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SUPPORTING STATEMENT FOR THE RENEWAL OF

EPA INFORMATION COLLECTION REQUEST NUMBER 1613.03

DATA REPORTING REQUIREMENTS FOR STATE AND LOCAL VEHICLE 

EMISSION INSPECTION AND MAINTENANCE (I/M) PROGRAMS

February 29, 2012
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TABLE OF CONTENTS

1. IDENTIFICATION OF THE INFORMATION COLLECTION ............................ 3

1(a) Title and Number of the Information Collection .............................................. 3

1(b) Characterization of the Information Collection ................................................ 3

2. NEED FOR AND USE OF THE COLLECTION ................................................... 3

2(a) Need and Authority for the Collection ............................................................. 3

2(b) Use and Users of the Data ................................................................................ 4

3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION

CRITERIA ............................................................................................................... 5

3(a) Non-Duplication ............................................................................................... 5

3(b) Public Notice Required Prior to ICR Submission to OMB............................... 5

3(c) Consultations .................................................................................................... 6

3(d) Effects of Less Frequent Collection ................................................................. 7

3(e) General Guidelines ........................................................................................... 7

3(f) Confidentiality .................................................................................................. 7

3(g) Sensitive Questions ........................................................................................... 7

4. THE RESPONDENTS AND THE INFORMATION COLLECTED ..................... 7

4(a) State and Local Respondents............................................................................. 7

4(b) Information Requested ..................................................................................... 8

5. THE INFORMATION COLLECTED -- AGENCY ACTIONS, COLLECTION

METHODOLOGY, AND INFORMATION MANAGEMENT ............................. 15

5(a) Federal Agency Activities ................................................................................ 15

5(b) Collection Methodology and Management ...................................................... 16

5(c) Small Entity Flexibility .................................................................................... 16

5(d) Collection Schedule ......................................................................................... 17

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION ..................17

6(a) Estimating Respondent Burden ........................................................................ 17

6(b) Estimating Respondent Costs ........................................................................... 18

6(c) Estimated Agency Burden and Cost ................................................................. 20

6(d) Bottom Line Burden Hours and Costs ............................................................. 22

6(e) Reasons for Change in Burden ......................................................................... 22

6(f) Burden Statement .............................................................................................. 23

APPENDIX A ...................................................................................................................... 24
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1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection

This information collection request (ICR) renewal is entitled “Data Reporting 

Requirements for State and Local Vehicle Emission Inspection and Maintenance (I/M) Programs”

[EPA ICR Number 1613.03; Office of Management and Budget (OMB) Control Number 2060-

0252].

1(b) Characterization of the Information Collection

To provide general oversight and support to state and local I/M programs, the U. S. 

Environmental Protection Agency (EPA) requires that state or local program management for 

both basic and enhanced I/M programs compile and submit two different reports to their Regional 

EPA office. The first reporting requirement is the submittal of an annual report providing general 

program operating data and summary statistics, addressing the program’s current design and 

coverage, a summary of testing data, enforcement program efforts, quality assurance and quality 

control efforts, as well as other miscellaneous information allowing for an assessment of the 

program’s relative effectiveness; the second is a biennial report addressing any changes to the 

program over the two-year period prior to the biennial report’s submission, including the impact 

of such changes, any weaknesses discovered during the reporting period, and the corrections made 

or planned. 

General program effectiveness is determined by the degree to which the operating 

program compares to the program described in the state’s approved State Implementation Plan 

(SIP), which, in turn, must meet or exceed the minimum requirements for mandatory I/M 

programs, as promulgated under 40 CFR, Part 5, Subpart S in response to requirements 

established in section 182 of the Clean Air Act Amendments of 1990 (Act). The information 

provided by the annual and biennial I/M reports described above are used by the EPA Regional 

office to determine whether a given I/M program is meeting its obligations under the approved 

SIP. The information may also be used by EPA Headquarters to assess national trends in the 

implementation of both basic and enhanced I/M programs, as well as to help determine when 

anomalous reporting results are due to national versus local causes.

2. Need for and Use of the Collection

2(a) Need and Authority for the Collection
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The collection of a variety of program operating and summary data is essential to the 

assessment of an I/M program’s overall effectiveness and the degree to which it complies with 

requirements established in response to sections 182(a)(2)(b)(ii); 182(b)(4); and 182(c)(3) of the 

Act, under which EPA is authorized to impose these collection and recordkeeping requirements. 

The specific program data to be collected are listed under the “Data analysis and reporting” 

section of EPA’s I/M rule (40 CFR Part 51, subpart S, section 51.366). A list of the required 

reporting elements is included in section 4(b) of this Information Collection Request (ICR)

renewal.

2(b) Use and Users of the Data

There are, in effect, three users of the information required by this collection – the 

primary user, represented by the state or local agency or department in charge of managing the 

I/M program itself (hereafter referred to as “the state” and/or “the respondent”), the secondary

user, represented by the EPA Regional office (henceforth referred to as “the Region”) to help 

determine the degree to which the program complies with its approved SIP, and finally, EPA 

Headquarters, to help identify national trends in the implementation of both basic and enhanced 

I/M programs, as well as to help determine when anomalous results being observed by a State or 

Region are due to national versus local causes.

