These standards specify physical
requirements for the VIN and its installation format and content to
simplify information retrieval and increase the efficiency of
defect recall campaigns and identify likely high theft
vehicles.
When it last sought approval
for this information collection, the agency projected that it would
cost industry $13,348,000.to comply with the labelling and
reporting requirements of Parts 565 and 567. This was based on the
assumption that it would take a manufacturer one minute to affix
the certification label to a vehicle and that there would be 14.2
million vehicles labelled in this fashion per year. We have
adjusted the time needed to label each vehicle from one to three
minutes to also account for the time needed to assemble the
information to be included on the label and to print the label
before it is affixed to the vehicle. Additionally, the vehicle
count has been reduced to 12,000,000 vehicles per year to better
reflect e actual sales figures for the U.S. portion of the North
American market over the past three years. In its last request for
approval of this information collection, the agency also estimated
that it would take a manufacturer 10 hours to assemble the
VIN-deciphering information needed to be submitted under Part 565,
and that such information would be submitted by 1,104 manufacturers
per year. The current estimate is based on the assumption that it
would take the typical manufacturer one hour to assemble the
required information. This reduced estimate takes into account the
fact that most manufacturers submitting VIN-deciphering information
to the agency are small manufacturers of vehicles such as trailers,
and that these manufacturers do not produce an extensive range of
vehicles, as the major automotive companies do. As a consequence,
the prior estimate of the time that would need to be expended by
the great majority of companies that submit Part 565
VIN-deciphering information to the agency was greatly in excess of
what is estimated to be needed at the present time. In addition,
the agency has prepared and disseminated comprehensive guidance to
members of the industry on how to configure VINs and how to report
VIN-deciphering information to the agency, reducing the time that
would need to be expended in meeting the reporting requirement.
Finally, the current estimate is based on the agency's assumption
that it would receive 562 Part 565 submissions per year, as opposed
to the 1,104 submission estimated in the prior request for
approval. The current figure was reached by taking the average of
the approximate number of Part 565 submissions made in each of the
past three years (650 submission in 2011, 500 in 2012, and 475 in
2013; 650+500+475=1,625; 1,625/3=542). The prior request for
approval also stated that there is no annualized cost to the
Federal Government for the information collections associated with
Parts 565 and 567, as the labelling requirements are met by motor
vehicle manufacturers and there is no exchange of correspondence,
tabulation of data or response necessary from the agency. This
failed to take account of the fact that manufacturers do submit
VIN-deciphering information to the agency under Part 565, and the
review and processing of that information does consume agency
resources.
$29,117
No
No
No
No
No
Uncollected
coleman sachs 202
366-3151
No
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.