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Emissions Certification and Compliance Requirements for Nonroad Spark-ignition Engines (Renewal)

OMB: 2060-0338

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Supporting Statement


for


Information Collection Request






Emissions Certification and Compliance Requirements for Nonroad Spark-ignition Engines (Renewal)



EPA ICR Number 1695.09, OMB Control Number 2060-0338




42 USC 7521 § 206

42 USC 7521 § 213(d)

40 CFR Part 90

40 CFR Part 1048

40 CFR Part 1051

40 CFR Part 1065

40 CFR Part 1068




March 17, 2008







Certification and Compliance Division

Office of Transportation and Air Quality

Office of Air and Radiation

U.S. Environmental Protection Agency




1. Identification of the Information Collection


1(a) Title and Number of the Information Collection


Emissions Certification and Compliance Requirements for Nonroad Spark-ignition Engines (Renewal); EPA ICR Number 1695.09, OMB Control Number 2060-0338.



1(b) Short Characterization


Under Title II of the Clean Air Act (42 U.S.C. 7521 et seq.; CAA), EPA is charged with issuing certificates of conformity for engine prototypes that comply with applicable emission standards. Such a certificate must be issued before engines produced after these prototypes may be legally introduced into commerce. EPA regulations pertaining to spark-ignition engines rated at or below 19 kilowatts (small SI engines) are found at 40 CFR Part 90. Regulations pertaining to spark-ignition engines rated above 19 kilowatts ('large SI engines') are found at 40 CFR Part 1048. Throughout these documents, these two categories of engines (small and large SI engines) are collectively referred to as "SI engines" or simply as "engines." Recreational vehicle regulations are found at 40 CFR Part 1051. Parts 1065 and 1068 contain testing requirements and compliance regulations that apply to multiple engine types.


Manufacturers electing to participate in an Averaging, Banking and Trading (ABT) Program are also required to submit information regarding the calculation, actual generation, and usage of credits in an initial report, end-of-the-year report, and final report. These reports are used for certification and enforcement purposes. Manufacturers will also maintain records for eight years on the engine families included in the program.


The CAA also mandates EPA to verify that manufacturers have successfully translated their certified prototypes into mass produced engines, and that these engines comply with emission standards throughout their useful lives. Under the Production-line Testing (PLT) Program, manufacturers are required to test a sample of engines as they leave the assembly line. This self-audit program (referred to as the "PLT Program") allows manufacturers to monitor compliance with statistical certainty and minimize the cost of correcting errors through early detection. Through Selective Enforcement Audits (SEAs), EPA verifies that test data submitted by engine manufacturers is reliable and testing is performed according to EPA regulations. Compliance with emission regulations throughout the useful life of an engine is verified through the In-use Testing (In-use) Programs under which manufacturers test SI engines after a number of years of use. Participation in the PLT program is mandatory. The In-use Programs are voluntary for small SI engines, but mandatory for large SI engines. All manufacturers are subject to SEAs.


This information is collected by the Heavy-Duty and Nonroad Engines Group (HDNEG), Compliance and Innovative Strategies Division (CISD), Office of Transportation and Air Quality (OTAQ), Office of Air and Radiation (OAR), U.S. Environmental Protection Agency (EPA). Besides CISD, this information could be used by the Office of Enforcement and Compliance Assurance (OECA) and the Department of Justice for enforcement purposes. Non-confidential portions of the information submitted to EPA could be disclosed in a public database and over the Internet. This information is used by trade associations, environmental groups, and the public. Respondents usually submit this information in an electronic format and HDNEG stores it in a database.


It has been estimated that a total of 241 manufacturers will respond to this collection with an approximate cost of $26,167,036.


2. Need for and Use of the Collection


2(a) Need/Authority for the Collection


EPA's emission certification programs are statutorily mandated; the agency does not have discretion to cease these functions. 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."


This provision also applies to nonroad engines, pursuant to §213(d) of the CAA. Also, under the authority of the CAA §217, engine manufacturers are required to pay a fee when applying for a certificate of conformity.


Therefore, vehicle and engine manufacturers may not legally introduce their product into U.S. commerce unless EPA has certified that their vehicles and engines comply with applicable emission standards. To ensure compliance with these statutes, EPA reviews product information and manufacturers' test results and may test some vehicles and engines to confirm manufacturers' certification testing results. EPA also conducts an ABT Program, which is one of the many regulatory features designed to enhance the compliance flexibility for and reduce the burden on the affected engine manufacturers, without compromising the expected emissions benefit derived from these emissions standards. Note that there is no ABT program for large SI engines.


Section 206(b)(1) of the CAA authorizes EPA to inspect and require testing of new vehicles and engines to: (1) verify that manufacturer's final product actually complies with EPA standards; (2) assure that the correct parts are installed correctly in each engine; and (3) audit the manufacturer's testing process to ensure testing is being done correctly. The PLT Program and the SEA Program fulfill these requirements by inspecting and testing engines taken directly from the assembly line and by auditing the engine manufacturer's testing procedures and facilities. Section 207(b) of the CAA mandates the establishment of methods and testing procedures to ascertain whether certified engines in actual use in fact comply with applicable emission standards throughout their useful lives.


The programs are codified at Parts 90, 1048, 1051 and 1068 of Title 40 of the Code of Federal Regulations as indicated in Table 1 below.


Table 1
Regulations


Program

Small SI

40 CFR Part 90

Large SI

40 CFR Parts 1048 and 1068

Recreational Vehicles

40 CFR Parts 1051 and 1068

Certification

Subpart B

Subpart C (Part 1048)

Subpart A (Part 1068)

Subpart C (Part 1051)

Subpart A (Part 1068)

ABT

Subpart B

NA

Subpart H (Part 1051)

PLT

Subpart H

Subpart D (Part 1048)

Subpart D (Part 1051)

In-Use

Subparts B and M

Subpart E (Part 1048)

NA

SEA

Subpart F

Subpart E (Part 1068)

Subpart E (Part 1068)



The specific subparts listed contain the reporting and recordkeeping requirements covered by this ICR. Other subparts in each part provide information that support and supplement the subparts listed.