The State

For the purpose of effectively managing its I/M program, the state must gather a wide 

range of program data, including data from the testing program, quality control and assurance 

efforts, and the enforcement program. For example, sufficient test data must be gathered to 

unambiguously link specific test results to a specific vehicle, I/M program registrant, test site, and 

inspector, to help determine whether or not the correct test parameters were observed for the 

specific vehicle in question. This programmatic need – which is distinct from any need and/or 

burden imposed by this ICR – is reflected in the fact that current testing equipment specifications

include extensive data capture requirements to serve just this purpose. In turn, the state can 

analyze this data and compare it to the registration database (in programs enforced through 

registration denial, per the Act) or otherwise use it to establish a vehicle’s compliance with 

program requirements. Owners of vehicles found to be out-of-compliance are not allowed to 

register said vehicle(s) (again, in programs enforced through registration denial) or must be 

otherwise prevented from operating the non-complying vehicle(s) in the program area. Penalties 

may also be assessed for non-compliance with program requirements. 

Data collected as part of the testing program can also be used to target audits of inspection 

stations and inspectors, with irregularities such as unusually high pass or fail rates, mismatched 

vehicle information, etc. acting as flags to possible problems. In addition, the state must gather 

and analyze quality control data to ensure that motorists are given accurate and consistent 

measurements. In the interest of effectively managing its enforcement and quality assurance 

efforts, the program must keep records of such efforts, including the number of investigations 
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conducted (including internal control reviews to detect weaknesses within the program itself, as 

well as investigations of testing sites and inspectors), the methodology used, and the results of 

investigations and other enforcement and quality assurance activities.

EPA Regional Office 

To comply with this information collection, the state must summarize and report the above 

data to the EPA Regional Office with jurisdiction over the state in question. The state will have 

maximum flexibility to use pre-existing, internal reporting mechanisms to meet these summary

data reporting requirements, and may submit the required reports in whatever format is most 

convenient for the state, including electronically, via hardcopy, or by directing the EPA Regional 

Office to web resources which include the required information. The Regional Office will use 

this information to assess specific state programs and their success in complying with I/M 

requirements. This assessment will lead to follow-up conversations with the state to discuss 

possible program improvements or corrective action necessary to address anomalies, and in some 

instances may lead to site visits and audits of the programs in question. 

EPA Headquarters

When anomalies are discovered in the reported summary information and cannot be 

resolved by the state and Region, EPA Headquarters may be called in to help determine whether a 

given anomaly is the result of local conditions or is perhaps indicative of a larger, national trend. 

In such situations, EPA Headquarters will work with the state and the Region to identify and 

address the causes of the anomaly. Information regarding the resolution of such cases – to the 

extent it may be relevant outside the program in question – will be made available to other states, 

Regions, and the public in general through various communication methods, including biweekly 

conference calls with the EPA Regions, a bimonthly stakeholder call with the I/M states, and the 

I/M Clearinghouse web site, currently managed by Weber State University under a grant from 

EPA.

3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

3(a) Non-Duplication

EPA has made an effort to ensure that the data collection efforts associated with renewal 

of this ICR are not duplicated. EPA has consulted with State and Local environmental programs, 

other Federal agencies (such as EPA’s Regional Offices). To the best of EPA’s knowledge, data 

currently required by this information collection are not available from any other source.

3(b) Public Notice Required Prior to ICR Submission to OMB
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To comply with the 1995 Amendments to the Paperwork Reduction Act (PRA), EPA has 

solicited public comment on the renewal of this ICR for a 60-day period before the renewal 

request was submitted to OMB. Specifically, EPA has published a notice in the Federal Register 

requesting comment on the continued use of the estimated respondent burden and other aspects of 

this ICR renewal (XX FR XXXX, see Appendix A). An additional Federal Register notice will 

be published prior to submission of this request for ICR renewal to OMB. The public comment 

period for this additional notice will be 30 days.

3(c) Consultations

In an effort to address state concerns regarding a wide-range of environmental reporting 

requirements, EPA and the Environmental Council of the States (ECOS) launched the Burden 

Reduction Initiative (BRI) in October 2006. As part of this initiative, EPA invited states to 

identify their top five reporting requirements with potential for streamlining or elimination. A 

total of 39 states responded to this invitation, identifying more than 200 reporting requirements as 

candidates for possible burden reduction or elimination. 

Although 33 states plus the District of Columbia currently run I/M programs subject to the 

reporting requirements covered by the information collection currently up for renewal, only 5 of 

the 39 states responding to the reporting burden reduction initiative – Illinois, Massachusetts, 

Maryland, New Hampshire, and Virginia – identified some aspect of the I/M reporting 

requirements as potential candidates for burden reduction. It should be noted, however, that there 

was no consensus among the 5 states regarding what sort of relief was needed. EPA has met with 

ECOS representatives concerning the 5 states commenting on I/M reporting requirements as well 

as the need for additional program evaluation guidance. Clarification with regard to the existing 

reporting requirements satisfied the workgroup.

