| Table 5 - Annual Respondent Burden and Cost |
| CI Exhaust Emissions Certification & AB&T Programs - All Industries Except Alternative Fuels & HD GHG |
| Information Collection Activity |
Burden and Cost per Application |
Total Burden and Cost |
| Engineer |
Manager |
Legal |
Mechanical Engineering Technician |
Truck Driver |
Assembler |
Clerical |
Respondent hr/yr |
Labor Cost/yr |
Capital Startup Cost |
O & M Cost1 |
Frequency or Applications/Respondent2 |
Number of Respondents |
Total hr/yr |
Total Cost/yr |
| Rate/hour |
Rate/hour |
Rate/hour |
Rate/hour |
Rate/hour |
Rate/hour |
Rate/hour |
| $88.01 |
$132.91 |
$168.46 |
$60.10 |
$40.67 |
$39.35 |
$40.38 |
| Certification |
| Review of regulations and guidance documents |
16 |
9 |
10 |
4 |
0 |
0 |
1 |
40 |
$4,570 |
$0 |
$5 |
2.0 |
103 |
8,240 |
$942,394 |
| Developing engine family groups |
5 |
1 |
0 |
0 |
0 |
0 |
1 |
7 |
$613 |
$0 |
$0 |
1.0 |
103 |
721 |
$63,174 |
| Developing deterioration factors |
30 |
5 |
0 |
38 |
2 |
0 |
3 |
78 |
$5,791 |
$0 |
$5 |
2.1 |
103 |
17,018 |
$1,264,616 |
| In-houseTesting3 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Testing/Gathering
emission data |
10 |
7 |
0 |
60 |
4 |
1 |
14 |
95 |
$6,144 |
$0 |
$5 |
2.5 |
56 |
13,395 |
$867,075 |
Laboratory
maintenance |
|
$81,237 |
1.0 |
56 |
0 |
$4,533,013 |
| Outsourced Testing Costs, Annualized4 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| HD and NR |
|
$15,982 |
3.5 |
8 |
0 |
$447,487 |
| Marine CI |
|
$17,970 |
3.0 |
10 |
0 |
$539,110 |
| HD Evaporative |
|
|
|
|
|
|
|
|
|
|
$2,689 |
0.6 |
9 |
0 |
$14,520 |
| Analyze data to determine compliance |
5 |
6 |
1 |
0 |
0 |
0 |
1 |
13 |
$1,446 |
$0 |
$0 |
2.1 |
93 |
2,561 |
$284,931 |
| Preparing and submitting certification application and fee filing form |
5 |
1 |
0 |
0 |
0 |
0 |
4 |
10 |
$668 |
$0 |
$4 |
10.4 |
93 |
9,206 |
$651,192 |
| 4Preparing and submitting "carry over" applications |
1 |
0 |
0 |
0 |
0 |
0 |
2 |
3 |
$169 |
$0 |
$5 |
8.3 |
93 |
2,316 |
$134,150 |
| Application Fee5 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| HD Federal |
|
$55,892 |
3.1 |
8 |
0 |
$1,397,300 |
| HD California only |
|
$563 |
0.8 |
8 |
0 |
$3,378 |
| HD Evaporative |
|
$563 |
0.8 |
6 |
0 |
$2,815 |
| NRCI |
|
$2,940 |
9.3 |
40 |
0 |
$1,087,800 |
| Marine CI (All Categories) |
|
$563 |
10.7 |
29 |
0 |
$174,530 |
| Locomotives |
|
$563 |
4.1 |
15 |
|
$34,343 |
| Preparing and supporting running changes |
4 |
1 |
1 |
2 |
0 |
0 |
1 |
9 |
$784 |
$0 |
$6 |
11.6 |
103 |
10,167 |
$944,870 |
| Answer questions related to EPA's confirmatory testing |
5 |
3 |
2 |
0 |
0 |
0 |
0 |
10 |
$1,176 |
$0 |
$10 |
2.0 |
10 |
200 |
$23,714 |
| Compliance Programs |
| Preparing and Submitting Annual Production Report |
12 |
2 |
1 |
0 |
0 |
0 |
2 |
17 |
$1,571 |
$0 |
$3 |
1.0 |
103 |
1,751 |
$162,138 |
| Preparing and Submitting AB&T Reports |
90 |
8 |
6 |
0 |
0 |
0 |
50 |
154 |
$12,014 |
$0 |
$50 |
1.0 |
33 |
5,082 |
$398,110 |
| SEAs |
95 |
5 |
2 |
79 |
2 |
2 |
8 |
191 |
$14,515 |
$0 |
$16,970 |
1.0 |
2 |
382 |
$62,969 |
| Recordkeeping |
| Store, file and maintain records |
15 |
10 |
4 |
2 |
2 |
2 |
51 |
84 |
$5,584 |
$0 |
$1,000 |
1.0 |
103 |
8,652 |
$678,153 |
| Total per respondent |
293 |
58 |
27 |
185 |
10 |
5 |
138 |
710 |
$55,045 |
$0 |
varies |
varies |
N/A |
N/A |
N/A |
| Total for the industry |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
$6,320,651 |
$0 |
$8,391,133 |
varies |
103 |
79,691 |
$14,711,784 |