2(b) Practical Utility/Users of the Data


EPA uses the information requested to support various enforcement actions as mandated by the CAA. This information collection enables EPA to ensure that small SI, large SI and recreational engine manufacturers are complying with applicable emission regulations, measure the impact of nonroad engines' emissions on air quality, and take corrective actions as needed.


The information will be received and used by HDNEG/CISD/OTAQ/OAR. Non-confidential portions of the information submitted to HDNEG is available to and used by importers, environmental groups, members of the public, and local, state and federal government organizations.



3. Nonduplication, Consultations and Other Collection Criteria


3(a) Nonduplication


The information requested under this ICR is required by statute. Because of its specialized nature, the information collected is not available from any other source. Furthermore, some of the information, such as projected U.S. sales volume, is claimed as confidential business information (CBI) by manufacturers; therefore EPA can only obtain it if manufacturers submit it.


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


An announcement of the public comment period for this ICR renewal was published in the Federal Register (73 FR 2487) on January 15, 2008. This document may be accessed through the Federal Register's website at http://www.gpoaccess.gov/fr/index.html. In addition, all documents associated with this ICR renewal are accessible on www.regulations.gov, under Docket # EPA-HQ-OAR-2007-1183.


No comments were received in response to this ICR renewal.



3(c) Consultations


EPA consulted less than ten past respondents regarding this information collection burden, including the following industry professionals:


Contact: Eric Barnes

Company: Honda

Phone: 310-783-3864


Contact: Christine Ueno

Company: MTU Detroit

Phone: 313-592-5427


Contact: Dave Land

Company: Industrial Equipment

Phone: 812-342-8643




3(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 design is "carried over" to a subsequent model year, the amount of new information required is substantially reduced.


For practical reasons, PLT reports are submitted on a quarterly basis. Manufacturers are required to test up to one percent of their production at random to ensure that mass produced engines comply with emission requirements. If a problem is found, manufacturers must correct it and might need to recall engines that have already been sold. Engine manufacturing companies update their internal production volume reports every quarter. By conducting this quality control testing also on a quarterly basis, manufacturers are able to learn about and address any problems early, before the start of the next quarter's production, thus minimizing costs.


In-use testing reports are submitted annually, within three months of the completion of the required testing. Providing this information to EPA at a less frequent interval would compromise EPA's ability to expeditiously evaluate the emissions results and determine, in a timely manner, whether in-use engines conform to the applicable emission standards. Any delay in making such a determination reduces the universe of engines which will be reached by a potential recall because both engine scrappage and owners' unwillingness to participate in recalls increase with the age of the engine.


SEA information is only collected on occasion, when EPA has reason to believe that an audit of a particular manufacturer is in order.



3(e) General Guidelines


According to 40 CFR 90.121(b), emission test records must be maintained for eight years, except for routine emission test data such as those reporting the condition of the test cells. Such data need to be kept for one year only. However, records may be kept in any format and media, provided the manufacturer is able to provide organized, written records to EPA upon request (see: 40 CFR 90.121(c)). This requirement stems from the CAA mandate that manufacturers recall engines failing to meet emission standards throughout their useful lives.


When audited, manufacturers must submit test results and information within 30 working days after all testing ordered under an SEA notification has been completed. The items requested are all readily available or generated during the SEA. The information is requested in this time frame so that EPA can verify the accuracy and validity of the emission data and expeditiously reach a conclusive audit decision. An expeditious audit decision allows the manufacturer to quickly release the tested vehicles or engines for introduction into commerce.


Under this information collection, manufacturers are required to submit confidential business information such as sales projections. Furthermore, certain sensitive technical and proprietary information submitted during the certification process could be used during SEAs. This information is kept confidential in accordance with the Freedom of Information Act (FOIA), EPA regulations at 40 CFR Part 2, and class determinations issued by EPA's Office of General Counsel.


No other general guideline is exceeded by this information collection.


3(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 (FOIA) and EPA regulations at 40 CFR Part 2.


3(g) Sensitive Questions


No sensitive questions are asked in this information collection.




4. Respondents and Information Requested


4(a) Respondents/North American Industry Classification System (NAICS) Codes


Respondents are manufacturers of nonroad engines within the following North American Industry Classification System (NAICS) code:


333618 Other Engine Equipment Manufacturing

336312 Gasoline Engine and Engine Parts Manufacturing

336999 Other Transportation Equipment Manufacturing

336991 Motorcycle, Bicycle and Parts Manufacturing



4(b) Information Requested


Manufacturers must describe their products and supply test data to verify compliance. This information is organized by "engine family" groups expected to have similar emission characteristics. Manufacturers must also retain these records.


(i) Data Items


The following lists are meant to give an idea of the data items requested under each program, but do not represent a comprehensive list of data items. Regulations may call for additional/different items depending on the characteristics of the regulated engine or vehicle. Please refer to the regulations cited previously in this ICR for a comprehensive list of items per engine/vehicle category. Some of these data items are required to be kept in records and submitted only upon request.


A. Certification



Engine families need to be certified each model year. A model year refers to the manufacturers' annual new model production period, or a calendar year if the manufacturer does not have a model year. Manufacturers may make changes to one or more engine models within a family at any time during the model year. These changes may significantly affect the engine models, and therefore, the engine family's emission levels. For this reason, all SI engine programs run on a model year basis.


The certification burden for a given engine family is reduced after the model's first production year, because data and information from previous years can be "carried over" when no significant changes have occurred. For instance, an engine family certified in model year 2006 can be certified in the 2007 model year by "carry-over" of data and paperwork from the 2006 model year if no significant changes have occurred to the engine family between model years. EPA may also allow manufacturers to "carry-across" data and paperwork from on-highway certification of an engine family which they produce for both the on-highway and nonroad markets if there are no significant differences between the on-highway and nonroad versions of the engine family. Allowing manufacturers to "carry-over" and "carry-across" data and paperwork saves manufacturers the burden of duplication of data and paperwork which would occur in the absence of such provisions.


A label identifying each engine and stating the engine family name, the fuels the engine is certified to run on, the engine useful life and category, if applicable, must be affixed to each engine. Manufacturers are also required to provide warranties to consumers.