For this most recent renewal of the ICR for I/M reporting requirements, EPA has 

published the first 60 day notice soliciting comments on its proposed renewal of the I/M ICR on 

February XX, 2012 (XX FR XXXX, see Appendix A). The public comment period closed on 

May XX, 2012. EPA did not receive comments on any portion of its proposal from the states 

which originally identified I/M reporting requirements as warranting relief under the BRI, nor

from any other source. 

3(d) Effects of Less Frequent Collection

The I/M Rule requires annual and biennial reporting by the I/M programs to ensure that 

states are achieving the emission reductions claimed by such programs in their approved SIPs. 

EPA has considered a range of alternatives for data reporting requirement frequency. It is EPA’s

judgment that collecting the required information less frequently would limit its ability to 

determine a program’s progress toward meeting requirements under 40 CFR, Part 51 and would 

delay its ability to identify and resolve programmatic deficiencies that may negatively impact a 
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program’s ability to achieve the needed emission reductions, thus magnifying any potential 

shortfall. It may be argued that more frequent reporting would therefore shrink the potential for 

negative impacts by identifying deficiencies sooner, relative to the current reporting frequency. In 

setting the current reporting frequency, EPA has attempted to strike a reasonable balance and 

believes that more frequent reporting would be unduly burdensome. To supplement the current 

reporting cycle and thus ensure that major program deficiencies do not go undetected for an 

unreasonable period of time, EPA holds bimonthly conference calls with I/M states as a forum for 

raising, discussing, and resolving implementation issues as they arise. State participation in these 

calls is, of course, voluntary.

3(e) General Guidelines

This ICR was prepared in accordance with the October 2009 version of EPA’s Guide to

Writing Information Collection Requests Under the Paperwork Reduction Act (PRA) of 1995 (or

“ICR Handbook”) prepared by EPA’s Office of Environmental Information, Office of 

Information Collection, Collection Strategies Division. The ICR Handbook provides the most 

current instructions for ICR preparation to ensure compliance with the 1995 PRA amendments 

and OMB’s implementing guidelines.

3(f) Confidentiality

No confidential information will be collected as a result of this ICR.

3(g) Sensitive Questions

No information of a sensitive nature will be collected as a result of this ICR.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) State and Local Respondents 

The respondents to this information collection are the state government agencies or 

departments responsible for oversight and operation of the I/M programs (SIC# 91). As of 

January 2012, thirty-three states plus the District of Columbia are affected by I/M program 

requirements. This category of respondent was selected because it represents the entities most 

comprehensively involved in gathering the information which must be summarized for this 

collection (i.e., those parties responsible for establishing, maintaining, and analyzing the 

program’s central database, or overseeing contractor personnel responsible for such activities). 

Although I/M programs can and do vary by type (i.e., basic I/M programs versus enhanced I/M 

programs), the data elements to be addressed by this information collection remain consistent 

across program types, and hence the burden does not vary by program type. 
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4(b) Information Requested

Under current I/M program practice, various internal analyses and reports are routinely

generated using the data collected on vehicle tests, as well as quality control, quality assurance, 

and enforcement efforts. The information requested in this ICR renewal is, in fact, based upon the 

data items currently collected in and the reports currently generated by many of the better run I/M 

programs. These reports are used primarily as management tools for internal monitoring and 

evaluation of the program. Summaries of the information provided in these reports are also 

currently being used by EPA (primarily the Agency’s Regional Offices and, secondarily, EPA 

Headquarters) to fulfill the Agency’s statutory obligation to provide oversight to mandatory I/M 

programs and to ensure that such programs are achieving the emission reductions claimed in their 

approved SIPs. The purpose of this current request is to renew a previously approved information 

collection (OMB Control Number 2060-0252; EPA ICR Number 1613.03) so that EPA can 

continue to meet is statutory obligation with regard to providing I/M program implementation 

guidance and oversight.

(i) Data items

A. Recordkeeping Requirements

In fulfilling the requirements of this information collection, respondents gather and 

maintain records on the following data items per vehicle inspected as part of the I/M program. As 

stated previously, similar information is currently collected by existing I/M programs and is 

written into the data recording requirements of their testing equipment specifications. As stated in 

the introduction to this section, these records represent information which a program needs to 

gather and maintain as part of the day-to-day administration and enforcement of the program, and, 

as such, do not constitute an additional burden triggered by this information collection or its 

renewal.

