Supporting Statement for

Information Collection Request

Notice of Proposed Rulemaking

Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty 

Engines and Vehicles - Phase 2

EPA ICR Tracking Number 2394.04

Office of Transportation and Air Quality

Office of Air and Radiation

U.S. Environmental Protection Agency

and

National Highway Traffic Safety Administration

U.S. Department of Transportation
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I. Identification of the Information Collection

A. Title and Number of the Information Collection

Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty 

Engines and Vehicles – Phase 2, EPA ICR Number 2394.04, OMB Control Number 2060-0678.

B. Short Characterization

The Environmental Protection Agency (EPA) and the National Highway Traffic Safety 

Administration (NHTSA) are proposing Phase 2 standards to address greenhouse gas (GHG) 

emissions and fuel consumption in the medium- and heavy-duty (HD) trucking sector. As a 

result of these proposed standards, HD engine and HD vehicle manufacturers would be subject to 

new testing, reporting, recordkeeping, and labeling requirements. The paperwork and cost 

burdens associated with these requirements are identified in this ICR, which is an extension of a 

currently approved ICR that covers the HD Phase 1 program. The cost burden is also adjusted to 

account for amendments made to the Phase 1 program which reduce final reporting provisions.

EPA and NHTSA are each proposing rules to establish a comprehensive Phase 2 HeavyDuty National Program that will reduce GHG emissions and fuel consumption for new HD

vehicles. This technology-advancing program would phase in over the long-term, beginning in 

the 2018 model year and culminating in standards for model year 2027, responding to the 

President’s directive on February 18, 2014, to develop new standards that will take us well into 

the next decade. NHTSA’s proposed fuel consumption standards and EPA’s proposed carbon 

dioxide (CO2) emissions standards are tailored to each of four regulatory categories of heavyduty vehicles: (1) Combination Tractors; (2) Trailers used in combination with those tractors; (3) 

Heavy-duty Pickup Trucks and Vans; and (4) Vocational Vehicles. The proposal also includes 

separate standards for the engines that power combination tractors and vocational vehicles. 

Certain proposed requirements for control of GHG emissions are exclusive to EPA programs. 

These include EPA’s proposed hydrofluorocarbon standards to control leakage from air 

conditioning systems in vocational vehicles, and EPA’s proposed nitrous oxide (N2O) and 

methane (CH4) standards for heavy-duty engines. 

As a result, the standards that support the HD Phase 2 National Program address the 

complete vehicle, through complementary engine and vehicle standards. Consistent with the 

structure of this program and the Phase 1 program, the testing, reporting, labeling and 

recordkeeping requirements described in this ICR cover heavy-duty gas and diesel engines, and 

four regulatory categories of heavy-duty vehicles, including combination tractors, combination 

trailers, vocational vehicles and heavy-duty pickup trucks and vans.

Under the HD Phase 2 National Program these manufacturers would be subject to new 

CO2 and fuel consumption standards. As their vehicles are not directly responsible for N2O and 

CH4 emissions, trailer, vocational vehicle chassis and combination tractor manufacturers are not 

subject to the new standards for these pollutants. To demonstrate compliance with the Phase 2 

CO2 and fuel consumption standards, vocational vehicle chassis and tractor manufacturers would 

need to modify the testing programs, reporting, labeling and recordkeeping systems developed 
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for the Phase 1 HD National Program. Trailer manufacturers, who would be subject to CO2 and 

fuel consumption standards for the first time, would have to put in place entirely new testing 

programs, reporting, labeling, and recordkeeping systems.

The proposed Phase 2 program sets new CO2, fuel consumption, and N2O standards with 

the following implementation years, as shown in Table 1.

Table 1 Implementation Years for Proposed Phase 2 Standards

Regulatory Category EPA GHG Standards NHTSA Fuel Consumption Standards

HD Engines 2021, 2024, 2027 Model Years 2021, 2024, 2027 Model Years

HD Pickups and Vans Phase in 2021 through 2027 Model 

Years

Phase in 2021 through 2027 Model Years

Vocational Vehicles 2021, 2024, 2027 Model Years 2021, 2024, 2027 Model Years

Tractors 2021, 2024, 2027 Model Years 2021, 2024, 2027 Model Years

Trailers 2018, 2021, 2024, 2027 Model 

Years

2018 (voluntary)

2021, 2024, 2027 Model Years (mandatory)

For model years 2018 through 2020, NHTSA’s fuel consumption standards for trailers 

are voluntary for manufacturers. For the purpose of determining the cost burden to 

manufacturers and the government, all estimates are derived assuming 100 percent participation 

of all regulated entities during the voluntary compliance model years.

Notably, to streamline the reporting process and reduce industry burden for all 

manufacturers, EPA and NHTSA established a harmonized approach by which all information 

for the HD Phase 1 and Phase 2 National Programs is submitted by manufacturers through the 

EPA’s database system. Both EPA and NHTSA have access to data in this database system, 

which also helps the agencies to efficiently review, process, and store the heavy duty data 

relevant to each agency’s program requirements. 

Over the years 2017 through 2019, 12 engine manufacturers and 143 vehicle 

manufacturers will submit a combined 3-year total of 1,128 applications (72 heavy-duty pickup 

truck, 324 heavy-duty engine, 180 vocational vehicle, 96 combination tractor, and 456 trailer 

applications) to certify their products and respond to the information collection activities detailed 

in the HD National Program.

The manufacturers regulated under this program would need to: 1) submit applications to 

certify vehicles; 2) submit reports with early estimates to demonstrate their compliance plans; 3) 

conduct compliance testing; 4) label certified vehicles; 5) provide final year-end-reports with 

compliance test results; and 6) retain records of information submitted to the agencies, which 

will be maintained for eight years. A manufacturer would need to send an application for a 

certificate of conformity and gain approval by EPA before it can legally introduce any vehicle or 

engine into commerce in the U.S. To ensure compliance with the Clean Air Act (CAA) and the 

Energy Independence and Security Act (EISA), EPA and NHTSA would annually audit

manufacturers’ submitted information and compliance test results and conduct inspections and 

confirmatory testing on vehicles. NHTSA would conduct such inspections and confirmatory 

testing on vehicles prior to first sale. Manufacturer test results would be used by EPA to perform 
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confirmatory testing on a sufficient number of engines and vehicles to confirm manufacturerreported results. Limited equipment testing and modeling runs would also be performed by 

NHTSA to confirm manufacturer test results. 

The testing data submitted by manufacturers are needed for EPA and NHTSA to verify 

that manufacturers have selected the proper engines and vehicles, and conducted the testing 

necessary to demonstrate that their equipment complies with the new GHG emissions and fuel 

consumption standards. 

The first year the Phase 2 program becomes effective is in the calendar year 2018. For 

the years 2017, 2018, and 2019, these collection activities are estimated to impose annual costs 

of $8 million and an annual labor hour burden of 62,400 hours. 

II. Need for and Use of the Collection

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 and engines 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, 549 U.S. 497 (2007), holding that greenhouse gases are pollutants under 

the Clean Air Act. 

Specifically, under Section 206(a) of the CAA (42 USC 7521): 

“The Administrator shall test, or require to be tested in such manner as he deems 

appropriate, any new motor vehicle or new motor vehicle engine submitted by a 

manufacturer to determine whether such vehicle or engine conforms with the 

regulations prescribed under §202 of this Act. If such vehicle or engine conforms 

to such regulations, the Administrator shall issue a certificate of conformity upon 

such terms, and for such period (not in excess of one year) as he may prescribe.”

Pursuant to 49 U.S.C. 32902(k), NHTSA requires that manufacturers comply with fuel 

economy and consumption standards:

“...the Secretary, in consultation with the Secretary of Energy and the 

Administrator of the Environmental Protection Agency, by regulation, shall 

determine in a rulemaking proceeding how to implement a commercial mediumand heavy-duty on-highway vehicle and work truck fuel efficiency improvement 

program designed to achieve the maximum feasible improvement, and shall adopt 

and implement appropriate test methods, measurement metrics, fuel economy 

standards, and compliance and enforcement protocols that are appropriate, costeffective, and technologically feasible for commercial medium- and heavy-duty 

on-highway vehicles and work trucks. The Secretary may prescribe separate 

standards for different classes of vehicles under this subsection.”
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In addition to test results, as part of their application for a certificate of conformity, under 

CAA §217, manufacturers are required to pay an application fee when applying for a vehicle or 

engine certificate. At this time, the exact costs associated with the heavy-duty vehicle 

compliance are not known. The agency is not modifying its fees provisions in this proposed rule 

and is determining how to appropriately address this issue in the future. When EPA finalizes a 

cost assessment of its compliance program, it will amend its fees regulations to include any 

warranted new costs.

EPA and NHTSA also established an Averaging, Banking and Trading (ABT) program, 

as outlined in 40 CFR parts 1036.701 and 1037.701, and in 49 CFR part 535.7. Engine and 

vehicle manufacturers covered by the HD Phase 1 and 2 National Program have the option to 

participate in this ABT program. The agencies’ ABT programs, and others like it, are designed 

to enhance compliance flexibility and reduce the burden on affected manufacturers, without 

compromising the expected emissions benefits derived from EPA’s emissions standards and 

NHTSA’s fuel consumption standards. 

EPA’s Phase 2 GHG standards for HD engines and vehicles amend 40 CFR part 86 part 

1036 (engines), and part 1037 (vehicles). NHTSA’s Phase 2 fuel consumption standards for HD 

engines and vehicles amend 49 CFR parts 523, 534, and 535. These regulations are not attached 

to this statement due to their length and technical nature. 

The testing data submitted by manufacturers are needed for EPA and NHTSA to verify 

that manufacturers have selected the proper engines and vehicles, and conducted the testing 

necessary to demonstrate that their equipment complies with the new GHG emissions and fuel 

consumption standards. 

Under the proposed Phase 2 rules, manufacturers of heavy-duty pickup trucks and vans 

would submit “pre-model year reports” to satisfy EPA’s and NHTSA’s requirements for 

receiving compliance reports in advance of the model year. These pre-model reports for heavy 

duty pickup trucks and vans are similar to early model year compliance reports that are required 

for light duty vehicles.

For engine and vehicle manufacturers, the agencies are using the manufacturer’s 

applications for certificates of conformity to obtain early model production estimates and related 

data. The agencies treat information submitted in the applications as a manufacturer’s 

demonstration of providing early compliance information, similar to the pre-model year report 

submitted for heavy-duty pickup trucks and vans. A summary of that information can be found 

in IV.C. 

Once the engines and vehicles have been produced, EPA and NHTSA would use the test 

data and the data included in the final reports and certification applications to support various 

enforcement actions, such as selective enforcement audits, inspections and confirmatory

compliance testing.

As noted, the HD National Program offers manufacturers an opportunity to participate in 

an Averaging, Banking and Trading (ABT) program and other regulatory flexibilities that allow 
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manufacturers to generate emission and fuel consumption credits. For manufacturers that choose 

to participate and take advantage of these flexibilities, EPA and NHTSA collect data to ensure 

that allowable emission and fuel consumption credits are properly allocated, traded and applied. 

These data are provided in a final production report and compared against production estimates 

submitted in the pre-model year report and certification applications. 

Throughout the year, manufacturers may also be required to report various submissions 

to the agencies to comply with other various aspects of the rule. This other data collected, such 

as notifications that a manufacturer intends to participate in the ABT program or that a vehicle 

qualifies for an exclusion are needed so that the agencies can ensure that manufacturers are 

complying with the HD National Program’s regulatory provisions. The agencies would also 

continue to require manufacturers to submit a credit plan whenever a credit transaction is 

required. 

All test and ABT data will be received and used by EPA’s Compliance Division (CD) 

within the agency’s Office of Transportation and Air Quality. Other EPA offices and divisions 

also may access the data to assess the effectiveness of the HD Phase 2 National program. Nonconfidential portions of the information submitted to CD are available to and may be used by 

importers, engine users, environmental groups, members of the public and state and local 

government organizations. Information would be shared with NHTSA as needed. The NHTSA 

Office of Vehicle Safety Compliance would use the data for compliance purposes and the Office 

of Rulemaking would use it to measure the effectiveness of fuel consumption standards and in 

future rulemaking efforts.

