2345t03

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Overview

Tbl2-SI Cert All
Tbl3-SI PLT
Tbl4-SEA
Tbl5-Owners,etc
Tbl6-Agency Burden
Resp Tally

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Sheet 1: Tbl2-SI Cert All

Table 2 - Annual Respondent Burden and Cost for Marine CI Category 3 Engine Certification & Special Provisions
	Hours and Cost per Application									Total Hours and Cost
Information Collection Activity	Engineer $65.20/hr	Manager $102.50/hr	Legal $100.69/hr	Clerical $25.81/hr	Respondents hr/yr	Labor Cost/yr	Capital Startup Cost	O&M Cost, Annualized (1)	Applications/Respondent (2)	Number of Respondents	Total hr/yr	Total Cost/yr
Review of regulations and guidance documents	18.0	9.0	10.0	1.0	38	$3,128.81	$0.00	$15.00	1.0	4	152	12,575
Developing eng families groups	15.0	3.0	1.0	1.0	20	$1,412.00	$0.00	$0.00	1.0	4	80	5,648
Testing/Gathering emission data on test engines	30.0	14.0	0.0	14.0	58	$3,752.34	$0.00	$0.00	1.0	2	116	7,505
Cert & Durability Testing(1)
For exhaust certification								$10,858.00	1.0	2	0	21,716
For IMO certification								$3,619.33	1.0	2	0	7,239
Analyze data to determine compliance	6.0	4.0	1.0	1.0	12	$927.70	$0.00	$0.00	1.0	2	24	1,855
Preparing and submitting certification application	2.0	0.5	1.0	1.0	5	$308.15	$0.00	$6.00	1.0	2	9	628
Preparing and submitting "carry over" applications	1.0	0.5	0.0	2.0	4	$168.07	$0.00	$3.00	1.5	2	11	513
Paying Certification Fee	0.5	0.5	0.0	0.5	3	$96.76	$0.00	$1.00	1.25	4	15	489
Certification Fee (3)								$563.00	1.25	4	0	2,815
Preparing and supporting running changes	3.0	2.0	1.0	2.0	8	$552.91	$0.00	$6.00	3.25	4	104	7,266
Preparing and Submitting Annual Production Report	5.0	2.0	1.0	2.0	10	$683.31	0	$3	1.25	4	50	3,432
Prepare and submit request for special provisions, exemptions	8	0	0	0	8	$521.60	$0	$10	0.6	1	5	$319
Label engines	1	0	0	0	1	$65.20	$0	$30	15.0	4	60	$5,712
Store, file and maintain records	3.0	1.0	1.0	7.0	12	$579.46	$0.00	$20.00	1.0	4	48	2,398
Total per respondent	92.5	36.5	16	31.5	178.0	$12,196	0	varies	varies	N/A	N/A	N/A
Total for the industry	N/A	N/A	N/A	N/A	N/A	$46,275	0	$33,835	varies	354	673.3	$80,109
(1) See section 6(b)ii for details.
(2) See section 6(d) for details.
(3) See section 6(b)(ii) for details.

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Sheet 2: Tbl3-SI PLT

Table 3 - Annual Respondent Burden and Cost - Marine CI Category 3 Production Line Testing Program
	Hours and Cost per Engine Family								Total Hours and Cost
Information Collection Activity	Engineer $65.20/hr	Manager $102.50/hr	Legal $100.69/hr	Clerical $25.81/hr	Respondents hr/yr	Labor Cost/yr	Capital Startup Cost	O&M Cost(1)	Frequency (2)	Number of Respondents	Total hr/yr	Total Cost/yr
Review of instructions and regulations	45	5	8	0	58	$4,252.02	$0.00	$0.00	1.0	4	232	$17,008.08
Training	8	0	0	0	9	$521.60	$0.00	$40.00	1.0	4	36	$2,246.40
Projecting testing needs and planning test schedules	11	1	0	1	13	$845.51	$0.00	$20.00	1.0	4	52	$3,462.04
Engine inspection	1	0	0	0	7	$65.20	$0.00	$0.00	15.0	4	420	$3,912.00
Testing								$10,858.00	15.0	4	0	$651,480.00
Data entry and analysis	8	0	0	1	9	$547.41	$0.00	$30.00	15.0	4	540	$34,644.60
Other tasks (test equipment calibration, engine repair, etc.)	4	0	0	0	64	$260.80	$0.00	$100.00	15.0	4	3,840	$21,648.00
Preparing and submitting report	8	1	1	2	12	$776.41	$0.00	$5.00	2.8	4	132	$8,595.51
Store, file and maintain records	2	0	0	3	6	$207.83	$0.00	$50.00	1.0	4	24	$1,031.32
Total per manufacturer	101	8	11	9	214	$8,745.08	$0.00	varies	varies	N/A	N/A	N/A
Total for the industry	N/A	N/A	N/A	N/A	N/A	$84,252.95	$0.00	$659,775.00	N/A	179	5,276	744,028
(1) Includes phone calls and testing costs. See section 6(b)(iii) for details.
(2) Explanation of frequencies:	1.0	= One time task
	2.8	= Estimated number of PLT reports submitted per manufacturer per year. While PLT reports are due quarterly for each engine family, most engine families do not have enough production to cover all quarters.
		Five out of eight engine families only have a projected production between 1 and 4 engines. Therefore, PLT testing for those families is completed in less than 4 quarters.
	15.0	= Number of engines tested per manufacturer (average).