1) Test record number

2) Inspection station and inspector number

3) Test system number

4) Date of the test

5) Emission test start time and the time final emission scores are determined

6) Vehicle Identification Number (VIN)

7) License plate number

8) Test certificate number

9) Gross Vehicle Weight Rating (GVWR)

10) Vehicle model year, make, and type

11) Number of cylinders or displacement

12) Transmission type
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13) Odometer reading

14) Type of test performed (i.e., initial test, first retest, or subsequent retest)

15) Fuel type of the vehicle (i.e., gas, diesel, or other fuel)

16) Type of vehicle preconditioning performed (if any)

17) Emission test sequence(s) used

18) Hydrocarbon emission scores and standards for each applicable test mode

19) Carbon monoxide emission scores and standards for each applicable test mode

20) Carbon dioxide emission scores (CO+CO2) and standards for each applicable 

test mode

21) Nitrogen oxides emission scores and standards for each applicable test mode

22) Results (Pass/Fail/Not Applicable) of the applicable visual inspections for the 

catalytic converter, air system, gas cap, evaporative system, positive crankcase 

ventilation (PCV) valve, and fuel inlet restrictor

23) Results of the evaporative pressure test expressed as a pass or fail (where 

applicable)

24) Results of the evaporative system purge test expressed as a pass or fail along 

with the total purge flow in liters achieved during the test (where applicable)

25) Results of the on-board diagnostic check expressed as pass or fail along with 

the diagnostic trouble codes revealed (where applicable).

In addition, I/M programs must gather and maintain records on the results of all applicable 

quality control checks conducted in response to 40 CFR 51, subpart S, section 359, identifying 

each check by station number, system number, date, and start time. The record shall also contain 

the concentration values of the calibration gases used to perform the gas characterization portion 

of the quality control checks (if applicable). Raw test data (both vehicle inspections and quality

control checks, if applicable) shall be saved for a minimum of two complete inspection cycles 

(i.e., two years in annual programs, and four years in biennial programs), and submitted to EPA 

electronically upon request. Current practice is for states to save data for five to nine years, 

typically.

B. Reporting Requirements

(1) Annual Report

Internal data analysis and reporting are currently employed in better-run I/M programs as 

management tools to facilitate the monitoring and evaluation of the program by program 

management. Under the ICR EPA proposes to renew, state I/M programs submit summaries of 

this information to the EPA Regional Office with jurisdiction over the I/M program in question. 

To be considered complete, these reports must include information regarding the types of program 

activities performed and their final outcomes, including summary statistics and effectiveness 

evaluations of the enforcement mechanism, the quality assurance system, the quality control 
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program, and the testing element. Under the existing ICR, respondents are required to provide 

their respective EPA Regional Offices with the following data annually. Again, as previously 

stated, these reporting requirements were originally based upon the reporting practices of betterrun I/M programs at the time the original information collection was developed, and, as such, do 

not constitute an additional respondent burden. 

It should be noted that as state programs gradually phase-out tailpipe testing and begin to 

move toward the exclusive use of onboard diagnostic1(OBD) based testing, an added benefit of 

doing such will be a significant reduction in the number of reporting elements that need to be 

gathered, summarized, and reported. For example, all the by-pollutant reporting requirements 

will no longer apply, and neither will any of the reporting elements that presume dual testing of 

OBD-equipped vehicles. Additionally, because OBD-based testing equipment does not need to 

be calibrated like tailpipe based systems, the need to perform and record calibration results as part 

of the overt equipment auditing process is likewise eliminated. Although EPA notes this 

eventuality, the Agency has not attempted to quantify the impact on respondent burden because 

individual respondent programs will vary greatly with regard to when such a change to OBD-only 

testing may be possible and/or desirable. Because most programs will eventually reach the stage 

described above (varying only with regard to when) EPA is confident that the respondent burden 

estimates in this proposed information collection renewal reflect a worst-case scenario and can 

therefore be characterized as conservative. 

Test Data Summary

I/M programs are required to submit to their EPA Regional Office by July of each year a 

report providing basic statistics on the testing program for January through December of the 

previous year, including:

(1) The number of vehicles tested by model year and vehicle type;

(2) By model year and vehicle type, the number and percentage of vehicles:

(i) Failing initially, per test type;

(ii) Failing the first retest per test type;

(iii) Passing the first retest per test type;

(iv) Initially failed vehicles passing the second or subsequent retest per test type;

(v) Initially failed vehicles receiving a waiver; and

(vi) Vehicles with no known final outcome (regardless of reason).

 

1 All light-duty vehicles and light-duty trucks, model year 1996 and newer are required to have OBD computers that 

alert the driver when the vehicle’s emission controls are in need of service or replacement. EPA has found that 

testing vehicles by downloading fault codes from the OBD system is at least as effective as traditional tailpipe testing 

and EPA has amended the I/M rule to allow for OBD-only testing on MY 1996 and newer vehicles, as opposed to the 

previous requirement which stipulated that such vehicles were to receive both an OBD inspection as well as a tailpipe 

test. As given I/M program areas have seen their in-use fleets come to be dominated by MY 1996 and newer 

vehicles, EPA has encouraged them to consider switching to an OBD-only I/M program design. 
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(vii)–(x) [Reserved]

(xi) Passing the on-board diagnostic check;

(xii) Failing the on-board diagnostic check;

(xiii) Failing the on-board diagnostic check and passing the tailpipe test (if 

applicable);

(xiv) Failing the on-board diagnostic check and failing the tailpipe test (if 

applicable);

(xv) Passing the on-board diagnostic check and failing the I/M gas cap evaporative 

system test (if applicable);

(xvi) Failing the on-board diagnostic check and passing the I/M gas cap 

evaporative system test (if applicable);