| 1Includes phone calls, lab maintenance and testing limited to GHG certification. Other lab-related costs have already been accounted for in the general certification collection, ICR 1684. See section 6(b)(ii) for details. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| 2See section 6(d) for details. Frequency refers to the number of times a respondent performs each task per year. In most instances, this is tied to the number of certification applications in each category, except when in one-time tasks or tasks that apply all applicactions, such as reviewing regulations. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| 3Some manufacturers, usually large companies with many engine families, invest in in-house testing laboratories for compliance testing as well as research & development. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| 4 Some manufacturers, usually smaller companies, hire outside laboratories for testing. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| 5Carry over applications are generally a copy of the previous year application except for the first letter of the engine family name. The submittal of certification applications is already accounted for in the certification ICR. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Table 6 - Annual Respondent Burden and Cost |
| HD Engines Certification & Compliance |
| Information Collection Activity1 |
Burden and Cost per Application |
Total Burden and Cost |
| Engineer |
Manager |
Legal |
Mechanical Engineering Technician |
Clerical |
Respondent hr/yr |
Labor Cost/yr |
Capital Startup Cost |
O & M Cost2 |
Frequency or Applications/Respondent3 |
Number of Respondents |
Total hr/yr |
Total Cost/yr |
| Rate/hour |
Rate/hour |
Rate/hour |
Rate/hour |
Rate/hour |
| $88.01 |
$132.91 |
$168.46 |
$60.10 |
$40.38 |
| Review of regs and guidance document |
8.0 |
3.0 |
1.0 |
1.0 |
0.0 |
13.0 |
$1,331 |
$0 |
$20 |
1.0 |
7 |
91 |
$9,460 |
| Testing/Gathering emission data on test engines |
8.0 |
1.0 |
0.0 |
8.0 |
1.0 |
18.0 |
$1,358 |
$0 |
$1,000 |
0.3 |
7 |
33 |
$4,363 |
| Analyze data to determine compliance |
1.0 |
0.5 |
0.0 |
0.0 |
0.0 |
1.5 |
$154 |
$0 |
$0 |
0.3 |
7 |
3 |
$286 |
| Adding GHG data to new, non carry-over certification applications |
0.5 |
0.0 |
0.0 |
0.0 |
0.0 |
0.5 |
$44 |
$0 |
$2 |
0.3 |
7 |
1 |
$85 |
| Carry over applications4 |
0.0 |
0.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
$0 |
5.3 |
7 |
0 |
$0 |
| Prepare & Review GHG Compliance Plan |
1.0 |
1.0 |
0.0 |
0.0 |
0.0 |
2.0 |
$221 |
$0 |
$5 |
1.0 |
7 |
14 |
$1,581 |
| Preparing and supporting running changes/corrections |
7.0 |
5.0 |
1.0 |
3.0 |
8.0 |
24.0 |
$1,952 |
$0 |
$2 |
1.0 |
5 |
120 |
$9,772 |
| Submitting AB&T and Production Reports |
4.0 |
1.0 |
0.0 |
0.0 |
0.0 |
5.0 |
$485 |
$0 |
$5 |
1.0 |
7 |
35 |
$3,430 |
| Store, file and maintain records |
0.0 |
0.0 |
0.0 |
0.0 |
2.0 |
2.0 |
$81 |
$0 |
$10 |
1.0 |
7 |
14 |
$635 |
| Total per manufacturer |
30 |
12 |
2 |
12 |
11 |
66 |
5,627 |
0 |
$307 |
varies |
N/A |
N/A |
N/A |
| Total for the industry |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
$27,468 |
$0 |
$2,144 |
1.9 |
7 |
311 |
29,612 |
| 1This table accounts for the incremental cost of adding GHG data to the HD certification application. Other certification burden and costs are accounted for on Table 5, Certification. |
|
|
|
|
|
|
|
|
|
|
|
|
|
| 2Includes phone calls, lab maintenance and testing limited to GHG certification. Other lab-related costs have already been accounted for in Table 5, Certification. |
|
|
|
|
|
|
|
|
|
|
|
|
|
| 3See section 6(d) for details. Frequency refers to the number of times a respondent performs each task per year. In most instances, this is tied to the number of certification applications in each category, except when in one-time tasks or tasks that apply all applicactions, such as reviewing regulations. |
|
|
|
|
|
|
|
|
|
|
|
|
|