III. Nonduplication, Consultations and Other Collection Criteria

A. Nonduplication

This proposed rulemaking contains specific recordkeeping provisions in 40 CFR 

1036.205 and 1037.205, which are summarized in Table 3. NHTSA’s proposed rule contains the 

same recordkeeping requirement at 49 CFR 535.8 that is currently in EPA’s regulations requiring 

manufacturers to keep records with equivalent fuel consumption information. Because of its 

specialized (and sometimes confidential) nature, and the fact that it is submitted jointly with 

NHTSA prior to the start of vehicle or engine production, the information collected is not 

available from any other source. The agencies developed this rulemaking to build on existing 

test procedures and reporting structures where possible to prevent duplication

B. Public Notice Required Prior to ICR Submission to OMB

Through the proposed rulemaking that EPA and NHTSA are issuing, EPA is seeking 

public comment on the testing, reporting, and recordkeeping burdens outlined in this ICR and 

associated with demonstrating compliance with the proposal’s GHG and fuel consumption 

standards. To comment on the agencies’ needs for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, the agencies have established public dockets for this 

proposal, which includes this ICR, under Docket ID numbers EPA–HQ–OAR–2014–0827 and 
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NHTSA- 2014-0132. The final rules will respond to any OMB or public comments on the 

information collection requirements contained in the proposal.

C. Consultations

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

developed based on experience with the Phase 1 regulations developed in the past in close 

consultation with the affected industry. Prior to publication of the proposal, EPA and NHTSA 

also met extensively with individual manufacturers, groups of manufacturers, industrial trade 

associations, public interest groups, environmental and professional industry organizations. 

In preparing this ICR submission, the agencies considered these discussions. Following 

the publication and formal request for comment on the Phase 2 proposal, EPA and NHTSA will 

further develop the testing, reporting and recordkeeping requirement included in this ICR, as 

needed. 

D. Effects of Less Frequent Collection

The CAA states that emission certification must be done on a yearly basis (CAA 

206(a)(1)), coinciding with the industry's ‘model year’. Major product changes typically occur at 

the start of a model year. For these reasons, a collection frequency of less than a model year is 

not possible. However, when an engine or vehicle design is "carried over" to a subsequent 

model year, the amount of new information required is substantially reduced. Existing 

regulations also call for an end-of-year report, with final production numbers, and the HD Phase 

2 National Program conforms to this existing requirement as well. 

E. General Guidelines

Under 40 CFR 1036.250 and 1037.250 of the proposed regulations, copies of all 

documents sent to EPA including pre-model reports, certification applications, ABT reports, and 

final reports, must be kept and maintained for eight years. These records may be stored in any 

format and on any media, as long as they are organized and can be sent promptly to EPA, if 

requested. These recordkeeping requirements stem, in part, from the statutory requirement to 

warrant some items for long periods of time. Manufacturers also must comply with requirements 

to submit to an EPA audit, and recall vehicles and engines failing to meet emission standards 

during their useful lives. Other data, (such as routine emissions tests, i.e.: test cell temperatures 

and relative humidity readings, etc.) need to be kept for only one year after a certificate of 

conformity is issued. 

Manufacturers would be required to submit confidential business information such as 

sales projections and certain sensitive technical descriptions (see section 4(b)(i) for reference). 

This information is kept confidential 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. Also, non-proprietary information submitted by manufacturers is held as confidential 

until the specific vehicle or engine to which it pertains is available for purchase. No other general 

guideline is exceeded by this information collection. 
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F. Confidentiality

Manufacturers are allowed to assert a claim of confidentiality over information provided 

to EPA. Confidentiality is provided in accordance with the Freedom of Information Act and 

EPA regulations at 40 CFR part 2. For further detail, refer to section III.E, above. 

G. Sensitive Questions

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

with the Privacy Act and OMB Circular A-108.

IV. Respondents and Information Requested

A. Respondents/NAICS Codes

Respondents are manufacturers of engines and vehicles within the North American 

Industry Classification System (NAICS) and use the coding structure as defined by NAICS. 

336111, 336112, 333618, 336120, 541514, 811112, 811198, 336111, 336112, 422720, 454312, 

541514, 541690, 811198, 333618, 336510, for Motor Vehicle Manufacturers, Engine and Truck 

Manufacturers, Truck Trailer Manufacturers, Commercial Importers of Vehicles and Vehicle 

Components, and Alternative Fuel Vehicle Converters and Manufacturers.

B. Information Requested

All manufacturers would be required to provide good faith estimates of production 

volumes and related data in either a pre-model year report or as part of their application for a 

certificate of conformity. Data included in the pre-model year report and application will 

provide the best estimate of the vehicles and engines that a manufacturer will produce for the 

year and are needed to help construct an annual testing plan. Information that manufacturers 

would include in their pre-model year reports and certification applications is outlined in the 

sections below. 

NHTSA would require manufacturers to determine equivalent fuel consumption values 

from CO2 emissions test results and provide the values along with the applications for 

certification submitted to EPA. Manufacturers would submit their pre-model year reports, 

applications, test data and related information to EPA electronically via a single database system 

that NHTSA will access as needed. 

In order to obtain a certificate of conformity, all manufacturers would complete a 

compliance demonstration, normally consisting of test data showing that their engines or 

vehicles meet the rule’s emission standards and other regulatory requirements. For testing 

purposes, manufacturers typically establish either “test groups” or engine and vehicle “families” 

that share certain design and emissions characteristics. 

Specific criteria for establishing these test groups and families for each regulatory 

category is outlined in the rule at 40 CFR 86.1827 (pickup trucks and vans), 40 CFR 1036.230 
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(engines), and 40 CFR 1037.230 (trailers, vocational vehicles and combination tractors). Within 

the families and test groups a manufacturer establishes, engines and vehicles are selected and 

subject to actual testing. 

In addition to test results and related documents that demonstrate compliance, an 

application for a certificate of conformity describes other key aspects of the manufacturer’s 

proposed product line, such as controls put in place to reduce GHG emissions and fuel 

consumption, warranty and service information, and emission control information labels. 

All manufacturers would be also required to submit final reports that will be used to 

reconcile initial production estimates with final year figures. For manufacturers not participating 

in ABT, the final reports are required to assess compliance. The requirements for final reports for 

engine, HD pickup truck, vocational chassis, and tractor manufacturers in years 2017 through 

2019 would be identical to the Phase 1 requirements except for an allowance to streamline 

reporting for tractor, vocational vehicle, and engine manufacturers with the option for these 

manufacturers to provide only one final ABT report, 90-days after the end of each model year. 

The final report requirements for trailer manufacturers would begin with the 2018 model year. A 

summary of the data included in a final report is listed in Table 2. Tractor, vocational, HD 

pickup truck and van, and engine manufacturers also must state whether they intend to 

participate in the Averaging, Banking and Trading (ABT) program that EPA and NHTSA have 

proposed for these regulatory categories. Separate final reports also are necessary for the ABT 

program since they are a resource for identifying emissions and fuel consumption credits and 

deficits. Box trailer manufacturers that choose to participate in the proposed averaging program 

and would also be required to submit a separate averaging report. 

Table 2 Summary of Required Information for Final Reports

Vehicle family or test group designation and averaging set

Vehicle emissions and fuel consumption standards including any alternative standards used

Vehicle family FELs

Final production volumes

Certified test cycles

A credit plan identifying the manufacturers actual credit balances, credit flexibilities, credit 

trades and a credit deficit plan if needed demonstrating how it plans to resolve any credit deficits 

that might occur for a model year within a period of up to three model years after that deficit has 

occurred

A plan describing the vehicles that were exempted such as for off-road or small business 

purposes

A plan describing any alternative fueled vehicles that were produced for the model year 

identifying the approaches used to determinate compliance and the production volumes

In addition, all manufacturers would be required to retain records per the provisions in 40 

CFR parts 86, 1036, and 1037, and 49 CFR Part 535.8 as outlined in Table 3. The record 

retention requirements for engine, HD pickup truck, vocational chassis, and tractor 

manufacturers in years 2017 through 2019 would be identical to the Phase 1 requirements. The 
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record retention requirements for trailer manufacturers would be required beginning with the 

2018 model year. 

Table 3 Key Recordkeeping requirements, HD National Certification Program

Information Itema Engine 

Manufacturers 

Vehicle 

Manufacturersb

Pickup Truck 

and Van 

Manufacturers

General records: 40 CFR 

1036.205 and 

1036.735

40 CFR 

1037.205 and 

1037.735

40 CFR 

Identification and description of all 86.1844-01

engines and vehicles for which testing 

is required 

Description of emission control system

Description of test procedures and 

supporting documents demonstrating 

compliance 

Individual Records: 40 CFR 

1036.250

40 CFR 

1037.250

40 CFR 

Copies of all applications submitted 86.1844-01

Test records, instructions and other 

data provided to or received from other 

manufacturers (for example: 

emissions-related engine installation 

instructions, instructions for air 

conditioning installation, etc.) 

A complete record of all emission tests

performed

A complete record of all model inputs

Record and description of each test 

performed to diagnose engine and 

vehicle emissions

Notes: 

a Records are to be kept for eight years.

b Part 1037 covers Tractors, Trailers, and Vocational Vehicles 

The proposed Phase 2 rule has an initial effective date of model year 2018. Under this 

timeframe, manufacturers are expected to conduct testing and submit their applications and other 

pre-production documents to EPA and NHTSA in 2017. The time horizon of this ICR is 

intended to cover the annualized impacts of the rule at the time that manufacturers initiate their 

testing and compliance activities. 

C. Data Items

In addition to the data items described above, brief summaries of the data items the 

agency collects from engine manufacturers and the four regulatory categories of the heavy duty 
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vehicle manufacturers covered by the rules are provided below. Detailed lists of these data items 

are given in Table 4 through Table 11. 

1. Heavy Duty Pick Up Trucks and Vans 

The vast majority of heavy duty pickup trucks and vans are designed, manufactured and 

sold by manufacturers as complete vehicles, and many of these truck and van models already are 

certified to vehicle-based emission standards for criteria pollutants. Further, these heavy duty 

truck/van models typically are based on higher sales volume light duty truck/van designs and 

models, which already are subject to GHG emission and fuel economy standards under the joint 

light-duty vehicle program promulgated by EPA and NHTSA in March 2010. 

Thus, the HD national certification program closely tracks existing test procedures and 

reporting programs already in place for vans and pickup trucks. For example, the test 

procedures, GHG and fuel consumption standards for heavy duty pickup trucks and vans apply 

to the complete vehicle, just as similar procedures and standards apply to complete light duty 

trucks and vans (there are no separate engine and vehicle requirements, such as those that exist 

for vocational vehicles and combination tractors). 

Using test procedures, reporting and compliance requirements from already established 

and proven test protocols and programs that are applicable to HD pickup trucks and vans helps to 

minimize test costs and reporting burdens for this category of the HD Phase 1 and Phase 2 

National Programs. Burdens are further reduced for HD pickup truck and van manufacturers 

because manufacturers already have invested in test facilities and equipment for the light duty 

trucks and vans that they also produce. 

(a) Phase 1 Data Items: HD Pickups and Vans

The HD Phase 1 standards for HD trucks and vans were expected to create new testing 

burdens and reporting requirements. Specifically, EPA and NHTSA established weight-based 

attributes, namely payload and towing capacity, which support the GHG emission and fuel 

consumption limits for this vehicle category. Manufacturers are required to apply these 

attributes when establishing vehicle test groups to demonstrate compliance with the CO2 and fuel 

consumption standards. These attributes also are factored into the production volume-weighted 

calculation of a manufacturer’s annual fleet average compliance requirement. 

For demonstrating compliance with the N2O and CH4 standards, EPA believes that the 

current test group concept used by pickup truck and van manufacturers is appropriate because the 

technologies employed to control N2O and CH4 emissions are generally the same as those used 

to control criteria pollutants. 

However, by applying weight-based attributes to establish CO2 and fuel consumption 

standards for HD pickup trucks and vans, EPA and NHTSA expect that, manufacturers will find 

it in their best interest to test multiple vehicle configurations with a given test group to accurately 

estimate the fleet average CO2 emission levels. Ultimately these additional tests and estimates 

are necessary to demonstrate compliance with both Phase 1 and Phase 2. 
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EPA is requiring manufacturers to meet the air conditioning leakage standard as part of 

the HD Phase 1 program. To demonstrate compliance, the vehicle manufacturer must calculate 

the percent leakage rate of the hydrofluorocarbon (HFC) emissions from the air conditioning 

system by dividing the total leakage rate in grams per year by the refrigerant capacity as 

specified in 40 CFR 1037.115(c). The agency has adopted a test procedure for determining 

leakage rate that is consistent with the one adopted for Light Duty GHG, and therefore familiar 

to the HD pickup truck and van manufacturers. 

