Burden Tables

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Overview

Table 5 Cert
Table 6 GHG Engines
Table 7 GHG Vehicles
Table 8a MCI PLT
Table 8b Loco PLT
Table 9a HD In-use
Table 9b Loco In-use
Table 10 Defects
Table 11 MCI Owners
Table 12-Alt Fuel
Table 13 TPEM
Table 14 Special Compliance
Table 18 -Agency Burden
Table 19 Cert Participation
Table 20 Reports
Table 21 ICs
Table 22 IC Changes

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Sheet 1: Table 5 Cert

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	$16	2.0	103	8,240	$944,570
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
IMO											$4,000	1.0	2	0	$8,000
Evaporative											$2,689	0.6	9	0	$14,520
Locomotives											$16,387	1.0	15	0	$245,809
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	115
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	$8,647,118	varies	103	79,691	$14,967,768
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.

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Sheet 2: Table 6 GHG Engines

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	44.4285714285714
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.

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Sheet 3: Table 7 GHG Vehicles

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	1.0	42	546	$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	2.5	7	420	$39,034
Coast Down Testing	2.0	2.0	0.0	10.0	0.0	14	$1,043	$0.00	$500	2.5	7	245	$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	1.5	36	$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	42	95	$1,203
Prepare and submit "carryover" application (3)	1.0	0.0	0.0	0.0	0.0	1	$-	$0.00	$0	3.3	42	139	$0
Labeling Requirements	1.0	0.0	0.0	0.0	0.0	1	$-	$0.00	$10	3.3	42	139	$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	28.57
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.

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Sheet 4: Table 8a MCI PLT

Table 8 - Annual Respondent Burden and Cost
Marine CI Production Line Testing Program
Information Collection Activity	Burden and Cost per Application										Total Burden and Cost
	Engineer	Manager	Legal	Mechanical Engineering Technician	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	8,900	$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.

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Sheet 5: Table 8b Loco PLT

Table 8b - Annual Respondent Burden and Cost
Locomotive Production Line Testing Program
Information Collection Activity	Hours and cost per application										Total hours and cost
	Engineer	Manager	Legal	Clerical	Respondent hr/yr	Labor Cost/yr	Capital Startup Cost	O&M Cost (1)	Engine Families	Frequency per family	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 instructions and regulations	70	2	5	0	77	$7,268.82	$0.00	$0.00	1	1	15	1,155	$109,032
Training	16	0	0	0	16	$1,408.16	$0.00	$35.00	1	1	15	240	$21,647
Projecting testing needs and planning test schedules	16	1	0	0	17	$1,541.07	$0.00	$0.00	1	1	15	255	$23,116
Engine selection	4	0	0	4	8	$513.56	$0.00	$0.00	2.9	1	15	348	$22,340
Engine inspection (manufacturers)	6	0	0	1	7	$568.44	$0.00	$0.00	1	4	8	224	$18,190
Engine inspection and installation audit (remanufacturers)	25	0	0	5	30	$2,402.15	$0.00	$5,580.00	2	3	9	1,620	$431,036
Testing (manufacturers only)	55	0	0	8	63	$5,163.59	$0.00	$16,387	1	4	8	2,016	$689,628
Data entry and analysis (manufacturers)	18	0	0	2	20	$1,664.94	$0.00	$3.30	1	4	8	640	$53,384
Data entry and analysis (remanufacturers)	20	0	0	4	24	$1,921.72	$0.00	$3.30	2	3	9	1,296	$103,951
Preparing and submitting report (manufacturers)	15	1	1	4	21	$1,783.04	$0.00	$3.30	1	1	8	168	$14,291
Preparing and submitting report (remanufacturers)	15	0	0	2	17	$1,400.91	$0.00	$2.30	1	1	9	153	$12,629
Store, file and maintain records	4	0	0	10	14	$755.84	$0.00	$2.30	1	4	15	840	$45,488
Total per manufacturer	204	4	6	29	243	$20,667.46	$0.00	$16,431.18	varies	varies	N/A	N/A	N/A
Total per remanufacturer	170	3	5	25	203	$236.00	$0.00	$5,622.90	varies	varies	N/A	N/A	N/A
Total for the industry	N/A	N/A	N/A	N/A	N/A	$718,025.54	$0.00	$826,706.86	76	N/A	15	8,955	$1,544,732
(1) The required sample size is the lesser of one test per engine family or five tests per model year; with a minimum of one test per model year per family.
Remanufacturers only need to audit the installation of one remanufactured locomotive engine or 5% of their production, whichever is less.

