deterioration determinations, etc.) is 

electronically transmitted directly from the manufacturers through the Verify system. 

Remaining information, including diagrams and narrative descriptions of vehicles, is 

submitted on optical disc. The rule makes no changes in this reporting system, only 

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

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

electronically are automatically screened; test results that are close to emission and fuel 

economy standards are reviewed in more detail. Narrative descriptions of the proposed 

product line are checked to verify that the appropriate vehicles have been tested. (The 

emission and fuel economy programs rely on a combination of “worst case” and 

representative data to accomplish their goals.) Except for projected sales and a limited 

amount of proprietary product information, all information is available to the public as 

soon as the vehicle is offered for sale. Emission and fuel economy data are available on 

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

Information Act.

5(c) Small Entity Flexibility

The rule continues to exempt small businesses from the GHG standards, for any 

company that meets the SBA’s definition of a small business, as in the prior rule. These are 

referred to as "small entities". The rule adds the flexibility to opt into the standards applicable 

to regular manufacturers, and EPA expects paperwork costs for those companies opting in 

would be similar to other respondents, but this is a voluntary option that is not costed in this 

ICR. 

5(d) Standards for Small Volume Manufacturers

Under the prior rule, small volume manufacturers (SVMs) with U.S. annual sales of 

less than 5,000 vehicles were also eligible for an exemption from the CO2 standards. The MY 

2017-2025 rule brings these manufacturers into the CO2 program, but maintains flexibility 

with an opportunity to petition for alternative standards. For purposes of this ICR, the set of 

manufacturers meeting this condition (not a small business entity, but less than 5,000 

vehicles sold in the US) is from a low estimate of four, to a high estimate seven, including an 

estimated one to two manufacturers meeting the operational independence criteria . For these, 

the costs of paperwork and record keeping calculated for the prior rule apply unless they 

petition for alternative standards; for purposes of this estimate we treat all SVMs as applying 

for the alternative standards. Manufacturers with less than 5,000 total annual sales are 

exempt from IUVP, so the increased IUVP testing otherwise imposed by the prior rule do not 
17

apply to them. 

The prior rule's temporary leadtime allowance alternative standards (TLAAS) 

provisions which provided an allowance for a separate averaging fleet with a less 

stringent GHG standard as a phase-in provision for model years 2012 to 2015 for 

manufacturers with fewer than 400,000 vehicles, and for model years 2012 to 2016 for 

manufacturers with annual sales of less than 50,000 vehicles, is not being continued. As in 

the prior ICR, these are treated as compliance burden costs rather than paperwork 

burden costs.

EPA has other previously existing special procedures that might apply to smallvolume light-duty vehicle and light-duty truck manufacturers not otherwise excluded by 

the final rule's small-business exclusion. "Small-volume manufactures" for purposes of 

these provisions are defined as those whose total sales are less than 15,000 units per 

year (40 CFR 1836-01). These special procedures allow the small-volume 

manufacturer to submit a simplified application for certification with respect to 

durability demonstrations, and these manufacturers also have reduced requirements 

under the IUVP program. In addition, engine families with small numbers of vehicles 

are eligible for reduced certification fees. Finally, by the very nature of their size, 

small volume manufacturers typically have very limited product lines. This 

characteristic both reduces the amount of information which must be submitted and also 

simplifies the process of selecting the correct test vehicle(s).

5(d) Collection Schedule

See the description in Part 4(b)(i). Information must be submitted for each 

“model year” that a manufacturer intends to build (or import) vehicles. For emissions 

purposes, a “model year” is statutorily defined as the annual production period of a 

manufacturer, as decided by the Administrator, that includes January 1 of that calendar 

year; or that calendar year if the manufacturer does not have an annual production 

period. During the model year, the results of such additional fuel economy and GHG 

tests as the manufacturer conducts are also reported to EPA. After the end of the model 

year fleet-wide GHG emissions are calculated and reported. If a product is unchanged 

between model years, much of the information can be “carried over.” The collection 

frequency and burden are determined to a large extent by the manufacturer’s marketing 

and production plans. However, as required by law, some submission is required for 

each model year’s production. 