An application fee must be paid per engine family per model year. This fee is requested under the authority of Section 217 of the CAA and the Independent Offices Appropriation Act (31 U.S.C. 9701) to ensure that the motor vehicle emissions compliance program is self-sustaining to the extent possible. New fee schedules are published on EPA’s website. See section 6(b)(ii) for details.


EPA encourages manufacturers to apply electronically and has developed a simple electronic application format. Questions are answered as applicable to each engine category. A complete application consists of: 1) a Statement of Compliance; 2) a Family Information Form (FIF); 3) a Test Information Form (TIF); 4) a Technical Description Form (TDF); 5) an Engine Model Summary (EMS); and 6) an Engine Part Summary (EPS). However, manufacturers requesting a certificate of conformity for evaporative engine families are only required to submit the Statement of Compliance and an Evaporative Engine Form (EEF). There is also a PLT Information Form. These forms can be downloaded from EPA's website at http://www.epa.gov/otaq/certdat2.htm.


Information Items Requested Under the Certification Program:


Statement of compliance;

Identification and description of the basic engine design including, but not limited to, the engine family specifications (fuel, cooling medium, etc.);

Explanation of how the emission control system operates;

Fuel System type and components;

Useful life Period;

Deterioration factors;

Intended Service Class;

Projected Sales;

Estimated Production Period;

Sales Area;

● Plant Contact and Location;

Program information;

Family Emission Limits (FEL);

Nonroad engine equipment types;

Detailed description and justification of each auxiliary emission control device (AECD), and how they affect emissions;

Description of all adjustable parameters, their adjustable ranges and methods employed to prevent tampering, etc.;

Detailed drawings and descriptions of the various emission related components;

Description of the test equipment and fuel to be used;

Description of the test procedures to be used to establish the durability data or the exhaust emission deterioration factors;

All test data obtained by the manufacturer on each test engine;

Statement of the useful life;

Statement of the alternative useful-life period and a brief synopsis of the justification, if applicable;

Maintenance information;

Description of the provisions taken to prevent tampering with emission control computer instructions;

Proposed test fleet selection and the rationale for the test fleet selection;

Special or alternate test procedures, if applicable;

● Period of operation necessary to accumulate service hours on test engines and stabilize emission levels;

Fee Filing Form; and

  • If EPA submits a written request for an explanation of good engineering judgment, manufacturers must provide a written description of the judgment in question within 15 working days, unless otherwise specified.


Manufacturers must keep records for eight years except routine emission records. Manufacturers must keep routine emission records for only one year.


General Records:


Identification and description of all engines for which testing is required;

● Description of emission control systems; and

Description of test procedures.


Individual Records:


Copies of all the applications submitted;

A brief history of all test engines and running changes;

A complete record of all emission tests performed;

The date of each mileage accumulation run and the mileage accumulated;

Record and description of all maintenance and other servicing performed;

Record and description of each test performed to diagnose engine or emission control system performance;

A brief description of any significant events affecting the vehicle;

Actual U.S. sales volume;

For Heavy Duty engines model 1996 - 98: Shipment date, purchaser, purchaser contract, and EPA evaporative/refueling family; and

● Routine emission test data.


When a manufacturer needs to make changes to a certified engine, or to add an engine model to an already certified engine family, the following information must be submitted. Running changes are submitted using the same electronic format used to apply for a certificate of conformity. Data items requested:


Notification of changes made to the application and/or request to amend the application;

● Description of change to be made;

Engineering evaluations or data showing that engines as modified or added will comply with all applicable emission standards;

● Determination of whether the original test fleet selection is still appropriate, and proposed new test fleet selections, if applicable;

Test data on engines changed or added, upon request; and

● Supporting documentation, test data and engineering evaluations as appropriate to demonstrate that all affected engines will still meet applicable emission standards.


If an engine is installed that has been rebuilt, emissions-related components must be checked. The following records must be kept for at least two years after rebuilding an engine, and must be accessible for EPA's review. Records may be based on engine families rather than individual engines if that is a normal business practice.


● Hours of operation (or mileage, as appropriate) at the time of the rebuild;

● Work completed on the engine or any emission-related control components, including a listing of parts and components used;

● Any engine parameter adjustments; and

● Any emission-related codes or signals responded to and any retests.


For manufacturers or rebuilders of aftermarket engine parts for large SI engines and recreational vehicles, information must be maintained that shows how their parts or service affect emissions. EPA may test engines and equipment to investigate potential defeat devices or may require the manufacturer to complete this testing. Manufacturers may need to provide information regarding test programs, engineering evaluations, design specifications, calibrations, on-board computer algorithms, and design strategies. (see Section 1068.110)


Each manufacturer is also required to submit an annual production report identifying the number of engines produced by engine family, by gross power, by displacement, by fuel system, or by other categories as the Administrator may require. If the manufacturer requests a hearing on the Administrator's denial or revocation of a certificate of conformity, the request shall be filed within 30 days of the Administrator's decision, shall be in writing, and shall set forth the manufacturer's objections to the Administrator's decision and data to support the objections.


The Engine Model Summary (EMS) is requested to evaluate whether engine families were developed correctly. The information contained in this form allows EPA engineers to know if the engine models were grouped correctly, and, most important, if the test data submitted corresponds to the worst case within that family. The calculation of the engine's rated power, torque, etc., is customary business practice.


The Part Summary Form (PSF) allows EPA to make sure that the engine is actually built in its certified configuration. This information is used when conducting SEAs.

B. Average, Banking and Trading


ABT data requirements can be found at Part 90 Subpart B for small SI engines and Part 1051 Subpart H for recreational vehicles.


Information Items Required Under the ABT Program:


Intent to include the engine family in the ABT program;

Declaration that participation in this program will not cause the applicable emission standard to be exceeded (i.e., result in a negative credit balance);

Family Emission Limit (FEL);

Projected applicable production volumes for the model year;

Values required to calculate credits;

● Projected number of credits generated/used; and

● Designated use of generated credits and/or source of credits used.