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Sheet 6: Table 9a HD In-use

Table 9a - 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

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Sheet 7: Table 9b Loco In-use

Table 9b - Annual Respondent Burden and Cost
Manufacturer-run In-use Testing Program for Locomotives
Information Collection Activity	Hours and cost per application									Total hours and cost
	Engineer	Manager	Legal	Clerical	Respondent hr/yr	Labor Cost/yr	Capital Startup Cost	O & M Cost(1)	In-use tests/ Respondent (2)	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 instructions and regulations	10	1	1	0	12	$1,181	$0	$0	1.0	7	84	$8,270
Training	4	0	0	1	5	$392	$0	$50	1.0	7	35	$3,097
Procure locomotives	4	2	0	4	10	$779	$0	$30	1.0	7	70	$5,666
Testing (in-house) (3)	40	0	0	8	48	$3,843	$0	$710	1.0	3	144	$13,660
Testing (contracting out)	0	0	0	4	4	$162	$0	$16,387	1.5	4	24	$99,293
Loss of revenue	0	0	0	0	0	$0	$0	$1,469	1.5	7	0	$15,421
Data entry and analysis (manufacturers)	16	0	0	2	18	$1,489	$0	$4	1.5	7	189	$15,676
Data entry and analysis (remanufacturers)	2	0	0	5	7	$378	$0	$4			0	$0
Preparing and submitting report	6	1	1	2	10	$910	$0	$5	1.0	7	70	$6,406
Store, file and maintain records	2	0	0	10	12	$580	$0	$2	1.0	7	84	$4,073
Total per manufacturer (in-house testing)	82	4	2	27	115	$9,176	$0	$2,270	varies	varies	N/A	N/A
Total per remanufacturer (contracting out)	28	4	2	26	60	$4,383	$0	$17,947	varies	varies	N/A	N/A
Total for the industry	N/A	N/A	N/A	N/A	N/A	$55,036	$0	$116,526	varies	7	700	$171,562
(1) Includes phone calls to procure locomotives, testing and the expense of stopping a locomotive for testing, among others expenses, annualized. See section 6(b)(iii) for details.
(2) Manufacturers must test one engine family per year. For new engine families, a minimum of two locomotives must be tested (but only one per carry-over family).
Engine families of less than 10 locomotives need not be tested. Sixteen of 30 new families have over 10 locomotives.
(3) Lab maintenance costs are not included here because they were accounted for in the certification burden table (Table 1).