Section 6: Estimating the Burden and Cost of the Collection

The following estimates of changes in burden use baselines and methodologies 

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

last renewal (ICR 0783.54, OMB 2060-0104, approved August 31, 2009), the prior 

disaggregation of that ICR into five ICs, the cold hydrocarbon emissions standards rule 

(ICR 0783.52), the latest vehicle fuel-economy labeling rule (ICR 0783.60), and the 

prior GHG rule (ICR 0783.58). The reasoning behind estimates of increased burden 
18

from the current baseline are given below and summarized in Section 6(f) based on 

provisions of the rule that are summarized in Section 1(b). Most of the burden is 

included in the underlying certification authorization baseline; the numbers below are 

only changes to the baseline. "Respondent Burden" is taken to refer to hours, while 

"Respondent Costs" are taken to refer to non-labor capital and O&M costs. Hours or 

costs are reported to the hour or dollar without intending to imply that the totals are 

significant to the last digit. 

For both Respondent Burden and Respondent Costs, new and corrected estimates 

will be updated in subsequent ICRs, which should benefit from the most recent 

information available about real testing and reporting costs associated with credit 

pathways chosen, gathered through Verify queries based upon actual rather than 

projected certification applications.

6(a) Estimating Respondent Burden

The respondent burden hours changes for the Light-Duty Vehicle Emissions 

Information Collection reflect new labor hours associated with conducting tests and 

with reporting. As discussed above, the AC17 air conditioning test alternative could 

result in either an increase or a decrease in testing labor hours (and testing costs). Once 

additional information is received, as compliance cost decreases are translated into 

reporting cost increases or decreases using this alternative, further adjustments to the 

baseline will likely be warranted. Testing costs also contain a small addition to account 

for the estimated three to five SVMs that will be required to conduct AC testing for 

some fraction of its vehicle families, assuming the SVMs would seek to generate A/C 

credits. These two corrections decrease the low estimate by 128 and increase the high 

baseline, (which is used for the authorization request) by 618 hours.

The reporting (paperwork) and recordkeeping costs have been revised to reflect 

the estimated number of manufacturers reporting GHG results to EPA contained in the 

rule. A line item has been added to account for small volume manufacturers, which are 

assumed to submit applications for alternative standards the yearly burden of which in 

paperwork burdens is taken to subsume the above categories (initial total fleet 

reporting, and credits that are separately counted for other manufacturers). The yearly 

cost of doing so is scaled to account for the provision that the alternative standards can 

last up to five years, but may be less than that. We used three years as an 

approximation. The increment over their current burden is estimated at 467 hours per 

year. Since every manufacturer will be required to submit an end-of-year report on 

compliance with fleet average GHG requirements, the number used for this item is 33. 

All labor hours associated with startup costs for installing (updating) 

information technology systems to incorporate the new information to be reported, and 

startup costs for familiarization with the new regulations, are associated with 

capital/startup costs, so they are included under that heading, following EPA guidance (EPA 

ICR Handbook, Rev. 11/05, p. A-31). 
19

6(b) Estimating Respondent Costs

(i) Estimating labor costs

Information technology specialists for analysis and coding and label redesign are 

priced at $100 per hour. Labor costs for testing follow the testing labor cost assumptions of 

ICR 0783.47 and 0783.51 and average out to $55 per hour. Because this estimate underlies 

the entire certification program and not just this GHG portion, it will be adjusted for inflation 

in the next renewal of the ICR 0783 series. For labor costs associated with reporting and 

recordkeeping, rates for engineering managers (SOC 11-9199), mechanical engineers (SOC 

17-2141), and secretaries (except legal, medical, and executive; SOC 43-6014) are from the 

May 2010 BLS National Industry-Specific Occupational Employment and Wage Estimates 

for NAICS 336100 - Motor Vehicle Manufacturing 

(http://www.bls.gov/oes/current/naics4_336100.htm, accessed October 13, 2011). With a 

160% overhead multiplier, these are $87.33, $70.37, and $31.68, respectively.