Table 4 Required Information for Pre-Model Year Reports: 

Heavy-duty Pickup Truck and Van Manufacturers

A list of each unique vehicle configuration included in the manufacturer’s fleet describing the 

make and model designations, attribute based-values (GVWR, GCWR, Curb Weight and drive 

configurations) and standards

The emission and fuel consumption fleet average standard derived from the unique vehicle 

configurations

The estimated vehicle configuration, test group and fleet production volumes

Expected CO2, N2O, CH4, and HFC emissions and fuel consumption test group results and fleet 

average performance

A statement declaring whether the manufacturer will use fixed or increasing standards; 

acknowledging that once selected, the decision cannot be reversed and the manufacturer must 

continue to comply with the same alternative for subsequent model years

A statement declaring whether the manufacturer chooses to comply voluntarily with NHTSA’s 

fuel consumption standards for model years 2015 through 2018. The manufacturers must 

acknowledge that once selected, the decision cannot be reversed and the manufacturer will 

continue to comply with the fuel consumption standards for subsequent model years;

The list of Class 2b-3 cab-complete vehicles and the method use to certify, as vocational vehicles 

and engines, or as complete pickups and vans identifying the most similar complete vehicles 

used to derive the target standards and performance test results

The list of Class 2b-3 incomplete vehicles and the method use to certify, as vocational vehicles 

and engines, or as complete pickups and vans identifying the most similar complete vehicles 

used to derive the target standards and performance test results

The list of Class 4 through 6 incomplete and complete vehicles and the method used to certify, as 

vocational vehicles and engines, or as complete pickups and vans identifying the most similar 

complete vehicles used to derive the target standards and performance test results

List of loose engines included in the heavy-duty pickup and van category and the list of vehicles 

used to derive target standards

Copy of any notices a vehicle manufacturer sends to the engine manufacturer to notify the engine 

manufacturers that their engines are subject to emissions and fuel consumption standards and 

that it intends to use their engines in excluded vehicles

A credit plan identifying the manufacturers estimated credit balances, planned credit flexibilities 

(i.e., credit balances, planned credit trading, innovative, advanced and early credits and etc.) and 

if needed a credit deficit plan demonstrating how it plans to resolve any credit deficits that might 

occur for a model year within a period of up to three model years after that deficit has occurred
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For the purposes of this ICR, the test data accompanying these applications will include 

results from coastdown and chassis tests. HD pickup trucks and vans also are subject to HFC 

leakage, N2O, and CH4 standards and their applications will need to demonstrate how they are 

meeting the standards. The testing requirement costs are identified as the following in Table 16:

 Test/Gather CO2, N2O, CH4, and HFC emission data on test vehicles 

 Coastdown test

 Analyze CO2, N2O, CH4, and HFC data to determine compliance

As shown in Table 16, based on these estimates, EPA and NHTSA expect to receive a 

total of 24 applications for certificates of conformity each year from the heavy-duty pickup truck 

and van regulatory category. Because the manufacturers of heavy-duty pickup trucks and vans 

have recordkeeping systems in place for the existing criteria pollutant requirements, the agencies 

did not include a recordkeeping burden in this ICR. The requirements to develop the application 

for certification are identified as the following in Table 16:

 Review of regulations

 Information technology upgrade to track GHG emissions (CO2, N2O, CH4, and 

HFC) within the existing systems

 Prepare and submit certification application (including carryover applications)

 Collect and submit data for ADFE model

 Prepare and review GHG compliance plan

 End of year and final production reports

(b) Phase 2 Data Items: HD Pickups and Vans

The agencies are not proposing to require any new data items to be collected or reported 

in MY 2020 and beyond for these vehicle manufacturers.

2. Engine Manufacturers 

For engine manufacturers, the information and reporting burden associated with the 

proposed Phase 2 National HD Program occur within the context of EPA’s existing engine 

certification program for controlling criteria pollutants and the HD Phase 1 National Program. In 

constructing a program to address GHG pollutants, EPA built upon this existing infrastructure, 

thus creating minimal new certification testing and reporting requirements for engine 

manufacturers for Phase 2. 

(a) Phase 1 Data Items: HD Engines

The agencies developed the GHG certification by building on the existing criteria 

pollutant certification template. The Phase 1 rule directs engine manufacturers to use the same 

selection criteria, as outlined in 40 CFR part 86, subpart A, to define a single engine family 

designation for both criteria pollutant and GHG emissions. 
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The Phase 1 requirements for engine manufacturers’ application for certification in model 

years 2017-2019 are listed in Table 5 and Table 6. The majority of these requirements would be 

reported to the agencies through the HD engine certification template provided to manufacturers. 

Table 5 Engine Manufacturers 40 CFR 1036.205

Description of engine families as related to requirements for GHG standards, including 

CO2, CH4 and N2O, as applicable

Description of emission control system, including auxiliary-emission control devices to be 

installed on production vehicles

Description of test engines selected for testing and rationale for selection

Description of test procedures and equipment, including alternate tests if applicable 

Instructions for Engine Installation

Describe Label Information 

Engine placement (combination tractors, vocational vehicles)

Intent to participate in Averaging, Banking & Trading and/or other available emissions 

credit programs 

Family Certification Limits

Family Emission Limits

Statement of Compliance

Good-faith estimates of U.S. production volumes

Final production reports

Amendment to certification application

Name of U.S.-based service agent

Table 6 Summary of Additional Information Required for Compliance - Engines

Submission Applies to Required 

Submissions Date

EPA 

Regulation 

Reference

NHTSA 

Regulation 

Reference

Small 

business 

exemptions

Engine manufacturers 

meeting the Small Business 

Administration (SBA) size 

criteria of a small business as 

described in 13 CFR 121.201.

Before introducing 

any excluded vehicle 

into U.S. for 

commerce

40 CFR 

1036.150

49 CFR 

535.8

The existing HD criteria pollutant and HD GHG Phase 1 programs require engine labels 

per 40 CFR 86.007-35(a)(3). 
15

Table 7 Key labeling requirements, HD Phase 2 National Certification Program

Information Item Engine 

Manufacturers

Engine Labels 40 CFR 86.007-

35(a)(3) and 

1036.135

Additional Engine GHG Labeling:

Identify the emission control system. Use terms and 

abbreviations as described in 40 CFR 1068.45 or other 

applicable conventions.

40 CFR 1068.45

Identify any limitations on your certification. For example, 

if you certify heavy heavy-duty engines to the CO2 standards 

using only transient cycle testing, include the statement 

“VOCATIONAL VEHICLES ONLY”. 

40 CFR 1036.135

You may ask us to approve modified labeling requirements 

in this part 1036 if you show that it is necessary or 

appropriate. We will approve your request if your alternate 

label is consistent with the requirements of this part. We 

may also specify modified labeling requirement to be

consistent with the intent of 40 CFR part 1037. 

40 CFR 1036.135

Further, tests used today to demonstrate compliance with criteria pollutants in addition to 

Phase 1 GHG emissions and fuel consumption standards are all based on the Heavy Duty Federal 

Test Procedure (FTP) and Supplemental Engine Test (SET). However, depending on the type of 

vehicle in which the engine would be placed, manufacturers are required to identify relevant test 

results (steady state, transient or steady state and transient test results) in their certification 

application. The agencies calculated the burden of these activities in Table 17 as the 

“Testing/Gathering emission data on test vehicles” and “Analyze data to determine compliance” 

costs. The engine testing requirements for the Phase 2 amendment to the HD ICR in years 2017 

through 2019 are identical to the testing requirements for Phase 1.

With the exception of these GHG certification requirements for heavy duty engines, the 

existing compliance structure that engine manufacturers use for criteria pollutants is also valid 

for demonstrating compliance with the GHG regulations. Specifically, engine manufacturers 

would utilize the emissions, warranty and service programs already in place for CO2, CH4 and 

N2O as outlined in 40 CFR part 86. 

As a consequence, the burden associated with submitting engine certification applications 

in years 2017 through 2019, final reports and other data is minimal. This information will 

simply be integrated into the existing data already submitted to EPA. This ICR assumes and 

reflects the cost burden to report this new information for 12 heavy-duty engine manufacturers 

that on average will submit nine applications each, for a total of 108 engine certification 

applications. The requirements to develop the application for certification are identified as the 

following in Table 17:
16

 Review of regulations

 Prepare and submit certification application (including carryover applications)

 Prepare and review GHG compliance plan

 End of year and final production reports

 Store, file and maintain records 

(b) Phase 2 Data Items: HD Engines

Because the Phase 2 requirements for engine manufacturers’ applications for certification 

build on the Phase 1 requirements, the same data items listed above in Table 5 and Table 6 and 

Table 7 would also apply in model years 2020 and beyond. The proposed HD Phase 2 rule would 

also require new information that was not required Phase 1. The new information includes 

conducting tests to generate steady-state fuel maps to characterize engine performance for use 

with the GEM simulation tool. For manufacturers who elect to conduct powertrain testing, new 

dynamometer testing would be required to characterize the performance of engines that are 

integrated with transmissions. The burdens associated with these future requirements would 

potentially have both capital and operating expenses, depending on the current testing capacity of 

the manufacturer.

3. Vocational Vehicles and Combination Tractors

(a) Phase 1 Data Items: Vocational Vehicles and Tractors

Fuel consumption and emissions from vocational vehicles and combination tractors were 

regulated for the first time in Phase 1, and EPA recognizes that the HD National Program 

presents these segments with several testing, reporting, recordkeeping, and labeling requirements

that will continue through model year 2019, as shown in Table 8 through Table 11. The reporting 

requirements for the application for certification are covered in the HD GHG Vehicle application 

for certification template.

Table 8 Required Information for Certification Applications: Vocational Vehicle Chassis and Tractor 

Manufacturers (49 CFR 553.8)

A description of the vehicle family’s specifications and other basic parameters of the vehicle’s 

design and emission controls. List the fuel type on which the vehicles are designed to operate 

(for example, ultra low-sulfur diesel fuel). 

An explanation of how the emission control system operates. As applicable, describe in detail all 

system components for controlling greenhouse gas and evaporative emissions, including all 

auxiliary emission control devices (AECDs) and all fuel-system components will be installed on 

any production vehicle. Identify the part number of each component you describe. Treat as 

separate AECDs any devices that modulate or activate differently from each other. 

For vehicles subject to air conditioning standards (this means tractors for Phase 1), include:

(1) The refrigerant leakage rates (leak scores).

(2) The refrigerant capacity of the air conditioning systems.

(3) The corporate name of the final installer of the air conditioning system.

A description of any vehicles selected for testing and the reasons for selecting them.

A description of any test equipment and procedures that were used, including any special or 
17

alternate test procedures used (see § 1037.501). 

A description of how any emission-data vehicle was operated before testing, including the duty 

cycle and the number of vehicle operating miles used to stabilize emission levels. Explain why 

this method of service accumulation was selected. Include a description of any scheduled 

maintenance performed.

A list of the specifications of any test fuel used to show that it falls within the required ranges 

specified in 40 CFR part 1065.

Identification of the vehicle family’s useful life.

The maintenance instructions and warranty statement that will be provided to the ultimate 

purchaser of each new vehicle (see §§ 1037.120 and 1037.125).

A description of the vehicle’s emission control information label (see § 1037.135).

Identify the emission and fuel consumption standards or family emission limits (FEL)s to which 

you are certifying vehicles in the vehicle family. For families containing multiple subfamilies, 

this means that you must identify multiple CO2 and FC FELs. For example, you may identify the 

highest and lowest FELs to which any of your subfamilies will be certified and also list all 

possible FELs in between (which will be in 1 g/ton-mile and gallons/1,000 ton-mile increments).

Where applicable, identify the vehicle family’s deterioration factors and describe how they were 

developed. Present any emission test data used for determining the deterioration factors (see 

§1037.241(c)).

Where applicable, state that you operated your emission-data vehicles as described in the 

application (including the test procedures, test parameters, and test fuels) to show you meet the 

requirements of this part.

Present evaporative test data to show your vehicles meet the evaporative emission standards 

specified in subpart B of this part, if applicable. Report all valid test results from emission-data 

vehicles and indicate whether there are test results from invalid tests or from any other tests of the 

emission-data vehicle, whether or not they were conducted according to the test procedures of 

subpart F of this part. You may be required to report these additional test results. You may be 

asked to send other information to confirm the validity of test data.

Report modeling results for ten configurations. Include modeling inputs and detailed descriptions 

of how they were derived. Unless otherwise specified, include the configuration with the highest 

modeling result, the lowest modeling result, and the configurations with the highest projected 

sales. 

A description of all adjustable operating parameters (see § 1037.115), including production 

tolerances. It is not necessary to include parameters that do not affect emissions covered by the 

application. Include the following in your description of each parameter:

(1) The nominal or recommended setting.

(2) The intended physically adjustable range.

(3) The limits or stops used to establish adjustable ranges.

(4) Information showing why the limits, stops, or other means of inhibiting adjustment are 

effective in preventing adjustment of parameters on in-use vehicles to settings outside the 

intended physically adjustable ranges. 

A statement that unconditionally certifies that all the vehicles in the vehicle family comply with 

the requirements of the Clean Air Act.

Good-faith estimates of U.S.-directed production volumes by subfamily. You may be required to 

describe the basis of your estimates.
18

Other information, such as information required by § 1037.725 if participating in the ABT 

program.

Other applicable information, such as information specified in this part or 40 CFR part 1068 

related to requests for exemptions.