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Sheet 8: Table 10 Defects

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 & Recall Reports (DIRs & VERRs)
Review of instructions and regulations	10	8	3	0	21	$2,449	$0	$0	1.0	35	735	$85,707	35
Compile Data	44	12	0	0	56	$5,467	$0	$43	3.7	35	7,168	$705,265	128
Prepare and submit reports	12	4	2	5	23	$2,127	$0	$11	3.7	35	2,944	$273,563	128
Review reports	3.2	1.5	1	1	7	$690	$0	$0	3.7	35	858	$88,299	128
Recordkeeping	1	0	0	2	3	$169	$0	$2	1.0	35	105	$5,986	35
IC #2:Remedial Plans & Recall Update Reports													0
Review regulations	14	6	2	0	22	$2,367	$0	$0	1.0	6	132	$14,199	6
Compile Data	24	5	0	0	29	$2,777	$0	$43	4.1	6	713	$69,355	24.6
Prepare and submit report Remedial Plan	8	5	2	3	18	$1,827	$0	$11	4.1	6	443	$45,198	24.6
Prepare and submit report VERR updates	15	7	2	2	26	$2,668	$0	$11	6.0	6	936	$96,438	36
Maintain Owner Records	2	2	0	40	44	$2,057	$0	$2	4.1	6	1,082	$50,659	24.6
Recordkeeping													0
Recordkeeping	1	0	0	2	3	$169	$0	$2	1.0	35	105	$5,986	35
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	$1,431,947	$0	$8,706	varies	$29	15,221	$1,440,653
										0.275

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Sheet 9: Table 11 MCI Owners

Table 11 - Respondent Burden and Cost
Marine CI Vessel Owners, Operators & Engine Rebuilders
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	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
Review of instructions and regulations	3	1	1	0	5	$404.20	$0	$10	1.0	192	960	$79,526
Owners & Operators						$0.00
Inform EPA of malfunctions & other special events	4	1	1	2	8	$529.96	$0	$10	1.0	187	1,496	$100,973
Conduct Annual Records Review	10	3	3	5	21	$1,432.59	$0	$100	1.0	187	3,927	$286,594
Prepare and submit report	3	1	1	5	10	$561.25	$0	$30	1.0	187	1,870	$110,564
Owners, Ops & Rebuilders: Store, file and maintain records	15	5	5	30	55	$2,963.30	$0	$50	1.0	192	10,560	$578,554
Total per manufacturer	95	5	2	8	99	$6,955	$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	$1,118,511	$0	$37,700	N/A	192	18,813	$1,156,211
(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 10: Table 12-Alt Fuel

Table 12- 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.

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Sheet 11: Table 13 TPEM

Table 13 - 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	132	1,432	$297,308
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	$1,407,993	0	$261,649	107	14,647	$1,669,642
1Includes costs such as phone calls and photocopying. See section 6(b)(ii) for details.

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Sheet 12: Table 14 Special Compliance

Table 14 - 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.

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Sheet 13: Table 18 -Agency Burden

Table 18 - Annual Agency Burden and 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
CD Full-time Career Employees	GS 12 through 15	$1,746,822	$2,794,915	20	2080	80%	33,280	$2,235,932
SEE Support	N/A	$55,000	N/A	3	2080	90%	5,616	$49,500
IT/Contract Support	GS 13/5	$109,900	$175,840	5	2080	30%	3,120	$52,752
OGC & OECA (lawyers)	GS 13/10	$126,062	$201,699	4	2080	20%	1,664	$40,340
Division Director	SES-1	$201,700	$322,720	1	2080	25%	520	$80,680
Office Director	SES-2	$181,500	$290,400	1	2080	15%	312	$43,560
Other Staff	GS-11/5	$71,504	$114,406	4	2080	10%	832	$11,441
NHTSA Full-time Career Employees	GS 12 through 15	$873,411	$1,397,458	10	2080	70%	14,560	$978,220
Burden & Labor Total:		$3,365,899	$5,297,438	48	N/A	N/A	59,904	$3,492,425
O&M Costs
In-use Testing								$150,000
Travel								$12,000
Confirmatory & Other Testing								$230,000
SEAs								$12,000
Contract Support - Compliance								$30,000
Contract Support -Certification								$500,000
		O&M Total:						$934,000
							TOTAL:	$4,426,425

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Sheet 14: Table 19 Cert Participation