(ii) Estimating Operations and Maintenance Costs

Operation and Maintenance costs include the non-labor costs associated with 

conducting the new tests that are anticipated for model year 2011 and after. For the 

Emissions IC, the Idle Test is estimated to involve $210 to $420 per test (low and high 

estimates); in the prior ICR these were applied to the an estimate of the number of such 

tests the major manufacturers who choose to apply for the credit will need to do to 

represent their production volume in model year 2014 and after, for an industry total of 

$41,297 to $171,570 per year. After the initial year, there would presumably be a 

number of carry-overs, so this is a conservative estimate (i.e., tending to be on the high 

side) for the years after model year 2012. As discussed above, EPA is finalizing a new 

AC17 test procedure to begin in MY 2017 as a replacement for the idle test. Prior to 

MY 2017 the AC17 test is an optional alternative to the idle test. The AC17 test is more 

expensive from a testing and paperwork standpoint but only applies to "platforms", a 

smaller class than "test groups" so that, depending on the number of platforms using the 

AC17 test could either increase or decrease the testing burden associated with the A/C 

credit. This is reflected in an increased range of the high and low estimates for this 

paperwork cost item. This is applied to an estimate of 195 to 409 test groups 

(accounting for the addition of small volume manufacturers). The adjustment to account 

for the switch from the idle test to the AC17 test increases the high estimate by $34,566

annually from the current baseline. 

No changes are expected for the IUVP O&M costs. 

(iii) Start-up Capital Costs

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

are applicable to model year 2012 vehicles being certified or in-use tested by the respondent 

manufacturers. These startup burdens fall into three categories. 

For the Emissions IC, first are information technology costs involving familiarization 
20

with the new data reporting requirements and installation of reformatted management 

information systems to carry out and report the necessary data and calculations. All these 

burdens are add-ons to well established reporting requirements: manufacturers already 

submit similar data to EPA. However, because manufacturers must not only program the 

reporting requirements, but also make management decisions about which of the compliance 

pathways to follow, this ICR adds a line item familiarization cost not separately counted in 

the prior ICR. These adjustments add $160,990 (depreciated) to the baseline for this category 

of startup costs. 

Second are startup costs associated with N2O measurement. The prior ICR estimated 

a cost of $50,000 to $60,000 per analyzer, with one to five needed by 33 manufacturers. An 

updated cost estimate of $60,000 to $120,000 for each of the laser-based measurement 

systems likely to be chosen by most manufacturers, applied to 33 manufacturers, accounts for 

most of the increase in the high-estimate baseline for this item ($982,405, depreciated).

For the IUVP IC, some of the contracting laboratories that do IUVP testing may 

also need to install N2O analyzers, and the adjustment in analyzer cost for the three to 

five facilities doing IUVP testing adds an estimated discounted and annualized capital 

cost of $85,426 (undepreciated) to the IUVP IC baseline. Testing facilities and 

procedures vary widely, and this is reflected in the order of magnitude range of high and low 

items for N2O analyzer startup costs. 

Third are capital costs associated with the new testing facility. Because 

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

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

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

Compliance Division has for many year now used the approximation that a facility capable of 

performing 750 FTP/HFET tests per year costs $4,000,000 and allocated this cost to each 

testing increment. This cost is then allocated over ten years and discounted at 7%. This 

methodology is considered conservative, because it assumes no excess capacity. This 

estimate includes no change in the IUVP IC because there are no changes in the idle test cost. 