Name an agent for service located in the United States. Service on this agent constitutes service 

on the manufacturer or any of the manufacturer’s officers or employees for any action by EPA or 

otherwise by the United States related to the requirements of these regulations.

Table 9 Key Information Items Requested: HD National Certification Program: Vehicle Manufacturers 

(40 CFR 1037.205)

Description of vehicle families as related to requirements for GHG standards, including 

CO2 and HFC, as applicable

Description of emission control system, including auxiliary-emission control devices to be 

installed on production vehicles

Description of test vehicles selected for testing and rationale for selection

Description of test procedures and equipment, including alternate tests if applicable 

Describe Label Information 

Intent to participate in Average, Banking & Trading and/or other available emissions 

credit programs 

Family Emission Limits

Statement of Compliance

Good-faith estimates of U.S. production volumes

Final production reports

Amendment to certification application

Name of U.S.-based service agent

Table 10 Summary of Additional Information Required for Compliance 

Submission Applies to Required Submissions 

Date

EPA 

Regulation 

Reference

40 CFR 

part 1037

NHTSA 

Regulation 

Reference

49 CFR 

part 535

Small business 

exemptions

Vehicle manufacturers 

meeting the Small 

Business 

Administration (SBA) 

size criteria of a small 

business as described in 

13 CFR 121.201.

Before introducing any 

excluded vehicle into 

U.S. commerce

§1037.150 §535.8

Approval of 

alternate 

Tractors meeting § 

1037.106

EPA must be notified 

before the manufacturer 

§1037.150 §535.8
19

methods to 

determine drag 

coefficients for 

tractors

submits its applications 

for certificates of 

conformity

Air conditioning

leakage 

exemption for 

vocational 

vehicles

Vocational Vehicles 

excluded from § 

1037.115 

EPA must be notified 

before the manufacturer 

submits its application 

for certificates of 

conformity

§1037.150 §535.8

Off-road 

exemption

Manufacturers wanting 

to exclude tractors or 

vocational vehicles 

from vehicle standards

EPA must be notified 

before the manufacturer 

submits its applications 

for certificates of 

conformity

§1037.150 §535.8

Vocational 

Tractor

Manufacturers wanting 

to reclassify tractor as 

vocational tractors 

making them 

applicable to vocational 

vehicle standards

EPA must be notified 

before the manufacturer 

submits its application 

for certificates of 

conformity

§1037.150 §535.8

Exemption for 

electric vehicles

All electric vehicles are 

deemed to have zero 

exhaust emissions of 

CO2, CH4, and N2O

End of December prior 

to model year

§1037.150 §535.8

Exemption from 

final reports

Manufacturers with 

surplus credits at the 

end of the model year

90-days after the 

calendar year ends

§535.8
20

Table 11 Key labeling requirements, HD National Certification Program

Information Item Vehicle 

Manufacturers

Vehicle Labels: 40 CFR 1037.135

Assign each vehicle a unique identification number and 

permanently affix, engrave, or stamp it on the vehicle in a legible 

way. The vehicle identification number (VIN) serves this 

purpose.

40 CFR 1037.135

At the time of manufacture, affix a permanent and legible label 

identifying each vehicle. 

40 CFR 1037.135

The label must include information contained in § 1037.135(c). 40 CFR 1037.135

You may add information to the emission control information 

label to identify other emission standards that the vehicle meets or 

does not meet (such as European standards). You may also add 

other information to ensure that the vehicle will be properly 

maintained and used. 

40 CFR 1037.135

You may ask us to approve modified labeling requirements in this 

part 1037 if you show that it is necessary or appropriate. We will 

approve your request if your alternate label is consistent with the 

requirements of this part.

40 CFR 1037.135

Additional Vehicle GHG Labeling: 

The original vehicle manufacturer of an off-road vocational 

vehicle must apply a removable label meeting the requirements of 

40 CFR 1068.45 that identifies the corporate name of the original 

manufacturer and states that the vehicle is exempt under the 

provisions of § 1037.620. The name of the certifying 

manufacturer must also be on the label or, alternatively, on the bill 

of lading that accompanies the vehicles during shipment. The 

original manufacturer may not apply a permanent emission control 

information label identifying the vehicle's eventual status as a 

certified vehicle.

40 CFR 1037.615

You must include the following additional statement on the 

vehicle’s emission control information label for a vocational 

tractor under §1037.135: “THIS VEHICLE WAS CERTIFIED AS 

A VOCATIONAL TRACTOR UNDER 40 CFR 1037.630.”

40 CFR 1037.630

The requirements to develop the application for certification are identified as the 

following in Table 18 and Table 19:

 Review of regulations and guidance document

 Prepare and submit certification application (including carryover applications)

 Labeling requirements

 Final year production and ABT update

 Store, file, and maintain records
21

For both these vehicle categories, the Phase 1 CO2 and fuel consumption standards focus 

on reductions that can be achieved primarily through changes to vehicle systems, such as tires, 

and some modifications to vehicle design. Both the fuel consumption and CO2 standards are 

expressed in terms of moving a ton of freight over one mile: the fuel consumption standard is 

represented as gallons of fuel used to move one ton of freight (payload) 1000 miles, or gal/1000 

ton-mile; and the CO2 vehicle standards are represented as grams of CO2 per ton-mile. Neither 

vocational vehicles nor combination tractors are subject to N2O or CH4 emission standards, but 

tractors equipped with air conditioning are subject to HFC leakage standards.

To help reduce testing and reporting burdens on vocational vehicle chassis and 

combination tractor manufacturers, EPA developed a vehicle simulation model, the Greenhouse 

gas Emissions Model (GEM) for the HD Phase 1 program. Phase 1 GEM was developed for 

manufacturers to demonstrate compliance with the new GHG standards. Under the rule, 

manufacturers evaluate and report CO2 emissions and fuel consumption through a 

simulation of their vehicles using GEM. GEM is directly available to vocational vehicle 

chassis and combination tractor manufacturers as a download from the internet, at no cost. 

Outputs from the GEM model also generate summary data that can be integrated into the 

application for a certificate of conformity. 

EPA programmed the Phase 1 GEM with two sets of predefined parameters; one set of 

parameters for vocational vehicles, and a second set of parameters for combination tractors. 

Values for these predefined parameters are detailed in the rule, and include several key vehicle 

characteristics common to the vocational vehicle and combination tractor configurations subject 

to CO2 and fuel consumption limits. 

These characteristics include vehicle frontal area dimensions; total and payload weight; 

engine/transmission/wheel inertia, accessory load, axle base, tire radius, and engine fuel map, 

among others. Additional predefined inputs, unique to combination tractors, such as trailer tire 

coefficient of rolling resistance (Crr), also are included. 

These preprogrammed inputs substantially reduce the testing burden on manufacturers of 

vocational vehicle chassis and combination tractors. For example, the GEM provides an 

alternative to chassis and other tests traditionally performed in a laboratory or on the road. 

Manufacturers are required to test their vehicles, collect data and input at least two key 

data elements (based on testing) prior to running GEM. As discussed below, these two inputs 

are: 1) the coefficient of rolling resistance (Crr) of the vehicle’s steer and drive tires; and (for 

combination tractors) 2) the aerodynamic drag (expressed as the vehicle’s coefficient of drag 

area or “CdA”) of a truck. 

Additional inputs needed to run the GEM include basic information, such as 

manufacturer name, vehicle family and configuration, and model year. The Phase 1 testing 

requirement costs are identified as the following in Table 18 and Table 19:

 Tire testing 

 Tractor coefficient of drag testing (using coastdown, wind tunnel, and CFD)
22

 Collect, input data for the Greenhouse Gas Emissions Model (GEM), and run 

model

 Analyze data to determine compliance

(i) Test Items: Tire Rolling Resistance

Both vocational vehicle chassis and combination tractor manufacturers will need to 

determine the rolling resistance of a vehicle’s steer and drive tires from either their tire suppliers 

or by testing the tires using the test method adopted by the International Organization for 

Standardization, ISO 28580:2009. 

Specifically, the ISO test must be conducted on three tire samples within each tire model 

one time each to account for some production variability. Details for conducting the ISO test are 

specified in the rule (§1037.520(c)). In summary, the average of the three tests would be the 

rolling resistance coefficient value for use as an input into the GEM. Whether tested in-house, or 

contracted out, this ICR assumes a cost of $300 for each tire model tested. The ICR further 

assumes that each manufacturer (vocational vehicle chassis and combination tractor) will need to 

test 10 tire models for each vehicle family or certification application that is submitted for the 

first year of certification. In subsequent years, the manufacturers will be able to carry-over tire 

test results so the agencies assumed one new tire will be tested for each application for each 

manufacturer. 

Although the results of the tire tests do not need to be submitted as part of the 

certification application, the Crr is needed to run GEM and demonstrate compliance with the 

rule’s CO2 and fuel consumption standards. Test results are to be maintained for 8 years, as 

required under 40 CFR 1037.250. 

(ii) Test Items: Aerodynamic Assessment

In addition to providing inputs on the rolling resistance of their steer and drive tires, 

combination tractor manufacturers must also establish the GEM inputs for the aerodynamic drag 

– expressed as the coefficient of drag or “CdA” – of their vehicles. Vocational vehicle chassis 

manufacturers are not subject to this requirement to test and establish drag for their vehicles.

Manufacturers must determine a combination tractor’s CdA through testing, which then 

is to be used as an input into the GEM. Under the rule, manufacturers may choose from test 

methods to assess the aerodynamics of their vehicle and establish appropriate CdA values. 

These test methods include coastdown testing, wind tunnel testing and computational fluid 

dynamics.

To estimate the cost associated with testing combination tractors to establish a CdA, 

procedures for conducting coastdown tests are specified in 40 CFR 1037.527 of the rule; 

procedures for conducting wind tunnel testing can be found in (§1037.529 of the rule. Detailed 

guidance on the role of computational fluid dynamics in establishing a CdA for specific tractor 

models can be found in 40 CFR 1037.531. 

Importantly, tractor manufacturers must conduct coastdown testing on at least one truck. 
23

Based on the CdA established from coastdown testing, manufacturers have the option of 

developing an adjustment factor that can be applied to assess the aerodynamic drag of other 

trucks. If a manufacturer chooses to develop this adjustment factor, it must also conduct 

alternate aerodynamic testing on the same truck that was subject to the coastdown test. The rule 

also provides guidance on using the coastdown and alternate aerodynamic test results (from the 

same truck) to establish this adjustment factor (40 CFR 1037.525). 

As stated, at this time the agencies recognize that manufacturers may not have the 

facilities or onsite expertise necessary to conduct either coastdown or alternate aerodynamic 

testing in house. Consequently, the ICR assumes that manufacturers will work with testing 

contractors that possess the expertise and facilities to meet the rule’s testing requirements. 

Further, the contract costs (operations and maintenance, or “O&M”) presented in Table 

19 assume that tractor manufacturers will choose to derive and apply an adjustment factor to 

establish the CdA for their trucks. As specified in the rule, this factor can only be used in 

conjunction with actual alternate aerodynamic tests conducted on vehicles that are selected to 

represent specific vehicle families.

Thus, as shown in Table 19, testing burdens for tractor manufacturers are presented as 

O&M costs, based on the assumption that manufacturers will contract out the testing –

coastdown and wind tunnel - needed to establish the CdA for their vehicles, and subsequently to 

run the GEM. 

Tractor manufacturers also will have options for including other parameters in the GEM, 

if their vehicles are equipped with technologies to reduce idling, lower vehicle weight and limit 

speed. 

Although this data is not reported as a GEM input, at the time of certification, tractor 

manufacturers also will be required to outline the design of their air conditioning systems used in 

cabs, and an HFC leakage score. Test procedures for establishing an HFC leakage score are 

detailed in 40 CFR 1037.115(c).

The ICR assumes that 22 vocational vehicle chassis manufacturers, on average, will 

identify between two and three vehicle families and that the agencies will receive a total of 60 

applications for certificates of conformity from this regulatory category. 

The agencies expect to receive an additional 32 applications from manufacturers of 

combination tractors (on average eight applications from four manufacturers). The four tractor 

manufacturers also manufacture the vocational vehicles accounted for in the ICR. 

However, these manufacturers operate distinctly different truck divisions and based on 

significant differences in vehicle design, the agencies expect to receive a total of 92 applications 

for certificates of conformity from the vocational vehicle and tractor categories annually. 
24

(b) Phase 2 Data Items: Tractors

Because the Phase 2 requirements for tractor manufacturers’ applications for certification 

build on the Phase 1 requirements, the same data items listed above in Table 9, Table 10, and Table 

11would also apply in calendar years 2020 and beyond. The proposed HD Phase 2 rule would 

also require new information that was not required Phase 1. Beginning in 2021 model year, the 

manufacturers would need to supply additional inputs to GEM, including the following:

 Engine information including manufacturer, model, combustion type, fuel type, 

family name, and calibration identification

 Engine fuel map,

 Engine full-load torque curve,

 Engine motoring curve,

 Transmission information including manufacturer and model

 Transmission type,

 Transmission gear ratios,

 Drive axle ratio,

 Loaded tire radius for drive tires, and 

 Other technology inputs.