| 4Carry over applications are generally a copy of the previous year application except for the first letter of the engine family name. The submittal of certification applications is already accounted for in the certification ICR. |
|
|
|
|
|
|
|
|
|
|
|
|
|
| Table 7 - Annual Respondent Burden and Cost |
| Pickups & Vans Certification & Compliance |
| Information Collection Activity |
Burden and Cost per Application |
Total Burden and Cost |
| Engineer |
Manager |
Legal |
Mechanical Engineering Technician |
Clerical |
Respondent hr/yr |
Labor Cost/yr |
Capital Startup Cost |
O & M Cost1 |
Frequency or Applications/Respondent2 |
Number of Respondents |
Total hr/yr |
Total Cost/yr |
| Rate/hour |
Rate/hour |
Rate/hour |
Rate/hour |
Rate/hour |
| $88.01 |
$132.91 |
$168.46 |
$60.10 |
$40.38 |
| Review of regulations and guidance |
8.0 |
3.0 |
1.0 |
1.0 |
0.0 |
13 |
$1,331 |
$0.00 |
$10 |
2.6 |
42 |
1,420 |
$146,478 |
| Test/Gather emission data on test vehicles |
| Pickups/Vans |
|
| Dyno Testing |
12.0 |
4.0 |
0.0 |
8.0 |
0.0 |
24 |
$2,069 |
$0.00 |
$100 |
2.6 |
7 |
432 |
$39,034 |
| Coast Down Testing |
2.0 |
2.0 |
0.0 |
10.0 |
0.0 |
14 |
$1,043 |
$0.00 |
$500 |
2.6 |
7 |
255 |
$28,080 |
| Vocational Vehicles |
|
| Tire Testing (ISO28580) |
2.0 |
1.0 |
0.0 |
8.0 |
|
11 |
$309 |
$0.00 |
$321 |
0.1 |
31 |
47 |
$2,709 |
| Collect, Input GEM Data & Run Model |
20.0 |
4.0 |
0.0 |
0.0 |
0.0 |
24 |
$2,292 |
$0.00 |
$0 |
0.1 |
31 |
103 |
$9,855 |
| Combination Tractors |
|
| Coefficient of Drag Tests: |
|
| - Coast Down Testing |
0.0 |
0.0 |
0.0 |
0.0 |
0.0 |
0 |
$- |
$0.00 |
$1,658 |
0.4 |
4 |
0 |
$2,918 |
| - Wind Tunnel Testing |
8.0 |
2.0 |
0.0 |
0.0 |
0.0 |
10 |
$970 |
$0.00 |
$21,411 |
0.4 |
4 |
18 |
$39,390 |
| - Cfd (initial drawing) |
8.0 |
4.0 |
0.0 |
0.0 |
0.0 |
12 |
$1,236 |
$0.00 |
$5,352 |
0.4 |
4 |
21 |
$11,594 |
| - Cfd (layers) |
2.0 |
1.0 |
0.0 |
0.0 |
0.0 |
3 |
$309 |
$0.00 |
$535 |
0.4 |
4 |
5 |
$1,486 |
| Tire Testing ISO 28580 |
6.0 |
2.0 |
0.0 |
0.0 |
0.0 |
8 |
$794 |
$0.00 |
$321 |
0.4 |
4 |
14 |
$1,962 |
| Collect Data & Run GEM |
20.0 |
4.0 |
0.0 |
0.0 |
0.0 |
24 |
$2,292 |
$0.00 |
$2 |
0.4 |
4 |
42 |
$4,037 |
| Prepare & submit certification applications |
| Analyze data to determine compliance |
16.0 |
4.0 |
2.0 |
2.0 |
0.0 |
24 |
$2,397 |
$0.00 |
$0 |
1.0 |
6 |
144 |
$14,382 |
| Prepare and submit new, non-carryover certification applications |
1.0 |
0.3 |
0.3 |
0.3 |
0.5 |
2 |
$199 |
$0.00 |
$2 |
1.0 |
6 |
14 |
$1,203 |
| Prepare and submit "carryover" application (3) |
0.0 |
0.0 |
0.0 |
0.0 |
0.0 |
0 |
$- |
$0.00 |
$0 |
3.2 |
42 |
0 |
$0 |
| Labeling Requirements |
0.0 |
0.0 |
0.0 |
0.0 |
0.0 |
0 |
$- |
$0.00 |
$10 |
3.3 |
42 |
0 |
$1,386 |
| Prepare & Review GHG Compliance Plan (pick up mfrs only) |
9.0 |
8.0 |
1.0 |
0.0 |
1.0 |
19 |
$2,064 |
$0.00 |
$5 |
1.0 |
7 |
133 |
$14,484 |
| Preparing and supporting running changes/corrections |
7.0 |
5.0 |
1.0 |
3.0 |
8.0 |
24 |
$1,952 |
$0.00 |
$2 |
3.0 |
20 |
1,440 |
$117,265 |
| Store, file and maintain records |
3.0 |
0.5 |
0.5 |
0.5 |
7.0 |
12 |
$727 |
$0.00 |
$10 |
1.0 |
42 |
483 |
$30,972 |
| Total per manufacturer |
124 |
45 |
6 |
33 |
17 |
224 |
$19,983 |
$0 |
$14,541 |
varies |
N/A |
N/A |
N/A |
| Total for the industry |
N/A |
N/A |
N/A |
|
N/A |
N/A |
$400,359 |
$0 |
$66,877 |
3.3 |
42 |
4,571 |
$467,236 |
| 1Includes expenses such phone calls, printing costs and testing limited to GHG certification, annualized. See section 6(b)(ii) for details. |
|
|
|
|
|
|
|
|
|
|
|
|
|
| 2See section 6(d) for details. Frequency refers to the number of times a respondent performs each task per year, usually equal to the number of applications or reports per respondent per year. |
|
|
|
|
|
|
|
|
|
|
|
|
|