(xvii) Passing both the on-board diagnostic check and I/M gas cap evaporative 

system test (if applicable);

(xviii) Failing both the on-board diagnostic check and I/M gas cap evaporative 

system test (if applicable);

(xix) MIL is commanded on and no codes are stored;

(xx) MIL is not commanded on and codes are stored;

(xxi) MIL is commanded on and codes are stored;

(xxii) MIL is not commanded on and codes are not stored;

(xxiii) Readiness status indicates that the evaluation is not complete for any 

module supported by on-board diagnostic systems;

(3) The initial test volume by model year and test station;

(4) The initial test failure rate by model year and test station; and

(5) The average increase or decrease in tailpipe emission levels for HC, CO, and NOX (if 

applicable) after repairs by model year and vehicle type for vehicles receiving a mass 

emissions test.

Quality Assurance Summary

I/M programs are required to submit to their EPA Regional Office by July of each year a 

report providing basic statistics on the quality assurance program for January through December 

of the previous year, including:

(1) The number of inspection stations and lanes:

(i) Operating throughout the year; and

(ii) Operating for only part of the year;

(2) The number of inspection stations and lanes operating throughout the year:

(i) Receiving overt performance audits in the year;

(ii) Not receiving overt performance audits in the year;

(iii) Receiving covert performance audits in the year;

(iv) Not receiving covert performance audits in the year; and

(v) That have been shut down as a result of overt performance audits;
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(3) The number of covert audits:

(i) Conducted with the vehicle set to fail per test type;

(ii) Conducted with the vehicle set to fail any combination of two or more test 

types;

(iii) Resulting in a false pass per test type;

(iv) Resulting in a false pass for any combination of two or more test types;

(v)–(viii) [Reserved]

(4) The number of inspectors and stations:

(i) That were suspended, fired, or otherwise prohibited from testing as a result of 

covert audits;

(ii) That were suspended, fired, or otherwise prohibited from testing for other 

causes; and

(iii) That received fines;

(5) The number of inspectors licensed or certified to conduct testing;

(6) The number of hearings:

(i) Held to consider adverse actions against inspectors and stations; and

(ii) Resulting in adverse actions against inspectors and stations;

(7) The total amount collected in fines from inspectors and stations by type of violation;

(8) The total number of covert vehicles available for undercover audits over the year; and

(9) The number of covert auditors available for undercover audits.

Quality Control Summary

I/M programs are required to submit to their EPA Regional Office by July of each year a 

report providing basic statistics on the quality assurance program for January through December 

of the previous year, including:

(1) The number of emission testing sites and lanes in use in the program;

(2) The number of equipment audits by station and lane;

(3) The number and percentage of stations that have failed equipment audits; and

(4) Number and percentage of stations and lanes shut down as a result of equipment 

audits.

Enforcement Summary

(1) All varieties of enforcement programs shall, at a minimum, submit to their EPA 

Regional Office by July of each year a report providing basic statistics on the enforcement 

program for January through December of the previous year, including:

(i) An estimate of the number of vehicles subject to the inspection program, 

including the results of an analysis of the registration data base;

(ii) The percentage of motorist compliance based upon a comparison of the number

of valid final tests with the number of subject vehicles;
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(iii) The total number of compliance documents issued to inspection stations;

(iv) The number of missing compliance documents;

(v) The number of time extensions and other exemptions granted to motorists; and

(vi) The number of compliance surveys conducted, number of vehicles surveyed in 

each, and the compliance rates found.

(2) Registration denial based enforcement programs shall provide the following additional 

information:

(i) A report of the program’s efforts and actions to prevent motorists from falsely

registering vehicles out of the program area or falsely changing fuel type or 

weight class on the vehicle registration, and the results of special studies to 

investigate the frequency of such activity; and

(ii) The number of registration file audits, number of registrations reviewed, and 

compliance rates found in such audits.

(3) Computer-matching based enforcement programs shall provide the following 

additional information:

(i) The number and percentage of subject vehicles that were tested by the initial 

deadline, and by other milestones in the cycle;

(ii) A report on the program’s efforts to detect and enforce against motorists falsely

changing vehicle classifications to circumvent program requirements, and the 

frequency of this type of activity; and

(iii) The number of enforcement system audits, and the error rate found during 

those audits.

(4) Sticker-based enforcement systems shall provide the following additional information:

(i) A report on the program’s efforts to prevent, detect, and enforce against sticker 

theft and counterfeiting, and the frequency of this type of activity;

(ii) A report on the program’s efforts to detect and enforce against motorists falsely

changing vehicle classifications to circumvent program requirements, and the 

frequency of this type of activity; and

(iii) The number of parking lot sticker audits conducted, the number of vehicles 

surveyed in each, and the noncompliance rate found during those audits.