The manufacturers would also be required to conduct enhanced aerodynamic testing to 

obtain a coefficient of drag area that includes wind impacts to better simulate the real world 

operating conditions. The manufacturers would also be required to conduct additional 

coastdown tests to obtain an alternative aerodynamic procedure correction factor based on the 

configuration of the tractor. Finally, manufacturers would be required to conduct limited tractor 

chassis testing to continue to affirm the representativeness of the GEM simulations.

(c) Phase 2 Data Items: Vocational Vehicles

For the Phase 2 HD GHG program, manufacturers of vocational vehicles would be 

required to collect the same data items listed above in Table 9, Table 10, and Table 11 in calendar 

years 2020 and beyond. In addition, new information would be required beginning in MY 2021. 

When a vocational vehicle manufacturer installs an air conditioning system or directs a second 

stage manufacturer to install an air conditioning system, the same information as is required for 

tractors in phase 1 related to HFC leakage from air conditioning systems would become required 

for Phase 2. Similar to the data items described above for Phase 2 tractors, Phase 2 GEM would 

require additional inputs to simulate vocational vehicles, including transmission type and gear 

ratios, drive axle ratio, and tire revs/mile. Each of these data fields would need to be tracked by 

manufacturers. Also, if a manufacturer elects to substitute a lightweight material such as 

aluminum for a chassis component as part of its compliance strategy, the use of such components 

would need to be tracked. The additional engine testing to characterize engine performance in 

GEM is described above for the engine manufacturers. Vocational vehicle manufacturers would 

need to obtain these testing results from engine manufacturers and enter the data in GEM.
25

4. Trailers

Prior to this proposed Phase 2 program, manufacturers of trailers have not been regulated 

for CO2 emissions or fuel consumption and the agencies recognize that the proposed trailer 

program presents these manufacturers with several new testing, reporting, labeling, and 

recordkeeping requirements. For trailers, the proposed CO2 and fuel consumption standards are 

based on reductions that we believe can be achieved by applying currently-available 

aerodynamic, tire, tire inflation technologies, and light-weight components. The proposed fuel 

consumption standards are represented as gallons of fuel used to move one ton of freight 

(payload) 1,000 miles, or gal/1,000 ton-mile. The CO2 trailer standards are represented as grams 

of CO2 per ton-mile.

The proposed Phase 2 regulations lay out several information-related requirements for 

trailer manufacturers, as summarized in Table 12. For this proposal, the agencies adopted the 

Small Business Administration’s definition of small business, which states that trailer

manufacturers with fewer than 500 employees (including parent and subsidiary companies) are 

considered small businesses. Of the 114 trailer manufacturers, 95 are considered small 

businesses. Box trailers have the most stringent standards in the Phase 2 proposal, and 14 of 

these companies manufacturer box trailers (9 large and 5 small businesses). Only 17 of the 109 

non-box trailer manufacturers are large businesses. The agencies are proposing a one-year delay 

in implementation for small businesses to provide additional lead time to prepare for the 

program. As a result, the cost information in this ICR is presented in separate tables for the large 

and small trailer manufacturers. 

Table 12 Required Information for Trailer Manufacturers

Information Collection Activity 40 CFR 1037 Reference

Review the regulations and any guidance documents

Develop trailer families 1037.230

Describe each trailer family’s basic specs 1037.205(a)

Identify the vehicle family’s useful life 1037.205(h)

Provide customer maintenance and warranty info 1037.205(i)

Describe label 1037.205(j)

Identify CO2 FELs 1037.205(k)

Provide information describing the procedures you used to 

determine trailer CDA values 1037.525

Test trailers and provide CDA testing results OR 1037.515(c)

Provide data on use pre-approved devices OR 1037.211

Provide carryover data 1037.235(d)

Determine TRRL and provide tire test data 1037.515(b)

Provide information on ATI system 1037.515

Determine weight reduction and provide description 1037.515(d)

Calculate and provide CO2 and fuel consumption from compliance 

equation 1037.515(a)

Use averaging provisions to calculate average CO2 and fuel 

consumption 1037.705
26

Information Collection Activity 40 CFR 1037 Reference

Prepare Final Production 1037.250

Prepare Final Averaging Report 1037.730

Maintain records 1037.250

In the case of trailers, we propose that compliance be demonstrated with an equation that 

is based on and updated version of GEM, but without the need for trailer manufacturers to run 

GEM for compliance (as is required for tractors and vocational vehicles). Under the proposed 

rule, trailer manufacturers would apply performance values for improvements in aerodynamic 

drag, tire rolling resistance, and as well as values for use of weight-reducing components and 

automatic tire inflation systems. 

To determine a value for the aerodynamic drag improvement to use in the compliance 

equation, manufacturers would have the option of testing their trailer’s aerodynamic 

performance. Alternatively, we propose that a manufacturer could use “pre-approved” devices,

for which the device manufacturer had previously performed appropriate testing. Because of the 

convenience and economy of using pre-approved devices, we expect that most manufacturers 

would use this compliance approach and only six of the largest box trailer manufacturers would 

perform their own testing.

For the large box trailer manufacturers that choose to perform their own aerodynamic 

testing, the agencies are proposing four optional test procedures could be used to establish the 

aerodynamic drag improvement from the addition of aerodynamic devices. The procedures are 

coastdown, constant speed, wind tunnel, and computational fluid dynamics (CFD). Each of 

these test methods has unique cost and practical advantages and disadvantages, and these could 

apply somewhat differently from manufacturer to manufacturer. We expect that the remaining 

box trailer manufacturers (three large and five small manufacturers) would rely on pre-approved 

devices for their aerodynamic performance data. Of the manufacturers that choose to perform 

testing, we estimate that they would tend to use wind tunnel and CFD testing most often. 

For compliance with the tire rolling resistance standards, we believe that essentially all 

manufacturers would rely on test data on their trailer tires provided by the tire manufactures. In 

this analysis, assume the five largest trailer manufacturers would contract one tire test per year. 

We also account for a small administrative burden for the manufacturer to obtain and report the 

tire rolling resistance numbers for the tires they provide on their trailers. 

Finally, we are proposing that all trailers subject to the Phase 2 program incorporate 

appropriate automatic tire inflation (ATI) systems. We do not assign an administrative cost for 

manufacturers to simply report that their families incorporate ATI systems. 

In 2017, large trailer manufacturers are expected to have costs associated with reviewing 

the regulations and guidance documents, performing some preliminary aerodynamic testing and 

acquiring the new equipment and software needed to begin labeling and certifying their trailers 

the following year. The labeling and certification costs include some capital startup costs as well 

as labor. Costs in 2017 are expected to average $127,000 for the large manufacturers. The 

program begins in 2018 for large manufacturers, and additional costs are included for data 
27

collection, report preparation, and recordkeeping. Some additional testing is also expected for a 

few of the large manufacturers. Costs in 2018 are expected to average $128,000 for the large 

manufacturers, and we expect these costs to remain the same in 2019, since the standards and 

compliance requirements are stable until model year 2021. 

We assume all small business manufacturers will use the one-year delay in 

implementation offered in the proposed rule, and as a result, they would not begin their program 

until 2019. Therefore, their only costs in 2017 are related to reviewing the regulations and we 

estimate those costs to average less than $9,000 for the small manufacturers. In 2018, we expect 

small businesses to purchase the required equipment and software for labeling and certification 

in preparation for the following model year. Those costs are reflected in both labor and capital 

startup costs. We assume all small box trailer manufacturers will rely on pre-approved devices 

for their aerodynamic performance data and information from the tire manufacturers for their tire 

performance data. Therefore we do not expect them to take on any costs for preliminary testing 

in 2018. The 2018 small business trailer costs are expected to average $64,000. In 2019 the 

compliance program would begin for small manufacturers, and additional costs are included for 

data collection, report preparation, and recordkeeping. We continue to predict that small 

manufacturers would not perform testing for their aerodynamic and tire performance data. The 

costs are expected to average $16,000 for small trailer manufacturers.

D. Respondent Activities

The types of activities a manufacturer would do to certify an engine or vehicle family are 

as follows:

 Review the regulations and guidance document

 Prepare and submit pre-model year reports or related production data for 

certification applications

 Develop engine or vehicle “test” or “family” groups

 Test engines and vehicles for compliance with emission and fuel consumption 

standards

 Gather and analyze test results 

 Collect inputs and run GEM, as needed 

 Apply for off-cycle credits

 Submit the Application for Certification and Pre-Model Year Information

 Label certified engines or vehicles

 Prepare and submit carryover applications

 Prepare GHG compliance plan and reports, as needed

 Prepare and submit final ABT and production reports

 Store, file and maintain records
28

V. The Information Collected--Agency Activities, Collection 

Methodology, and Information Management

A. Agency Activities

As part of the implementation of the certification programs, EPA and NHTSA officials 

carry out the following activities:

 Review and interpret regulations, provide guidance

 Review certification applications for completeness and accuracy

 Verify that the correct engines and vehicles have been selected and tested

 Answer questions from manufacturers and the public

 Issue appropriate certificates of conformity 

 Periodically perform maintenance or enhance the database

 Make data available to the public

 Analyze and manage requests for confidentiality

 Determine if “carry over” of data from a previous model year is appropriate or if 

new testing will be required

 Audit data, conduct inspections, and confirmatory testing

 Review final production/ABT reports, establish final credit balances, and 

maintain manufacturer’s credit accounts

 Store, file and maintain data

B. Collection Methodology and Management

EPA and NHTSA currently make extensive use of computers in collecting information 

from vehicle manufacturers. Essentially all applications for certification and related product 

descriptions, test results, ABT and final reports, etc. will be submitted electronically through a 

single point of entry to a database that both EPA and NHTSA can access. Once the data are

received, the information is uploaded, monitored and reviewed for completeness by EPA and 

NHTSA. 

The public can access non-confidential portions of the certification applications and test 

data by contacting CD or through the Certification Information Center at

http://www.epa.gov/otaq/certdata.htm.

C. Small Entity Flexibility

As discussed in the preamble of the regulation, the respondent class for the years 2017 

through 2019 is defined to exclude tractor, vocational, HD pickup truck and van, and engine

manufacturers who would fall into the definition of small business entities, except for a onceper-year declaration of small business status. The proposed EPA standards for trailers in the 

Phase 2 program would become effective in 2018 and are voluntary for NHTSA through model 

year 2020. The respondent class in 2017 includes both large and small business trailer 

manufacturers. However, the agencies are proposing a small business flexibility of a one-year 
29

delay in implementation for small businesses and it is assumed that the only cost to small 

businesses in 2017 would be reviewing the regulations. These small businesses would also be 

obligated to declare their small business status to the agencies. 

D. Collection Schedule

Information must be submitted prior to and after the end of each “model year” that a 

manufacturer intends to build (or import) vehicles. For emissions and fuel consumption 

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

manufacturer, which includes January 1 of the calendar year for which the model year is named, 

may not begin before January 2 of the previous calendar year, and it must end by December 31 

of the named calendar year. 

During the model year, the results of such additional fuel consumption and greenhouse 

gas tests as the manufacturer conducts are also reported to EPA and NHTSA. After the end of the 

model year fleet-wide greenhouse gas emissions and equivalent fuel consumption results are 

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. 

VI. Estimating the Burden and Cost of the Collection

Table 17 through Table 24 represent the costs for each year of the program for years 2017 

through 2019. These tables represent burdens and costs for manufacturers of HD engines and 

the four vehicle categories covered by the HD Phase 2 National Program.

A. Estimating Respondent Burden

Burden estimates were taken from the previous ICRs and adjusted to reflect EPA 

experience in these and other similar programs. In general, the burden related to engine, tractor, 

vocational vehicle, and HD pickup truck compliance associated with years 2017 through 2019 

are due to requirements of the HD Phase 1 program. This is due to the fact that the proposed HD 

Phase 2 program does not set new standards for engines, tractors, vocational vehicles and HD 

pickup trucks until the 2021 model year.

B. Estimating Respondent Costs

1. Estimating labor costs

To estimate labor costs, EPA used the Bureau of Labor Statistics’ National Industryspecific Occupational Wage Estimates (2009) for the Manufacturing Industry (NAICS 31-33), 

Transportation Equipment Manufacturing Subsector (NAICS 336) and the Professional,

Scientific, and Technical Services Sector (NAICS 54). These rates were increased by a factor of 

2.1 to account for benefits and overhead. The specific rates used are listed below in Table 13. 