| 3Carry over applications are generally a copy of the previous year application except for the first letter of the engine family name. The submittal of certification applications is already accounted for in the certification ICR. |
|
|
|
|
|
|
|
|
|
|
|
|
|
| Table 8 - Annual Respondent Burden and Cost |
| Marine CI & Locomotive Production Line Testing Program |
| Information Collection Activity |
Burden and Cost per Application |
Total Burden and Cost |
| Engineer |
Manager |
Legal |
Mechanical Engineering Technician |
Truck Driver |
Assembler |
Clerical |
Respondent hr/yr |
Labor Cost/yr |
Capital Startup Cost |
O & M Cost1 |
Frequency or Applications/Respondent2 |
Number of Respondents |
Total hr/yr |
Total Cost/yr |
| Rate/hour |
Rate/hour |
Rate/hour |
Rate/hour |
Rate/hour |
Rate/hour |
Rate/hour |
| $88.01 |
$132.91 |
$168.46 |
$60.10 |
$40.67 |
$39.35 |
$40.38 |
| Review of instructions and regulations |
20 |
4 |
6 |
0 |
0 |
0 |
0 |
30 |
$3,303 |
$0 |
$0 |
1 |
25 |
750 |
$82,565 |
| Training |
8 |
0 |
0 |
0 |
1 |
0 |
0 |
9 |
$745 |
$0 |
$30 |
1 |
25 |
225 |
$19,369 |
| Projecting testing needs and planning test schedules |
11 |
5 |
0 |
1 |
0 |
0 |
0 |
17 |
$1,693 |
$0 |
$5 |
3.5 |
25 |
1487.5 |
$148,554 |
| Engine selection and transport |
4 |
0 |
0 |
0 |
1 |
1 |
1 |
7 |
$472 |
$0 |
$1 |
3.5 |
25 |
612.5 |
$41,426 |
| Engine inspection |
1 |
0 |
0 |
0 |
6 |
0 |
0 |
7 |
$332 |
$0 |
$0 |
3.5 |
25 |
612.5 |
$29,053 |
| Testing |
| Testing (In-house)3 |
8 |
0 |
0 |
0 |
12 |
2 |
0 |
22 |
$1,271 |
$0 |
$100 |
4 |
15 |
1320 |
$82,249 |
| Data entry and analysis |
8 |
0 |
0 |
1 |
0 |
0 |
0 |
9 |
$764 |
$0 |
$5 |
4 |
15 |
540 |
$46,151 |
| Other tasks (test equipment calibration, engine repair, etc.) |
1 |
0 |
0 |
0 |
93 |
0 |
0 |
94 |
$3,870 |
$0 |
$5 |
1 |
15 |
1410 |
$58,130 |
| Testing (Contract out)4 |
8 |
1 |
0 |
5 |
0 |
0 |
0 |
14 |
$1,137 |
$0 |
$17,970 |
2.8 |
10 |
392 |
$535,019 |
| Preparing and submitting report |
8 |
1 |
1 |
2 |
0 |
0 |
0 |
12 |
$1,126 |
$0 |
$5 |
3.5 |
25 |
1050 |
$98,932 |
| Recordkeeping |
| Store, file and maintain records |
4 |
2 |
0 |
3 |
0 |
1 |
10 |
20 |
$1,241 |
$0 |
$2 |
1 |
25 |
500 |
$31,083 |
| Total per manufacturer |
108 |
7 |
9 |
7 |
113 |
4 |
1 |
249 |
$15,954 |
$0 |
varies |
varies |
N/A |
N/A |
N/A |
| Total for the industry |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
$661,223 |
$0 |
$511,307 |
N/A |
25 |
8899.5 |
$1,172,530 |
| 1Includes photocopying, postage expenses, phone calls, testing costs and some lab costs, annualized. Most lab costs for in-house testing are accounted for in Table 5, Certification. See section 6(b)(iii) for details. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| 2Frequency: 1 = one time tasks; 4 = tasks carried out quarterly; other # = based on actual number of tests. Refer to Section 6(d) for further detail. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| 3Some manufacturers, usually large companies with many engine families, invest in in-house testing laboratories for compliance testing as well as research & development. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| 4 Some manufacturers, usually smaller companies, hire outside laboratories for testing. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Table 9 - Annual Respondent Burden and Cost |
| Manufacturer-run In-use Testing Program for HD Engines/Vehicles |
| Information Collection |
Hour and Cost per Response |
Total Hours and Cost |
| Activity |
Description |
Burden Hours per Vehicle Tested |
Cost per vehicle |
Cost for 5 vehicles (minimum for in-use each test) |
Number of Respondents (3) |
Total hr/yr |
Total Cost/yr |
| Vendor Cost |