(2) Biennial Report

In addition to the annual reports identified above, programs shall submit to their EPA 

Regional Office by July of every other year, biennial reports addressing:

(1) Any changes made in program design, funding, personnel levels, procedures, 

regulations, and legal authority, with detailed discussion and evaluation of the impact on 

the program of all such changes; and

(2) Any weaknesses or problems identified in the program within the two-year reporting 

period, what steps have already been taken to correct those problems, the results of those 

steps, and any future efforts planned.
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(ii) Respondent Activities

When responding programs were originally preparing to submit the first round of the 

above-listed summary data for this approved information collection, the respondents had to pursue 

the activities identified below. Several of these activities were essentially one-time efforts (such 

as pursuing legal authority and constructing testing sites) required to comply with the Act’s 

mandate that such programs be implemented in the first place, while others are activities that are 

currently conducted in better-run I/M programs for the sake of program implementation, 

management, and enforcement, and would therefore be pursued regardless of this information 

collection. Such activities have been identified here as common business practice (CBP), even 

though, properly speaking, the respondent entities are representatives of state government 

agencies or departments. Respondent activities have been separated for the annual and biennial 

reports, and separate burden estimates are provided for each in section 6 of this submittal.

Annual Report

 Read the I/M regulation (CBP)

 Review the regulatory provisions addressing the annual reporting requirement and assess

respondent responsibility

 Prepare a State Implementation Plan (SIP) and submit to EPA (CBP)

 Secure necessary legal authority to establish program (CBP)

 Develop regulatory basis for program (CBP)

 Receive appropriate training relative to program operation (CBP)

 Begin program implementation (i.e., establish testing sites, begin testing, etc.) (CBP)

 Gather test and quality control information and review for accuracy (CBP)

 Analyze the test and quality control data (CBP)

 Based upon analysis of data, begin enforcement efforts against motorists, stations, and 

inspectors (CBP)

 Complete written or electronic “paperwork” associated with enforcement and program 

oversight efforts (CBP)

 Store, file, and maintain all relevant program records and information (CBP)

 Assemble existing reports in preparation for summarization

 Prepare annual summaries of program operating statistics for the enforcement mechanism, 

the quality assurance system, the quality control program, and the testing element based 

upon existing, internal reports

 Review summary information for accuracy

 Prepare and submit annual report to EPA (or otherwise provide EPA access to the required 

information)

Biennial Report

In addition to the above activities associated with the submittal of the annual information 
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collection, I/M programs must also submit a biennial report that addresses program changes since 

the last reporting period, including any program weaknesses identified and improvements made. 

Again, many of these activities, given their importance in the areas of effective program 

management and helping to ensure that program resources are not wasted or abused, will need to 

be pursued internally regardless of this external reporting requirement. As such, many of these 

activities are designated as CBP. 

 Track and record all changes made in program design, funding, personnel levels, 

procedures, regulations, and legal authority 

 Conduct an evaluation of the impact on the program of all such changes (CBP)

 Conduct periodic internal investigations to discover and correct weaknesses (CBP)

 Track and record all such weaknesses or problems identified in the program within the 

two-year reporting period, and the steps taken to correct those problems

 Evaluate the results of those steps (CBP)

 Assemble and report the above required information, including any future efforts planned

5. THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Federal Agency Activities

In executing the original information collection, EPA had to (and, in some instances, still 

needs to) do the following:

 Develop regulations (one-time activity)

 Prepare initial ICR (one-time activity)

 Renew initial ICR (periodic) 

 Answer respondent questions

 Review individual annual and biennial reports

 Meet with its Regional Offices to review and discuss collective findings, trends

 Through its Regional Offices, communicate the findings of individual reviews to 

individual responding states

5(b) Collection Methodology and Management

A portion of this information has been assembled in one form or another since the 

inception of I/M programs as a result of the Clean Air Act Amendments of l977 which required 

urban areas failing to meet the National Air Quality Standards to implement in-use vehicle I/M 

programs. Historically, the sources of this information have included, among other things, on-site 

audits by EPA personnel, internal program data reports courtesy-copied to EPA, raw program data 
16

submitted to EPA for analysis, and, since it was originally approved, the responses to this existing 

information collection. 

Respondents have the option to supply their data in either hardcopy or electronically, and 

are free to adopt whatever reporting format results in the least burden for the respondent, while 

also addressing the data elements listed in this ICR. EPA is aware of at least one Regional Office 

which has been granted limited, online access to a state’s I/M database so the Region itself may 

generate the required data summary reports when they are due. 

The information received from the I/M programs has been used by EPA Regional Offices 

to assess specific state programs and their success in complying with the I/M rulemaking 

requirements as well as their approved SIPs. As part of this assessment, EPA’s Regional Offices

conduct follow-up conversations with their states to discuss possible program improvements or 

corrective actions necessary to address anomalies (if found). When an anomaly discovered in the 

reported summary information cannot be resolved by the state and/or Region, EPA Headquarters 

has been called in to help determine whether the anomaly is the result of local conditions or is 

perhaps indicative of a larger, national trend. In such situations, EPA Headquarters has worked

with the state and the Region to identify and address the causes of the anomaly. Information 

regarding the resolution of such cases – to the extent it may be relevant outside the program in 

question – are made available to other states, Regions, and the public in general through various 

communication vehicles, including biweekly conference calls with the EPA Regions, a bimonthly 

stakeholder call with the I/M states, and the I/M Clearinghouse web site, currently managed by 

Weber State University under a grant from EPA. The last of these may be accessed at the 

following: 

http://www.obdclearinghouse.com/

5(c) Small Entity Flexibility

This section is not applicable. Our respondents are not small business entities but state 

governments and their representatives.