These are mean hourly rates. 
30

Table 13 Labor Cost Estimates

Occupation Mean Hourly Rate (BLS) Mean Hourly Rate (Including benefits and 

Overhead) 

Mechanical Engineers $39.16 $82.24

Engineering Managers $50.71 $106.50

Test Cell Operator $23.05 $48.40

Lawyers $65.81 $138.20

Secretaries, Except Legal, 

Medical and Executive $14.95 $31.39

2. Estimating Capital, Operations and Maintenance Costs

Operations and Maintenance costs include the non-labor costs associated with conducting 

tests that are required for MY 2017 through 2019. Costs are for contracted laboratory time, the 

use of test equipment, vehicle and engine parts, fuel and other supplies. 

The agencies expect that manufacturers of trailers, vocational vehicle chassis and 

combination tractors will contract with testing firms for most of their testing. Under the 

regulations, these manufacturers need to establish a coefficient of rolling resistance (Crr) for the 

tires they will specify for vehicles to demonstrate compliance with the new GHG and fuel 

standards. In addition, tractor and trailer manufacturers need to test vehicles for a coefficient of 

drag, or a CdA, also needed to demonstrate compliance. 

Based on contract costs for running tests to establish Crr (ISO 28580) these test costs 

amount to a total of $12,273 for vocational vehicles, $18,000) for tractors, and $3,000 for 

trailers. As listed in Table 18 through Table 24 below, these 3-year values estimate that annually 

each of the 22 vocational vehicle manufacturers will carry over previous tire testing results, 

while five manufacturers will test a total of 14 tires, each of the four tractor manufacturers will 

test 5 tires, and five trailer manufacturers will each test 1 tire.

Based on contract costs for running tests to establish CDA (either coastdown, wind tunnel 

or computational fluid dynamics (CFD) models), these aerodynamic test costs amount to a 3-year 

total of $354,000 for tractors, and $3,780,000 for trailers. For tractors, the annual costs include 

zero coastdown tests, one wind tunnel test, one full computational fluid dynamics (CFD) models, 

and nine CFD iterations for each of the four tractor manufacturers. For trailers, the annual costs 

include as many as four coastdown tests, four wind tunnel tests, four full computational fluid 

dynamics (CFD) models, and four CFD iterations for five of the largest trailer manufacturers. 

Zero small business trailer manufacturers are expected to perform testing.

3. Capital/Start Up Costs

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

normally are applicable to the first year of the program, of which becomes effective is in the 

calendar year 2018. These startup costs fall into three categories. First are costs associated with 
31

information management. Second, are start up costs associated with acquiring test equipment. 

Third, are costs associated with equipment to generate vehicle labels.

For all trailer manufacturers, the rule’s electronic reporting requirements will generate 

first-year start up costs for programming computer systems so that certification and related data 

can be submitted to EPA/NHTSA in the necessary formats. We also assume they will need to 

purchase appropriate equipment and software to generate labels. We believe the large business 

trailer manufacturers will incur these capital costs in 2017 and small business trailer 

manufacturers will delay these costs until 2018. For the other engine and vehicle manufacturers, 

there are no new start-up costs estimated for this Phase 2 amendment to the HD ICR in years 

2017 through 2019. As described above, we anticipate there would be start up costs for the nontrailer manufacturers to modify their systems to meet the Phase 2 requirements in 2020.

C. Estimating Agency Burden

1. Environmental Protection Agency (EPA)

Existing heavy duty certification and compliance programs are administered by EPA’s 

Compliance Division (CD). CD works closely with the agency’s Testing and Advanced 

Technology Division (TATD) to establish and implement testing programs that enable the 

agency to ensure compliance with its mobile source emissions standards. Together CD and 

TATD have identified resources that would be needed to support the National HD Phase 2 

program, including full time equivalent (FTE) staff and information system upgrades. 

Implementation of the HD Phase 2 engine, tractor, vocational vehicle, and HD pickup 

truck standards in years 2017 through 2019 would be carried out by existing staff. The 

implementation of the HD Phase 2 trailer program would require up to two additional FTE.

We project 480 hours per week of staff time at $80 per hour (loaded to include benefits 

and overhead) will be expended by the agency to manage compliance related to the engine, 

tractor, vocational vehicle, and HD pickup truck standards in calendar years 2017, 2018, and 

2019. This comes to 22,000hours or $1.76 million per year to oversee the requirements of the 

programs associated with this ICR. These labor estimates are based on Office of Personnel 

Management labor rates effective January 2011, with a 2.1 multiplier used to account for benefits 

and overhead. 

In addition to FTE costs, the agency will need to maintain a HD engine and vehicle 

compliance information system. This system will serve as a single point of entry for 

manufacturers to submit and EPA to collect emissions and fuel economy compliance 

information. Both EPA and NHTSA will have access to this database system. EPA estimates it 

will incur ongoing, annualized support costs of $150,000 in 2017, 2018, and 2019 for this 

database system that currently covers engine, tractor, vocational vehicle, and HD pickup truck 

reporting. The HD Phase 2 reporting requirements for engines, tractors, and vocational vehicles 

would increase in 2020, therefore EPA estimates that updates to the certification, ABT, and 

production reporting modules would be required in 2019 in preparation for these new 

requirements, at an estimated cost of $200,000. EPA would also be required to develop a new 

certification module for trailer certifications. We estimate that the trailer certification module 
32

would cost $350,000 to develop. In addition, a trailer ABT and production volume reporting 

module would cost approximately $100,000 to develop. Therefore, the total EPA cost is 

$2,560,000 for the first three implementation years of this proposed rule as found in Table 15.

2. Department of Transportation, National Highway Traffic Safety 

Administration (NHTSA)

NHTSA has an existing consumer average fuel economy program to increase the fuel 

economy performance of passenger cars and light trucks. The agency administers this program 

in conjunction with EPA and has four divisions including the Offices of Rulemaking, 

Enforcement, Statistical Analysis, and Chief Counsel responsible for carrying out the activities 

of the program. NHTSA is developing and plans to support its fuel consumption program for 

heavy-duty trucks as a part of its existing infrastructure for its LD CAFE program.

The agency plans to administer the HD program in the same manner it has historically 

done for the LD CAFE program. For both programs, manufacturers start the program each 

model year by submitting preliminary information in advance of the model year demonstrating 

their ability to comply with standards based on the test results of candidate makes and models. 

The information is used by EPA to conduct confirmatory testing and NHTSA conducts random 

audit verifications. Manufacturers continue to test the majority of their fleets throughout the 

model year and then submit final reports after the model year ends to EPA. EPA verifies 

manufactures final demonstration results and submits the findings to NHTSA. NHTSA 

determines compliance with its standards using a credits balancing system and imposes fines if 

necessary.

Administering the HD Phase 2 program for NHTSA would require using 10 persons on 

its existing staff and hiring two new FTEs or contractors. One FTE/contractor will be an 

engineer and will work on the HD program’s enforcement activities and the second will be a 

program analyst responsible for tracking credits and carrying out other enforcement reporting 

activities. 

NHTSA expects to expend 105.12 hours per week of staff time at cost of $80 per hour 

(loaded to include benefits and overhead) to manage its compliance activities (98 percent of the 

total hours) for fuel consumption standards. In total, NHTSA calculates that it will use 5,466

hours or $437,280 per year to oversee the requirements of the programs associated with this ICR. 

These labor estimates are based on Office of Personnel Management labor rates effective 

January 2010, with a 2.1 multiplier used to account for benefits and overhead. 

NHTSA would also incur cost for helping EPA maintain its compliance information 

database system. The final rule establishes a harmonized approach for the HD program by which 

manufacturers will submit compliance reports directly through the EPA system as the single 

point of entry for all GHG emission and fuel consumption information required for this national 

program. As a result, EPA would need to create access to its database system for NHTSA. 

NHTSA estimates that annual costs for contributing to maintain the EPA database in housing its 

fuel consumption information and ensure proper access to the data will cost approximately 

$33,000 per year for additional support of the heavy-duty truck program. This soft estimate is 
33

based upon NHTSA’s experience with a web-based system of comparable size and complexity. 

However, no costs are assigned on NHTSA’s part to enhance the system to meet our business 

requirements for this rule. EPA has agreed to assume all of these costs. Therefore, the total 

NHTSA cost is $470,280 per year for this rule as found in Table 15.

D. Estimating the Respondent Universe and Total Burden and Costs

1. Certification Estimates

There are 12 companies in this sector which manufacture on-highway heavy-duty 

engines, and 153 companies that manufacture vehicles including trailers that will be required to 

meet the proposed greenhouse gas emission standards. Notably, although EPA and NHTSA have

established distinct standards for the four vehicle categories covered by this rule: 1) heavy duty 

pickup trucks/vans; 2) vocational vehicles; 3) combination tractors; and 4) trailers -- many 

manufacturers are producing vehicles in more than one of these categories, and thus will be 

required to submit multiple certification applications.

In total, EPA projects that related to the HD National Program, it will receive 376

applications for certification, as follows:

(a) Engine Manufacturers

Engine manufacturers and heavy-duty pickup truck and van manufacturers are currently 

regulated by EPA and are already familiar with EPA regulations, policies and certification 

program. Under the proposed regulations, engine manufacturers will not be required to submit 

new certification applications, but will need to add CO2, N2O and CH4 test information and 

results to their applications. EPA expects that it will receive approximately 108 such amended 

applications from engine manufacturers each year. 

(b) HD Pickup Trucks and Vans

Although subject to regulation for non-GHG emissions in the past, heavy duty truck and 

van manufacturers have not been required to submit certification applications for GHG emissions 

and fuel consumption limits. To comply with the proposed new CO2, N2O and CH4 emission 

and fuel consumption standards, EPA expects to receive 24 certification applications each year 

from heavy duty pickup truck and van manufacturers. 

(c) Vocational Vehicle Chassis and Combination Tractors

From vocational vehicle chassis manufacturers EPA expects to receive 60 applications 

and from combination tractor manufacturers the agency estimates it may receive 32 applications 

each year as we do not expect every manufacturer to produce tractors in each of the nine 

subcategories. 

(d) Trailers

From trailer manufacturers EPA expects to receive 152 applications each year.
34

Table 14 below summarizes the labor, start up and operations and maintenance costs 

associated with meeting the proposed GHG and fuel consumption standards. Table 17 through 

Table 24 detail costs for the four categories of vehicle manufacturers affected by the proposal. 

(e) Bottom Line Burden Hours and Cost Tables

2. Respondent Tally 

Bottom-line burden and cost estimates for the first three years of the HD National 

Program are shown in the table below. Table 14 shows industry totals and values for each 

respondent by category by year. The annual number of responses is 376, the average annual time 

burden is 62,400 hours, and the average annual cost burden is $8 million (including Labor, 

Capital and O&M Costs).

Table 14 Total Estimated Respondent Burden and Cost Summary

Manufacturer 

Program

Number of 

Respondents

Number of 

Responses

Total 

Hours 

Per 

Year

Labor Costs Capital 

Costs

Annual 

O&M Costs

Total Annual 

Capital and 

O&M Costs

Total Labor, 

Capital, and 

O&M Costs

2017

Engine Testing 

& Certification 12 108 2,592 $207,491 $0 $0 $0 $207,491

HD Truck/Van 

Testing & 

Certification

3 24 3,828 $324,918 $0 $0 $0 $324,918

Vocational 

Vehicle Testing 

& Certification

22 60 10,860 $886,231 $0 $1,500 $1,500 $890,322

Combination 

Tractor 

Certification

4 32 16,420 $1,274,595 $0 $124,000 $124,000 $1,336,466 

Trailer 

Certification 114 152 17,552 $1,666,395 $950,000 $612,000 $1,562,000 $3,228,395

2018

Engine Testing 

& Certification 12 108 2,592 $207,491 $0 $0 $0 $207,491

HD Truck/Van 

Testing & 

Certification

3 24 4,824 $324,918 $0 $0 $0 $324,918

Vocational 

Vehicle Testing 

& Certification

22 60 10,860

$886,231 $0 $1,500 $1,500 $890,322

Combination 

Tractor 

Certification

4 32 17,120 $1,274,595 $0 $124,000 $124,000 $1,336,466 

Trailer 

Certification

114 152 31,242 $2,130,433 $4,750,000 $1,585,500 $ 6,335,500 $8,465,933
35

Manufacturer 

Program

Number of 

Respondents

Number of 

Responses

Total 

Hours 

Per 

Year

Labor Costs Capital 

Costs

Annual 

O&M Costs

Total Annual 

Capital and 

O&M Costs

Total Labor, 

Capital, and 

O&M Costs

2019

Engine Testing 

& Certification 12 108 2,592 $207,491 $0 $0 $0 $207,491

HD Truck/Van 

Testing & 

Certification

3 24 4,824 $324,918 $0 $0 $0 $324,918

Vocational 

Vehicle Testing 

& Certification

22 60 10,860 $886,231 $0 $1,500 $1,500 $890,322

Combination 

Tractor 

Certification

4 32 17,120 $1,274,595 $0 $124,000 $124,000 $1,336,466 

Trailer 

Certification 114 152 37,290 $2,341,694 $0 $1,585,500 $1,585,500 $3,927,194

2017-2019 TOTALS

2017 Total 155 376 51,252 $4,359,630 $950,000 $737,500 $1,687,500 $5,987,592

2018 Total 155 376 64,942 $4,823,688 $4,750,000 $1,711,000 $6,461,000 $11,225,130

2019 Total 155 376 70,990 $5,034,930 $0 $1,711,000 $1,711,000 $6,686,392

Three Year 

Total 155 1,128 187,200 $14,218,200 $5,700,000 $4,159,500 $9,859,500 $23,899,100

Annualized 

Burden (3-yr 

average)

155 376 62,400 $4,739,400 $1,900,000 $1,386,500 $3,286,500 $7,966,400

3. The Tally for the Agencies 

Table 15 Total Estimated Agency Burden and Cost Summary

Program Number of 

Applications

Number of 

Activities

Total Hours 

Per Year

Total Labor 

Cost Per Year

Total Capital 

Costs

Total Annual 

O&M Costs

Total Costs

EPA Emissions 

Certification

376 10 22,000 $1,760,000 $650,000 $150,000 $2,560,000

DOT Fuel 

Consumption

376 10 5,466 $437,280 0 $33,000 $470,280

EPA & DOT 

TOTALS

376 20 27,466 $2,197,280 $650,000 $183,000 $3,030,280

4. Reasons for change in burden

This is new information collection and it represents a new burden. There has been no 

change in the record keeping or reporting requirements for engine, HD pickup truck and van, 

vocational chassis and tractor manufacturers since the previous HD Phase 1 ICR renewal period; 

however, there are new burdens associated with trailers. 
36

5. Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average approximately 400 hours per respondent, or 200 hours per application. 