Table 19 - Certification Response Levels Per Respondent Type
\	# of Manufacturers (Cert IC only)	# Engine Families	New Engine Families	Carry-Over Applications	% Carry-Over	ABT	PLT
NRCI	40	370	53	317	86%	~33 manufacturers submit AB&T reports	N/A
HD Engines Gas & Diesel (Exhaust Emissions)	12	70	28	42	60%		N/A
HD Evaporative	9	15	4	11	73%		N/A
HD GHG Engines	7	37	2	35	95%		N/A
HD GHG Vehicles	42	139	6	133	96%		N/A
Alt Fuel	8	16	10	6	38%		N/A
MCI Categories 1-3	29	231	21	210	91%		10 manufacturers 71 reports
IMO Only	2	2	0	2	100%		N/A
Locomotives	15	61	18	43	70%		14 manufacturers 17 reports
Totals1:	103	941	142	799	85%
1Many companies certify engines/vehicles in more than one industry. Therefore, the real total of certification respondents (# of manufacturers) is lower than the sum of manufacturers in each industry.

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Sheet 15: Table 20 Reports

Table 20 - 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	103	941	218	1,159	11.3
Evaporative Cert	9	15	29	44	4.9
AB&T (end-of-year + final reports)	33	25	33	58	1.8
PLT	40	28		28	0.7
Defects	35	128	61	189	5.4
In-use	13	13		13	1.0
SEAs	2	2		2	1.0
MCI Owner Reporting	192	192		192	1.0
Total for Cert:	103	1,152	341	1,685	27
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	1,404	610	2,206	N/A
		Overall number of reports per respondent:			4.7
*As explained in Table 18's footnote, the real number of respondents in certification (not inlcuding HD Alternative Fuel Conversions) is 103 as many engine manufacturing companies respond to this collection in more than one industry or category.

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Sheet 16: Table 21 ICs

Table 21 - Summary by IC and Respondent Tally
Program	Table Number [Section 6(a)]	Number of Respondents	Total Hours Per Year	Total Labor Cost Per Year	Total Annual Capital Costs	Total Annual O&M Costs	Total Costs
Certification IC
Certification	5	103	79,691	$6,320,651	0	$8,647,118	$14,967,768
HD GHG Engines	6		311	$27,468	0	$2,144	$29,612
HD GHG Vehicles	7		4,571	$400,359	0	$66,877	$467,236
PLT	8a & 8b		17,855	$1,379,249	0	$1,338,014	$2,717,262
In-use	9a & 9b		1,060	$120,208	0	$1,889,215	$2,009,424
Defects	10		15,221	$1,431,947	0	$8,706	$1,440,653
MCI owners reporting	11	192	18,813	$1,118,511	0	$37,700	$1,156,211
Total for Cert IC:		295	137,521	10,798,392	0	11,989,774	22,788,166
Alternative Fuels IC
HD Alternative Fuel Conversions	11	8	651	$64,720	0	$597,111	$661,831
TPEM IC
TPEM	12	132	14,647	$1,407,993	0	$261,649	$1,669,642
Special Compliance Provisions IC
Special Compliance Provisions	13	225	8,906	$665,281	0	$12,885	$678,166
Respondent Tally:		660	161,725	12,936,386	0	$12,861,419	$25,797,805
		Average Burden Per Respondent	245

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Sheet 17: Table 22 IC Changes

Table 22 - Change in Burden per IC
Information Collection (IC)	Responses			Hours			O&M Costs			Reason
	Previously Approved	Change (+/-)	Total Requested	Previously Approved	Change (+/-)	Total Requested	Previously Approved	Change (+/-)	Total Requested
IC #1 – Certification	1,144	541	1,685	89,209	48,312	137,521	$16,423,301	$(4,433,527)	$11,989,774	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	2,329	(2,187)	142	101,066	(86,419)	14,647	$792,543	$(530,894)	$261,649	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	-1,674	2,206	201,037	-39,312	161,725	$17,371,993	$(4,510,574)	$12,861,419
* Previous ICR mistakenly included respondents from the spark-ignition and light-duty industries not covered under this collection.
For details, including the ICRs that cover those industries, see section 6(d)(iii), page 53.