5(d) Collection Schedule

Under the original 1992 I/M rulemaking, basic I/M programs were required to begin 

reporting by July 1995, with the first biennial report coming due in July 1996. Enhanced I/M 

programs were required to begin reporting by July 1996, with the first biennial report coming due 

in July 1997. Currently – and for simplicity sake – the reporting schedule is as follows: all 

required I/M programs must submit their annual I/M summary data reports by July of each year. 

Basic I/M programs must submit the required biennial report in even numbered years, and 

enhanced I/M programs must submit the biennial report in odd numbered years. If, for 

administrative reasons, it is easier for a given program to combine its biennial report with its 

annual report and submit the combined report annually, EPA will accommodate the state’s 
17

preference in this regard. 

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

In simple terms, EPA calculated the burden and cost estimates for this ICR using

the following equation:

Number of states X Number of burden hours X Cost per hour

implementing I/M for each state to comply 

with I/M ICR

Section 6(a) describes the information used to develop numbers for the first two variables above. 

Section 6(b) describes how the last variable above – state and local costs per hour – were 

estimated. Section 6(c) describes federal burden hours and costs for managing this information 

collection activity.

6(a) Estimating Respondent Burden

The burden estimates for both the recordkeeping and annual reporting requirements were 

made using professional judgment. Recordkeeping activities are assumed to be routine, 

automated, and conducted primarily for the effective management of the program. Nonetheless, 

an hour of burden has been assumed for this category. The estimate of the burden for information 

gathering by technical staff for the annual report is a conservative one based upon EPA’s previous 

experience working with states as they respond to the I/M reporting requirements. 

Estimates of respondent burden for the biennial report are based upon OTAQ program 

management staff experience with the assemblage and compilation of materials for the office’s 

annual Assurance Letter under the Federal Managers Financial Integrity Act (FMFIA). In many 

ways, the biennial report most resembles the Assurance Letter in its requirement that program 

changes and internal control activities be tracked, evaluated, and reported. 

6(b) Estimating Respondent Costs

Since the information gathering and recordkeeping requirements costs for the I/M rule are 

very minor compared with other costs for this rule, no estimates of information collection labor 

costs were made in the original Regulatory Impact Analysis. Given that the respondents to this 

ICR are state government employees, in managerial, technical, and clerical positions, the General 

Schedule was adopted as a yardstick for estimating hourly labor rates. To ensure that our 
18

estimates are conservative, only the higher ranges of these categories were used. For the clerical 

category, GS-8 was used, while GS-13 was selected to represent the technical position, and GS-15 

was used as the base for calculating management labor rates. First, EPA is assuming that state 

and local burden hours would be completed by an experienced staff person being paid hourly rates 

at a GS-8, step 3, GS-13, step 3 and GS-15, step 3 of federal government employee salary.

2

 

Second, EPA multiplied these hourly rates by the standard government overhead factor of 1.6.3 

This calculation results in a state and local cost of $30.77/burden hour, $58.61/burden hour, and 

$81.47/burden hour, respectively. Calendar year 2012 was chosen as the base year. The resulting 

labor rates are shown in the table below:

Table 1. Hourly Labor Rates, By Category, Adjusted for Overhead Factor

Hours Rates Clerical (GS-8.3) Technical (GS-13.3) Managerial (GS-15.3)

2012 base year 19.23 36.63 50.92

Adjusted by the 

overhead factor 1.6

30.77 58.61 81.47

Table 2. Respondent Burden Hours & Cost for Annual Report

Collection 

Activity

Managerial 

Hours

Technical 

Hours

Clerical 

Hours

Burden 

Hours

Annual 

Costs

1. Read 

regulatory

provisions

1 1 2 $140.08

2. Assess data 

requirements

8 8 $468.88

 

2

January 2012, U.S. Office of Personnel Management, Salary Table 2012-GS, 

http://www.opm.gov/oca/12tables/html/gs_h.asp.

3 U.S. Department of Labor Department, www.dol.gov.
19

3. Assemble

reports & data

16 16 $937.76

4. Review 

information for 

accuracy

8 8 $468.88

5. Summarize 

information

4 4 $234.44

6. Prepare and 

submit report 

4 1 5 $265.21

7. Record, store, 

& maintain files

1 1 $58.61

Total 1 42 1 43 $2,574

Table 3. Respondent Burden Hours & Cost for Biennial Report

Collection Activity Managerial 

Hours

Technical 

Hours

Clerical 

Hours

Burden 

Hours

Annual 

Costs

1. Track/record 

program change

16 16 $937.76

2. Track/record 

weakness/correction

16 16 $937.76

3. Assemble/report 

findings/future plans

16 32 4 52 $3,302.12

Total 16 64 4 84 $5,178

Annual burden hours

per respondent = (Hr. of annual report) + (Hr of biennial report)/2

= 43 + 84/2
20

= 85

Annual burden cost

per respondent = $2,574 + ($5,178) / 2 

= $5,163

Annual total burden hours for all respondents: 