Vendor supplies PEMS equipment, all expendables; Installs, operate, removes equipment. Maintains and calibrates equipment, analyzes data, supplies draft EPA submittal files, a test summary, and all backup QA/QC documentation. Travel time and travel costs included. |
|
$48,000 |
$240,000 |
6 |
|
$1,440,000 |
| Vehicle manufacturer staff travel |
Inspection and testing - varies by locaction, this is an estimate of an average |
|
$1,150 |
$5,750 |
6 |
|
$34,500 |
| Customer incentive |
Voluntary payment to customers lending their vehicles for testing. |
|
$1,000 |
$5,000 |
6 |
|
$30,000 |
| Replacement vehicle rental |
For customer to use during equipment installation |
|
$250 |
$1,250 |
6 |
|
$7,500 |
| Vehicle manufacturer hours |
60 hours per vehicle for recruiting, inspection, testing, data review and submission, test follow up, etc |
58 |
$10,500 |
$52,500 |
6 |
348 |
$315,000 |
| Recordkeeping |
|
2 |
$362 |
$1,810 |
6 |
12 |
$10,862.07 |
| Total per respondent |
N/A |
60 |
$61,262 |
$306,310 |
N/A |
N/A |
N/A |
| Total for the industry |
N/A |
N/A |
N/A |
N/A |
6 |
360 |
$1,837,862 |
|
|
|
|
|
|
|
|
|
Total Labor Cost: |
$65,172 |
|
|
|
|
|
|
Total O&M Costs: |
$1,772,690 |
|
|
|
|
|
| Table 10 - Defects Respondent Burden and Cost |
| All Industries |
| Information Collection Activity |
Burden and Cost per Application |
Total Burden and Cost |
| Engineer |
Manager |
Legal |
Clerical |
Respondent hr/yr |
Labor Cost/yr |
Capital Startup Cost |
O & M Cost1 |
Frequency or
Reports per Respondent2 |
Number of Respondents |
Total hr/yr |
Total Cost/yr |
| Rate/hour |
Rate/hour |
Rate/hour |
Rate/hour |
| $88.01 |
$132.91 |
$168.46 |
$40.38 |
|
|
|
|
|
|
|
|
|
|
|
|
|
| IC 1: Investigation Reports & Defect Information Reports (DIRs) |
| Review of instructions and regulations |
10 |
8 |
3 |
0 |
21 |
$2,449 |
$0 |
$0 |
1.0 |
35 |
735 |
$85,707 |
| Compile Data |
44 |
12 |
0 |
0 |
56 |
$5,467 |
$0 |
$43 |
1.9 |
35 |
3,724 |
$366,407 |
| Prepare and submit reports |
12 |
4 |
2 |
5 |
23 |
$2,127 |
$0 |
$11 |
1.9 |
35 |
1,530 |
$142,124 |
| Review reports |
3.2 |
1.5 |
1 |
1 |
7 |
$690 |
$0 |
$0 |
1.9 |
35 |
446 |
$45,874 |
| Recordkeeping |
1 |
0 |
0 |
2 |
3 |
$169 |
$0 |
$2 |
1.0 |
35 |
105 |
$5,986 |
| IC #2:Remedial Plans & Recall Reports |
| Review regulations |
14 |
6 |
2 |
0 |
22 |
$2,367 |
$0 |
$0 |
1.0 |
6 |
132 |
$14,199 |
| Compile Data |
24 |
5 |
0 |
0 |
29 |
$2,777 |
$0 |
$43 |
4.1 |
6 |
713 |
$69,355 |
| Prepare and submit report Remedial Plan |
8 |
5 |
2 |
3 |
18 |
$1,827 |
$0 |
$11 |
4.1 |
6 |
443 |
$45,198 |
| Prepare and submit report VERR updates |
15 |
7 |
2 |
2 |
26 |
$2,668 |
$0 |
$11 |
6.0 |
6 |
936 |
$96,438 |
| Maintain Owner Records |
2 |
2 |
0 |
40 |
44 |
$2,057 |
$0 |
$2 |
4.1 |
6 |
1,082 |
$50,659 |
| Recordkeeping |
| Recordkeeping |
1 |
0 |
0 |
2 |
3 |
$169 |
$0 |
$2 |
1.0 |
6 |
18 |
$1,026 |
| Total per manufacturer |
134 |
51 |
12 |
55 |
252 |
$22,765.32 |
0 |
$123.68 |
varies |
N/A |
N/A |
N/A |
| Total for the Industry |
N/A |
N/A |
N/A |
N/A |
N/A |
$917,600 |
$0 |
$5,372 |
varies |
$29 |
9,864 |
$922,973 |
|
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|
0.275 |
|
|
| Table 11- Respondent Burden and Cost |
| Alternative Fuel Conversions - Beginning-of-Useful-Life Conversions |
| Information Collection Activity |
Total Burden and Cost |
| Labor Cost/yr |
Capital Startup Cost |
O & M Cost1 |
Frequency or Applications/Respondent2 |
Number of Respondents |
Total hr/yr |
Total Cost/yr |
| General Tasks |
| Review of regulations and guidance documents |
$3,027 |
$0 |
$0 |
1.0 |
8 |
188 |
$24,217 |
| Developing engine family groups |
$309 |
$0 |
$0 |
1.4 |
8 |
34 |
$3,460 |
| Analyze data to determine compliance |
$1,534 |
$0 |
$0 |
1.4 |
8 |
157 |
$17,185 |
| Preparing and submitting certification application and fee filing form |
$404 |
$0 |
$4 |
1.4 |