The following ABT records are to be kept for eight years:


EPA engine family;

Engine identification number;

Engine build date and model year;

Power rating;

Purchaser and destination;

Assembly plant;

Family Emission Limit (FEL);

● Useful life;

Projected and actual production for each model;

Applicable production/sales volume -- actual quarterly and cumulative (this is required quarterly for all families participating in trading);

Values required to calculate credits;

Resulting type and number of credits generated/required;

How and where credit surpluses are dispersed; and

● How and through what means credit deficits are met.


C. Production-Line Testing (PLT) Program


In the small SI engine sector, only Phase 2 small SI engines are subject to PLT requirements. Phase 2 refers to a second, more stringer tier of emission regulations for small SI engines. The different provisions in these and other small SI emission control programs are designed to ease manufacturers' transition from Phase 1 to Phase 2 standards. Participation in PLT is optional for small volume engine manufacturers and small volume engine families (see section 5(c) for details). Engine families, regardless of size, for which the manufacturer opts to conduct in-use testing are exempt from PLT requirements. All manufacturers and engine families, however, remain subject to SEAs. PLT is mandatory for all large SI engines and recreational vehicles.


Each calendar quarter, participating manufacturers must test a sample of SI engines taken directly from the assembly line. These tests must be performed unless EPA approves a variation.


EPA can require manufacturers to submit or retain additional information not specifically listed here. Within 45 days of the end of each quarter, manufacturers must report the following information:


● Location and description of the test facilities where testing was conducted;

● Total production and sample size for each engine family;

● Applicable standards and/or FELs;

Description of the process used to obtain engines on a random basis; and

Description of the test engine.


For each test conducted, submit the following information:


Description of the test engine, including engine family and configuration, year, make, build date, engine ID number, and number of hours of service accumulated on the engine prior to testing;

Location(s) where service accumulation was conducted and description of accumulation procedure and schedule;

Test number, date, test procedure used, initial test results before and after rounding, final test results before and after rounding, and final deteriorated test results for all tests, etc.;

● Complete description of any adjustment, modification, repair, preparation, maintenance, and testing which was performed on the test engine, etc.;

CumSum Analysis;

Any other information the Administrator may request;

For each failed engine, a description of the remedy and test results for all retests;

Date of the end of the engine manufacturer's model year production for each engine family;

A signed statement (e.g., see 90.709(e)(9) for small SI engines) and endorsement by an authorized representative of the manufacturer; and

Submit, upon request: 1) projected production for each configuration within each engine family for which certification has been requested and/or approved; and 2) Number of engines, by configuration and assembly plant, scheduled for production or actually produced.


Record and maintain the following information for one year after completion of testing:


Description of all testing equipment used and each test cell that can be used to perform PLT;

Date, time, and location of each test or audit;

Number of service accumulation hours on the test engine at the start and end of the test(s);

Names of all supervisory personnel involved in the conduct of the test or audit;

Record and description of any adjustment, repair, preparation or modification performed on test engines, including date, associated time, justification, name(s) of the authorizing personnel, and/or name(s) of supervisory personnel responsible for the conduct of the repair;

If applicable, the date the engine was shipped from the assembly plant, associated storage facility or port facility, and the date the engine was received at the testing facility;

Complete record of all PLT emission tests or audits performed (except tests performed directly by EPA), including all individual worksheets and/or other documentation relating to each test, or exact copies; and

● Brief description of any significant events during testing not otherwise described, commencing with the test engine selection process and including such extraordinary events as engine damage during shipment.


When an engine family fails PLT, its certificate of conformity may be suspended, effective from the time testing was completed. Before suspending a certificate, EPA will work with the affected manufacturer to achieve appropriate production line changes and try to avoid the need to halt engine production. Manufacturers with a suspended certificate must remedy the non-conformity, retest or re-audit. After a successful test is completed, the manufacturer must submit a report with the same information required during the initial test.


For EPA to consider reinstating a suspended certificate of conformity, the manufacturer must submit another report with the following information:


● Description of the reason for noncompliance;

Description of the proposed remedies, including a description of any proposed quality control measures to be taken to prevent future occurrences of the problem, and the date when the remedies will be implemented;

Demonstration, through testing, that the failed engine family does in fact conform;

Manufacturers may request a hearing; and

Manufacturers may request conditional reinstatement of a revoked certificate while conducting further testing.


The manufacturer must submit a request for public hearing, if the reason for suspension of the certificate is being challenged. This request must be made in writing within 15 days of the revocation. Four copies of the request must be filed containing the following information:


Statement regarding which engine family configuration(s) will be the subject of the hearing;

Concise statement of the issues to be raised at the hearing;

Statement specifying reasons why the manufacturer believes it will prevail on the merits of each of the issues raised; and

● Summary of the evidence which supports the manufacturer's position on each of the issues raised.


D. In-use Testing Programs


In-use testing requirements are different for small SI Phase 1 and Phase 2 engines and large SI engines. There is no in-use testing requirement at this point for recreational vehicles. Phase 1 and Phase 2 in-use testing provisions can be found at 40 CFR Part 90 Subpart B (Section 90.113) and Subpart M, respectively.




(1) In-use Testing for Small SI Phase 1 Engines


Each model year, Phase 1 small SI engine manufacturers propose a list of engine families to be included in the Phase 1 In-use Testing Program. If the list complies with requirements at section 90.113(c), EPA may approve it or suggest modifications.


In-use records, including data generated in the engine procurement process, must be kept for eight years (90.113(d)(2)(ii), 90.113(d)(3)(ii) and 90.121(a)(2)).


By January 30 of every year, Phase 1 engine manufacturers may submit the results from all in-use tests performed during the previous year. The report may include:


Engine family;

Model;

Engine serial number;

Date of manufacture;

Estimated hours of use;

Results of all emission testing;

Summary of all maintenance and/or adjustments performed;

Summary of all modifications and/or repairs; and

● Determinations of compliance or noncompliance.