No change in facility costs is included in the IUVP program for small volume manufacturers 

because small volume manufacturers are exempt from the IUVP program. Given the 

flexibility in the timing of AC testing (manufacturers will be able to conduct the testing in off 

peak times of year) and minimization of testing burden noted above for AC17 as discussed 

above, EPA believes manufacturers will be able to absorb the additional testing within their 

current facilities and EPA is not projecting that significant additional testing facilities will be 

needed to accommodate AC17 requirements beyond those projected previously for the AC 

idle test. For the Emissions IC, the AC17 test is projected to increase the range of facility 

costs slightly to correspond to the increase in testing costs discussed above. This results in a 

small increase of $6,983 (depreciated) per year in the high estimate. 

6(c) Estimating Agency Burden

The emissions certification, fuel economy, and IUVP programs are administered 

by EPA’s Compliance Division. Approximately 47.5 full time employee equivalents 
21

are directly involved in the combined emission and fuel economy programs for lightduty vehicle, motorcycle, and other, secondary programs; their cost is approximately 

$5.9 million, including benefits but not overhead. EPA also participates in a program 

whereby the agency contracts with organizations that provide qualified persons to 

perform duties for the agency that are not performed by EPA employees. The cost 

associated with these persons who work directly on these programs is approximately 

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

approximately 16.9%, yielding an estimated total agency labor cost of $7.17 million. 

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

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

million for FY 2007. 

Implementation of the new GHG rule will be carried out by existing staff. The 

prior rule included startup costs for information systems and programming, including 

overhead of $4,000,000 (high estimate). Annualized over ten years with 7% 

depreciation this cost burden came to $569,510. Ongoing agency burden added by the 

rule for maintaining and managing the database after startup was estimated at 12% of 

the startup costs, or $480,000, corresponding to approximately 6,281 hours. Combined 

labor and annual startup costs therefore totaled 6,281 hours (startup hours not 

annualized) and $1,049,510. Implementing the new GHG rule will undoubtedly require 

additional information systems startup costs and ongoing O&M. As the Agency has not 

yet determined this level of effort, this ICR will use one-third of the expenses of the 

prior rule as a placeholder: $1,333,333 startup capital costs with a yearly discounted 

value of $189,837, and $160,000 a year including overhead in ongoing maintenance and 

management of the database, equivalent to 2094 hours. This estimate includes costs 

associated with developing formats and collecting information within the Verify system 

for the new reporting elements summarized in 4(b)(i). Other ongoing database 

management, oversight, and certification activities are part of the fuel economy and 

emissions program Agency baseline. All EPA labor estimates are based on Office of 

Personnel Management Salary Table 2011-GS 

(http://www.opm.gov/oca/11tables/pdf/gs_h.pdf , accessed 10/17/2011) with a 1.6 

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

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

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

developing the rule and preliminary consultations with manufacturers on database 

issues. 

6(d) Estimating the Respondent Universe and Total Burden and Costs

As mentioned above, the respondent universe is a total of 33, including 4 to 7

small volume manufacturers that may petition for alternative standards. The rule also 

exempts police and emergency vehicles from the GHG rule. It is possible that this could 

change the number of test groups by one or two out of the 823 model level and 427 

certification vehicle submissions assumed in the baseline. This is below the threshold of 

accuracy for the current estimate. The main benefit of the exemption is in reducing the 

sales figures for purposes of compliance with the standards. 
22

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

calculated. (Due to the diverse nature of the motor vehicle industry, there is no typical 

or average respondent, and this estimate makes many assumptions in an attempt to 

accommodate this diversity.) 