8 |
73 |
$4,570 |
| Preparing and submitting "carry over" applications |
$44 |
$0 |
$4 |
0.4 |
8 |
2 |
$154 |
| Preparing and supporting running changes |
$389 |
$0 |
$6 |
1.0 |
4 |
22 |
$1,579 |
| Beginning of Useful Life Conversions - New Applications Only |
| Test Cost (annualized)3 |
$0 |
$0 |
$10,900 |
2.5 |
4 |
0 |
$109,000 |
| OBD Compliance Demo |
$176 |
$0 |
$200 |
2.5 |
4 |
20 |
$3,760 |
| Engine Shipping Costs |
$0 |
$0 |
$833 |
2.5 |
4 |
0 |
$8,333 |
| Lodging for employees to oversee testing |
$0 |
$0 |
$83 |
2.5 |
4 |
0 |
$833 |
| Fee |
$0 |
$0 |
$47,664 |
2.5 |
4 |
0 |
$476,640 |
| Intermediate Age Conversions - New applications Only |
| Cost of OBD Scan Tool software updates (annualized) |
$128 |
$0 |
$183 |
1.0 |
1 |
2 |
$311 |
| Scan OBD and print results |
$176 |
$0 |
$0 |
1.0 |
1 |
2 |
$176 |
| Recordkeeping |
| Store, file and maintain records |
$1,447 |
$0 |
$5 |
1.0 |
8 |
152 |
$11,613 |
| Total per response (eng family) |
$7,634 |
$0 |
$59,883 |
varies |
N/A |
N/A |
N/A |
| Total for the industry |
$64,720 |
$0 |
$597,111 |
varies |
8 |
651 |
$661,831 |
| 1Includes phone calls, lab maintenance and testing limited to GHG certification. Other lab-related costs have already been accounted for in the general certification collection, ICR 1684. See section 6(b)(ii) for details. |
|
|
|
|
|
|
|
| 2See section 6(d) for details. Frequency refers to the number of times a respondent performs each task per year. In most instances, this is tied to the number of certification applications in each category, except when in one-time tasks or tasks that apply all applicactions, such as reviewing regulations. |
|
|
|
|
|
|
|
| 3Exhaust Testing only. Evap Certification is accounted for in Table 5 Certification. |
|
|
|
|
|
|
|
| Table 11 - Annual Respondent Burden and Cost |
| Transition Program for Equipment Manufacturers - Equipment Manufacturers |
| Information Collection Activity |
Burden and Cost per Application |
Total Burden and Cost |
| Engineer |
Manager |
Legal |
Clerical |
Respondent hr/yr |
Labor Cost/yr |
Capital Startup Cost |
O & M Cost1 |
Number of Respondents |
Total hr/yr |
Total Cost/yr |
| Rate/hour |
Rate/hour |
Rate/hour |
Rate/hour |
| $88.01 |
$132.91 |
$168.46 |
$40.38 |
| Equipment Manufacturers |
| Review of regulations, contact EPA for guidance |
12 |
5 |
5 |
1 |
23 |
$2,603 |
0 |
$17 |
107 |
2,461 |
$280,377 |
| Select an allowance |
3 |
5 |
3 |
0 |
11 |
$1,434 |
0 |
$- |
20 |
220 |
$28,679 |
| Notify EPA of participation |
1 |
1 |
1 |
1 |
4 |
$430 |
0 |
$5 |
20 |
80 |
$8,695 |
| Prepare and send letter to engine manufacturer |
5 |
1 |
0 |
1 |
7 |
$613 |
0 |
$3 |
107 |
749 |
$65,948 |
| Post Bonds (foreign OEMs only) |
1 |
3 |
5 |
10 |
19 |
$1,733 |
0 |
$5,000 |
50 |
950 |
$336,642 |
| Apply for Bond Waivers |
0.5 |
0 |
0 |
1 |
1.5 |
$84 |
0 |
$2 |
10 |
15 |
$864 |
| Keep track of exempt equipment/gather information |
10 |
5 |
2 |
25 |
42 |
$2,891 |
0 |
$5 |
107 |
4,494 |
$309,879 |
| Develop and submit final calculations (Annual Report) |
5 |
1 |
0 |
3 |
9 |
$694 |
0 |
$3 |
107 |
963 |
$74,590 |
| Prepare Hardship Relief Requests (annualized) |
25 |
10 |
25 |
20 |
80 |
$8,548 |
0 |
$15 |
2 |
160 |
$17,127 |
| Meet with EPA staff to answer questions (annualized) |
3 |
1 |
0 |
1 |
5 |
$437 |
0 |
$1,200 |
6 |
30 |
$9,824 |
| Gather additional Data (annualized) |
1.5 |
0.5 |
0 |
1 |
3 |
$239 |
0 |
$3 |
6 |
18 |
$1,451 |
| Engine Manufacturers |
| Review of regulations, contact EPA for guidance |
40 |
5 |
5 |
0 |
50 |
$4,724.95 |
0 |
$17 |
25 |
1250 |
$118,549 |
| Keep track of engines to be used in exempt equipment/gather information |
20 |
7 |
0 |
35 |
62 |
$3,880.46 |
0 |
$5 |
25 |
1550 |
$97,137 |
| Develop and submit reports |