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 and 48 CFR chapter 15 (OMB Control No. 2060-0678).

To comment on the agencies’ need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA–HQ–OAR–2014–0827, which is available for online viewing at 

www.regulations.gov, or in person viewing at the Air and Radiation Docket and Information 

Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 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 holidays. The telephone number 

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

Docket and Information Center is (202) 566-1742. An electronic version of the public docket is 

available at www.regulations.gov. This site can be used to submit or view public comments, 

access the index listing of the contents of the public docket, and to access those documents in the 

public docket that are available electronically. When in the system, select “search,” then key in 

the Docket ID Number identified above. Also, you can send comments to the Office of

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID

Number EPA–HQ–OAR–2014–0827 and OMB Control Number 2060-0678 in any 

correspondence.
37

Table 16 Annual Respondent Burden and Cost for Heavy-Duty Pickup Trucks and Vans 

Total hours and cost

Information Collection Activity

Engineer 

hrs Manager hrs Legal hrs Test Cell Operator hrs Clerical hrs Respon. Hr / Application

Labor 

Cost/yr

Applications/ 

respondent

Number of 

Respondents

Total 

hr/yr

Total 

Cost/yr

Rate $/hr $ 82.24 $ 106.50 $ 138.20 $ 48.40 $ 31.39 

Review of regs and guidance document 2 1 0 1 0 4 $ 319 8.0 3 96 $ 7,665 

Test/Gather emission data on test 

vehicles (dyno) 12 4 0 8 0 24 $ 1,800 4.0 3 288 $ 21,601 

Test Cost (Coast Down) 10 2 0 2 0 14 $ 1,132 4.0 3 168 $ 13,586 

Analyze Data to Determine Compliance 16 4 2 2 0 24 $ 2,115 8.0 3 576 $ 50,761 

Prepare and submit "carryover" 

application 2 1 1 2 2 8 $ 569 4.0 3 96 $ 6,825 

Prepare & submit certification 

applications 8 12 3 4 10 37 $ 2,858 4.0 3 444 $ 34,296 

Prepare & Review GHG Compliance Plan 9 8 1 0 1 19 $ 1,762 8.0 3 456 $ 42,282 

End-of-year Production Report 20 10 8 0 8 46 $ 4,067 8.0 3 1,104 $ 97,596 

ABT, Emissions Credit Report 10 5 4 0 4 23 $ 2,033 8.0 3 552 $ 48,798 

Store, file and maintain records 0 0 0 0 2 2 $ 63 8.0 3 48 $ 1,507 

Total per respondent 89 47 19 19 27 201 $ 16,718 8 3 160 $ 108,306 

Total for the industry 2,136 1,128 456 456 648 4,824 $ 324,918 24 24 3,828 $ 324,918 

* In these years of program implementation, manufacturers will only be required to run coastdown and dyno tests on newly introduced vehicles 

Hours and cost per application
38

Table 17 Annual Respondent Burden and Cost for Heavy-Duty Engine Manufacturers 

Hours and cost per application Total hours and cost

Information Collection 

Activity

Enginee

r hrs

Manage

r hrs 

Legal 

hrs 

Test Cell 

Operator 

hrs

Clerical 

hrs 

Respon. 

Hr / 

Application

Labor 

Cost/yr

Capital 

Startup 

Cost

O & M 

Cost 

Applications/ 

respondent

Number of 

Respondents

Total 

hr/yr

Total 

Cost/yr

Rate $/hr $ 82.24 $106.50 $ 138.20 $ 48.40 $ 31.39 

Review of regs and 

guidance document 2 1 0 0 0 3 $ 271 0 0 9 12 324 29,266

Testing/Gathering 

emission data on test 

engines 1 0 0 2 0 3 $ 179 0 0 9 12 324 19,336

Analyze data to 

determine compliance 1 1 0 0 0 2 $ 189 0 0 9 12 216 20,384

Prepare and submit 

certification application 1 1 1 1 1 5 $ 407 0 0 9 12 540 43,927

Preparing and submitting 

"carry over" applications 1 1 0 0 0 2 $ 189 0 0 9 12 216 20,384

Prepare & Review GHG 

Compliance Plan 1 1 0 0 0 2 $ 189 0 0 9 12 216 20,384

Final Year Production 

Update 4 1 0 0 0 5 $ 435 0 0 9 12 540 47,030

Store, file and maintain 

records 0 0 0 0 2 2 $ 63 0 0 9 12 216 6,780

Total per respondent 11 6 1 3 3 24 $ 1,921 $ - $ - 9 12 24 $17,291

Total for the industry 1,188 648 108 324 324 2,592 $ 207,491 $ - $ - 108 108 2,592 $207,491
39

Table 18 Annual Respondent Burden and Costs for Vocational Vehicles

Total hours and cost

Information Collection Activity

Engineer 

hrs

Manager 

hrs Legal hrs Test Cell Operator hrs

Clerical 

hrs 

Respon. 

hr/Application

Labor 

Cost/yr

Capital 

Startup 

Cost

O & M 

Cost *

Applications/ 

respondent

Number of 

Respondents

Total 

hr/yr

Total 

Cost/yr

Rate $/hr $ 82.24 $ 106.50 $138.20 $ 48.40 $ 31.39 

Review of regs and guidance document 6 3 1 0 0 10 $ 951 0 0 2.7 22 600 57,068

Tire Testing - ISO28580 2 1 0 0 0 3 $ 271 0 300 2.7 5 180 20,350

Collect Data & Run GEM 15 3 0 0 0 18 $ 1,553 0 0 2.7 22 1,080 93,186

Analyze Data to Determine Compliance 10 4 1 0 0 15 $ 1,387 0 0 2.7 22 900 83,196

Preparing and submitting "carry over" 

applications 16 2 2 0 4 24 $ 1,931 0 0 2.7 22 1,440 115,848

Labeling Requirements 8 3 2 0 4 17 $ 1,379 0 0 2.7 22 1,020 82,763

End-of-year Production Report 30 4 1 0 8 43 $ 3,283 0 0 2.7 22 2,580 196,951

ABT, Emissions Credit Report 20 5 2 0 6 33 $ 2,642 0 0 2.7 22 1,980 158,522

Store, file, maintain records 10 4 0 0 4 18 $ 1,374 0 0 2.7 22 1,080 82,438

Total per respondent 117 29 9 0 26 181 $ 14,771 $ - $ 300 2.7 22 494 $40,469

Total for the industry 7,020 1,740 540 0 1,560 10,860 $ 886,231 $ - $ 1,500 60 60 10,860 $890,322

* The O&M cost reflects that each manufacturer will be able to carry-over tire test results and estimates that only 5 mfrs will test 1 new tire per certification at a cost of $300 per tire, for a total of 14 new tire tests each year for the indu

**Based on 22 manufacturers, each submitting an average 2.7 applications for certificates of conformity to cover production of their Class 3, 4, 5, 6, 7 and 8 vocational trucks

Hours and cost per application
40

Table 19 Annual Respondent Burden and Costs for Combination Tractors

Information Collection Activity

Engineer hrs Manager hrs Legal hrs Test Cell 

Operator hrs Clerical hrs Respon. hr/Application

Labor 

Cost/yr

Capital 

Startup 

Cost

O & M 

Cost *

Applications/ 

respondent

Number of 

Respondents

Total 

hr/yr

Total 

Cost/yr

Rate $/hr $ 82.24 $ 106.50 $138.20 $ 48.40 $ 31.39 

Review of regs and guidance 

document 6 4 2 0 0 12 $ 1,196 0 0 8 4 384 $ 38,267

Test tractors for Cd (coefficient 

of drag)

 - Coast Down Testing 0 0 0 0 0 0 $ - 0 15,000 0 4 0 $ -

 - Wind Tunnel Testing 8 2 0 0 0 10 $ 871 0 20,000 1 4 40 $ 83,484

 - Cfd (initial drawing) 8 4 0 0 0 12 $ 1,084 0 5,000 1 4 48 $ 24,336

 - Cfd (layers) 2 1 0 0 0 3 $ 271 0 500 9 4 108 $ 27,755

Tire Testing

 - ISO 28580 6 2 0 0 0 8 $ 706 0 300 5 4 160 $ 20,129

Collect Data & Run GEM 51 10 0 0 8 69 $ 5,510 0 0 8 4 2,208 $ 176,332

Labeling Requirements 10 4 3 0 80 97 $ 4,174 0 0 8 4 3,104 $ 133,574

Prepare & submit certification 

application, including carryover 

apps 40 20 10 0 70 $ 6,802 0 0 8 4 2,240 $ 217,651

End-of-year Production Report 80 5 2 0 10 97 $ 7,702 0 0 8 4 3,104 $ 246,464

ABT, Emissions Credit Report 60 15 4 0 6 85 $ 7,273 0 0 8 4 2,720 $ 232,737

Store, file, maintain records 20 10 2 0 40 72 $ 4,242 0 0 8 4 2,304 $ 135,738

Total per respondent 291 77 23 0 144 535 $ 39,831 $ - $ 40,800 8 4 4,105 $ 334,117

Total for the industry 9,312 2,464 736 0 4,608 17,120 $1,274,595 $ - $124,000 32 32 16,420 $1,336,466

* Operations & Maintenance Costs include contract costs for running coast down and wind tunnel tests. The O&M cost reflects that each manufacturer will be able to carry-over tire test results and 

estimates that each will test 1 new tire for 5 applications at a cost of $300 per tire, for a total of 20 new tire tests each year for the industry.

Hours and cost per application Total hours and cost
41

Table 20 Annual Respondent Burden and Costs for Large Business Trailer Manufacturers – 2017

Table 21: Annual Respondent Burden and Costs for Small Business Trailer Manufacturers - 2017

Total hours and cost

Information Collection Activity

Engineer 

hrs @ Rate

Manager 

hrs @ Rate

Legal 

hrs @ Rate

Test Cell Operator 

hrs @ Rate

Clerical 

hrs @ Rate

Respon. 

hr/Application

Labor

Cost/yr

Capital 

Startup Cost (1)

O & M

Cost (2)

Applications/

respondent

Number of 

Respon.