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Sheet 3: Tbl4-SEA

Table 4 - Annual Respondent Burden and Cost - Selective Enforcement Auditing (SEA) Program
	Hours and Cost per Application									Total Hours and Cost
Information Collection Activity	Engineer $65.20/hr	Manager $102.50/hr	Legal $100.69/hr	Clerical $25.81/hr	Respondent hr/yr	Labor Cost/yr	Capital Startup Cost	O&M Cost(1)	Frequency (2)	Number of Respondents (3)	Total hr/yr	Total Cost/yr
Provide Pre-audit information	20	10	2	5	37	$2,659.43	$0	$0	0.3	2	22	$1,596
Review of instructions and regulations	7	1	1	0	9	$659.59	$0	$0	0.3	1	3	$198
Training	3	1	0	0	4	$298.10	$0	$32	0.3	1	1	$99
Plan activities	16	0	0	0	16	$1,043.20	$0	$32	0.3	1	5	$323
Testing	8	0	0	0	8	$521.60	$0	$10,858.00	0.3	1	2	$3,414
Data entry and analysis	22	0	0	5	27	$1,563.45	$0	$1	0.3	1	8	$469
Preparing and submitting report	18	1	1	1	21	$1,402.60	$0	$3	0.3	1	6	$422
Store, file and maintain records	8	0	0	1	9	$547.41	$0	$1	0.3	1	3	$165
Total per manufacturer	95	5	2	8	131	$7,114	$0	varies	varies	N/A	N/A	N/A
Annualized totals = total for the industry	N/A	N/A	N/A	N/A	N/A	$3,406	$0	$3,278	N/A	2	50	$6,685
(1) Includes CDs, photocopying, postage expenses, phone calls, and testing costs. See section 6(b)(iii) for details.
(2) Frequency: A frequency of 0.3 has been used to annualize the burden and costs over a 3-year period. Refer to Section 6(d)(ii) for further details.
(3) EPA estimates it will audit 1 manufacturer over the next 3 years. It might, however, request pre-audit information from more than one manufacturer.

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Sheet 4: Tbl5-Owners,etc

Table 5 - Annual Respondent Burden and Cost - Vessel Owners, Operators & Engine Rebuilders
	Hours and Cost per Application									Total Hours and Cost
Information Collection Activity	Engineer $65.20/hr	Manager $102.50/hr	Legal $100.69/hr	Clerical $25.81/hr	Respondent hr/yr	Labor Cost/yr	Capital Startup Cost	O&M Cost(1)	Frequency (2)	# of Respondents (3)	Total hr/yr	Total Cost/yr
Review of instructions and regulations	3	1	1	0	5	$398.79	$0	$10	1.0	192	960	$78,488
Owners & Operators
Inform EPA of malfunctions & other special events	4	1	1	2	8	$515.61	$0	$10	1.0	187	1,496	$98,289
Conduct Annual Records Review	10	3	3	5	21	$1,390.62	$0	$100	1.0	187	3,927	$278,746
Prepare and submit report	3	1	1	5	10	$527.84	$0	$30	1.0	187	1,870	$104,316
Owners, Ops & Rebuilders: Store, file and maintain records	15	5	5	30	55	$2,768.25	$0	$50	1.0	192	10,560	$541,104
Total per manufacturer	95	5	2	8	99	$7,114	$0	varies	varies	N/A	N/A	N/A
Annualized totals = total for the industry	N/A	N/A	N/A	N/A	N/A	$1,063,243	$0	$37,700	N/A	192	18,813	$1,100,943
(1) Includes CDs, photocopying, postage expenses, phone calls, and testing costs.
(2) Frequency: A frequency of 1 has been used to denote an annual event.
(3) EPA estimates it will audit 1 manufacturer over the next 3 years. It might, however, request pre-audit information from more than one manufacturer.

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Sheet 5: Tbl6-Agency Burden

Table 6 - Annual Agency Burden and Cost
Marine CI Category 3 Program
Employee	Hours and Labor Cost
	Level	Rate	Rate Increase by 1.6	Number of Employees	Full time hours	% of Time	Total hr/yr	Total Labor cost/yr
Engineer	GS-13/6	$55.46	$79.55	1	2080	7.0%	145.6	$11,582
Contracts/Compliance	GS-13/7	$51.19	$79.55	1	2080	1.5%	31.2	$2,482
Attorney	GS-13/7	$51.14	$81.82	1	2080	1.0%	20.8	$1,702
Managers	GS-15/1	$59.30	$94.78	1	2080	1.0%	20.8	$1,971
SES-1	SES - 1	$96.01	$153.62	1	2080	0.5%	10.4	$1,598
IT Support	GS-14/1	$50.41	$79.55	1	2080	1.0%	20.8	$1,655
Contract Support								$83,000
Subtotal				6	N/A	N/A	250	$103,990
O&M Costs
Testing	(for one in-use test or confirmatory testing in three years, annualized)							$3,619
Other								$20,000
SEE Support								$2,000
Contract Support - Compliance								$1,151
Contract Support -Certification								$3,030
							Subtotal:	$29,800
							TOTAL:	$133,790

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Sheet 6: Resp Tally

Table 7
Respondent Burden Tally
Program	Number of Respond.	Number of Activities	Total Hours Per Year	Total Labor Cost Per Year	Total Annual Capital Costs	Total Annual O&M Costs	Total Costs
Certification	4	13	673	46,275	-	33,835	80,109
PLT	4	9	5,276	84,253	-	659,775	744,028
SEAs	1	8	50	3,406	-	3,278	6,685
Owners, Ops & Rbldrs	192	5	18,813	1,063,243	-	37,700	1,100,943
Totals:	201	35	24,813	1,197,177	-	734,588	1,931,765
	Hours per respondent:		123