5 |
3 |
0 |
3 |
11 |
$899.87 |
0 |
$3 |
25 |
275 |
$22,572 |
| Recordkeeping |
| Recordkeeping |
8 |
3 |
2 |
20 |
33 |
$2,247 |
0 |
$5 |
107 |
1,432 |
$240,999 |
| Total per respondent |
140 |
51 |
48 |
122 |
361 |
$31,460 |
0 |
$6,283 |
N/A |
N/A |
N/A |
| Total for the industry |
N/A |
N/A |
N/A |
N/A |
N/A |
$1,351,810 |
0 |
$261,524 |
107 |
14,647 |
$1,613,334 |
| 1Includes costs such as phone calls and photocopying. See section 6(b)(ii) for details. |
|
|
|
|
|
|
|
|
|
|
|
| Table 13 - Annual Respondent Burden and Cost |
| Special Compliance Provisions |
| Information Collection Activity |
Burden and Cost per Application |
Total Burden and Cost |
| Engineer |
Manager |
Legal |
Clerical |
Respondent hr/yr |
Labor Cost/yr |
Capital Startup Cost |
O & M Cost1 |
Number of Respondents |
Total hr/yr |
Total Cost/yr |
| Rate/hour |
Rate/hour |
Rate/hour |
Rate/hour |
| $88.01 |
$132.91 |
$168.46 |
$40.38 |
| Review of regulations, contact EPA for guidance |
1.5 |
1 |
0 |
0 |
2.5 |
$265 |
0 |
$17 |
220 |
550 |
$62,024 |
| Prepare and submit National Security Exemptions (NSEs), annualized |
5 |
3 |
2 |
4 |
14 |
$1,337 |
0 |
$20 |
20 |
280 |
$27,144 |
| Amend NSEs |
1 |
0.5 |
0.5 |
1 |
3 |
$279 |
0 |
$5 |
16 |
48 |
$4,545 |
| Prepare and submit general exemptions (e.g. testing, display, not including imports/exports) |
3 |
0 |
0 |
0 |
3 |
$264 |
0 |
$2 |
205 |
615 |
$54,536 |
| Keep track of exempt engines |
10 |
0 |
0 |
10 |
20 |
$1,284 |
0 |
$20 |
205 |
4100 |
$267,300 |
| Develop and submit reports,if applicable |
5 |
3 |
0 |
3 |
11 |
$960 |
0 |
$3 |
205 |
2255 |
$197,399 |
| Prepare and submit exemptions-related FOIA requests |
1 |
0 |
0 |
0 |
1 |
$88 |
0 |
$10 |
68 |
68 |
$6,665 |
| Recordkeeping |
|
|
|
|
|
|
|
|
|
|
|
| Recordkeeping |
1.5 |
0 |
0 |
3 |
4.5 |
$253 |
0 |
$13 |
220 |
990 |
$58,554 |
| Total per respondent |
28 |
7.5 |
2.5 |
21 |
59 |
$4,730 |
0 |
$90 |
N/A |
N/A |
N/A |
| Total for the industry |
N/A |
N/A |
N/A |
N/A |
N/A |
$665,281 |
0 |
$12,885 |
225 |
8,906 |
$678,166 |
| 1Includes costs such as phone calls and photocopying. See section 6(b)(ii) for details. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
13-5 |
$109,900 |
$439,600 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
13-10 |
$126,060 |
$756,360 |
|
|
|
|
|
|
|
| Table 17 - Annual Agency Burden and Cost |
14-5 |
129869 |
519476 |
|
|
|
|
|
|
|
| Employee |
|
Hours and Labor Cost |
|
Employee |
Hours and Labor Cost |
| Level |
Total Annual Labor Cost |
Rate Increase by 1.6 |
Number of Employees |
Full time hours per employee |
% of Time |
Total hr/yr |
Total Labor cost/yr |
|
Level |
Rate |
Rate Increase by 1.6 |
Number of Employees |
Full time hours |
% of Time |
Total hr/yr |
Total Labor cost/yr |
| CD Full-time Career Employees |
GS 12 through 15 |
$1,746,822 |
$2,794,915 |
20 |
2080 |
80% |
33,280 |
$2,235,932 |
|
Engineer |
GS-14/1 |
$53.08 |
$53.08 |
2 |
2080 |
90% |
3,744 |
$198,732 |
| SEE Support |
N/A |
$55,000 |
N/A |
3 |
2080 |
90% |
5,616 |
$49,500 |
|
Engineer |
GS-13/1 |
$44.91 |
$44.91 |
13 |
2080 |
90% |
24,336 |
$1,092,930 |
| IT/Contract Support |
GS 13/5 |
$109,900 |
$175,840 |
5 |
2080 |
30% |
3,120 |
$52,752 |
|
Contracts/Compliance |
GS-13/1 |
$44.91 |
$44.91 |
1 |
2080 |
25% |
520 |
$23,353 |
| OGC & OECA (lawyers) |
GS 13/10 |
$126,062 |
$201,699 |
4 |
2080 |
20% |
1,664 |
$40,340 |
|
Attorney |
GS-13/1 |
$44.91 |
$44.91 |
1 |
2080 |
25% |
520 |
$23,353 |
| Division Director |
SES-1 |
$201,700 |
$322,720 |
1 |
2080 |
25% |
520 |
$80,680 |
|
Managers |
GS-15/1 |
$62.43 |
$62.43 |
2 |
2080 |
50% |
2,080 |
$129,854 |
| Office Director |
SES-2 |
$181,500 |
$290,400 |
1 |
2080 |
15% |
312 |
$43,560 |
|
SES-1 |
SES - 1 |
|
|
2 |
|
15% |
- |
$0 |