Total

hr/yr

Total

Cost/yr

Rate $/hr $ 82.24 $ 106.50 $ 138.20 $ 48.40 $ 31.39 

Review of regs and guidance document 20 6 40 0 0 66 $ 7,812 0 0 2.5 19 3,135 $ 371,061

Test trailers for Cd (coefficient of drag)

 - Coastdown Testing 12 3 0 0 0 15 $ 1,306 $ 30,000 0.0 0 0 $ -

 - Wind Tunnel Testing 8 2 0 0 0 10 $ 871 $ 40,000 2.0 6 120 $ 490,451

 - Cfd (initial drawing) 8 4 0 0 0 12 $ 1,084 $ 10,000 2.0 6 144 $ 133,007

 - Cfd (layers) 2 1 0 0 0 3 $ 271 $ 1,000 2.0 6 36 $ 15,252

Tire Testing

 - ISO 28580 6 2 0 0 0 8 $ 706 $ 300 0.0 0 0 $ -

Collect Data & Calculate Compliance Values 20 4 0 0 8 32 $ 2,322 $ - 0.0 0 0 $ -

Labeling Requirements 32 6 6 0 80 124 $ 6,611 $ 25,000 $ - 2.5 19 5,890 $ 789,026

Prepare & submit certification application, including carryover apps 16 2 10 0 0 28 $ 2,911 $ 25,000 $ - 2.5 19 1,330 $ 613,265

End-of-year Production Report 10 4 2 0 10 26 $ 1,839 $ - 0.0 0 0 $ -

ABT, Emissions Credit Report 5 4 4 0 6 19 $ 1,578 $ - 0.0 0 0 $ -

Store, file, maintain records 2 1 2 0 40 45 $ 1,803 $ - 0.0 0 0 $ -

Total per respondent 141 39 64 0 144 388 $ 44,740 $ 50,000 $ 32,211 2.5 1 561 $ 126,951

Total for the industry 2,679 741 1,216 0 2,736 7,372 $ 850,062 $ 950,000 $ 612,000 47.5 19 10,655 $ 2,412,062

(1) Capital start up costs include upgrades in information and management system to record and report test data to EPA.

(2) Operations & Maintenance Costs include contract costs for running 2 coastdown, wind tunnel, or CFD test (baseline and tested configuration) and 

 contract costs for 1 new tire test for each of the 5 largest manufacturers, at a cost of $300 per tire, for a total of 5 new tire tests each year for the industry.

Hours and cost per application Total hours and cost

Information Collection Activity

Engineer 

hrs @ Rate

Manager 

hrs @ Rate

Legal 

hrs @ Rate

Test Cell Operator 

hrs @ Rate

Clerical 

hrs @ Rate

Respon. 

hr/Application

Labor

Cost/yr

Capital 

Startup Cost (1)

O & M

Cost (2)

Applications/

respondent

Number of 

Respon.

Total

hr/yr

Total

Cost/yr

Rate $/hr $ 82.24 $ 106.50 $ 138.20 $ 48.40 $ 31.39 

Review of regs and guidance document 20 6 40 0 0 66 $ 7,812 0 0 1.1 95 6,897 $ 816,333

Test trailers for Cd (coefficient of drag)

 - Coastdown Testing 12 3 0 0 0 15 $ 1,306 $ 30,000 0.0 0 0 $ -

 - Wind Tunnel Testing 8 2 0 0 0 10 $ 871 $ 40,000 0.0 0 0 $ -

 - Cfd (initial drawing) 8 4 0 0 0 12 $ 1,084 $ 10,000 0.0 0 0 $ -

 - Cfd (layers) 2 1 0 0 0 3 $ 271 $ 1,000 0.0 0 0 $ -

Tire Testing

 - ISO 28580 6 2 0 0 0 8 $ 706 $ 300 0.0 0 0 $ -

Collect Data & Calculate Compliance Values 20 4 0 0 8 32 $ 2,322 $ - 0.0 0 0 $ -

Labeling Requirements 8 3 3 0 80 94 $ 3,903 $ - 0.0 0 0 $ -

Prepare & submit certification application, including carryover apps 16 2 10 0 0 28 $ 2,911 $ - 0.0 0 0 $ -

End-of-year Production Report 10 4 2 0 10 26 $ 1,839 $ - 0.0 0 0 $ -

ABT, Emissions Credit Report 5 4 4 0 6 19 $ 1,578 $ - 0.0 0 0 $ -

Store, file, maintain records 2 1 2 0 40 45 $ 1,803 $ - 0.0 0 0 $ -

Total per respondent 117 36 61 0 144 358 $ 8,593 $ - $ - 1.1 1 73 $ 8,593

Total for the industry 11,115 3,420 5,795 0 13,680 34,010 $ 816,333 $ - $ - 104.5 95 6,897 $ 816,333

(1) Capital start up costs include upgrades in information and management system to record and report test data to EPA.

(2) Operations & Maintenance Costs include contract costs for running 2 coastdown, wind tunnel, or CFD test (baseline and tested configuration) and 

 contract costs for 1 new tire test for each of the 5 largest manufacturers, at a cost of $300 per tire, for a total of 5 new tire tests each year for the industry.

Hours and cost per application
42

Table 22 Annual Respondent Burden and Costs for Large Business Trailer Manufacturers – 2018 & 2019

Total hours and cost

Information Collection Activity

Engineer 

hrs @ Rate

Manager 

hrs @ Rate

Legal 

hrs @ Rate

Test Cell Operator 

hrs @ Rate

Clerical 

hrs @ Rate

Respon. 

hr/Application

Labor

Cost/yr

Capital 

Startup Cost (1)

O & M

Cost (2)

Applications/

respondent

Number of 

Respon.

Total

hr/yr

Total

Cost/yr

Rate $/hr $ 82.24 $ 106.50 $ 138.20 $ 48.40 $ 31.39 

Review of regs and guidance document 20 6 10 0 0 36 $ 3,666 0 0 2.5 19 1,710 $ 174,126

Test trailers for Cd (coefficient of drag)

 - Coastdown Testing 12 3 0 0 0 15 $ 1,306 $ 30,000 4.0 3 180 $ 375,677

 - Wind Tunnel Testing 8 2 0 0 0 10 $ 871 $ 40,000 4.0 6 240 $ 980,902

 - Cfd (initial drawing) 8 4 0 0 0 12 $ 1,084 $ 10,000 4.0 6 288 $ 266,014

 - Cfd (layers) 2 1 0 0 0 3 $ 271 $ 1,000 4.0 6 72 $ 30,504

Tire Testing

 - ISO 28580 6 2 0 0 0 8 $ 706 $ 300 1.0 5 40 $ 5,032

Collect Data & Calculate Compliance Values 20 4 0 0 8 32 $ 2,322 $ - 4.0 9 1,152 $ 83,589

Labeling Requirements 8 3 3 0 80 94 $ 3,903 $ - 2.5 19 4,465 $ 185,403

Prepare & submit certification application, including carryover apps 16 2 10 0 0 28 $ 2,911 $ - 2.5 19 1,330 $ 138,265

End-of-year Production Report 10 4 2 0 10 26 $ 1,839 $ - 2.5 19 1,235 $ 87,338

ABT, Emissions Credit Report 5 4 4 0 6 19 $ 1,578 $ - 2.0 5 190 $ 15,783

Store, file, maintain records 2 1 2 0 40 45 $ 1,803 $ - 2.5 19 2,138 $ 85,642

Total per respondent 117 36 31 0 144 328 $ 44,357 $ - $ 83,447 2.5 1 686 $ 127,804

Total for the industry 2,223 684 589 0 2,736 6,232 $ 842,774 $ - $ 1,585,500 47.5 19 13,040 $ 2,428,274

(1) Capital start up costs include upgrades in information and management system to record and report test data to EPA.

(2) Operations & Maintenance Costs include contract costs for running 2 coastdown, wind tunnel, or CFD test (baseline and tested configuration) and 

 contract costs for 1 new tire test for each of the 5 largest manufacturers, at a cost of $300 per tire, for a total of 5 new tire tests each year for the industry.

Hours and cost per application
43

Table 23 Annual Respondent Burden and Costs for Small Business Trailer Manufacturers – 2018

Table 24: Annual Respondent Burden and Costs for Small Business Trailer Manufacturers - 2019

Total hours and cost

Information Collection Activity

Engineer 

hrs @ Rate

Manager 

hrs @ Rate

Legal 

hrs @ Rate

Test Cell Operator 

hrs @ Rate

Clerical 

hrs @ Rate

Respon. 

hr/Application

Labor

Cost/yr

Capital 

Startup Cost (1)

O & M

Cost (2)

Applications/

respondent

Number of 

Respon.

Total

hr/yr

Total

Cost/yr

Rate $/hr $ 82.24 $ 106.50 $ 138.20 $ 48.40 $ 31.39 

Review of regs and guidance document 20 6 10 0 0 36 $ 3,666 0 0 1.1 95 3,762 $ 383,076

Test trailers for Cd (coefficient of drag)

 - Coastdown Testing 12 3 0 0 0 15 $ 1,306 $ 30,000 0.0 0 0 $ -

 - Wind Tunnel Testing 8 2 0 0 0 10 $ 871 $ 40,000 0.0 0 0 $ -

 - Cfd (initial drawing) 8 4 0 0 0 12 $ 1,084 $ 10,000 0.0 0 0 $ -

 - Cfd (layers) 2 1 0 0 0 3 $ 271 $ 1,000 0.0 0 0 $ -

Tire Testing

 - ISO 28580 6 2 0 0 0 8 $ 706 $ 300 0.0 0 0 $ -

Collect Data & Calculate Compliance Values 20 4 0 0 8 32 $ 2,322 $ - 0.0 0 0 $ -

Labeling Requirements 32 6 6 0 80 124 $ 6,611 $ 25,000 $ - 1.0 95 11,780 $ 3,003,053

Prepare & submit certification application, including carryover apps 16 2 10 0 0 28 $ 2,911 $ 25,000 $ - 1.0 95 2,660 $ 2,651,530

End-of-year Production Report 10 4 2 0 10 26 $ 1,839 $ - 0.0 0 0 $ -

ABT, Emissions Credit Report 5 4 4 0 6 19 $ 1,578 $ - 0.0 0 0 $ -

Store, file, maintain records 2 1 2 0 40 45 $ 1,803 $ - 0.0 0 0 $ -

Total per respondent 141 39 34 0 144 358 $ 13,554 $ 50,000 $ - 1.1 1 192 $ 63,554

Total for the industry 13,395 3,705 3,230 0 13,680 34,010 $1,287,659 $ 4,750,000 $ - 104.5 95 18,202 $ 6,037,659

(1) Capital start up costs include upgrades in information and management system to record and report test data to EPA.

(2) Operations & Maintenance Costs include contract costs for running 2 coastdown, wind tunnel, or CFD test (baseline and tested configuration) and 

 contract costs for 1 new tire test for each of the 5 largest manufacturers, at a cost of $300 per tire, for a total of 5 new tire tests each year for the industry.

Hours and cost per application Total hours and cost

Information Collection Activity

Engineer 

hrs @ Rate

Manager 

hrs @ Rate

Legal 

hrs @ Rate

Test Cell Operator 

hrs @ Rate

Clerical 

hrs @ Rate

Respon. 

hr/Application

Labor

Cost/yr

Capital 

Startup Cost (1)

O & M

Cost (2)

Applications/

respondent

Number of 

Respon.

Total

hr/yr

Total

Cost/yr

Rate $/hr $ 82.24 $ 106.50 $ 138.20 $ 48.40 $ 31.39 

Review of regs and guidance document 20 6 10 0 0 36 $ 3,666 0 0 1.1 95 3,762 $ 383,076

Test trailers for Cd (coefficient of drag)

 - Coastdown Testing 12 3 0 0 0 15 $ 1,306 $ 30,000 0.0 0 0 $ -

 - Wind Tunnel Testing 8 2 0 0 0 10 $ 871 $ 40,000 0.0 0 0 $ -

 - Cfd (initial drawing) 8 4 0 0 0 12 $ 1,084 $ 10,000 0.0 0 0 $ -

 - Cfd (layers) 2 1 0 0 0 3 $ 271 $ 1,000 0.0 0 0 $ -

Tire Testing

 - ISO 28580 6 2 0 0 0 8 $ 706 $ 300 0.0 0 0 $ -

Collect Data & Calculate Compliance Values 20 4 0 0 8 32 $ 2,322 $ - 2.0 5 320 $ 23,219

Labeling Requirements 8 3 3 0 80 94 $ 3,903 $ - 1.1 95 9,823 $ 407,886

Prepare & submit certification application, including carryover apps 16 2 10 0 0 28 $ 2,911 $ - 1.1 95 2,926 $ 304,183

End-of-year Production Report 10 4 2 0 10 26 $ 1,839 $ - 1.1 95 2,717 $ 192,144

ABT, Emissions Credit Report 5 4 4 0 6 19 $ 1,578 $ - 0.0 0 0 $ -

Store, file, maintain records 2 1 2 0 40 45 $ 1,803 $ - 1.1 95 4,703 $ 188,411

Total per respondent 117 36 31 0 144 328 $ 15,778 $ - $ - 1.1 1 255 $ 15,778

Total for the industry 11,115 3,420 2,945 0 13,680 31,160 $1,498,920 $ - $ - 104.5 95 24,251 $ 1,498,920

(1) Capital start up costs include upgrades in information and management system to record and report test data to EPA.

(2) Operations & Maintenance Costs include contract costs for running 2 coastdown, wind tunnel, or CFD test (baseline and tested configuration) and 

 contract costs for 1 new tire test for each of the 5 largest manufacturers, at a cost of $300 per tire, for a total of 5 new tire tests each year for the industry.

Hours and cost per application