(2) In-use Testing for Phase 2 Engines


Participation in the Phase 2 In-use Testing Program is voluntary. Manufacturers may make an election to participate by notifying EPA of their intent to conduct in-use testing. This election must be made in writing, before the beginning of each model year, and must include a list of engine families on which an in-use test will be performed. Note that 40 CFR 90.1203(b) exempts participating engine families from PLT requirements for two model years. Only 20% of a manufacturer's engine families in any given model year may be included in the In-use Testing Program.


The program requires that manufacturers randomly select or procure a minimum of three engines from each participating engine family, and then age and test them in accordance with sections 90.1203 and 90.1204. Manufacturers must complete testing within three years of notifying EPA of their intention to participate, unless otherwise approved by EPA ((Section 90.1203(f)).


Per sections 90.1204(e) and 90.121(b), all data generated under this program must be kept for eight years.


For each Phase 2 small SI engine tested, the manufacturer must submit the following information within 90 days of completion of the testing:


Engine family;

Models;

Application;

Engine serial numbers;

Date of manufacture;

Hours of use;

Date and time of each test attempt;

Results (if any) of each test attempt;

Schedules, descriptions and justifications of all maintenance and/or adjustments performed;

Schedules, descriptions and justifications of all modifications and/or repairs; and

● List of engines deleted from the aging process and a technical justification.


(3) In-use Testing for Large SI Engines


The data reporting structure for large SI in-use testing is very similar to that of small SI Phase 2 engines. However in-use testing for large SI engines is mandatory. Manufacturers need to test at least two engines if: 1) the manufacturer's total production is 2,000 engines or less, or 2) if the engine family in particular has a production volume of 500 engines or less (1048.410(c)(1)).


E. Selective Enforcement Auditing (SEAs)


All engine and vehicle manufacturers are subject to potential audits by EPA. EPA collects the information needed for SEAs in two stages. First, a limited number of manufacturers are asked to submit their production plans for a specified period of time, as described below. EPA uses this "pre-audit" information to efficiently determine which manufacturers and engine models to audit. After a manufacturer has been selected, EPA issues a test order specifying which engine models and configurations will be tested. When all required testing is completed, manufacturers submit a report containing all testing results. This "audit" information is then used to determine compliance with applicable emission standards.


Upon EPA's request, engine manufacturers must submit the following information regarding engine production. EPA uses these data to determine which engines will be audited.


Projected U.S. sales data for each engine family and configuration;

Number of engines, by configuration and assembly plant, scheduled for production within the time period designated by EPA;

Number of engines, by configuration and assembly plant, storage facility or port facility, scheduled to be stored during the time period designated by EPA; and

● Number of engines, by configuration and assembly plant, produced during the designated period that are complete for introduction into commerce.


Within 30 calendar days of the end of each audit, large SI and recreational manufacturers must submit a report to EPA based on the requirements in Section 1068.450. Small SI manufacturers are required to submit reports as requested by EPA (see Section 90.505). Manufacturers' reports should include the following information:


Testing facilities' location and description.

U.S.-directed production volume and number of tests for each engine family.

Applicable standards or compliance levels against which the engines were tested.

● Description of the engine and the method used to select its emission-related components.

For each test conducted, the following information:


-- Test engine description;

-- Location where service accumulation was conducted and a description of the procedure;

-- Test information, raw results, which include emission figures for all measured pollutants, for both valid and invalid test results;

-- A complete description of any modification, repair, preparation, maintenance and/or testing performed on the engine not previously reported. This must include the results of any emission measurements, regardless of the procedure or type of equipment;

-- Reason(s) for removal of engines from the test sequence (as authorization by EPA), if applicable; and

-- Any other information as requested by EPA.


● Statement of compliance and endorsement.

  • For large SI and recreational engines, a report on each failed engine.

● Request for re-testing of failed engines, if applicable.

  • Signed statement by an authorized manufacturer representative (for large SI and recreational engine manufacturers) as required under section 1068.450(c).


Records must be kept for one year after all ordered tests have been completed. Records may be kept in any media, according to the manufacturer's procedures, provided that in every case all the information contained in the hard copy is maintained. EPA may review manufacturer records at any time.


● General records: a description of all test equipment used, including the information submitted with the audit report described above.

Individual records for each audit:


-- Date, time and location of each test;

-- Number of hours accumulated in each engine when testing began and ended;

-- Names of all supervisory personnel involved in the conduct of the audit;

-- Detailed records of all repairs performed prior/after EPA's authorization;

-- Any records related to an audit not in the written report;

-- Date engine(s) shipped, associated port/storage facility and date received, if applicable;

-- A complete record of all tests performed including worksheets and other documentation; and

-- Brief description of any significant event(s) that occurred during the audit.


  • For large SI and recreational engines, a manufacturer must be able to provide projected or actual production for an engine family, by assembly plant.

● Description of the equipment in each test cell that can be used to perform SEA testing.


EPA can request manufacturers to submit additional SEA information or keep records not specifically listed in this section.



(ii) Respondent Activities


The activities manufacturers need to perform to comply with the requirements of each program are as follows:


A. Certification activities


Review the regulations and the guidance document;

Develop engine family groups;

Test engines for compliance with emission standards;

Develop deterioration factors, if applicable;

Gather emissions data;

Submit the fee filing form;

Pay the corresponding fee;

Submit the Application for Certification;

Retain and maintain records, and submit them upon Administrator's request; and

Submit an annual production report.


B. ABT Activities


Pre-certification Activities;

Familiarization with the ABT program provisions;

Determine which engine families will participate in ABT;

Project applicable production volumes for the model year for all engine families;

Submit ABT information with the certification application;

Gather information regarding point of first retail sale;

Monitor production volumes and engine sales (customary business practice);

Develop and submit end-of-year reports;

Develop and submit final reports; and

Store, file, and maintain information as required.


C. Production Line Testing


Gather/maintain production data (customary business practice);

Read instructions and regulations;

Train personnel;

Project testing needs and plan schedules;

Select engines to be tested;

Inspect engines to be tested;

Contract an independent facility to test engines (if needed);

Test engines;

Enter data and analyze it;

Prepare and submit reports; and

Keep records.