6(e) Bottom Line Burden Hours and Cost

(i) Respondent Tally

RESPONDENTS 33

BURDEN HOURS 5,667

OPERATING COST $163,918

CAPITALIZED COST $1,235,714

A more detailed summary can be seen in the tables below:

COST BURDEN

Min Max

Emissions IC 

Startup: Capital one-time 

IT/Paperwork/Familiarization/N2O 

(annualized 10yrs/7%) $62,721 $1,143,395

New Facilities: Ongoing Capital 

(annualized 10yrs/7%) -$3,318 $6,893 

Capital Subtotal $59,403 $1,150,288 

New Testing (O&M) $-8,537 $34,566

New Reporting & Recordkeeping $36,336 $129,352

Total $87,202 $1,314,206

IUVP IC

Startup: one-time (10yrs/7%) $4,271 $85,426

New Facilities: Ongoing Capital, 

annualized 10 yrs/7%) $0 $0

Capital Subtotal $4,271 $85,426
23

New Testing (O&M) $0 $0

New Reporting & Recordkeeping $0 $0

Total $4,271 $85,426 

TOTAL CAPITAL $63,674 $1,235,714 

TOTAL O&M $27,800 $163,918

TOTAL LDV & IUVP $91,473 $1,399,632

HOURS BURDEN

LDV/LDT Emissions IC 

Startup: Capital one-time 

IT/Paperwork (annualized 10yrs/7%) 0 0

New Facilities: Ongoing Capital 

(annualized 10yrs/7%) 0 0

New Testing -142 576

New Reporting & Recordkeeping 2,855 5,091

Total 2,713 5,667

IUVP IC

Startup: one-time IT/Paperwork and 

O&M (annualized 10yrs/7%) 0 0

New Facilities: Ongoing Capital, 

annualized 10 yrs/7%) 0 0

New Testing (Labor & O&M) 0 0

New Reporting & Recordkeeping 0 0

Total 0 0

TOTAL LDV & IUVP 2,713 5,667
24

(ii) Agency Tally

EMPLOYEES 26

STARTUP $349,837

LABOR HOURS 2,094

6(f) Reasons for change in burden

The burden change is from new capital and operations and maintenance costs 

and labor hours associated with implementing the new programs detailed in this final

ICR. The increase in burden is due largely to an increase in the estimated (high 

estimate) cost of information system upgrades for industry. There is also a slight 

increase in the reporting burden associated with the end of model year GHG emissions 

report and the optional credit calculations that they may include.

6(g) Burden Statement

The table in Section 6(e) presents the total estimated burden for the final rule: 

approximately 5,667 additional hours per year, with total annual capitalized and O&M costs 

estimated at $1,399,632. These estimates represent the high end of a high-low range that was

used for many of the cost elements. The annual costs and hours for information collection 

activities by a given manufacturer under any of the options in this rule depend upon 

manufacturer-specific variables, such as the number of different test groups, the number 

of vehicles tested, the number of new N2O analyzers needed, the credit options chosen 

if any, and the cost of information system upgrades. The estimated number of likely 

respondent manufacturers is 33. The responses will be submitted annually and 

occasionally as a part of the existing EPA certification and IUVP programs. 

Burden means the total time, effort, or financial resources expended by persons 

to generate, maintain, retain, or disclose or provide information to or for a Federal 

agency. This includes the time needed to review instructions; develop, acquire, install, 

and utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and 

providing information; adjust the existing ways to comply with any previously 

applicable instructions and requirements; train personnel to be able to respond to a 

collection of information; search data sources; complete and review the collection of 

information; and transmit or otherwise disclose the information. An agency may not 

conduct or sponsor, and a person is not required to respond to, a collection of 

information unless it displays a currently valid OMB control number. The OMB 

control numbers for EPA’s regulations are listed in 40 CFR Part 9.

EPA has established a public docket for this rule, which includes this ICR, under 

Docket ID number EPA-HQ-OAR-2010-0799. Docket ID No. EPA-HQ-OAR-2010-

0799, is available for public viewing at the Air And Radiation Docket in the EPA 
25

Docket Center (EPA/DC), EPA West, Room B102, 1301 Constitution Ave., NW, 

Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. 

to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number 

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

Radiation Docket is also (202) 566-1744. An electronic version of the public docket is 

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