= (annual burden hours per respondent) x (total number of 

respondents)

= 85 x 28

= 2,380

Annual total burden costs for all respondents

= (annual burden cost per respondent) x (total number of respondent)

= $5,163 X 28

= $ 144,564

6(c) Estimating Agency Burden and Cost

The estimates of each class of hours needed to handle the burdens associated with this ICR 

are based upon the experience EPA has had in handling similar tasks such as assembling and 

processing pre-audit information from individual states on an as-needed basis. The labor 

categories and hourly labor rates are the same as those used for the respondent burden estimates, 

and are decidedly conservative.

Table 4. Agency Burden for One Time ICR Costs

One- time 

Activity

Managerial 

Hours

Technical 

Hours

Clerical 

Hours

Burden 

Hours

Annual Costs

Reg 

Development

4 20 24 $1,498.08

ICR 

development

2 80 1 83 $4,882.51

Database Set 

Up

2 40 42 $4,835.74

Total 8 136 1 149 $11,216
21

Table 5. Agency Burden Hours & Cost per Annual & Biennial Report

Collection 

Activity

Manage

rial 

Hours

Technical 

Hours

Clerical 

Hours

Burden Hours Annual Costs

1.Answer 

questions

4 34 38 $2,318.62

2. Review data 

submissions

34 34 $1,992.74

3. Record data 

submission

34 34 $1,046.18

4. Analyze data 

and store

4 4 $234.44

5.Summarize data 

& report

8 68 8 84 $4,637.24

Total 12 140 42 194 $10,229

Annual total burden hours for agency 

= (annual agency burden hours) + (Average start up hours over 3 years)

= 194 + 149/3

= 244

Annual total burden cost for agency 

= (annual agency burden costs) + (Average start up cost over 3 years)

= $11,216 + $10,229/3

= $14,626

6(d) Bottom Line Burden Hours and Costs

The bottom line burden hours and costs appear in Table 6. Total annual respondent 

burden associated with this ICR is estimated to be approximately 2,380 burden hours. The 

corresponding total annual respondent costs are estimated to be $144,564. Total national burden, 

including respondent burden and EPA burden, is estimated to be 2,624 hours annually. The total 

national cost, for respondents and EPA, is estimated to be $159,190 annually.

Table 6. Bottom Line Annual Burden and Cost

number of respondents 28 27 states plus D. C. 
22

total annual respondents 28 one response per respondent

hours per respondent 85 table 2 and 3

cost per respondent $5,163 table 2 and 3

total respondent hours 2,380 hours per resp. x 28

total respondent cost $144,564 cost per resp. x 28

total agency hours 244 table 5

total agency cost $14,626 table 5

total burden hours (resp. + 

agency)

2,624 total respondent hours + total 

EPA hours

total burden cost (resp. + 

agency)

$159,190 total respondent cost + total 

EPA cost

6(e) Reasons for Change in Burden

The total annual burden estimated in 1992, I/M Program Proposed Rule ICR, approved by

OMB, was 2,282 hours. The annual burden hours per respondent was 85 hours. When the 

original ICR was subsequently renewed, the annual burden hours per respondent was retained at 

85 hours, but the estimate of total respondents’ burden was changed to 2,890 hours. The reason 

for that change was that the number of states (respondents) implementing the I/M program had 

increased to 34. During the current renewal, the total burden hours and costs associated with this 

ICR are going down due to the fact that now, only 28 states (respondents) are covered by 

mandatory I/M reporting requirements. This is due to areas redesignating to attainment for the 

criteria pollutant(s) that triggered the original I/M program requirement and either dropping the 

program, or continuing a revised version of the program for maintenance purposes only. At the 

same time, however, the individual cost per respondent has risen, due to increases in the Office of 

Personnel Management’s hourly wage estimates for clerical, technical, and managerial positions 

used to estimate the cost of the respondent’s burden. 

6(f) Burden Statement

Public reporting burden for collections included in this ICR is detailed above. The annual 

burden per respondent is estimated to be 85 hours, and the total annual respondent burden 

imposed by these collections is estimated to be 2,380 hours (28 respondents). These estimates 

include time for summarizing data as well as reporting summaries. 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 
23

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 number for this ICR is OCN # 2060-0252. 

To comment on the Agency’s need for this information, the accuracy of the provided 

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

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID No. EPA-HQ-OAR-2008-0707: Notice-3, which is available for online viewing at 

www.regulations.gov, or in person viewing at the Air Docket in the EPA Docket Center 

(EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The 

EPA/DC 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 Docket is 202-566-1742. 

Use www.regulations.gov to obtain a copy of the draft collection of information, submit or 

view public comments, access the index listing of the contents of the docket, and to access those 

documents in the public docket that are available electronically. Once in the system, select 

“search,” then key in the docket ID number identified in this document. 
24

APPENDIX A