D. In-use Testing


Read instructions and regulations;

Train personnel;

Plan activities;

Procure engines;

Ship engines;

Maintain engines;

Contract an independent facility to test engines (if needed);

Test engines;

Enter data and analyze it;

Prepare and submit reports; and

Keep records.


E. Selective Enforcement Auditing


Gather/maintain production data (customary business practice);

Read instructions and regulations;

Provide pre-audit information;

Plan activities;

Train personnel;

Test engines;

Enter data and analyze it;

Prepare and submit reports; and

Keep records.



5. The Information Collected -- Agency Activities, Collection Methodology, and Information Management


5(a) Agency Activities


As part of the implementation of the certification programs, EPA officials carry out the following activities:


Review and interpret regulations, provide guidance;

Gather applications from the industry, enter data into the database;

Review the applications for completeness and accuracy;

Verify that the correct engines 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, including making it available through the Internet;

Analyze and manage requests for confidentiality;

Determining if "carry-over" of data from a previous model year is appropriate or if new testing will be required; and

Store, file and maintain data.

Activities related to ABT involve:


Reviewing requirements and providing guidance;

Entering the data into the database;

Receiving quarterly and final reports, reviewing calculations, making sure that the information submitted by manufacturers is accurate and complete;

Audit manufacturers reports and files to make sure all participants have zero or positive credit balances at the end of the year; and

Keep records.


The following are EPA's activities associated with the implementation of the PLT and SEA Programs:


Review and interpret applicable regulations;

Answer questions from manufacturers and the public;

Review submissions for format and completeness, input data into the database;

Analyze data submitted in reports, compare results to standards and FELs;

Request and review additional information as needed;

Periodically perform maintenance or make enhancements to the database;

Make data from completed test programs available to the public, including posting it on the Internet;

Analyze and manage requests for confidentiality;

Take any appropriate enforcement actions; and

Keep records of the information submitted by manufacturers and EPA's actions and determinations.


EPA activities associated with the implementation of the in-use testing programs are similar:


Review and interpret regulations;

Answer manufacturers' questions;

Evaluate testing programs submitted by manufacturers and ensure that the programs comply with applicable requirements;

Enter data from reports into the database;

Review submissions for format and completeness;

Analyze information submitted;

Keep records;

Request and review additional information, as needed;

Perform maintenance or make enhancements to the database;

Make data from completed test programs available to the public, including posting it on the Internet; and

Analyze and manage requests for confidentiality.


In addition, when conducting SEAs, the agency must:


Request and gather production data from manufacturers;

Make a determination as to which manufacturers and engine families to audit;

Issue an SEA test order;

Travel to the testing laboratory to witness the testing; and

Oversee testing, ensure proper procedures are followed, answer questions.


5(b) Collection Methodology and Management


EPA currently makes extensive use of electronic media in gathering and evaluating information from SI engine manufacturers. Manufacturers submit certification, ABT, PLT and In-use data in electronic formats. SEA reports can be submitted electronically, but the manufacturer may submit these reports using other methods.


Once the data are received, the information is entered into a database and reviewed for completeness. If the manufacturer chooses to make hard copy submittals, then EPA manually enters the information into the database. The certification reviewer analyzes the information to ensure compliance with the CAA and applicable regulations.


Non-confidential portions of the applications for certification are available through the Engine Certification Information Center at http://www.epa.gov/otaq/certdata.htm.


5(c) Small Entity Flexibility


Participation in the Phase 2 PLT program is optional for 'small volume engine manufacturers' and 'small volume engine families.' A 'small volume engine manufacturer' is, as defined at section 90.3, "for non-handheld engines, any engine manufacturer whose total eligible production of non-handheld engines [is] projected at the time of certification of a given model year to be no more than 10,000 non-handheld engines." For handheld engines, the term 'small volume engine manufacturer' means "any engine manufacturer whose total eligible production of handheld engines [is] projected at the time of certification to be no more than 25,000 handheld engines." A "small volume engine family" is any family, non-handheld or handheld, with an eligible production in any given model year of no more than 5,000 engines.


Under the Phase 1 In-use Testing Program, EPA has provided flexibility to engine manufacturers with even larger production volumes. Manufacturers whose total U.S. projected annual production for any given model year is 75,000 engines or less may test a minimum of two engines. This provision, found at 90.113(b)(2), reduces the cost of the program for manufacturers with limited production. Manufacturers with larger production volumes calculate the minimum amount of engines they need to test by following the criteria found at Section 90.113(b)(1).


Further reductions in burden are achieved by allowing engine manufacturers with annual sales of less than 50,000 engines to obtain, with EPA approval, in-use engines from sources associated with itself or its equipment manufacturers. Other engine manufactures must procure engines from sources outside of their and their equipment manufacturers' control.


There are also reductions in testing burden for small volume engine families and manufacturers under the large SI rule. Please refer to section 6(d)(4) for more details.

The provisions of part 1068 also provide flexibilities for engine and equipment manufacturers who find themselves in a difficult situation at the start of a new set of regulations. Section 1068.245, 1068.250 and 1068.255 provide additional time for manufacturers to comply with regulations if they meet a number of criteria.


Under the other programs included in this ICR, the information being requested is considered to be the minimum needed to effectively maintain the programs' integrity and comply with the requirements of the Clean Air Act. Further measures to simplify reporting requirements for small businesses do not appear prudent or necessary.


5(d) Collection Schedule


Collection frequency is largely determined by the manufacturer's marketing and product plans. Information must be submitted for each 'model year' that a manufacturer intends to build (or import) an engine model. A certificate of conformity must be obtained before the start of production (or importation). Taking these two considerations into account, manufacturers normally submit information on an annual basis and submit their applications at their earliest convenience.


Running change and correction applications are submitted by manufacturers as the need occurs. PLT reports are submitted quarterly. SEA reports are submitted on occasion, after EPA has completed an audit. Under the in-use testing program, Phase 1 engine manufacturers must submit, by January 30 of each calendar year, all emission test results generated from in-use testing. Phase 2 manufacturers need to submit their reports within 90 days of having completed all in-use testing for a given engine family, but have up to three years to complete such testing. Section 3(d) elaborates on the reasons for this collection schedule.