| Other Staff |
GS-11/5 |
$71,504 |
$114,406 |
4 |
2080 |
10% |
832 |
$11,441 |
$2,514,205 |
IT Support |
GS-12/1 |
$37.77 |
$37.77 |
4 |
|
25% |
- |
$0 |
| NHTSA Full-time Career Employees |
GS 12 through 15 |
$873,411 |
$1,397,458 |
10 |
2080 |
70% |
14,560 |
$978,220 |
|
IT Support (EPA) |
|
|
|
|
|
|
|
|
| Burden & Labor Total: |
$3,365,899 |
$5,297,438 |
48 |
N/A |
N/A |
59,904 |
$3,492,425 |
58 |
Subtotal |
|
15 |
N/A |
N/A |
1,726 |
$1,468,222 |
| O&M Costs |
|
|
|
|
|
|
|
|
|
|
| In-use Testing |
|
|
|
|
|
|
|
$150,000 |
|
O&M Costs |
| Travel |
|
|
|
|
|
|
|
$12,000 |
|
Other |
|
|
|
|
|
|
|
$4,000 |
| Confirmatory & Other Testing |
|
|
|
|
|
|
|
$230,000 |
|
Contract Support - Compliance |
|
|
|
|
|
|
|
$100 |
| SEAs |
|
|
|
|
|
|
|
$12,000 |
|
Contract Support -Certification |
|
|
|
|
|
|
|
$2,000 |
| Contract Support - Compliance |
|
|
|
|
|
|
|
$30,000 |
|
|
|
|
|
|
|
|
|
|
| Contract Support -Certification |
|
|
|
|
|
|
|
$500,000 |
|
|
|
|
|
|
|
|
|
|
|
|
O&M Total: |
|
|
|
|
$934,000 |
|
|
|
|
|
|
|
|
TOTAL: |
$183,395 |
|
|
|
|
|
|
|
TOTAL: |
$4,426,425 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Table 19 - Number of Reports |
| Program |
Number of Respondents1 |
Initial Response (Application/
Notification/
Report) |
Annual Reports + Running Changes + Amendments |
Total number of Reports Per Program |
Number of Reports per Respondent |
| Certification (IC #1) |
|
|
|
|
|
| Certification + Annual Production Reports |
103 |
1,008 |
1,058 |
2,066 |
20.1 |
| Evaporative Cert |
9 |
15 |
29 |
44 |
4.9 |
| AB&T (end-of-year + final reports) |
33 |
25 |
33 |
58 |
1.8 |
| PLT |
25 |
88 |
0 |
88 |
3.5 |
| Defects |
35 |
67 |
61 |
128 |
3.7 |
| In-use |
6 |
6 |
0 |
6 |
1.0 |
| SEAs |
2 |
2 |
0 |
2 |
1.0 |
| Total for Cert: |
103 |
1,211 |
1,181 |
2,392 |
36 |
| Other Programs (ICs #2-4) |
|
|
|
|
|
| HD Alternative Fuel Conversions |
8 |
17 |
17 |
34 |
4.3 |
| TPEM |
132 |
10 |
132 |
142 |
1.1 |
| Special Compliance Provisions |
225 |
225 |
120 |
345 |
1.5 |
| Total: |
468 |
1,463 |
1,450 |
2,913 |
N/A |
|
|
Overall number of reports per respondent: |
6.2 |
| *Per the footnote in Table 18, the real number of respondents in certification (not inlcuding HD Alternative Fuel Conversions) is 103. The total shown here comes from 103 respondents in Certification + 8 in HD Alternative Fuel Convertions + 132 in TPEM and 225 in Special Compliance = 468. |
| Table 21 - Change in Burden per IC |
| Information Collection (IC) |
Responses |
Hours |
Non-labor Costs |
Reason |
| Previously Approved |
Change
(+/-) |
Total Requested |
Previously Approved |
Change
(+/-) |
Total Requested |
Previously Approved |
Change
(+/-) |
Total Requested |
| IC #1 – Certification |
1,144 |
1,248 |
2,392 |
89,209 |
14,487 |
103,696 |
$16,423,301 |
$(5,612,273) |
$10,811,028 |
Consolidation of 4 ICRs into ICR 1684.20, as discussed in Section 1(b). The reduction in cost is likely due to the higher use of carry-over applications (from an average of 56% to 78%). |
| IC #2 – Alternative Fuel Conversions |
4 |
30 |
34 |
293 |
358 |
651 |
$132,820 |
$464,291 |
$597,111 |
Increase in the number of respondents (2 to 8) and responses (4 to 16). |
| IC #3 – Transition Program for Equipment Manufacturers |
2329 |
-2,187 |
142 |
101,066 |
-86,419 |
14,647 |
$792,543 |
$(531,019) |
$261,524 |
Far fewer respondents as program is no longer available for most former respondents |
| IC #4 – Special Compliance Provisions |
403 |
-58 |
345 |
10,469 |
-1,563 |
8,906 |
$23,329 |
$(10,444) |
$12,885 |
Adjustment in estimates. Previous ICR mistakenly included respondents not covered in this ICR. |
| Total: |
3,880 |
-967 |
2,913 |
201,037 |
-73,137 |
127,900 |
$17,371,993 |
$(5,689,445) |
$11,682,548 |
|