6. Estimating the Burden and Cost of the Collection


6(a) Estimating Respondent Burden


Burden estimates were taken from previous ICRs and adjusted to reflect experience gained by EPA and comments from fewer than ten respondents consulted by EPA. These estimates are included in Tables 2 through 10 in the attached excel sheet. The estimate for total number of responses across all programs is based on the number of responses over the last three years.


6(b) Estimating Respondent Costs


(i) Estimating Labor Costs


To estimate labor costs, EPA used the Bureau of Labor Statistics' (BLS) National Industry-specific Occupational Wage Estimates (May 2006) for the Engine and Turbines Industry under Standard Industrial Classification (SIC) code 351) and increased by a factor of 2.1 to account for benefits and overhead. A reference between the applicable SIC and NAICS codes used to update hourly rates for this ICR is available on the BLS website at: http://www.bls.gov/ppi/ppisicnaics14.htm. Mean, hourly rates were used for this estimate and are listed below.


Table 11
Labor Costs Estimates


Occupation

SOC Code Number

Mean Hourly Rate (BLS)

Rate Increased by Factor of 2.1

Mechanical Engineers

17-2141

$34.49

$72.43

Engineering Managers

11-9041

$52.52

$110.29

Lawyers

23-1011

$54.65

$114.77

Secretaries, Except Legal, Medical and Executive

43-6014

$14.25

$29.93

Mechanical Engineering Technicians

17-3027

$24.11

$50.63

Engine and Other Machine Assemblers

51-2031

$19.53

$41.01

Truck Drivers, Heavy and Tractor-Trailer

53-3032

$20.41

$42.86



(ii) Estimating Capital and Operations and Maintenance Costs


Capital costs (associated with building emission testing facilities) were incurred by manufacturers when the small SI industry became regulated for the first time. In the large SI sector and the recreational vehicles sector, those respondents that control the vast majority of the market are companies which manufacture engines regulated under other programs (such as the small SI or marine SI regulations) and have already invested in developing their own test cells. Section 6(d)(1) provides more details. The small production volume of the other respondents makes it more economical for them to contract out their testing needs than to build expensive test cells. Therefore, capital costs are excluded from this ICR. EPA does not expect any new engine manufacturers to build its own emission testing laboratories in the next three years. Other emission testing expenses are included as operation and maintenance (O&M) costs as explained below.


O&M costs associated with this information collection include diskettes, photocopying, postage and other shipping expenses, calls, maintenance of emission laboratories, and testing costs. Diskettes are used by manufacturers to submit their electronic applications and to keep records.


Engine manufacturers that have in-house testing facilities use them for all their certification and compliance testing needs as well as for research and development. The cost of maintaining these laboratories have been estimated at $69,300 per year. This estimate (which appears under the certification program estimates) includes the cost of test fuels, calibration gases and equipment.


EPA has also accounted for the cost incurred by those manufacturers who hire a contractor to conduct the necessary certification and compliance emission testing in the contractor's facilities. EPA has estimated that testing at a private facility would cost, on average, $3,100. Testing cost is a one-time cost per engine family since manufacturers can carry-over emissions data from one model year to the next. This cost has been annualized to $1,033 over the 3 year approval period requested for this ICR.


For calendar year (CY) 2008, engine manufacturers are required to pay a fee of $694 when submitting an application for a certificate of conformity. This fee is requested under the authority of the CAA Section 217. EPA recently published the new schedule of fees in the document CISD-07-01, which can be found at: http://www.epa.gov/oms/cert/dearmfr/cisd0701rev.pdf.


The fees rule provides for a reduction in fee when "the full fee exceeds 1.0 percent of the projected aggregate retail price of all vehicles or engines covered by that certificate." (69 FR 26226, Section F). The reduced fee must not exceed one percent of the aggregate retail price of the vehicles and engines covered by the certificate.


(iii) Capital/Start Up Operations and Maintenance Costs


There are no capital or start up costs associated with the renewal of this ICR. See 6(b)(ii) for details.


(iv) Annualizing capital costs


There are no capital costs associated with the renewal of this ICR. See 6(b)(ii) for details.



6(c) Estimating Agency Burden


Tables 12 through 16 in the attached excel sheet summarize EPA's overall burden associated with this ICR.


Table 17 summarizes EPA's labor costs associated with this ICR. These costs are based on 2007 hourly wage rates obtained from the Office of Personnel Management and adjusted by a factor of 1.6 to account for benefits and overhead.

Table 17
Agency Labor Costs


Occupation

Hourly Rate

Rates Increased by a Factor of 1.6

Engineer (GS-13/6)

$44.39

$71.02

Lawyers (GS-13/7)

$45.65

$73.04

Managers (GS-15)

$52.88

$84.61

SES-1

$89.42

$143.07

Senior Employee

$13.81*

$20.72*


* The salary of a senior from the Senior Environmental Employment (SEE) Program for clerical support is $13.81 per hour plus approximately 150% increase for benefits, for a total of $20.72. EPA also pays $2,151.83 as an administrative fee to the Senior Services America, Inc., the organization from which EPA’s SEE Employees are obtained. These data were obtained from HDNEG’s financial officer.




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


6(d)(1) Certification Estimates


Based on the number of emission certification applications received for model year 2007, there are 170 small SI engine manufacturers in the U.S. market today. Combined, they submitted 1,084 applications, 742 of which were carry-overs. Eleven manufacturers submitted 44 applications for large SI engines, 31 of which were carry-overs. Approximately 60 manufacturers submitted a total of 452 applications for recreational engines. Of those, about 140 were carry-overs.


To estimate the financial burden of engine testing, two primary factors were taken into account: 1) whether a manufacturer is capable of performing emission testing in-house (has its own equipment) or contracts an independent facility; and 2) the number of tests needed to demonstrate compliance. The number of tests depends on the requirements of each program, the manufacturer's projected U.S. production per engine family, and total number of engine families.


Testing equipment is used for a variety of purposes other than to respond to this information collection, such as Research and Development, and foreign certification-related testing. The total cost of maintaining these laboratories have been estimated at $69,300 per year. This estimate includes the cost of test fuels, calibration gases and equipment. The full amount was included in certification estimates.


Twenty-four small SI engine manufacturers own testing laboratories. They account for the 109 new applications for certification (non-"carry-overs”). To the small SI numbers, EPA added large SI data: all 11 manufacturers own laboratories. EPA estimates that 10 of the recreational vehicle manufacturers own testing facilities.




6(d)(2) Average, Banking and Trading


Participation in the ABT Program is voluntary for small SI and recreational vehicle manufacturers. EPA estimated that 27 small SI manufacturers and 10 recreational vehicle manufacturers will participate during the next three years. There is no ABT program for large SI, except for an early certification provision for snowmobiles.


6(d)(3) Production-line Testing


The number of tests manufacturers need to perform under the PLT program depends on several factors. However, per 90.706(b)(8); 1048.310(g)(1) and 1051.310(g)(1), the sample size need not exceed the lesser of: 1) 30 engines per engine family; or 2) one percent of the projected annual U.S. production for that engine family. The frequency of testing expressed in each burden table reflects those limits.


Table 5 accounts for small SI and large SI PLT programs. There are 168 engine manufacturers that participate in the small SI PLT program (Phase 2 only). Twenty-six of these manufacturers own testing facilities. Together, they account for 878 engine families (5 engine families per manufacturer) and perform an average of about 27 tests per engine family to comply with PLT requirements. Participation in PLT is mandatory for Phase 2 engines (not applicable to Phase 1), but it is voluntary for small volume engine families and small volume engine manufacturers.


To this estimate, EPA added 11 large SI manufacturers who should perform at least 538 tests in total. As explained above, they all own laboratories. PLT is mandatory for large SI manufacturers.


Table 6 includes PLT estimates for all recreational vehicles. EPA estimates that 50 manufacturers will contract out their testing needs and will test an average of three engines per engine family (for a total of 150 tests).


6(d)(4) In-use Testing


The in-use program requirements are different for different types of engines. In the small SI sector, there are different requirements for Phase 1 and Phase 2 engines. Participation in the program is voluntary for both. For Phase 1, manufacturers whose total projected U.S. production volume does not exceed 75,000 engines need to test a minimum of 2 engines per model year (90.113(b)(2)). Those whose total projected U.S. production exceeds 75,000 engines, follow the instruction at 90.113(b)(1) to determine the minimum number of engines they need to test.


EPA has calculated that a total of 26 manufacturers with U.S. production of less than 75,000 engines participate in the in-use program. Nine of them contract out testing services. Also, EPA estimates that only six manufacturers have projected U.S. production in excess of 75,000 engines. They need to perform an average of 16 tests per model year to comply.


Phase 2 manufacturers only need to test a minimum of three engines per engine family and can include up to 20 percent of their engine families in the program. EPA estimates that two engine manufacturers will participate with three engine families each.


Large SI manufacturers are required to conduct in-use testing. They need to test at least two engines if: 1) the manufacturer's total production is 2,000 or less; or 2) if the engine family in particular has a production volume of 500 engines or less (1068.410(c)(1)). According to the data submitted by large SI engine manufacturers this year, EPA projects they will need to perform a total of at least 632 tests.


In-use testing requirements for recreational vehicles have not been finalized yet.


6(d)(4) Selective Enforcement Audits


Regarding SEAs, EPA has not conducted small SI audits in recent years. However, EPA is now planning to conduct approximately 5 SEAs (including all three types of sectors in this ICR: small and large SI and recreational vehicles) within the next three years.




6(e) Bottom Line Burden Hours and Cost Tables


(i) Respondent Tally



Table 18
Total Estimated Respondent Burden and Cost Summary


Program

Number of Respondents

Number of Activities

Total Hours Per Year

Total Labor Cost Per Year

Total Annual Capital Costs

Total Annual O&M Costs

Total Costs

Cert (small and large SI)

181

11

147,072

$9,498,906

$0

$1,972,336

$11,471,242

Cert (Rec Vehicles)

60

10

23,230

$2,874,129

$0

$288,789

$3,162,918

ABT

37

5

12,913

$911,841

$0

$4,070

$915,911

PLT (small and large SI)

179

11

55,395

$3,521,213

$0

$4,453,511

$7,974,724

PLT (Rec Vehicles)

60

12

15,650

$1,029,648

$0

$220,525

$1,250,173

In-use Testing Phase1

26

11

10,591

$604,778

$0

$38,404

$643,182

In-use Testing Phase2

2

10

1,436

$78,965

$0

$2,804

$81,769

In-use Testing (large SI)

11

10

12,300

$605,267

$0

$19,998

$625,265

SEAs

5

8

595

$37,432

$0

$2,861

$40,293

Total

241

88

279,182

$19,162,178

$0

$7,004,857

$26,167,036



(ii) The Agency Tally



Table 19
Total Estimated Agency Burden and Cost Summary


Program

Number of Respondents

Number of Activities

Total Hours Per Year

Total Labor Cost Per Year

Total Annual Capital Costs

Total Annual O&M Costs

Total Costs

Certification

241

11

175,334

$10,375,545

$0

$154,735

$10,530,280

ABT

37

6

386

$27,414

$0

$338

$27,752

PLT

239

10

2,107

$531,878

$0

$6,936

$538,814

In-use Testing

39

9

956

$70,505

$0

$765

$71,270

SEAs

5

10

474

$34,568

$0

$15,098

$49,666

Total

241

46

179,257

$11,039,910

$0

$177,872

$11,217,782



6(f) Change in Burden


The increase in burden from the previous ICR is primarily due to the increase in the number of respondents. The estimated burden for each individual respondent has essentially remained the same. The costs associated with testing were increased by approximately 3 percent per year (from 2004 through 2007) to account for inflation.



6(g) Burden Statement


The annual public reporting and recordkeeping burden for this collection is estimated to average 1,158 hours per respondent for certification and compliance activities.



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.



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 Number EPA-HQ-OAR-2007-1183, 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. The electronic version of the public docket at www.regulations.gov can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access all documents in the public docket. 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-2007-1183 and OMB Control Number 2060-0338 in any correspondence.





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